California's Child Abuse Index clearance represents a distinct background screening requirement separate from DOJ Live Scan fingerprinting, mandated for individuals in childcare, education, and youth services who will have supervisory or disciplinary authority over children. Recent AB 1432 legislative amendments effective January 2024 have expanded exemption eligibility and streamlined processing procedures, making it essential for HR professionals to understand both the standard clearance pathway and the exemption request process to avoid costly hiring delays.
Key Takeaways
- CACI clearance is a mandatory background check separate from DOJ Live Scan that screens against California's central registry of substantiated child abuse reports, required for specific positions involving child supervision in licensed facilities.
- AB 1432 expanded exemption eligibility beginning in 2024, allowing individuals listed on CACI to request case-by-case reviews if ten years have passed since the incident or their name was added to the index.
- Standard CACI clearance processing typically takes 7-10 business days, while exemption requests can extend 60-90 days depending on case complexity and documentation completeness.
- Only positions with supervisory or disciplinary authority over children require CACI clearance—administrative staff, maintenance workers, and volunteers without direct supervision responsibilities are generally exempt.
- Employers must submit CACI requests using form LIC 508 through licensed childcare facilities, as individual applicants cannot directly request their own clearance.
- A CACI denial does not automatically disqualify employment—applicants can pursue exemptions through the California Department of Social Services with supporting documentation demonstrating rehabilitation.
- Facilities that hire individuals before receiving CACI clearance risk license revocation and civil penalties up to $5,000 per violation under California Health and Safety Code Section 1596.8995.
- California childcare licensing background checks require three distinct components: CACI clearance, DOJ criminal history background check, and FBI fingerprint clearance for comprehensive screening compliance.
Understanding California Child Abuse Index Clearance Requirements
The California Child Abuse Index serves as a confidential database maintained by the Department of Justice. It contains reports of substantiated child abuse and severe neglect investigated by county welfare departments. Unlike criminal background checks that reveal arrests and convictions, CACI clearance specifically screens whether an individual appears on this centralized registry of child welfare findings.
Established under Penal Code Section 11170, the Child Abuse Index contains information submitted by county child protective services when investigations substantiate abuse allegations. Reports remain on the index indefinitely unless successfully challenged through the grievance process or granted an exemption. The California Department of Social Services maintains exclusive authority to grant CACI clearances for employment purposes in licensed facilities.
Who Needs CACI Clearance in 2025
California law mandates CACI clearance for specific categories of employees and volunteers working in licensed childcare facilities, foster family agencies, and resource family approval settings. Positions requiring supervisory or disciplinary authority over children must obtain clearance before employment commencement. Understanding which roles require screening helps organizations allocate resources efficiently and avoid compliance violations.
Positions requiring CACI clearance include:

- Preschool teachers and classroom aides with unsupervised access to children
- Daycare providers and program directors in licensed facilities
- Foster parents and residential treatment facility staff serving minors
- School counselors in private institutions with supervisory responsibilities
- Youth sports coaches and after-school program coordinators
- Volunteers with sole supervisory authority during activities or field trips
Administrative employees, food service workers, maintenance staff, and delivery personnel who lack direct supervisory responsibilities typically do not require CACI clearance. Facility licensing standards may impose more stringent requirements than state minimums, making it essential to verify specific licensing category mandates.
CACI Clearance vs. DOJ Live Scan: Critical Differences
Many HR professionals mistakenly believe DOJ Live Scan satisfies all background check requirements. This creates compliance gaps that expose facilities to licensing violations. California childcare licensing background checks actually comprise three distinct components that serve different screening purposes.
| Screening Component | What It Reveals | Database Source |
| DOJ Live Scan | Arrests, convictions, and dispositions from California law enforcement | California Department of Justice criminal records |
| FBI Fingerprint Clearance | National criminal record information and interstate violations | Federal Bureau of Investigation national database |
| CACI Clearance | Substantiated child abuse reports from welfare investigations | California Child Abuse Index maintained by DOJ |
An individual can pass DOJ and FBI clearances while appearing on CACI if child abuse was substantiated through civil child welfare proceedings rather than criminal prosecution. Conversely, someone listed on CACI may have no criminal record whatsoever, as child protective services investigations operate independently of law enforcement systems.
AB 1432 Legislative Changes and Compliance Impact
Assembly Bill 1432, which took effect January 1, 2024, represents the most significant reform to California's CACI exemption framework in over a decade. The legislation expanded exemption eligibility criteria, established clearer rehabilitation standards, and created streamlined procedures for case reviews.
Prior to AB 1432, exemption requests faced extremely narrow approval criteria with minimal consideration of circumstances or rehabilitation evidence. The updated framework introduces a temporal limitation, allowing exemption requests after ten years from either the incident date or index listing date. This temporal threshold acknowledges that decade-old substantiated reports may not accurately reflect current fitness to work with children.
Expanded Exemption Eligibility Under AB 1432
The new legislation establishes multiple pathways for exemption consideration that were previously unavailable. Applicants can now request exemptions if ten or more years have passed since the abuse incident occurred, regardless of when they were added to CACI. Alternatively, they can pursue exemptions ten years after being listed on the index, even if the underlying incident was more recent.
AB 1432 also mandates consideration of rehabilitation evidence. Documentation showing changed circumstances, therapy completion, stable employment history, and community ties significantly strengthens exemption applications. The Department of Social Services must evaluate whether granting an exemption would pose unreasonable risk to children in care, rather than applying blanket prohibitions.
Implementation Timeline and Transitional Provisions
California childcare facilities had until March 1, 2024, to update hiring policies and procedures to reflect AB 1432 requirements. The Department of Social Services issued revised guidance documents, updated form LIC 508, and established new review protocols during the first quarter of 2024.
Key implementation milestones included:
- January 1, 2024: AB 1432 official effective date with new exemption eligibility standards
- February 15, 2024: Release of revised LIC 508 forms and updated guidance documents
- March 1, 2024: Compliance deadline for facilities to update internal hiring policies
- Ongoing: Acceptance of resubmitted exemption applications from previously denied individuals
Individuals previously denied exemptions under the old framework gained the right to resubmit applications if they now meet the ten-year threshold or can provide additional rehabilitation evidence. Employers should advise affected applicants about reapplication options if initial denials occurred before 2024 under more restrictive standards.
CACI Exemption Request Process Step-by-Step
Requesting a CACI exemption requires thorough documentation, strategic presentation of rehabilitation evidence, and understanding of evaluation criteria applied by Department of Social Services reviewers. The process begins when an employer submits form LIC 508 and receives notification that the applicant appears on the Child Abuse Index. At that point, the applicant can initiate an exemption request rather than accepting automatic disqualification.
Required Documentation and Supporting Evidence
Successful exemption applications include comprehensive supporting documentation that addresses the specific circumstances of the original incident. Essential documents demonstrate rehabilitation and establish current fitness to work with children. Professional documentation carries particular weight in exemption decisions.
Critical supporting documents include:

- Personal statement: Detailed explanation of incident context, acceptance of responsibility, and life changes since occurrence
- Professional treatment records: Completion certificates from parenting classes, substance abuse programs, anger management courses, or mental health treatment
- Character references: Letters from employers, counselors, clergy, or community leaders providing third-party validation
- Employment verification: Letters showing stable work history, particularly in positions requiring trustworthiness and responsibility
- Educational credentials: Transcripts, vocational training certificates, and professional licenses evidencing personal development
Incomplete applications delay processing significantly. Gathering all documentation before submission accelerates review timelines and demonstrates organizational competence to evaluators.
CACI Clearance Processing Time Expectations
Processing times vary based on application type and complexity. Standard clearance requests follow expedited timelines, while exemption reviews require comprehensive evaluation.
| Application Type | Standard Timeline | Peak Season Timeline | Complex Case Timeline |
| Standard CACI Clearance | 7-10 business days | 14-21 business days | N/A |
| Exemption Request | 60-90 days | 90-120 days | 120+ days |
| Resubmitted Exemption | 45-75 days | 75-105 days | 105+ days |
Processing times fluctuate based on application volume, with delays common during peak hiring seasons in August and January. The Department of Social Services may request additional information or clarification during review, which suspends the processing timeline until the applicant responds.
Navigating Denials and Appeal Options
CACI clearance denials do not constitute final employment prohibitions in all circumstances, despite common misconceptions among HR professionals and applicants. The denial simply indicates an individual appears on the Child Abuse Index, triggering the need for exemption evaluation. Understanding available remedies and appeal processes enables employers and applicants to pursue appropriate next steps rather than prematurely abandoning employment opportunities.
Exemption Denial Appeals and Reconsideration
When the Department of Social Services denies an exemption request, applicants receive written notification explaining the decision basis. Explanations often provide limited detail about weighing factors. Applicants can request reconsideration by submitting additional rehabilitation evidence, correcting factual errors in the application, or providing information not included in the initial submission.
Effective reconsideration strategies:

- Address timing concerns: If denial emphasized recency, provide additional evidence of time passage and stability markers
- Counter severity arguments: Submit documentation demonstrating extraordinary rehabilitation efforts and expert opinions about current risk levels
- Correct factual errors: Identify and rectify any inaccuracies in the original application that may have influenced the decision
- Add new evidence: Include recently completed treatment programs, certifications, or character references unavailable during initial review
Legal representation significantly improves reconsideration success rates. Attorneys experienced in CACI matters understand evaluation criteria and effective evidence presentation strategies.
CACI Grievance Process for Inaccurate Listings
Separate from exemption requests, individuals can challenge their CACI listing's accuracy through the formal grievance process outlined in Penal Code Section 11169. This administrative procedure seeks removal from the index by demonstrating the original substantiation was erroneous, based on false information, or violated procedural requirements during the child welfare investigation.
Grievances must be filed with the county welfare department that submitted the original report to CACI. The county conducts an administrative review, which may include hearings where the individual presents evidence and testimony. If the county denies the grievance, applicants can appeal to the California Department of Social Services for secondary review. Successful grievances result in complete removal from CACI, eliminating the need for exemptions.
Employer Compliance Obligations and Best Practices
California childcare facilities, educational institutions, and youth-serving organizations bear significant compliance responsibilities regarding CACI clearance. Licensing regulations impose specific requirements for verification timing, documentation retention, and ongoing monitoring that create potential liability if mishandled. Recent enforcement actions by Community Care Licensing demonstrate increased scrutiny of background check compliance, with substantial penalties for violations.
Developing Compliant Hiring Procedures
Effective compliance begins with accurate position classification identifying which roles require CACI clearance based on supervisory authority and child interaction levels. Written job descriptions should explicitly address whether positions involve supervisory or disciplinary authority over children, as this determines clearance necessity.
Essential hiring workflow components:

- Early clearance submission: Submit form LIC 508 immediately following conditional offer acceptance to minimize delays
- Clear applicant communication: Explain the three-component background check process, approximate timelines, and employment contingencies
- Live Scan coordination: Establish relationships with multiple fingerprinting locations to facilitate rapid completion
- Tracking system maintenance: Implement tickler systems that prevent individuals from starting work before approvals arrive
- Regular position audits: Review role classifications quarterly to ensure organizational changes don't create compliance gaps
Facilities must establish systematic procedures ensuring no individual begins work in a position requiring CACI clearance before receiving confirmation from the Department of Social Services. Employing individuals before clearance completion constitutes a serious licensing violation regardless of operational necessity or eventual clearance approval.
Documentation Requirements and Retention Policies
California regulations mandate specific documentation retention related to background checks and clearances. Facilities must maintain copies of all LIC 508 submissions, clearance confirmations, exemption approvals, and related correspondence in employees' confidential personnel files. These records must remain accessible for licensing inspections and audits throughout employment and for at least three years post-separation.
Privacy considerations require restricted access to background check documentation. Only designated personnel with legitimate business need should access files containing CACI clearance information. Facilities must implement confidentiality protocols preventing unauthorized disclosure of an individual's CACI status, exemption requests, or related information.
Special Considerations for Educational Institutions

Educational institutions in California navigate complex intersections between state childcare licensing requirements, California Department of Education credentialing standards, and federal background check mandates. Private schools, preschools, and after-school programs face different CACI clearance requirements than traditional K-12 public schools. The employment category and facility licensure status determine specific clearance obligations.
Credential Holders and CACI Requirements
California teaching credential holders employed in public K-12 schools generally do not require CACI clearance. Commission on Teacher Credentialing background checks and ongoing fitness determinations provide equivalent screening. However, credentialed teachers working in licensed preschools, infant centers, or school-age childcare programs operated by school districts must obtain CACI clearance specific to those assignments.
Exemption criteria for credentialed educators:

- Public K-12 teaching positions: Commission on Teacher Credentialing screening satisfies CACI requirements
- Licensed preschool employment: CACI clearance required even with valid teaching credentials
- School-age extended day programs: Separate CACI clearance mandatory for before/after-school assignments
- Summer camp counselor roles: Full CACI clearance necessary regardless of school-year credential exemption
The credential exemption from CACI does not extend to non-credentialed employees or volunteers in school settings. Paraprofessionals, classroom aides, coaches, and volunteers with supervisory authority over children in licensed extended-day programs require full CACI clearance.
Volunteer Background Check Requirements
Volunteers present unique compliance challenges because regulations distinguish between supervised and unsupervised child contact. Volunteers who never have sole supervisory authority—always working under direct supervision of cleared employees—may qualify for abbreviated background checks excluding CACI clearance. However, facilities must document the supervision structure and maintain constant oversight to justify the exemption.
Unsupervised volunteers require full CACI clearance identical to paid employees. The volunteer versus employee distinction does not alter background check requirements; only the supervision level determines clearance necessity. Organizations should establish clear volunteer policies defining supervision requirements, document training about boundaries and oversight, and maintain systems tracking which volunteers have completed required clearances for specific activity types.
Addressing Common CACI Clearance Misconceptions
Persistent misconceptions about CACI clearance requirements create compliance vulnerabilities and unnecessary barriers to employment for qualified individuals. HR professionals frequently operate under incorrect assumptions passed through informal networks rather than authoritative regulatory sources. Understanding these common myths helps organizations implement accurate screening procedures.
Criminal Convictions vs. CACI Listings
Many individuals assume criminal convictions for child abuse automatically generate CACI listings. Others believe CACI contains only civil findings without criminal implications. The reality involves more complexity, as child abuse cases can proceed through criminal justice systems, civil child welfare systems, or both simultaneously.
Key distinctions between systems:
- Criminal convictions: May trigger CACI listings when prosecutors share information with child protective services, but the listing stems from the welfare substantiation rather than the conviction itself
- Civil substantiations: Frequently occur without any criminal charges or convictions, as child protective services operate under preponderance of evidence standards
- Independent proceedings: An individual can have abuse substantiated through welfare proceedings while prosecutors decline criminal charges due to insufficient evidence for conviction
- No criminal record: People with CACI listings may have completely clean criminal backgrounds if no law enforcement involvement occurred
This creates situations where individuals pass comprehensive criminal background checks but fail CACI clearance. Employers cannot assume criminal history screening provides complete child safety protection without the separate CACI component.
Geographic Scope and Out-of-State Records
California's Child Abuse Index contains only reports from California county welfare departments, creating gaps in screening for individuals with child welfare histories in other states. Unlike criminal background checks that access national databases through FBI fingerprinting, CACI clearance does not reveal out-of-state child abuse substantiations.
This limitation requires additional screening measures for applicants with recent out-of-state residency. Facilities should require applicants to disclose previous states of residence and submit to background checks in those jurisdictions when available. California employers cannot rely solely on CACI clearance to identify all child welfare concerns for applicants who lived in other states within the past 5-10 years.
Conclusion
California Child Abuse Index clearance represents a critical but frequently misunderstood component of comprehensive background screening for positions involving child supervision and care. The recent AB 1432 legislative reforms have created meaningful opportunities for individuals with historical substantiations to demonstrate rehabilitation and obtain exemptions, while maintaining essential protections for children in licensed facilities. HR professionals must distinguish between CACI clearance, DOJ criminal checks, and FBI fingerprinting to ensure complete compliance while avoiding unnecessary delays or exclusions. By implementing systematic procedures, maintaining proper documentation, and staying current with regulatory changes, employers can navigate these complex requirements effectively while advancing both child safety and workforce fairness objectives.
Frequently Asked Questions
How long does CACI clearance take in California?
Standard CACI clearance processing typically takes 7-10 business days from submission to receiving results from the California Department of Social Services. Processing times may extend to 14-21 days during peak hiring periods in January and August when application volumes surge. Exemption requests require significantly longer timelines, generally 60-90 days for complete review, with complex cases potentially exceeding 120 days.
Can you work while waiting for CACI clearance?
No, California regulations strictly prohibit individuals from beginning employment in positions requiring CACI clearance before receiving approval from the Department of Social Services. Facilities that allow employees to start work before clearance completion face serious licensing violations, civil penalties up to $5,000 per occurrence, and potential license revocation. Employers must wait for written confirmation of clearance before permitting any work activities involving supervisory or disciplinary authority over children.
What disqualifies you from CACI clearance?
Appearing on the California Child Abuse Index due to a substantiated child abuse or severe neglect report disqualifies individuals from automatic clearance. Substantiated findings include physical abuse causing injury, sexual abuse, severe neglect resulting in harm, or general neglect meeting statutory definitions under Welfare and Institutions Code Section 300. However, disqualification is not permanent—individuals can request exemptions demonstrating rehabilitation, particularly if ten or more years have passed since the incident.
How do I check my CACI status in California?
Individuals cannot directly check their CACI status because the index is confidential and accessible only to authorized agencies for employment screening purposes. To determine if you appear on CACI, you must apply for a position requiring clearance through a licensed facility, which submits form LIC 508 to the Department of Social Services on your behalf. Alternatively, you can contact the county welfare department that may have investigated allegations to request information about substantiated reports.
Does CACI clearance expire?
CACI clearance does not have a formal expiration date and remains valid throughout continuous employment at the facility that requested it. However, if you leave that position and later seek employment at a different licensed facility requiring CACI clearance, the new employer must submit a fresh LIC 508 request to verify your current status. Some licensing categories require periodic re-verification every 5 years even for continuing employees.
What is the difference between Live Scan and CACI clearance?
Live Scan is the electronic fingerprinting process that submits prints to California DOJ and FBI databases for criminal history checks, revealing arrests, convictions, and dispositions from law enforcement systems. CACI clearance screens a completely separate database—the Child Abuse Index—containing substantiated child abuse reports from county welfare investigations that may or may not involve criminal charges. Both are required for most childcare positions in California, along with FBI clearance.
Can I get a CACI exemption with recent charges?
AB 1432 requires a minimum of ten years to have passed either since the incident occurred or since being added to the index before exemption eligibility. Recent charges generally do not qualify for exemption consideration. However, charges may qualify if the underlying incident occurred over ten years ago but formal substantiation and index listing happened more recently. Applicants with charges less than ten years old should focus on the grievance process to challenge listing accuracy.
Who needs CACI clearance in California schools?
In licensed childcare programs operated by schools—including preschools, infant centers, and before/after-school care—employees with supervisory or disciplinary authority over children require CACI clearance. This includes preschool teachers, program directors, childcare aides, and extended-day program staff who work directly with children. Public K-12 credentialed teachers generally do not need CACI clearance for their teaching duties due to Commission on Teacher Credentialing background checks.
Additional Resources
- California Department of Social Services - Child Abuse Central Index Information
https://www.cdss.ca.gov/inforesources/community-care-licensing - Assembly Bill 1432 - Full Legislative Text and Analysis
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB1432 - California Community Care Licensing - Background Check Requirements
https://www.cdss.ca.gov/inforesources/community-care-licensing/policy/provider-information-notices - California Penal Code Section 11170 - Child Abuse Index Provisions
https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=PEN§ionNum=11170 - Form LIC 508 - Request for CACI Clearance
https://www.cdss.ca.gov/inforesources/forms-brochures/forms-listed-by-program