A pharmacist sits closer to controlled substances than almost any other licensed professional outside of medicine, which is why the screening around this role happens in layers. A state board of pharmacy vets the license itself before anyone can legally practice. The Drug Enforcement Administration governs the separate registration needed to handle controlled substances. Federal health program exclusion lists determine whether a pharmacist can touch Medicare or Medicaid billed work at all. And on top of all of that, the employer runs its own background check under the Fair Credit Reporting Act. Each layer answers a different question, and employers who understand where one stops and the next begins tend to build a much tighter hiring process.
State board of pharmacy licensing and fingerprint based background checks
Licensure is the foundation. Every state requires a pharmacist to hold an active license issued by its own board of pharmacy, and nearly every board conditions initial licensure, and often renewal, on a criminal history background check tied to fingerprints. The fingerprints typically get submitted through a state identification bureau and the FBI, so the check reaches both state and federal criminal records rather than relying on a name search alone.
The specifics vary by state. The California State Board of Pharmacy requires applicants to complete a criminal background check as part of the licensing process and details the submission steps on its applicant page. The Texas State Board of Pharmacy requires fingerprint based criminal history checks for pharmacist licensure and renewal. Washington State’s Department of Health outlines fingerprinting and background check steps for pharmacist applicants as part of its credentialing process. New York’s Office of the Professions, which oversees pharmacist licensure through the State Education Department, lists the requirements a candidate must satisfy before the license is issued.
| State board | What the licensing check generally covers | Primary source |
|---|---|---|
| California | Fingerprint based state and FBI criminal history submitted with the license application | California State Board of Pharmacy, applicant information |
| Texas | Fingerprint based criminal history check required for licensure and renewal | Texas State Board of Pharmacy, pharmacist licensing |
| Washington | Fingerprinting and background check as part of the credentialing process | Washington State Department of Health, pharmacist credentialing |
| New York | Licensure requirements administered through the Office of the Professions | New York State Education Department, Office of the Professions, pharmacy |
Because licensing rules are set state by state, an employer should never assume a pharmacist licensed in one state has cleared the same background review a neighboring state would require. Confirm the license is active and in good standing directly with the issuing board rather than relying solely on what the candidate reports.
DEA registration and controlled substances context
A pharmacy license lets a pharmacist practice. It does not by itself authorize handling controlled substances. That authority runs through the Drug Enforcement Administration’s registration process, administered by DEA’s Diversion Control Division, which registers pharmacies and, in many practice settings, the individual practitioners who order, dispense, or otherwise handle scheduled drugs. Registration review can consider factors tied to a state license, prior denials, or a controlled substance related conviction record. Employers hiring for roles with dispensing authority should confirm that any required DEA registration is current and unrestricted, in addition to confirming the state license.
Drug diversion, meaning the unauthorized channeling of legally manufactured controlled substances away from their intended medical use, is a real risk in pharmacy settings specifically because pharmacists have legitimate access to inventory that other employees do not. This is not a reason to speculate about any individual candidate. It is a reason employers in this field lean on the verification layers described here, rather than informal reference checks alone, when a role includes controlled substance access.
Federal exclusion screening: OIG LEIE and SAM
If a pharmacy or health system bills Medicare, Medicaid, or another federal health care program, it has a compliance obligation that goes beyond licensure. The Department of Health and Human Services Office of Inspector General maintains the List of Excluded Individuals and Entities, commonly called the LEIE, which identifies people barred from participation in federally funded health programs because of program related convictions, patient abuse findings, licensure revocations, or other statutory grounds. OIG publishes the legal authorities behind exclusion, and the LEIE itself, on its exclusions program page. Employers in this space are generally expected to check new hires against the LEIE before employment and to rescreen on an ongoing basis, since an exclusion can be added at any time.
The System for Award Management, known as SAM.gov, maintains a separate federal exclusions record tied to parties barred from receiving federal contracts, grants, and certain other federal benefits. It does not fully overlap with the LEIE, so healthcare employers billing federal programs commonly check both. Screening against a name alone can also produce false matches, so employers should confirm any potential hit using date of birth, license number, or other identifying detail before acting on it, and should document the check itself as part of a compliance file. We cover the mechanics of running both lists in more depth in our guide to healthcare exclusion screening with OIG LEIE and SAM.
NPDB and prior disciplinary or diversion history
The National Practitioner Data Bank, operated by the Health Resources and Services Administration, collects reports on licensure actions, clinical privilege actions, and certain malpractice payments involving health care practitioners, and pharmacists can be reportable subjects depending on the underlying event and the reporting entity involved. Hospitals, health plans, and state licensing boards are the primary parties that query the NPDB, and access is governed by federal rules rather than open to the general public or to a typical employer background check vendor. A hospital credentialing office bringing on a pharmacist, or a state board investigating a license, may query the NPDB as part of that specific process. HRSA explains who may query the databank and under what circumstances on the official NPDB site.
Separately, a pharmacist’s own state licensing file, which is generally public record through the board’s website, will typically show any formal disciplinary action, including matters connected to drug diversion, dispensing errors, or practice restrictions. Checking that public license record directly with the issuing board is one of the more reliable and least ambiguous steps in the process, and it costs nothing.
The employer background check and the FCRA process
Separate from licensing and exclusion screening, most employers also run a standard pre-employment background check through a consumer reporting agency, and when they do, the Fair Credit Reporting Act sets the rules for how that has to happen. The Federal Trade Commission’s guidance for employers lays out the core steps in order.
- Give the candidate a clear, standalone disclosure that a background check will be obtained, separate from the job application itself.
- Get the candidate’s written authorization before requesting the report.
- If the employer is considering an adverse decision based on the report, such as not hiring, send a pre-adverse action notice that includes a copy of the report and a copy of the Summary of Your Rights Under the Fair Credit Reporting Act, and give the candidate a reasonable opportunity to respond before finalizing the decision.
- If the employer proceeds with the adverse decision, send a final adverse action notice that includes the required FCRA disclosures, including how to reach the reporting agency and how to dispute the report.
A criminal record does not automatically disqualify a candidate, and what typically appears on a report, and how far back it can be reported, varies by state and by the type of check run. Employers should not assume a background check will surface every past record in every state, since reporting limits and state specific rules genuinely differ, and should not represent to a candidate that any particular record is certain to be hidden or certain to appear. For pharmacist and other licensed roles specifically, confirming license status directly with the issuing board remains a separate step from the FCRA background check and should not be skipped just because a report came back clean. Our overview of professional license verification for background checks walks through how that confirmation step typically works across licensing boards.
Putting the layers together
| Screening layer | Who runs it | What it answers |
|---|---|---|
| State board licensure check | State board of pharmacy | Is this person legally allowed to practice as a pharmacist in this state |
| DEA registration | DEA Diversion Control Division | Is this pharmacist or pharmacy authorized to handle controlled substances |
| OIG LEIE and SAM exclusion check | Employer or health system compliance team | Is this person barred from federal health program or federal contract participation |
| NPDB query | Hospitals, health plans, and licensing boards, where authorized | Has this practitioner had a reportable licensure, privilege, or malpractice event |
| FCRA background check | Employer through a consumer reporting agency | What does this candidate’s broader criminal, employment, and record history show |
No single layer covers everything the others do. A clean state license does not confirm DEA registration status. A clean FCRA report does not confirm exclusion status. Building all five checks into a standard pharmacist hiring workflow, and repeating the license and exclusion checks periodically rather than only at hire, is the more defensible approach for pharmacies, health systems, and long term care providers that carry real regulatory exposure if a gap gets missed.
Frequently asked questions
Does a state pharmacy license check replace a standard background check?
No. The licensing board confirms the person is authorized to practice and reviews criminal history tied specifically to licensure standards. A separate FCRA compliant background check through a consumer reporting agency covers the broader hiring decision and follows its own disclosure and authorization rules.
Do all pharmacists need DEA registration?
Registration requirements depend on the practice setting and whether the individual, as opposed to only the pharmacy itself, needs authority to handle controlled substances in that role. Employers should confirm the applicable registration status for the specific position rather than assuming one standard answer covers every pharmacy job.
Who has to check the OIG exclusion list for pharmacist hires?
Any employer that bills or participates in Medicare, Medicaid, or other federal health care programs generally needs to screen new and current staff against the LEIE, since employing an excluded individual in a role connected to federally reimbursed care can create liability for the employer, not just the individual.
Can employers access a pharmacist’s full NPDB history directly?
Generally no. NPDB access is limited by federal rule to specific eligible entities such as hospitals, health plans, and state licensing boards for defined purposes, not to general employer background check requests.
Will a background check always show a past pharmacy license disciplinary action?
A standard FCRA background check may not automatically surface board disciplinary history the way a direct check of the state board’s public licensee record would. Verifying license status and any disciplinary history directly with the issuing board is a separate, and often more reliable, step for this profession.
Is a criminal record an automatic disqualifier for a pharmacist role?
Not automatically. What a record means for a specific role can depend on the nature and timing of the offense, the position’s duties, and applicable state and federal law. Employers should apply a consistent process and, where the situation is unclear, consult qualified counsel rather than assuming a blanket rule.
Reveal Background helps employers in healthcare and pharmacy operations build background check programs that hold up, from FCRA compliant reporting to exclusion list monitoring. Learn more at Reveal Background.
This article is general information, not legal advice. Employers should consult qualified counsel and the applicable state board and federal agency guidance before making licensing or hiring decisions.
