Important Update Regarding National Rap Back for FBC Checks

Texas CASA sent an important notice to Executive Directors via email on June 4, 2018, regarding the national rap back for criminal history checks. If you did not receive the notice, please be sure to continue reading for those important updates.

As you may be aware, the national rap back for criminal history checks obtained through a fingerprint-based check (FBC) came online in February 2018. Texas CASA has worked to ensure the network has been kept up to date throughout this process. As of today, the Department of Public Safety (DPS) is still working to get the new FBC checks entered into the rap back system. Once complete, DPS will then focus on uploading all the FBCs conducted between June 1, 2015, and Feb. 15, 2018. They anticipate that upload will be complete by Aug. 31, 2018.

You may recall that Texas CASA had learned the following in February 2018:

  • Both the process and permissions that allow the FBI to keep records of and access the FBC checks changed on June 1, 2015. As a result, all of the FBC checks conducted between Feb. 1, 2014, and May 31, 2015, would need to be re-printed.
  • We would no longer be able to subscribe to an Independent School District or to Child Care Licensing to obtain a FBC for a potential CASA volunteer. Additionally, those who we had previously subscribed to would need to be re-printed.

Texas CASA then submitted a waiver request to the Health and Human Services Commission (HHSC), which monitors compliance with the Texas Administrative Code and monitors Texas CASA, to see if we could “grandfather” in the FBC checks completed prior to June 1, 2015, as well as those who we’ve subscribed to and simply continue to run name-based criminal history checks on them every two years. Unfortunately, that request was denied on April 16, 2018.

Texas CASA then requested an in-person meeting to discuss the waiver request with HHSC again. That meeting was granted and set for May 22, 2018. DPS attended the meeting, as well as two attorneys, and three staff members for HHSC. Unfortunately, Texas CASA’s request for a waiver was denied for a second and final time on May 30, 2018. We now know the following:

  • All volunteers, staff and board members who had their FBC conducted prior to June 1, 2015, will have to be re-printed.
  • Any FBC you have subscribed to through the school or child care licensing systems will have to be re-printed.
  • All members of your organization will need their own FBC obtained by CASA. We can no longer subscribe to checks obtained through the school district or child care licensing.
  • DPS still has not given an implementation deadline for those reprints to occur.

As you can begin to schedule those re-prints, please remember that you can send your reimbursement requests to Texas CASA. If you have any questions, please do not hesitate to reach out to the Texas CASA Program Operations team at

Thank you, as always, for your diligence in this critical area.