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Educational information only — not legal advice. Background check rules vary by employer and state, and change over time. If you have a criminal record and are considering phlebotomy, contact the specific employer or state licensing board directly, or consult a licensed attorney, before assuming you are disqualified.

Phlebotomy Background Check: What Gets Checked and By Whom

Unlike CNA certification, there is no single federal law requiring a specific background check process for phlebotomists. What actually happens is layered: your employer runs its own check, and in 4 states, a state licensing board runs a separate one too.

There is no OBRA-style federal mandate for phlebotomy

CNA certification has a federal law (OBRA 1987) that directly ties background checks to a state abuse registry. Phlebotomy has no equivalent. Background checks for phlebotomists come from two different sources instead: standard employer hiring requirements (healthcare settings almost universally require one), and — only in California, Louisiana, Nevada, and Washington — a state licensing board review as part of issuing that state's separate phlebotomy credential.

What employers check (46 states and D.C. without a state license)

In every state except the 4 licensure states, there is no phlebotomy-specific background check law — the check you'll go through is your employer's own standard hiring requirement for a healthcare role:

Criminal background check

Standard county/state and often FBI-level checks, same as most hospital and lab employees. Specific disqualifying offenses vary by employer, not by a phlebotomy-specific law.

Health screening

TB test, proof of immunizations (hepatitis B, MMR, varicella), and sometimes a drug screen — standard for any role with direct patient contact and bloodborne-pathogen exposure risk.

Reference and employment history

Common for hospital systems and reference labs (Quest Diagnostics, Labcorp) — verification of prior healthcare employment and training-program completion.

No universal disqualifying-offense list

Unlike CNA registries, there is no published nationwide list of offenses that automatically bar you from phlebotomy work. Each employer sets its own hiring standards.

What the 4 licensure states check

California, Louisiana, Nevada, and Washington require their own state credential on top of national certification, and each state's licensing board runs its own review as part of issuing it.

California — the best-documented of the 4

CDPH requires DOJ and FBI fingerprint-based background checks via Live Scan as part of the CPT I/LPT application. When a conviction appears, CDPH conducts an individualized assessment rather than applying an automatic bar list — meaning the review considers the nature of the offense, how long ago it occurred, and your record since, rather than a fixed yes/no table. Dismissed cases and minor traffic offenses are generally not reported in the first place.

We could not find an equally detailed, published review process for Louisiana, Nevada, or Washington. If you're applying for one of those 3 states' credentials and have a record, contact that state's licensing board directly rather than assuming the same individualized-assessment approach applies.

What NHA itself requires

NHA does not publish a detailed criminal-history disclosure policy for the CPT exam the way some state licensing boards do. What is confirmed from NHA's own public documentation: NHA can invalidate your exam results, suspend or revoke your certification, and bar you from retesting or sitting for any other NHA exam if you provided false or incomplete information on your application, or for conduct like cheating. Beyond that, there's no published list of disqualifying criminal offenses specific to the CPT certification itself — the real gatekeepers are your employer and, in 4 states, the state licensing board described above.

Frequently asked questions

Can you be a phlebotomist with a felony or criminal record?
It depends on the employer, and in 4 states, the state licensing board. There's no single national disqualifying-offense list. Violent offenses, offenses against patients or vulnerable people, and healthcare fraud are the most consistently disqualifying across employers.
Does NHA run a criminal background check before certifying you?
NHA doesn't publish a detailed criminal-history policy. It can revoke certification or bar retesting for false/incomplete applications or cheating — beyond that, there's no published specific screening process. Contact NHA directly if you need certainty.
Do the 4 licensure states have their own disqualifying-offense list?
Not a published specific list that we could confirm. California uses DOJ/FBI Live Scan fingerprinting and an individualized case-by-case assessment rather than an automatic bar table. We couldn't find equally detailed public information for Louisiana, Nevada, or Washington — contact those boards directly if this applies to you.
What do phlebotomy employers typically require?
A standard criminal background check and a health screening (TB test, immunization proof, sometimes a drug screen) as a condition of employment — an employer hiring standard, not a specific phlebotomy law, in 46 states and D.C. without a state license.

Related guides

How to Become a Phlebotomist — All 50 States

State-specific licensure and certification information

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Phlebotomy Certification Reciprocity

What changes (and what doesn't) when you move states

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