Ultrasound Technician Background Check Requirements: State Licensing, Hospital Credentialing and OIG Screening

Ultrasound technicians, also called diagnostic medical sonographers, work in direct contact with patients, including pregnant patients, infants, and people being evaluated for serious conditions. Despite that level of trust, most states do not require a government issued license to work as a sonographer. National certification through a credentialing organization is common and often required by employers, but it is a professional credential, not a state license. Separately, almost every hospital, imaging center, and outpatient clinic runs its own background screening before hiring a sonographer, and that screening is governed by federal rules that apply regardless of whether a state license exists. This guide separates the two tracks: state licensing where it exists, and the employer level screening and Fair Credit Reporting Act (FCRA) duties that apply almost everywhere else.

Does your state license ultrasound technicians?

Licensing for sonographers is the exception, not the rule. In most states, a person can legally scan patients without a state license as long as the employer is satisfied with their training and certification. Two states confirmed to require an actual sonographer license are Oregon and New Hampshire.

Oregon

Oregon regulates diagnostic medical sonography as a category of medical imaging under Oregon Revised Statutes Chapter 688, administered by the Oregon Board of Medical Imaging. The statute defines diagnostic medical sonography as the use of nonionizing high frequency sound waves to generate diagnostic images, and it is listed as a licensed modality alongside radiography, nuclear medicine, and radiation therapy. Under ORS 688.557, the board has authority to require fingerprints from license applicants so it can request a state or nationwide criminal records check before issuing a license.

New Hampshire

New Hampshire licenses sonographers through its Board of Medical Imaging and Radiation Therapy under RSA Chapter 328-J. A sonographer applicant must complete an approved course of study and hold current certification and registration from a recognized sonography credentialing body. Separately, RSA 328-J:7-a requires the board’s executive director to run a criminal history records check for initial licensure, reinstatement, or temporary licensure, which includes submitting a full set of fingerprints that the state police forward to the FBI for a national criminal history check.

New Mexico and other states

New Mexico’s Regulation and Licensing Department publishes a public list of every board and commission it oversees. As of this review, that list does not include a sonography specific board or a medical imaging board, so we did not find a confirmed state license requirement for sonographers in New Mexico. Rules can change, so an employer or applicant in any state without a confirmed license requirement should still check directly with the relevant state agency rather than assume the rule is the same as a neighboring state. In the large majority of states, there is simply no sonographer license to check, and hiring decisions rest entirely on the employer’s own screening and credentialing process described below.

State State license required Licensing body Criminal history check tied to licensing
Oregon Yes, medical imaging license covering sonography Oregon Board of Medical Imaging Yes, fingerprint based under ORS 688.557
New Hampshire Yes, sonographer license Board of Medical Imaging and Radiation Therapy Yes, fingerprints and FBI check under RSA 328-J:7-a
New Mexico No sonography specific license found on the state board list Not applicable Not applicable
Most other states No state sonographer license Not applicable, national certification is voluntary Determined entirely by the employer

What hospitals and imaging centers typically screen for

Whether or not a state license exists, the employer still has to decide who gets access to patients, equipment, and protected health information. A hospital, outpatient imaging center, or staffing agency may screen for the items below, though exact practice generally varies by facility and by state law.

Criminal history

Because the role involves unsupervised, direct contact with patients, employers generally run a criminal history check as a condition of hire. What that check covers, how far back it looks, and how prior convictions are weighed varies by state law and by employer policy, so a sonographer with a record should not assume the same result in every state or at every facility.

OIG exclusion screening

Hospitals and clinics that bill Medicare or Medicaid have a strong incentive to check the HHS Office of Inspector General List of Excluded Individuals and Entities (LEIE) before and during employment. Anyone on the LEIE cannot receive payment from federal health care programs for items or services they furnish, order, or prescribe, and an employer that bills for services performed by an excluded person may face civil monetary penalties. This is one of the few screening steps that is effectively mandatory for any provider that participates in Medicare or Medicaid, regardless of whether the sonographer role itself is licensed.

National Practitioner Data Bank queries

The National Practitioner Data Bank (NPDB) is a federal repository that collects and releases reports on licensure actions, clinical privilege actions, and certain malpractice payments. It is queried most heavily for physicians and other licensed practitioners during credentialing. Where a sonographer holds a state license, such as in Oregon or New Hampshire, a licensing board action against that person could appear in an NPDB query run by a hospital during credentialing. In states with no sonographer license, there is no license to report, so NPDB plays a smaller role for this specific job.

Abuse and neglect registry checks

Many hospitals and clinics also check state administered abuse, neglect, or vulnerable adult registries for staff who will have direct contact with children, elderly patients, or patients with disabilities, since sonography frequently involves obstetric, pediatric, and geriatric patients. Whether this check is required by state law, by hospital policy, or simply by the facility’s own risk management practice varies, so applicants should expect the question to come up without assuming it is federally mandated for this role.

Hospital conditions of participation

Hospitals that accept Medicare and Medicaid payment must meet CMS conditions of participation set out in 42 CFR Part 482, which cover governing body oversight, quality assessment, and qualified staffing across hospital departments, including diagnostic services. These federal conditions establish the framework hospitals operate under, but they do not themselves spell out a specific criminal background check mandate for an individual sonographer. Hiring and screening decisions for that role are made at the hospital and state level, informed by the facility’s own credentialing policy.

Drug testing and driving records

Pre employment drug testing is common in hospital settings as a matter of employer policy, though it is not a federal requirement specific to diagnostic sonography the way it is for certain transportation jobs. A sonographer who travels to patient homes or between satellite clinics for a mobile imaging employer may also be asked to consent to a motor vehicle record check as part of that employer’s own risk policy.

FCRA duties when a third party runs the background check

When a hospital, imaging center, or staffing agency uses a background screening company rather than running checks itself, the hiring process is a consumer report under the Fair Credit Reporting Act, and specific employer duties apply under 15 U.S.C. 1681b and the Consumer Financial Protection Bureau’s implementing Regulation V. In general, the employer should:

  • Provide a clear, standalone disclosure that a background report will be obtained, separate from the job application.
  • Get the applicant’s written authorization before requesting the report.
  • Send a pre adverse action notice with a copy of the report and a summary of rights before taking any negative action based on it.
  • Wait a reasonable period to let the applicant respond, then send an adverse action notice if the employer still intends to decline the applicant.

The Federal Trade Commission’s guidance on background checks walks through these steps for employers in plain language. A background check does not show the same information in every state, since state law and the general seven year reporting guideline under the FCRA both affect what can be reported, so results should never be assumed to be identical across jurisdictions.

Criminal history and hiring decisions

Employers generally may consider a sonography applicant’s criminal history, but the EEOC’s guidance on arrest and conviction records in employment decisions explains that a blanket exclusion policy can raise discrimination concerns under Title VII. An individualized assessment that looks at the nature of the offense, how much time has passed, and the duties of the sonographer role is the approach EEOC describes as lower risk. Because this area involves both federal guidance and state specific rules, employers should consult counsel before adopting a screening policy rather than relying on a single source.

Practical steps for employers and applicants

Employers hiring for a sonographer role may want to confirm whether the state requires a license, check that any certification the applicant holds is current with the issuing credentialing body, run the standard criminal history and LEIE exclusion checks, and follow FCRA notice requirements if a third party vendor is used. Applicants can expect a criminal history check, an OIG exclusion check if the employer bills federal programs, and possibly a drug test or driving record check, even in states where no sonographer license exists. For related reading on how exclusion screening works across healthcare roles, see our post on healthcare exclusion screening and the OIG LEIE, and for a comparison with another allied health role that does carry state licensure in most places, see our post on respiratory therapist background check requirements.

Frequently asked questions

Do all ultrasound technicians need a state license?

No. Most states do not license sonographers at all. Oregon and New Hampshire are confirmed to require a state license for sonography, and other states may have requirements that should be confirmed directly with the relevant state licensing agency since rules can change.

Is national certification the same as a state license?

No. National certification from a sonography credentialing organization is a professional credential that demonstrates competency and is frequently required by employers, but it is not issued by a state government and does not replace a state license in states that do have one.

Why would a hospital check the OIG exclusion list for a sonographer who is not a licensed practitioner?

Any hospital or clinic that bills Medicare or Medicaid can face civil monetary penalties for employing someone on the LEIE in a role connected to items or services billed to those programs, so many providers screen all clinical staff against the list regardless of license status.

Can a criminal record automatically disqualify someone from a sonography job?

Employers may be able to consider criminal history as part of hiring, but an automatic, blanket exclusion can raise concerns under EEOC guidance on arrest and conviction records. State law also varies on what can be considered and for how long, so outcomes are not identical everywhere.

What notice does an employer have to give before rejecting an applicant because of a background report?

Under the FCRA, an employer that intends to take adverse action based on a third party background report generally must first send a pre adverse action notice with a copy of the report and a summary of rights, give the applicant a reasonable chance to respond, and then send a separate adverse action notice if it proceeds.

Does a background check show the same information in every state?

No. What appears on a background check depends on state record retention and reporting law as well as the general reporting guidelines under the FCRA, so the same person’s history can look different depending on where the check is run.

Reveal Background helps employers build FCRA compliant screening programs for healthcare hiring.

This article is general information, not legal advice. Employers should consult qualified counsel about screening policies and FCRA compliance in their state.

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