Minnesota DHS Background Study Changes for 2026: What Employers Should Do
- Carlos Crameri
- 1 hour ago
- 3 min read
Minnesota healthcare, care-provider, foster-care, behavioral-health, and social-service employers should review new 2026 requirements from the Minnesota Department of Human Services (DHS).
The changes expand certain roles that require a DHS background study, update some disqualification criteria, and continue the transition to NETStudy 2.0 for covered providers. These requirements apply to specific regulated Minnesota settings and are not the same as a standard employment background check.
Which Minnesota employers may be affected?
The changes are most relevant to organizations and providers involved in:
Personal Care Provider Organizations (PCPOs)
Community First Services and Supports (CFSS)
Adult rehabilitative mental health services (ARMHS)
Recovery community organizations and peer recovery support services
Child foster care
Family adult foster care
Family adult day services
Other DHS-regulated healthcare, behavioral-health, and human-services programs
Employers should confirm whether their organization, license type, contracts, or service model is subject to Minnesota DHS background-study rules.
What roles may now require a DHS background study?
Minnesota is expanding screening requirements beyond direct-care employees in some regulated settings. Depending on the provider type, the requirement may apply to board members, owners, operators, employees, volunteers, household members, or others with responsibility for billing, management, or policy decisions.
Key upcoming dates include:
September 15, 2026: Board members of PCPOs and CFSS providers must undergo DHS background studies.
No earlier than October 13, 2026: ARMHS owners, operators, employees, and volunteers may be required to undergo studies through NETStudy 2.0, subject to system implementation.
No earlier than December 15, 2026: Certain peer recovery support service owners and operators may be required to undergo studies through NETStudy 2.0.
September 1, 2026 through March 1, 2027: Certain foster-care and adult-day providers must move individuals with legacy background studies into NETStudy 2.0. Legacy studies will no longer be valid after March 1, 2027.
What should Minnesota employers do now?
Covered employers should take these steps:
1. Review every role—not only direct-care positions
Create a list of current employees, new hires, volunteers, board members, owners, operators, household members, and contractors. Determine which individuals are subject to a DHS background study under your organization’s specific program rules.
2. Confirm whether NETStudy 2.0 is required
A standard employment criminal background check does not replace a required Minnesota DHS background study. If DHS rules apply, the employer must use the appropriate state process and follow NETStudy 2.0 requirements.
A standard employment background check may support broader hiring due diligence, but it is not a substitute for a required state background study.
3. Plan ahead for upcoming effective dates
Do not wait until a person is scheduled to begin work. Review the applicable implementation date, gather required information, and start the background-study process early enough to avoid a licensing, onboarding, staffing, or service interruption.
This is especially important for providers transitioning individuals from Minnesota’s legacy background-study system before the March 1, 2027 deadline.
4. Update hiring and eligibility-review procedures
Minnesota’s 2026 changes include new and revised disqualification criteria for certain DHS background studies. Employers should update internal procedures so staff know:
Which roles require a qualifying study result before work may begin.
How to handle a pending result.
Who reviews notices or disqualification information.
When the state’s reconsideration or exemption process may apply.
How sensitive background information must be stored and accessed.
5. Protect applicant and worker information
Restrict access to DHS background-study information to authorized personnel who need it for licensing, onboarding, or eligibility decisions. Maintain secure records and follow your organization’s retention, privacy, and confidentiality requirements.
If you also use a consumer report for employment purposes, maintain separate FCRA compliance procedures, including required disclosures, authorization, and—when applicable—adverse action steps.
Can a standard background check replace a Minnesota DHS background study?
No. A Minnesota DHS background study is a state-required process for specific regulated roles and programs. Employers should not treat a standard criminal background check, employment verification, or other consumer report as a replacement when NETStudy 2.0 or another DHS process is required.
Minnesota DHS Background Study Compliance Checklist
Before onboarding or continuing a covered individual, employers should confirm that they have:
Determined whether the organization and role are regulated by Minnesota DHS.
Identified all potentially covered employees, owners, operators, board members, volunteers, contractors, and household members.
Confirmed the correct state screening process and NETStudy 2.0 requirements.
Started required studies before the applicable effective date or onboarding deadline.
Updated procedures for revised disqualification criteria.
Restricted access to sensitive screening information.
Kept FCRA procedures separate when using a consumer report for an employment decision.
This article is for general informational purposes and is not legal advice. Employers should consult qualified legal counsel or the appropriate Minnesota agency for role- and program-specific requirements.
