Quick Summary: What PIN 26-09-CCLD Changes

On May 4, 2026, the California Department of Social Services (CDSS), through its Community Care Licensing Division (CCLD) and Care Provider Management Branch (CPMB), released Provider Information Notice (PIN) 26-09-CCLD, which supersedes the prior PIN 24-02-CCLD. This updated notice directly impacts how every licensed Residential Care Facility for the Elderly (RCFE), Adult Residential Facility (ARF), Group Home (GH), Short-Term Residential Therapeutic Program (STRTP), and Resource Family Approval (RFA) home initiates background checks through California's Guardian System.

The headline change is procedural with major operational implications: applicants should now initiate their application in Guardian before visiting a Live Scan vendor. Combined with the rollout of Assembly Bill (AB) 1720, which discontinues the pre-Live Scan criminal history disclosure requirement for most applicants, PIN 26-09-CCLD represents one of the most significant background check workflow changes for California care facilities in years.

This guide breaks down what licensees, administrators, and prospective employees need to do to remain compliant, reduce clearance delays, and avoid the costly mistake of having an unclearable applicant on the premises.

Why PIN 26-09-CCLD Matters: The Cost of Doing It Wrong

Every California residential care administrator knows the pain of a stalled background check. A delayed clearance can mean a delayed start date, lost staffing capacity, unbilled care hours, and in worst-case scenarios, a citation for an unauthorized person being present in a licensed facility.

PIN 26-09-CCLD was issued because CDSS identified a recurring pattern: applicants were going directly to Live Scan vendors before their application existed in the Guardian System. The result was predictable: mismatched Department of Justice (DOJ) records, missing email addresses, no facility association, manual data requests from CPMB, and clearance delays that sometimes stretched weeks beyond the 14-day standard processing window.

The fix is procedural, free, and within the licensee's control. Facilities that adopt the "Guardian First" workflow described in this PIN typically see faster clearances, fewer rejected fingerprint submissions, and reduced back-and-forth with the Care Provider Management Branch.

Who Must Comply With PIN 26-09-CCLD

PIN 26-09-CCLD applies to all CCLD licensees, providers, and applicants, including but not limited to the following facility types and programs.

Covered facility types and programs

Residential Care Facilities for the Elderly (RCFE) - Title 22, Division 6, Chapter 8

Adult Residential Facilities (ARF) - Title 22, Division 6, Chapter 6

Group Homes (GH) - Title 22, Division 6, Chapter 5

Short-Term Residential Therapeutic Programs (STRTP) - Interim Licensing Standards

Resource Family Approval (RFA) Homes

Children's Residential Facilities

Foster Family Agencies (FFA) and associated certified family homes

If your facility is licensed by CCLD and you onboard employees, volunteers, board members, household members, or any individual subject to a criminal background check, this PIN applies to you.

The Major Update: AB 1720 and the End of Pre-Live Scan Criminal History Disclosure

Under prior policy, every applicant was required to complete a criminal history disclosure form before receiving Live Scan results. PIN 26-09-CCLD formalizes the implementation of Assembly Bill (AB) 1720, which discontinues this requirement for the majority of applicants.

Who is still required to disclose criminal history pre-Live Scan

The exemption from pre-disclosure does not apply to applicants seeking approval as Resource Family Homes (RFA), applicants associated with Children's Residential Programs that require Out-of-State Registry checks, and specific foster care program applicants required under federal law.

For these populations, the disclosure forms LIC 508 O-O-S (Out-of-State Disclosure) and LIC 508D (Out-of-State Disclosure and Criminal Record Statement) must still be physically obtained and submitted prior to the Live Scan being processed.

For most other applicants (RCFE caregivers, ARF direct care staff, GH staff, STRTP employees, household members, administrators, and most volunteers), the disclosure form requirement at the pre-Live Scan stage has been eliminated. This reduces administrative burden but increases the importance of following the Guardian System workflow correctly.

The "Guardian First" Workflow: Step-by-Step Compliance

PIN 26-09-CCLD outlines two compliant pathways for initiating a background check: an Applicant-Initiated process and a Licensee-Initiated process. Both must begin in Guardian before any fingerprinting occurs.

Pathway 1: Applicant-Initiated Guardian Application

Step 1: Licensee issues the Applicant Instruction Form. The licensee provides the prospective applicant with the Applicant Instruction Form and a unique PIN code generated through Guardian. This PIN ties the applicant's submission to your facility.

Step 2: Applicant creates a Guardian profile. The applicant logs into the Guardian Applicant Portal using a valid, regularly monitored email address. CDSS communicates clearance status and documentation requests to this email.

Step 3: Licensee receives alert and resumes the application. Once the applicant completes their portion, an automatic alert appears in the licensee's Guardian queue. The administrator clicks "Resume" on the pending application.

Step 4: Licensee finalizes and generates the prepopulated Live Scan form. After facility association and role information are finalized, Guardian produces a prepopulated BCIA 8016 Live Scan form with the verified ORI number, billing code, and applicant data.

Step 5: Applicant takes the prepopulated form to a Live Scan vendor. The applicant brings the printed form to a certified California Live Scan vendor. Fingerprints are submitted electronically to DOJ and FBI.

Step 6: Clearance processing (14-day standard). For clean records, DOJ has 14 calendar days to return criminal history information to CDSS. Clearance is typically issued within this window when there are no DOJ/FBI criminal history hits, no Child Abuse Central Index (CACI) match, no Adult Abuse Registry System (AARS) match, and no required Out-of-State Registry check.

Pathway 2: Licensee-Initiated Guardian Application

Step 1: Search for existing PER ID. The licensee searches the Guardian database using the applicant's PER ID number if previously issued.

Step 2: Search by identifying information. If no PER ID is available, search using name, date of birth, Social Security Number, and driver's license.

Step 3: Add new applicant. If no profile exists, select "Add New Applicant" and enter the required information in Guardian.

Step 4: Children's Residential and RFA disclosure forms. For Children's Residential or RFA applicants, obtain the physical LIC 508 O-O-S or LIC 508D as appropriate before proceeding.

Step 5: Generate the prepopulated Live Scan form. Complete the application to produce the verified Live Scan submission form.

Step 6: Applicant submits fingerprints. The applicant proceeds to a Live Scan vendor with the Guardian-generated form.

The 14-Day Clearance Standard: What to Expect

PIN 26-09-CCLD reinforces that DOJ has 14 days to provide criminal history results to CDSS. For applicants with no disqualifying history, clearance typically follows shortly after.

However, the 14-day clock starts only when the Live Scan submission successfully matches the Guardian application. Mismatches caused by skipping the Guardian-First workflow, transcription errors on hand-filled BCIA 8016 forms, or incorrect ORI numbers can reset the clock and trigger manual review delays.

This is why the PIN emphasizes the prepopulated form: it is one of the most important tools for hitting the 14-day clearance window.

Critical Compliance Rule: Out-of-State Registry Applicants

PIN 26-09-CCLD restates a non-negotiable requirement: applicants subject to an Out-of-State Registry check are not authorized to work or be present in a licensed facility or approved home until the out-of-state child abuse and neglect registry check has been completed.

This most often applies to Children's Residential and RFA applicants who have lived outside California within the last five years. Allowing such an individual to be present in the facility prior to completed clearance can result in a citation and potential licensing action.

Required Forms and Reference Documents

To remain compliant with PIN 26-09-CCLD, licensees should maintain ready access to the following documents: LIC 508 O-O-S, LIC 508D, LIC 9277LUA, and BCIA 8016 (prepopulated by Guardian). Related references include PIN 22-16-CRP, PIN 21-22-CCLD, and AB 1720.

Administrators should also ensure their Guardian user accounts remain active. Inactive accounts must be reinstated via the LIC 9277LUA before any new applications can be initiated.

Common Pitfalls That Delay Clearance

The most frequent causes of background check delays include going to Live Scan first, using non-prepopulated BCIA 8016 forms, invalid applicant email addresses, missing facility association (no unique PIN code used), allowing pre-clearance presence in the facility for out-of-state applicants, and failing to monitor the Guardian queue for pending applications.

How PIN 26-09-CCLD Connects to Title 22 Compliance

California Title 22 background check requirements appear throughout each facility type's regulation framework, including RCFE (Title 22 sections 87355 and 87219), ARF (Title 22 section 85019), GH (Title 22 section 84019), and STRTP (Interim Licensing Standards section 87019).

PIN 26-09-CCLD is not a regulatory change by itself. It is a procedural update for how existing Title 22 requirements are operationalized through the Guardian System.

Practical Action Items for Administrators

Confirm your Guardian user account is active and your LIC 9277LUA is on file. Update your hiring workflow to require Guardian application initiation before Live Scan referral. Train staff to issue the Applicant Instruction Form and unique PIN code at the offer stage. Remove pre-Live Scan disclosure forms from standard onboarding for non-RFA/non-Children's Residential applicants (per AB 1720). Retain LIC 508 O-O-S and LIC 508D for applicable out-of-state applicants. Review the Guardian queue daily. Document the procedure in policies and procedures. Ensure staff understand out-of-state applicants cannot be on-site until clearance is complete.

CDSS Support and Contact Information

For technical or procedural questions related to PIN 26-09-CCLD:

Guardian General Inquiries: Guardian@dss.ca.gov

CPMB Phone Line: 1-888-422-5669 (Monday - Friday, 8:00 AM - 12:00 PM)

Login Support: GuardianLoginSupport@dss.ca.gov

Administrators are encouraged to subscribe to the CCLD email distribution list to receive future PIN updates directly.

Staying Ahead of California Background Check Compliance

PIN 26-09-CCLD reflects a broader trend in California Community Care Licensing: process modernization paired with stricter accountability for licensees. Administrators who internalize this workflow now will be positioned to comply with PIN 26-09-CCLD and to operate more efficiently as additional modernization PINs are released.

Administrators completing biennial certification renewal can explore CDSS-approved Title 22 continuing education courses at 123ceu.com, which include current regulatory updates within the "Laws, Regulations, Policies and Procedural Standards" core knowledge area required for license renewal.

Frequently Asked Questions About PIN 26-09-CCLD

Does PIN 26-09-CCLD apply to my RCFE if I only hire occasionally?

Yes. Any time you initiate a background check for a new employee, volunteer, household member, or applicant, the Guardian-First workflow applies.

What happens if my applicant already went to Live Scan before I created the Guardian application?

The Live Scan submission may not match in the Guardian system, requiring manual reconciliation by CPMB. This commonly adds 5-15 business days to the clearance timeline.

Do I still need the LIC 508D for my new RCFE caregiver?

Under AB 1720, no, unless your applicant is part of a Resource Family Home or a specific Children's Residential program. Most RCFE, ARF, GH, and STRTP applicants are no longer required to complete pre-Live Scan disclosure.

How long does a clean background check take under PIN 26-09-CCLD?

DOJ has 14 calendar days to return results. For applicants with no criminal history, no CACI hits, and no out-of-state requirement, clearance typically follows within that window.

Can a new hire start work while their background check is pending?

Only under specific conditions and never for applicants requiring out-of-state registry checks. Refer to your facility type's Title 22 section for clearance transfer and exemption rules.