• verification of length and nature of each period of employment, including reasons for termination and eligibility for rehire • disciplinary history • any other information that would adversely reflect on the trustworthiness and reliability of the individual as it relates to the individual being permitted unescorted access • verification of activities during interruptions of employment in excess of 30 days Section 73.38(d) requires the licensee to use their best effort to verify a 10-year employment history record; however, a minimum of a 3-year inclusive employment history immediately preceding the application for unescorted access is strongly recommended. Best efforts include such activities as documented attempts to contact previous employers and obtaining verification by telephone, letter, or other means. If the employment history check could not be accomplished for the entire 10-year period, the licensee should document this in an explanatory statement delineating the reasons. Section 6.3.11 below describes the steps a licensee should take if employment history cannot be readily verified. For new hires without an employment history, the licensee will need to rely more on other aspects of the background investigation. A lack of employment history need not be a negative consideration in determining whether an individual is deemed to be trustworthy and reliable. 6.3.6. Verification of Education Licensees must verify any claimed enrollment at an educational institution during the previous 10 years, as required by 10 CFR 73.38(d)(5). In addition, the licensee should verify the highest claimed post-high school attendance leading to a degree, regardless of when the degree was conferred. Section 6.3.11 below describes the steps a licensee should take when educational history cannot be readily verified. 6.3.7. Verification of Military Service Section 73.38(d)(5) requires the licensee to verify any periods of active military service that an individual claims during the previous 10 years by reviewing a copy of the individual’s DD Form 214 (“Certificate of Release or Discharge from Active Duty”). The licensee should also contact the last duty station, verify the dates of the individual’s military service, determine the conditions under which the individual terminated his or her duty (i.e., honorable or dishonorable discharge), and if the individual would be eligible to serve again. The results of this contact should be documented. Section 6.3.11 below describes the steps a licensee should take when military service cannot be readily verified. 6.3.8. Credit History Evaluation Section 73.38(d)(6) requires licensees to ensure that the full credit history of any individual who is applying for unescorted access to SNF in transit is evaluated. A full credit history evaluation must include, but is not limited to, an inquiry to detect potential fraud or misuse of Social Security numbers or other financial identifiers, and a review and evaluation of all of the information provided by a national credit-reporting agency on the individual’s credit history. During the course of the credit history evaluation the licensee should ensure that its actions
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