Post-Hire Screening

           It’s common to perform a motor vehicle record (MVR) check during the hiring process to ensure you hire responsible drivers with the appropriate and valid licenses. While it is important to undergo a pre-employment screening process before hiring a candidate, screening current employees is no less critical. The Federal Motor Carrier Safety Administration (FMCSA) requires that companies annually review their drivers to guarantee that they maintain an appropriate, valid license and comply with FMCSA regulations. Even more, some insurance may require or prefer annual screening.

           An easy way to comply with this regulation is to have an annual employee screening process using MVR reports. There are several steps you can take to implement a post-hire screening program.

1. It would be best if you institute a post-hire or current employee screening policy. Having a written policy is an excellent way to initiate this process in an unbiased and impersonal manner. It can also help employees to understand what this process entails.
    
2. As part of this policy, you should consider how often you want to review driving records. MVR records should be re-ordered annually, as they provide driver license records that are important for compliance reasons. Other types of reports like complete background checks can be ordered more infrequently. Note: PSP reports should not be included as part of a current employee screening process, as these reports can only legally be pulled before hiring a candidate.
    
3. An essential step in establishing a current employee screening program is informing both existing employees and new hires of the policy. Presenting this process as routine and impersonal can help minimize resistance. Additionally, you must obtain consent for all screening you conduct. If an employee was screened before hiring, they might have already signed a form that gives their consent until they revoke it. However, some states require a new consent form to be signed each time a screening takes place. Make sure to check local laws, and always err on the side of caution.
    
4. Once you have established a process for completing a screening, you must decide what to do with the screening results. Ideally, the screening process will turn up nothing you don’t already know. However, on the off chance it does, you must consider how to proceed. Any action taken based on report results, such as firing an employee, should be done with careful consideration. There is some chance a report could turn up incorrect results. Always discuss with the employee and ask for an explanation before proceeding.

If you decide to terminate an employee due to the results of an MVR record, or another report, you must follow an adverse action process. You can learn more about the adverse action process here. While adverse action typically is about the new hire process, it also applies to current employees.

If your company does not have a post-hire screening program, it is vital to implement one as soon as possible. Not only does post-hire screening ensure compliance, but it allows you to check your employees’ driving histories and catch problems before they can cascade.