Verification Processing Standards

A verification is only as reliable as the source providing the information. Whenever possible, information should be confirmed directly with the organization or individual responsible for maintaining the original record.

• Employment. Verify employment through the employer’s HR or payroll department, or through the verification service designated by the employer.
• Education. Verify education through the institution’s registrar or its designated verification service.
• Credentials and licenses. Confirm licenses and certifications directly with the board, agency, or organization that issued them.
• Professional references. Confirm that the person contacted is the individual named by the consumer and has the stated relationship to them.
• Military service. Verify service through the National Personnel Records Center or with documentation confirmed by the issuing military branch.

Not everyone with knowledge of a fact is an authoritative source. A supervisor who remembers working with someone, for example, may provide a reference, but that recollection is not an employment verification. Employment should be verified through the source responsible for maintaining the employment record.

Documents provided by the consumer should also be treated as supporting information rather than independent verification. A diploma, transcript, certificate, or DD 214 can help identify the appropriate source, but the information is verified only when it is confirmed by the issuer or another authoritative source.

Some databases sell employment data drawn from payroll files with no arrangement with the employer. A database of that kind will return a match on a consumer. A match is not a verification, because no one at the employer confirmed it.

Employment verification confirms that the employment reported by the consumer can be substantiated by the employer or its designated verification source.

Information submitted to the source

• Consumer’s full legal name, and any other name used during that employment
• One matching identifier, ordinarily a partial Social Security number or date of birth
• Employer legal name and worksite location
• Dates of employment and position as reported by the consumer
• The consumer’s signed authorization, where the source requires one

Information confirmed before the verification is reported

• The employing entity’s name as stated by the source
• Dates of employment, month and year at minimum
• Job title
• The responding party or system, the method of contact, and the date completed

• Report what the source confirms. Dates of employment and job title are commonly available, but employers vary considerably in what they will disclose. Do not assume that additional information should be available.
• Do not treat a limited response as a discrepancy. If an employer confirms dates but has a policy against providing job titles, the title is unverified, not contradicted. Report what was confirmed and identify anything the source declined or was unable to verify.
• Handle salary and separation information carefully. Salary history and reasons for leaving may be restricted by state or local law, and many employers will not provide them as a matter of policy. Obtain and report this information only when appropriate for the purpose of the verification and permitted by applicable law.
• Know how to handle closed or acquired employers. A closed business does not necessarily make employment unverifiable. A successor company, payroll provider, records custodian, or other authorized source may still maintain the employment records. If no authoritative source can be located, report the employment as unable to verify and explain why.
• Identify the actual employer of record. Staffing, PEO, and other co employment arrangements can make the worksite different from the legal employer. Determine which entity maintained the employment record and direct the verification there.

Education verification should establish exactly what the institution can confirm about the consumer’s attendance, degree, and other reported educational history.

Information submitted to the source

• Consumer’s full legal name, and any other name used while enrolled
• Date of birth, or a partial Social Security number where the institution requires one
• Institution name and campus
• Dates of attendance, degree, and field of study as reported by the consumer
• The institution’s own release form, where it requires one

Information confirmed before the verification is reported

• Institution name as stated by the source
• Dates of attendance
• Whether a degree or credential was awarded
• The degree awarded, the field of study, and the date conferred
• The responding party or system, the method of contact, and the date completed

• Distinguish attendance from graduation. A consumer may have attended an institution without earning a degree. Confirm and report these as separate facts rather than treating attendance as evidence of graduation.
• Verify the degree as reported. Confirm the degree or credential awarded, field of study when available, and date conferred. A different degree, field, or conferral date may represent a discrepancy and should be reported accurately.
• Confirm accreditation when it matters. Accreditation is separate from degree verification. When accreditation is relevant to the purpose of the report, verify it through the appropriate recognized accrediting source rather than relying solely on the institution.
• Locate the records custodian for closed schools. When an institution closes, its records may be transferred to a state agency, successor institution, or other designated custodian. Once identified, that custodian becomes the appropriate source for verification.

A license or professional credential should be verified directly with the organization responsible for issuing and maintaining it.

Information submitted to the source

• Consumer’s full legal name, and any other name under which the credential may be held
• License or certification number as reported by the consumer
• Issuing board, agency, or organization
• Jurisdiction
• Credential type, with issue or expiration dates where reported

Information confirmed before the verification is reported

• The licensee name as stated by the issuer
• License or certification number
• Credential type and issuing jurisdiction
• Current status and the dates that status covers
• Disciplinary action recorded against the credential, where the issuer publishes it
• The registry or verification unit consulted, the method, and the date completed

• Verify with the issuing authority. Confirm licenses and certifications through the board, agency, or organization responsible for the credential rather than relying solely on documentation supplied by the consumer.
• Confirm current standing, not just issuance. Determine whether the credential is active, expired, suspended, revoked, restricted, or otherwise subject to a status that may be relevant to the report.
• Check each applicable jurisdiction. Professional licenses are often jurisdiction specific. A license in one state does not establish licensure or standing in another.
• Keep sanctions and exclusions separate. License verification does not necessarily identify healthcare sanctions, federal exclusions, disciplinary databases, or other specialized records. When those records are required, search the appropriate sources separately.

Reference checks require a different approach because the information comes from an individual rather than an institutional record.

Information submitted to the source

• Consumer’s full legal name
• The reference’s name, stated relationship to the consumer, and contact information as provided by the consumer
• The question set approved by the client, where one exists

Information confirmed before the verification is reported

• The identity of the person contacted
• That the person holds the relationship stated by the consumer
• The date, time, and method of contact
• The responses, recorded as given

• Confirm who is providing the reference. Before recording the response, establish that the person contacted is the individual identified by the consumer and confirm their stated relationship to the consumer.
• Attribute statements to the source. References are inherently subjective. Record what the reference actually says and clearly attribute opinions, observations, and other statements to that person rather than presenting them as independently established facts.
• Separate verification from opinion. A reference may confirm factual information while also providing opinions about performance, character, or reputation. Those are different types of information and should be reported accordingly.

A reference check can become an investigative consumer report when information about a consumer’s character, general reputation, personal characteristics, or mode of living is obtained through personal interviews. When the product meets that definition, the additional requirements of FCRA § 1681d may apply.

The CRA should therefore define clearly whether its product is a factual verification, a reference interview, or an investigative consumer report. The distinction depends on the information being obtained and reported, not simply on what the product is called.

Military service should be verified through the National Personnel Records Center (NPRC) or the issuing branch. What NPRC will release depends on whether the consumer has authorized the release and how long ago the service member separated.

Information submitted to the source

• Consumer’s full legal name as used in service
• Service number or Social Security number
• Branch of service
• Date and place of birth
• Dates of service as reported by the consumer
• The consumer’s signed and dated authorization, where the request goes beyond publicly releasable information

Information confirmed before the verification is reported

• Branch of service
• Dates of service
• Final rank and final duty status
• Type of separation, where the consumer has authorized its release
• The source consulted, the method, and the date completed

• Know what is releasable without authorization. From non-archival files, NPRC will release name, service number, dates of service, branch, final duty status, final rank, assignments and geographic locations, military education level, awards eligibility, and place of entrance and separation without the veteran’s consent.
• Obtain a signed authorization for anything further. A third party requester submits the request with the veteran’s signed and dated authorization, which NPRC treats as valid for 1 year from the date of signature.
• Records become archival 62 years after separation. Archival files are open to the public. Files from more recent separations remain restricted.
• Treat a consumer supplied DD 214 as a starting point. DD 214s are forged. The document identifies the record to request, and NPRC or the issuing branch confirms it.
• NPRC does not hold records of current service members. It maintains the records of discharged and deceased veterans. Current service status should be confirmed through the Department of Defense.

FCRA § 1681e(b) requires reasonable procedures to assure maximum possible accuracy of the information a report contains. For verifications, that standard is met through procedures applied the same way on every file.

• Establish an attempt standard and follow it. Define how many attempts will be made, over what interval, and through which channels before a verification is closed as unable to verify. Consistent application is what makes the outcome defensible.
• Treat unable to verify as a legitimate result. It is neither a failure nor an adverse finding. Report it with the reason stated and the attempts documented.
• Never report a result as confirmed by inference. A source that does not respond has confirmed nothing. A source that confirms dates has confirmed dates.
• Report discrepancies without characterizing them. State what the consumer provided and what the source confirmed. Whether a two month difference in dates reflects a payroll convention or a misstatement is the employer’s determination.
• Document every attempt. Record the date, time, method, party contacted, and outcome, including attempts that produced no response.
• Record the date of verification. A verification is accurate as of the date it was performed. Where substantial time passes between verification and delivery, the result should be confirmed again.