Every state licenses audiologists, and most state boards run some form of criminal history review before they issue that license. What a board actually checks, and how, varies a lot from state to state. Some boards fingerprint every applicant through a state and FBI criminal history search. Others ask applicants to disclose convictions on the application and investigate only when something is flagged. A handful publish almost nothing about criminal history screening at all. Employers who hire audiologists, whether in a hospital system, an ENT practice, a school district, or a hearing aid dispensing office, generally need to look past the license itself and run their own screening, because a license number by itself does not tell an employer what is in a candidate’s criminal history or whether the person has been excluded from federal health programs.
This guide walks through how a sample of state boards actually handle fingerprinting and criminal history, what the federal government separately tracks, and what an employer still has to do under the Fair Credit Reporting Act when it orders its own background check.
Why the license alone is not a background check
A state audiology license confirms education, supervised clinical hours, and a passing exam score, and in many states it also means the applicant cleared whatever criminal history review that board requires. But license verification and a criminal background check are not the same record. A board’s public license lookup typically shows status, expiration, and any formal discipline it has posted. It usually does not show arrests that did not lead to discipline, pending charges, out of state convictions the board never learned about, or exclusions from federal programs. Employers that rely only on “the board licensed them” skip information a direct background check and registry search would surface.
How selected state boards handle fingerprinting and criminal history
| State | Fingerprint or criminal history check at licensure | Source |
|---|---|---|
| California | Yes. The Speech-Language Pathology and Audiology and Hearing Aid Dispensers Board requires both a Department of Justice and FBI criminal history check on every applicant, submitted through Live Scan or a hard card fingerprint method. | California board fingerprinting requirements |
| Texas | Not a standard fingerprint submission for this program, but the Texas Department of Licensing and Regulation runs a criminal history evaluation letter process so an applicant can ask in advance whether a past conviction would bar licensure in the speech-language pathologist and audiologist program. | TDLR criminal history evaluation letter |
| Florida | Yes. Florida law requires a state and national (Level 2) criminal history screening for Department of Health licensed practitioners, including audiologists, with only a short list of exempt professions that does not include audiology. | Florida Department of Health background screening policy |
| New York | No published fingerprint or criminal history disclosure requirement. The Office of the Professions lists education, examination, and experience requirements for audiology licensure and does not list a criminal history or fingerprint step. | New York audiology license requirements |
These four states illustrate the range: a full DOJ and FBI fingerprint check in California, a Texas process that lets an applicant get an advance evaluation of a criminal record rather than a blanket background check, a Florida statute that now applies state and national screening broadly across health care licensure, and a New York program that simply does not publish a criminal history or fingerprint requirement for this license. Other states fall somewhere in between, and some ask about convictions on the application without fingerprinting at all. Because the rule genuinely differs by state and sometimes by whether the applicant is also seeking a hearing aid dispensing endorsement, employers and applicants should check the specific board rather than assume one state’s practice applies everywhere.
Audiology compacts and multistate practice
A number of states have joined an interstate licensure compact for audiologists and speech-language pathologists that is meant to let a licensee practice across member states without a full relicensing process in each one. As of this writing the compact’s own public materials are hosted on a non government compact commission site rather than a state or federal .gov page, so this post does not cite it as a source. Employers hiring an audiologist who will practice under a compact privilege should still confirm, directly with the relevant state board, what criminal history standard applies to that privilege, since compact rules can differ from a state’s standard initial licensure process.
Hearing aid dispensing and the FDA over the counter rule
Many audiologists also dispense hearing aids, and some states fold hearing aid dispensing into the audiology license while others require a separate dispenser license or registration. The FDA’s rule creating a category of over the counter hearing aids changed who can sell certain devices and under what conditions, and that rule is codified in the Code of Federal Regulations. The rule governs the device category itself, not a licensing board’s criminal history standard, so employers should not assume it changes background screening obligations. It is still worth knowing when a role spans clinical audiology and hearing aid sales, since some states regulate the two activities differently.
See the FDA’s hearing aid device rule at 21 CFR 800.30 for the current regulatory text.
Federal databases employers and boards both use
Two federal resources sit alongside state licensing checks and are relevant to any clinic, hospital, or school hiring an audiologist.
The National Practitioner Data Bank collects reports on medical malpractice payments and certain adverse licensure and clinical privilege actions against health care practitioners, and hospitals and some health care entities query it as part of credentialing. It is a credentialing and reporting tool, not a general criminal background check, and access is restricted to entities that are eligible to query it under federal rules.
The Department of Health and Human Services Office of Inspector General maintains the List of Excluded Individuals and Entities (LEIE). Health care employers generally screen new hires and check the list periodically because employing or contracting with an excluded individual can affect a provider’s ability to bill federal health care programs. An audiologist or hearing aid dispenser working in a practice that bills Medicare or Medicaid is a reasonable candidate for this check regardless of what the state license process already covered.
What employers still need to do under the FCRA
When a clinic, hospital, school district, or hearing aid dispensing business orders its own background check through a consumer reporting agency rather than relying on the license and federal lookups alone, the Fair Credit Reporting Act sets out specific duties. The employer must provide the applicant a standalone disclosure that a background check will be obtained, separate from the job application. The employer must get the applicant’s written authorization before ordering the report. If the employer is considering not hiring, or taking another adverse action, based on what the report shows, it must send a pre-adverse action notice along with a copy of the report and the Summary of Rights, give the applicant a reasonable opportunity to respond, and only then send a final adverse action notice if it proceeds. These duties apply whether the audiologist role is clinical, dispensing, or both, and they apply in addition to, not instead of, the license verification step.
What typically shows up on a background check varies by state, by the type of record, and by how long ago it occurred, since state law and reporting limits differ. A background check does not guarantee that every past record will appear, and employers should not assume a clean report means a clean history in every jurisdiction a candidate has lived or worked.
What employers typically screen for an audiologist hire
Beyond license verification, employers commonly combine a criminal history search, a check of the Office of Inspector General exclusion list and the System for Award Management exclusion list for federal program eligibility, verification of any required CPR or clinical certifications, and for roles that involve home visits or driving between clinic sites, a motor vehicle record check. Drug testing is common in hospital and health system settings and should follow the employer’s own policy and, where state law requires it, the medical review officer process for verifying any legitimate prescription before a result is reported as positive.
Frequently asked questions
Does every state fingerprint audiologist license applicants?
No. Some states, including California, require a full state and FBI fingerprint based criminal history check as part of licensure. Other states ask about convictions on the application or offer an advance criminal history evaluation instead of a blanket fingerprint requirement, and some states do not publish a fingerprint or criminal history step for this license at all. Check the specific state board.
Can an employer skip its own background check if the state already licensed the audiologist?
Generally not advisable. A license confirms education, exam results, and often a board level criminal history review at the time of licensure, but it does not substitute for an employer’s own screening of recent records, federal exclusion lists, or driving history where relevant to the role.
What is the National Practitioner Data Bank used for in audiology hiring?
It is a federal repository of malpractice payment reports and certain licensure and clinical privilege actions that eligible health care entities query during credentialing. It is not a general purpose criminal background check and is not available to the public in the same way a license lookup is.
Why would an employer check the OIG exclusion list for an audiologist?
Employing or contracting with someone on the List of Excluded Individuals and Entities can affect a health care employer’s ability to bill federal health programs for that person’s services, so many health care employers check it at hire and periodically afterward.
Does the FDA’s over the counter hearing aid rule change background check requirements?
No. That rule, found at 21 CFR 800.30, governs which hearing aid devices can be sold without a prescription and under what conditions. It does not set or change a state licensing board’s criminal history or background screening requirement.
What must an employer do before taking adverse action based on a background check?
Under the FCRA, the employer must send a pre-adverse action notice with a copy of the report and the Summary of Rights, allow the applicant a reasonable chance to respond, and then send a final adverse action notice before finalizing the decision not to hire.
For related screening topics, see our posts on hearing aid specialist license background checks and speech language pathologist background check requirements. Learn more about employment background screening at Reveal Background.
This article is general information, not legal advice. Employers should consult qualified counsel about screening and licensing obligations in their state.
