DHS Clarifies NETStudy 2.0 Requirements

Risk Level: Moderate Category: Provider Enrollment / Background Studies

DHS issued a revised provider notice clarifying background study requirements for EIDBI agencies and individual providers through NETStudy 2.0. The update emphasizes the need for location-specific background study tracking and reiterates several compliance obligations.

Requirements for Agencies

  1. Each EIDBI provider location must maintain its own unique NETStudy 2.0 Agency ID.

  2. Organizations operating multiple service locations will need to ensure that each location has its own Agency ID.

  3. Agencies that do not currently have a location-specific Agency ID must request one by submitting Form DHS-3891A.

  4. Once the request for an Agency ID is processed, agencies will then need to initiate background studies for owners and other required individuals.

Requirements for Individual Providers

  1. Before providing services, each individual EIDBI provider must have a completed background study with an “eligible” or “set-aside” result for that specific location.

  2. Providers working for multiple agencies must have a background study initiated by each agency.

  3. Providers working at multiple locations within the same agency must have separate affiliation records for each site. Affiliation records cannot be backdated.

Compliance Officer Insight

A short internal review of NETStudy 2.0 records in the near future is recommended. Even for agencies operating a single location, it is important to confirm that all staff and required individuals have completed background studies through NETStudy 2.0 and that the results show “eligible” or “set-aside.”

Particular focus should be given to Qualified Supervising Professionals (QSPs) who may provide supervision or services across multiple agencies or locations. In these cases, the agency should verify that a background study application has been properly initiated by the agency and that the provider’s affiliation record reflects their role with the organization.

Conducting this review proactively allows the agency to confirm that its NETStudy records align with DHS enrollment records and reduces the risk of provider enrollment interruptions or compliance findings during DHS screening or program integrity reviews.

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