Midwifery in the United States runs through two very different licensing paths, and each one carries its own background screening rules. A certified nurse midwife is licensed as an advanced practice registered nurse through a state board of nursing. A certified professional midwife is licensed, where a license even exists, through a separate state agency with its own criminal history standards. Employers, hospitals, birth centers, and home birth practices that hire either type of provider need to understand both paths before they build a hiring or credentialing process.
Two different licenses, two different screening paths
A certified nurse midwife (CNM) first becomes a registered nurse, then completes a graduate midwifery program and a national certification exam, and finally applies for advanced practice licensure through the same state board of nursing that licenses nurse practitioners. A certified professional midwife (CPM) is certified through a national credentialing exam built around out of hospital birth, but state licensing of that credential is inconsistent. Some states issue a state license to CPMs with their own application and background rules, and some states have no licensing category for direct entry midwifery at all. Where no state license exists, there is no state mandated criminal history check tied to a credential, and that gap should be stated plainly rather than filled in with a guess.
Certified nurse midwives: screened through the board of nursing
Because a CNM holds a nursing license, the applicant goes through the same initial licensure screening that a registered nurse or any other advanced practice registered nurse goes through in that state. Many state nursing and health licensing agencies require applicants to submit fingerprints for a state and FBI criminal history records check before a license is issued. Florida’s health care practitioner background screening program, which covers nursing applicants among other licensed professions, is a working example of how a state ties criminal history clearance directly to a health care license, and it is worth reading in full if your organization operates there or is comparing state approaches.
Certified professional midwives: state rules vary widely
CPM licensing sits outside the nursing board system, so the screening rule depends entirely on the specific state agency involved. Texas, for example, licenses midwives through its Department of Licensing and Regulation, and that agency publishes guidelines for applicants with criminal convictions along with a criminal history evaluation process applicants can use before they apply. Other states route direct entry midwifery licensing through a different board, a public health agency, or no board at all. An employer, hospital partner, or client working with a CPM should confirm the current rule with that state’s own licensing page rather than assume it matches the nursing board model, since the two systems were built independently and do not mirror each other.
| Factor | Certified nurse midwife (CNM) | Certified professional midwife (CPM) |
|---|---|---|
| Licensing authority | State board of nursing, as an advanced practice registered nurse | Varies by state; a separate midwifery board, a health agency, or no license at all |
| Underlying credential | Registered nurse license plus graduate midwifery education and national certification | National midwifery certification exam focused on out of hospital birth |
| State criminal history check | Generally required at initial licensure, consistent with other nursing licenses in that state | Depends on the state; required in states that license the credential, absent where no license exists |
| Typical practice setting | Hospitals, birth centers, and some home births | Primarily home births and licensed birth centers |
| Hospital credentialing exposure | Common, when affiliated with a hospital or hospital owned birth center | Less common, since most CPMs do not hold hospital privileges |
Hospital credentialing, the NPDB, and the OIG exclusion list
When a midwife, almost always a CNM, applies for clinical privileges at a hospital or an affiliated birth center, the credentialing office is required to query the National Practitioner Data Bank as part of that process. Federal regulation sets out who must report to the data bank and who must query it, and the current rule is published in full in the Code of Federal Regulations under the National Practitioner Data Bank reporting and querying requirements. Credentialing staff also typically check whether a candidate appears on the Department of Health and Human Services Office of Inspector General’s List of Excluded Individuals and Entities, since a provider on that list generally cannot be paid for services billed to a federal health care program and employers who bill Medicare or Medicaid have an ongoing duty to screen against it. For a deeper look at how exclusion screening fits alongside other healthcare checks, see our related post on OIG and SAM exclusion screening.
What else employers and birth centers typically screen
Licensure and exclusion checks confirm that a midwife can legally practice and bill, but they are not the whole hiring picture. Employers commonly run a separate criminal history search at the county, state, or national level, since state licensing checks do not always capture every jurisdiction a candidate has lived or worked in. A sex offender registry check is standard for any role involving direct patient contact. If the position involves driving between home visits or between a practice and a hospital, a motor vehicle record check is common. A pre employment drug test may also apply where the employer’s policy calls for one, administered and reviewed through a medical review officer so that legitimate prescriptions are accounted for rather than assumed to be a problem. What shows up on any of these searches varies by state record retention and reporting law, so no employer should assume a report will surface every record in every case. CNMs already move through a credentialing path similar to other licensed nurses; our post on nurse background check requirements covers that nursing side in more detail.
FCRA duties when a background check is run
Any time an employer, hospital, or staffing agency orders a background check on a midwife applicant through a consumer reporting agency, the Fair Credit Reporting Act applies. That means a standalone written disclosure, the applicant’s written authorization, a pre adverse action notice with a copy of the report and a copy of the Summary of Rights if the employer is considering not hiring or not credentialing based on the report, and a final adverse action notice if that decision is confirmed. The Federal Trade Commission’s guidance on using consumer reports for employment decisions lays out these duties for employers in plain terms and is worth keeping on file alongside your hiring policy. State law adds its own layer on top of the federal floor in a number of states, so an employer operating in several states should check each one rather than apply a single national policy. Reveal Background provides FCRA compliant screening for employers and property managers who need a background check built around these notice and authorization steps; you can review our services at revealbackground.com.
Frequently asked questions
Do certified nurse midwives have to pass a criminal background check to get licensed?
In most states, yes, because a CNM is licensed as an advanced practice registered nurse and nursing licensure in many states includes a fingerprint based state and FBI criminal history check. The exact process is set by each state’s board of nursing or health licensing agency, so the precise steps vary by state.
Are certified professional midwives required to pass a background check?
It depends on whether the state licenses the certified professional midwife credential at all. States that license CPMs, such as Texas through its Department of Licensing and Regulation, apply their own criminal history review to applicants. States that do not license direct entry midwifery have no state mandated check tied to that credential, though an employer can still choose to run its own screening.
Does a hospital have to check the National Practitioner Data Bank before granting a midwife clinical privileges?
Hospitals and other eligible entities are required to query the National Practitioner Data Bank as part of the credentialing process for practitioners who will hold clinical privileges, consistent with the federal reporting and querying rules for the data bank.
Why would an employer check the OIG exclusion list for a midwife?
Any provider on the Department of Health and Human Services exclusion list generally cannot be paid for services billed to a federal health care program. Employers and facilities that bill Medicare or Medicaid have an ongoing duty to confirm a provider is not on that list, both before hire and periodically afterward.
What does an employer need to do before running a midwife applicant’s background check?
Under the Fair Credit Reporting Act, the employer must provide a standalone written disclosure and get the applicant’s written authorization before ordering the report. If the results may lead to a decision not to hire or not to credential the applicant, the employer must send a pre adverse action notice with a copy of the report and the Summary of Rights, then a final adverse action notice if that decision is confirmed.
Will a background check always show a midwife applicant’s full criminal history?
Not necessarily. What a report captures depends on the search sources used and on each state’s record reporting and retention rules, which vary. A thorough screen generally combines the state licensing check with a separate criminal history search rather than relying on the license alone.
This article is general information, not legal or medical advice. Employers and healthcare organizations should consult qualified counsel for guidance specific to their state and situation.
