How should you background-check techs who work in customers' homes?
The FCRA process for HVAC and plumbing shops, what ban-the-box timing changes, how far back a report can reach, and what to do when something turns up.
Running a background check on an HVAC technician or plumber you are about to send into customers' homes means following the federal Fair Credit Reporting Act (FCRA) whenever a screening company produces the report: a stand-alone written disclosure first, a copy of the report and a Summary of Rights before any adverse decision, and an adverse action notice if you decline to hire.
This page walks through what to screen for, the steps in order, where state law changes the timing, and what to do when a record comes back.
What should a background check cover for in-home service work?
The screen should answer the questions a homeowner would ask before opening their door: who is this person, and can I trust them alone in my house?
An HVAC or plumbing tech works inside customers' homes, often without anyone from your company standing there, around belongings, children and home security.
In-home service is the reason this hire gets screened more carefully than a back-of-house role, and your criminal screen should be built around that reality.
Build it targeted, not sweeping.
The EEOC's guidance on criminal records in hiring says a targeted screen should consider at least the nature of the crime, the time elapsed and the nature of the job — and the nature of the job, for your techs, is unsupervised access to customers' homes.
Writing down the job's duties before you order the report gives you the scope for the screen, and it is also what makes the assessment steps later in this page defensible.
Know the hard exclusion: the FTC warns employers not to ask any medical questions before a conditional job offer has been made.
Medical history and disability stay out of your screening questions at the application stage.
One boundary note: criminal history is not the whole screening picture.
If your techs drive a company van, the driving record is its own check with its own rules, and drug testing is another — both belong to their own decisions.
And our research confirmed the process rules below, not a standard list of searches every check must include, so ask your screening provider what its report covers and have it tailored to in-home service work.
What steps does the FCRA require?
These steps apply when the report comes from a screening company: the Fair Credit Reporting Act governs that transaction, and the Federal Trade Commission's guidance for employers lays the process out as a sequence of notices.
Run it in order.
Before you order the report: tell the applicant in writing, in a stand-alone notice that is not part of the job application, that you intend to get a background report for employment purposes.
The FTC is explicit that the notice must be in writing and in a stand-alone format — it cannot live inside your employment application.
Before you act on the report: if what comes back might lead you to decline the hire, give the person a copy of the report you relied on and the Summary of Your Rights Under the FCRA, before you take the adverse action.
This pre-adverse step is where the candidate sees what the report actually says — and where mistaken matches and missing context surface while there is still time to correct them.
After you act: if you decline the hire based on the report, tell the person — orally, in writing or electronically — in the second, adverse action notice.
The order matters as much as the content: disclosure before the check, the report copy and rights summary before the decision, the notice after.
Whatever your screening provider automates, the obligations are yours — confirm your current workflow against the FTC's employer guidance before your next hire.
What do ban-the-box laws change?
At minimum, these laws change when the criminal-history question may be asked.
"Ban-the-box" is the everyday shorthand for fair-chance laws — rules that limit at which point in the hiring process an employer may ask about a candidate's criminal history — and the name refers to the conviction-history checkbox on job applications.
If a law where you hire delays criminal-history inquiries, sequence your stand-alone FCRA disclosure and the report order so the criminal check does not arrive before the point your law allows you to ask.
And timing is not necessarily the whole of it: a fair-chance law can also add its own notice, waiting or response requirements, or a written-assessment step, on top of the federal sequence.
What this page will not do is list states.
Our research covered the federal FCRA process; state and city ban-the-box, fair-chance licensing and reference-immunity laws were not researched, so we cannot tell you which jurisdictions restrict what, what extra steps they add, or how the two layers interact — and you should not assume the city you hire in is unaffected.
Confirm what applies where you hire: an employment attorney or your state labor department can tell you whether a fair-chance law covers a company like yours, where in the process it lets the question and the check happen, and what it adds to the FCRA sequence.
Build your application and screening sequence around that answer — run the FCRA notices from the previous section, plus any extra steps your local law adds.
How far back can you look?
We will not give you a number of years, because our research did not confirm one.
How far back a screening report reaches is governed by federal reporting rules and state laws this page's research did not cover, and the answer varies by jurisdiction and by what is being reported.
Ask your screening provider how far back its reports reach in your states, and confirm with an employment attorney what you may weigh in a hiring decision where you operate.
What is confirmed is how time is weighed once a record is in front of you.
The EEOC's guidance says a targeted screen should consider the nature of the crime, the time elapsed and the nature of the job — so even where an offense can appear on the report, how long ago it happened is an explicit factor in assessing it.
A reporting limit and a relevance judgment are two different questions: the first belongs to the rules above, the second to your assessment.
What do you do if something turns up?
Do not start from a blanket decline.
The EEOC's guidance says a targeted screen should consider the nature of the crime, the time elapsed and the nature of the job, plus an individualized assessment of the candidate.
For an in-home service hire, write the assessment down: what the record was, how long ago, how it relates to the work, and what the candidate says about it.
Then run the FCRA sequence if the report is driving the decision: before you decline, the candidate gets the report copy and the Summary of Your Rights Under the FCRA; if you go ahead and decline, the adverse action notice follows.
Handing the report over first is not a formality — it is where wrong matches and outdated records get caught, sometimes in time to save a hire worth keeping.
If the assessment leads you to hire anyway, the U.S. Department of Labor has a tool for exactly this.
Its Federal Bonding Program, created in 1966, provides free fidelity bonds of $5,000 with no deductible covering the first six months of an at-risk new hire's employment — insurance against the fidelity risk that makes in-home service owners hesitate, at no cost to you.
The bonding program is the second-chance piece to know about first.
Screening is one link in the hire.
What comes before it — sourcing, pay plans, offers — is in our guide to hiring HVAC and plumbing techs.
This page is employer career and business information, not legal advice. Screening rules come from federal agencies (FTC, EEOC, Department of Labor) and from state and city law — confirm what applies to your company with an employment attorney before you finalize your process.
Background-check steps, in order
- Ask no medical questions before a conditional job offer.
- Disclose in writing first — a stand-alone notice that is not part of the job application.
- Order the report from your screening company only after that disclosure.
- Assess each record that comes back individually: nature of the crime, time elapsed, nature of the job.
- Before any adverse decision, give the candidate the report copy plus the Summary of Your Rights Under the FCRA.
- If you decline, send the adverse action notice — orally, in writing or electronically.
Questions employers ask
Does the FCRA apply if I look up public records myself instead of using a screening company?
The FCRA steps on this page attach when the report comes from a company that screens for you.
If you search public records directly, different rules can apply — our research covered the screening-company process, so ask an employment attorney before substituting do-it-yourself searches.
Can I ask about an applicant's medical history during a background check?
Before a conditional job offer has been made, the FTC's guidance to employers is not to ask any medical questions.
What you may ask after an offer is a separate question this page does not cover — keep health and disability out of your screening questions at the application stage.
What is the Summary of Your Rights Under the FCRA?
It is the document that explains a candidate's rights under the federal Fair Credit Reporting Act.
When a background report might lead you to decline a hire, you must give the person a copy of the report you relied on and this summary before taking the adverse action.
Is there any help for hiring someone with a record?
Yes — the U.S. Department of Labor's Federal Bonding Program, created in 1966, provides free fidelity bonds of $5,000 with no deductible covering the first six months of an at-risk new hire's employment.
Pair it with the individualized assessment the EEOC recommends when a record turns up.
More hiring resources
Ready to hire a tech worth trusting in customers' homes?
Post your HVAC or plumbing opening where techs who take in-home work seriously look, then run the screening sequence above on the applicants who apply — disclosure ready before you order a single report.