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SENATE DOCKET, NO. 635 FILED ON: 1/14/2025
SENATE . . . . . . . . . . . . . . No. 198
The Commonwealth of Massachusetts
_________________
PRESENTED BY:
Cynthia Stone Creem
_________________
To the Honorable Senate and House of Representatives of the Commonwealth of Massachusetts in General
Court assembled:
The undersigned legislators and/or citizens respectfully petition for the adoption of the accompanying bill:
An Act relative to increasing opportunities for employment in professional licensure.
_______________
PETITION OF:
NAME:DISTRICT/ADDRESS :Cynthia Stone CreemNorfolk and Middlesex 1 of 18
SENATE DOCKET, NO. 635 FILED ON: 1/14/2025
SENATE . . . . . . . . . . . . . . No. 198
By Ms. Creem, a petition (accompanied by bill, Senate, No. 198) of Cynthia Stone Creem for
legislation to further regulate professional and occupational licensing. Consumer Protection and
Professional Licensure.
[SIMILAR MATTER FILED IN PREVIOUS SESSION
SEE SENATE, NO. 2451 OF 2023-2024.]
The Commonwealth of Massachusetts
_______________
In the One Hundred and Ninety-Fourth General Court
(2025-2026)
_______________
An Act relative to increasing opportunities for employment in professional licensure.
Be it enacted by the Senate and House of Representatives in General Court assembled, and by the authority
of the same, as follows:
1 SECTION 1. Section 172 of chapter 6 of the General Laws, as appearing in the 2022
2Official Edition, is hereby amended by inserting, after the word “entity”, in line 27, the following
3words:- , subject to section 172N.
4 SECTION 2. Said chapter 6 is hereby amended by striking out section 172N, as so
5appearing, and inserting in place thereof the following 2 sections:-
6 Section 172N. (a) For the purposes of this section, “licensing authority” shall include any
7agency, examining board, credentialing board or other office or commission, including boards
8supervised by the commissioner of professional licensure, with the authority to impose
9occupational fees or licensing requirements on a profession. 2 of 18
10 (b) Notwithstanding any other provision of law, a licensing authority shall not
11automatically bar an individual from a professional or occupational license because of a criminal
12record. A licensing authority shall provide individualized consideration of an individual’s
13circumstances as described in subsections (d) and (e) to deny, diminish, suspend, revoke,
14withhold or otherwise limit a professional or occupational license.
15 (c) Notwithstanding any general or special law to the contrary, a licensing authority shall
16not consider, nor require an individual to disclose:
17 (1) a deferred adjudication, including but not limited to a continuance without a finding,
18participation in a diversion program or an arrest not followed by a conviction;
19 (2) a conviction for which no sentence of incarceration may be imposed;
20 (3) a conviction that has been sealed, annulled, dismissed, vacated, set aside, expunged or
21pardoned;
22 (4) a juvenile adjudication;
23 (5) a non-violent misdemeanor;
24 (6) a conviction that occurred more than 3 years prior to the date of the licensing
25authority’s consideration or where the individual’s incarceration ended more than 3 years before
26the date of the licensing authority’s consideration, except for a conviction of:
27 (i) a crime punishable by imprisonment for a term exceeding 2 and a half years, or any
28act of juvenile delinquency involving the use or possession of a deadly weapon that would be
29punishable by imprisonment for such term if committed by an adult, that (A) has as an element
30involving the use, attempted use or threatened use of physical force or a deadly weapon against 3 of 18
31the person of another; (B) is burglary, extortion, arson or kidnapping; (C) involves the use of
32explosives; or (D) resulted in death, bodily injury, or serious bodily injury with malice
33aforethought;
34 (ii) a felony related to a sex offense, a sex offense involving a child or a sexually violent
35offense as defined in section 178C; or
36 (iii) a felony related to criminal fraud pursuant to section 1 of chapter 267 or
37embezzlement pursuant to chapter 266.
38 (d)(1) A licensing authority may deny, diminish, suspend, revoke, withhold or otherwise
39limit a professional or occupational license only if the licensing authority determines, by clear
40and convincing evidence, that:
41 (i) First, an individual’s non-excluded criminal record directly relates to the duties and
42responsibilities of the profession or occupation.
43 (ii) Second, if an individual’s non-excluded criminal record is directly related to the
44duties and responsibilities of the profession or occupation, the licensing authority must then
45determine if the interest of the licensing authority in protecting the public, an individual or
46property from harm outweighs the individual’s right to hold the professional or occupational
47license.
48 (iii) Third, if the licensing authority determines that the interest in protecting the public,
49an individual or property from harm outweighs the individual’s right to hold the professional or
50occupational license, then the licensing authority shall determine if the applicant has failed to be
51rehabilitated. 4 of 18
52 (2) The licensing authority shall bear the burden of proof to establish evidence of clauses
53(i) to (iii), inclusive.
54 (e) If the applicant’s criminal record is directly related to the performance, duties,
55responsibilities, practices or functions of the profession, the licensing authority shall consider the
56following factors, in a light most favorable to the applicant, to demonstrate evidence of
57rehabilitation:
58 (1) the age of the individual at the time of the offense;
59 (2) the length of time since the offense;
60 (3) the completion of a criminal sentence, not including financial obligations;
61 (4) a certificate of rehabilitation, restoration of rights or good conduct;
62 (5) completion of, or active participation in, rehabilitative drug or alcohol treatment or
63similar programs;
64 (6) testimonials and recommendations, including, but not limited to, progress reports
65from the individual’s probation or parole officer;
66 (7) other evidence of rehabilitation;
67 (8) education and training;
68 (9) employment history;
69 (10) the individual’s responsibilities, including civic and community engagement or
70family contributions; 5 of 18
71 (11) whether the individual will be bonded in the occupation; and
72 (12) other information that the individual submitted to the licensing authority including
73mitigating circumstances.
74 (f) The licensing authority shall make its decision using the criteria and process described
75in subsections (b) to (e), inclusive. The licensing authority shall issue and send a decision to the
76applicant on the petition not later than 60 days after the licensing authority receives the petition
77or, if a hearing is held, not later than 90 days after the licensing authority receives the petition.
78The decision shall be made in writing and include a copy of any criminal record report that the
79licensing authority reviewed. If the licensing authority determines that an occupational or
80professional license should not be granted because of the criminal conviction of an applicant, the
81decision shall set forth the reasons for the determination which shall address each of the factors
82in subsection (e) that the licensing authority deemed relevant to the determination.
83 (g)(1) An individual with a criminal record may petition a licensing authority at any time,
84including before obtaining any required personal qualifications or applying for a license, for a
85decision as to whether the individual’s criminal record is directly related to the profession and
86that criminal record would disqualify the individual from obtaining a professional or
87occupational license. The licensing authority may charge a fee to the petitioner to recoup costs
88related to the petition, not to exceed $100 for each petition. If the petitioner’s income is at or
89below 250 per cent of the federal poverty level used to determine indigency by the trial court of
90the commonwealth, the fee shall be waived.
91 (2) The petitioner shall include in the petition an authorization for the licensing authority
92to obtain the petitioner’s criminal record. 6 of 18
93 (3) The licensing authority will make its decision using the criteria and process in
94subsections (b) to (e), inclusive.
95 (4) The licensing authority shall issue and send a decision on the petition to the petitioner
96not later than 60 days after the licensing authority receives the petition or, if a hearing is held, not
97later than 90 days after the licensing authority receives the petition. The decision shall be made
98in writing, include a copy of any criminal record report that the licensing authority reviewed and,
99if the licensing authority determines that an occupational license should not be granted because
100of the petitioner’s criminal record, a description that details with specificity how the petitioner’s
101criminal record is directly and specifically related to the performance, duties, responsibilities,
102practices or functions of the profession.
103 (5) A decision that the licensing authority should grant the application under certain
104conditions is binding on the licensing authority in any later ruling on the petitioner’s professional
105or occupational license unless there is a change in the petitioner’s criminal record that is directly
106related to the duties or responsibilities of the licensed occupation.
107 (6) If the licensing authority decides that the professional or occupational license should
108not be granted, the licensing authority may provide an alternative advisory opinion, in which the
109licensing authority may advise the petitioner of actions the petitioner may take to remedy the
110disqualification.
111 (7) If advised by the licensing authority of remedial actions, the petitioner may submit a
112revised petition reflecting completion of the remedial actions before a deadline set by the
113licensing authority in the alternative advisory decision. 7 of 18
114 (8) The petitioner may appeal the licensing authority’s decision as provided in section
115176.
116 (9) The petitioner may submit a new petition to the licensing authority not sooner than 1
117year following a final judgment on the initial petition or upon obtaining the required personal
118qualifications.
119 (h)(1) An ambiguity in a professional or occupational regulation relating to a licensing
120authority’s use of an individual’s criminal record shall be resolved in the favor of the individual.
121 (2) Notwithstanding any general or special law to the contrary, a licensing authority shall
122not use vague terms in its consideration and decision making, including:
123 (i) good moral character;
124 (ii) moral turpitude; or
125 (iii) character and fitness.
126 (i) Nothing in this section shall be construed to change a licensing authority’s ability to
127enforce other conditions of professional and occupational licenses, including the personal
128qualifications required to obtain recognition or compliance with other regulations.
129 (j)(1) Each licensing authority shall annually report to the division of professional
130licensure, or the department under which the licensing authority sits:
131 (i) the number of times that each licensing authority acted to deny, diminish, suspend,
132revoke, withhold or otherwise limit state recognition for a license because of an individual’s
133criminal record; 8 of 18
134 (ii) the criminal convictions that were the subject of each licensing authority action
135described in clause (i);
136 (iii) the number of applicants petitioning each licensing authority pursuant to subsection
137(e);
138 (iv) the criminal convictions that were the subject of each approval or denial of a petition
139pursuant to subsection (e); and
140 (v) other relevant data as determined by the division of professional licensure or the
141department under which the licensing authority sits.
142 (2) The division of professional licensure or department governing the licensing body
143shall annually compile and publish a report on a searchable public website summarizing data
144reported in paragraph (1).
145 Section 172N ½. There shall be a commission on background record requirements for
146professional licensure consisting of 11 members: the commissioner of professional licensure or a
147designee, who shall serve as chair, the house and senate chairs of the joint committee on
148consumer protection and professional licensure, the executive director of the Massachusetts
149office of victim assistance or a designee, and 7 members to be appointed by the governor, 1 of
150whom shall be a representative of the Massachusetts AFL-CIO Council, Inc., 1 of whom shall be
151a representative of the Massachusetts Building Trades Council, 1 of whom shall be a
152representative of the NAACP Boston Branch, 1 of whom shall be a representative of a registered
153Massachusetts affiliate of the National Urban League, Inc., 1 of whom shall be a representative
154of the YMCA’s of Massachusetts, Inc., and 1 of whom shall be a representative of the Greater
155Boston Legal Services, Inc. 9 of 18
156 The commission shall advise the division of professional licensure and licensing
157authorities, as defined in section 172N, to provide recommendations for background record
158requirements for each professional and occupational license granted within the commonwealth.
159Background record requirements developed by the commission shall not be designed to eliminate
160certain licenses, nor to develop or recommend that the division of professional licensure create
161new licenses or additional requirements for licenses.
162 SECTION 4. Section 2 of chapter 112 of the General Laws, as appearing in the 2022
163Official Edition, is hereby amended by striking out, in line 5, the words “of good moral
164character” and inserting in place thereof the following words:- lacks a criminal record or history
165of disqualifying convictions that is directly related to the practice and duties of a physician
166pursuant to section 172N.
167 SECTION 5. Section 18 of said chapter 112, as so appearing, is hereby amended by
168striking out, in lines 1 and 2, the words “shall refuse to issue a certificate to a person, or”.
169 SECTION 6. Said section 18 of said chapter 112, as so appearing, is hereby further
170amended by adding the following paragraph:- The board shall refuse to issue a certificate to a
171person who is intemperate in the use of alcoholic liquors or narcotic drugs or has a conviction by
172a court of competent jurisdiction of a crime which the board determines, pursuant to section
173172N, to be of such a nature as to render such person unfit to practice as a podiatry.
174 SECTION 7. Section 23B of said chapter 112, as so appearing, is hereby amended by
175striking out, in line 11, the words “is of good moral character” and inserting in place thereof the
176following words:- lacks a criminal record or history of disqualifying convictions directly related
177to the duties or practices of the occupation pursuant to section 172N. 10 of 18
178 SECTION 8. Section 23S of said chapter 112, as so appearing, is hereby amended by
179striking out, in lines 11 and 12, the words “is of good moral character” and inserting in place
180thereof the following words:- lacks a criminal record or history of disqualifying convictions
181directly related to the duties or practices the occupation pursuant to section 172N.
182 SECTION 9. Section 45 of said chapter 112, as so appearing, is hereby amended by
183striking out, in line 5, the words “of good moral character” and inserting in place thereof the
184following words:- lacking a criminal record or history of disqualifying convictions directly
185related to the duties or practices of dentistry pursuant to section 172N.
186 SECTION 10. Section 45A of said chapter 112, as so appearing, is hereby amended by
187striking out, in line 2, the words “of good moral character” and inserting in place thereof the
188following words:- lacking a criminal record or history of disqualifying convictions directly
189related to the duties or practices of a dentist with a limited registration to section 172N.
190 SECTION 11. Section 45B of said chapter 112, as so appearing, is hereby amended by
191striking out, in line 2, the words “of good moral character” and inserting in place thereof the
192following words:- lacking a criminal record or history of disqualifying convictions directly
193related to the duties or practices of a temporarily registered dentist pursuant to section 172N.
194 SECTION 12. Section 51 of said chapter 112, as so appearing, is hereby amended by
195striking out, in line 1, the words “of good moral character” and inserting in place thereof the
196following words:- lacking a criminal record or history of disqualifying convictions directly
197related to the duties or practices of a dental hygienist pursuant to section 172N.
198 SECTION 13. Section 51½ of said chapter 112, as so appearing, is hereby amended by
199striking out, in line 3, the words “of good moral character” and inserting in place thereof the 11 of 18
200following words:- lacking a criminal record or history of disqualifying convictions directly
201related to the duties or practices of a dental assistant pursuant to section 172N.
202 SECTION 14. Section 55 of said chapter 112, as so appearing, is hereby amended by
203striking out, in lines 4 and 5, the words “of good moral character, and a” and inserting in place
204thereof the following words:- lacks a criminal record or history of disqualifying convictions
205directly related to the duties or practices of a veterinarian pursuant to section 172N and is a.
206 SECTION 15. Section 60B of said chapter 112, as so appearing, is hereby amended by
207striking out, in line 2, the words “of good moral character” and inserting in place thereof the
208following words:- who lacks a criminal record or history of disqualifying convictions directly
209related to the duties or practices of an architect pursuant to section 172N.
210 SECTION 16. Section 68 of said chapter 112, as so appearing, is hereby amended by
211striking out, in line 13 the words “of good moral character” and inserting in place thereof the
212following words:- lacks a criminal record or history of disqualifying convictions directly related
213to the duties or practices of an optometrist pursuant to section 172N.
214 SECTION 17. Section 73H of said chapter 112, as so appearing, is hereby amended by
215striking out, in line 8, the words “involving moral turpitude” and inserting in place thereof the
216following words:- related to the duties or practices of a dispensing optician pursuant to section
217172N.
218 SECTION 18. Section 74 of said chapter 112, as so appearing, hereby amended by
219striking out, in line 7 the words “he is of good moral character” and inserting in place thereof the
220following words:- the applicant lacks a criminal record or history of disqualifying convictions
221directly related to the duties or practices of a nurse pursuant to section 172N. 12 of 18
222 SECTION 19. Section 74A of said chapter 112, as so appearing, is hereby amended by
223striking out, in lines 5 and 6, the words “he is of good moral character and that he” and inserting
224in place thereof the following words:- the applicant lacks a criminal record or history of
225disqualifying convictions directly related to the duties or practices of a practical nurse pursuant
226to section 172N and.
227 SECTION 20. Section 76B of said chapter 112, as so appearing, is hereby amended by
228striking out, in lines 7, 20, 32, 47 and 61, the words “good moral character” and inserting in
229place thereof, in each instance, the following words:- lacking a criminal record or history of
230disqualifying convictions directly related to the duties or practices of a nurse pursuant to section
231172N.
232 SECTION 21. Section 84 of said chapter 112, as so appearing, is hereby amended by
233striking out, in line 35, the words “involving moral turpitude” and inserting in place thereof the
234following words:- that is related to the core functions of a funeral director pursuant to section
235172N
236 SECTION 22. Section 87A½ of said chapter 112, as so appearing, is hereby amended by
237striking out, in lines 43 and 44, the words “history of dishonest or felonious acts” and inserting in
238place thereof the following words:- criminal record or history of disqualifying convictions
239directly related to the duties or practices of a public accountant pursuant to section 172N.
240 SECTION 23. Section 87TT of said chapter 112, as so appearing, is hereby amended by
241striking out, in line 8, the words “good moral character” and inserting in place thereof, the
242following words:- a lack of criminal record or history of disqualifying convictions directly
243related to the duties or practices of real estate brokers and salesmen pursuant to section 172N. 13 of 18
244 SECTION 24. Said section 87TT of said chapter 112, as so appearing, is hereby further
245amended by striking out, in line 10, the words “good moral character” and inserting in place
246thereof the following words:- lack of a criminal record or history of disqualifying convictions
247pursuant to section 172N.
248 SECTION 25. The first paragraph of said section 87TT of said chapter 112, as so
249appearing, is hereby amended by striking out the last sentence.
250 SECTION 26. Section 87XX of said chapter 112, as so appearing, is hereby amended by
251inserting after the word “character”, in lines 20 and 22, in each instance, the following words:-
252pursuant to section 172N.
253 SECTION 27. Section 93 of said chapter 112, as so appearing, is hereby amended by
254striking out, in line 2, the words “involving moral turpitude” and inserting in place thereof the
255following words:- pursuant to section 172N.
256 SECTION 28. Section 101 of said chapter 112, as so appearing, is hereby amended by
257striking out, in lines 4 and 5, the words “of good moral character” and inserting in place thereof
258the following words:-lacks a criminal record or history of disqualifying convictions directly
259related to the duties or practices of a landscape architect pursuant to section 172N.
260 SECTION 29. Section 119 of said chapter 112, as so appearing, is hereby amended by
261striking out clause (a) and inserting in place thereof the following clause:- (a) lacks a criminal
262record or history of disqualifying convictions directly related to the duties or practices of a
263psychologist pursuant to section 172N. 14 of 18
264 SECTION 30. Section 136 of said chapter 112, as so appearing, is hereby amended by
265striking out, in line 12, the words “involving moral turpitude” and inserting in place thereof the
266following words:- directly related to the duties or practices of a social worker pursuant to section
267172N.
268 SECTION 31. Section 144 of said chapter 112, as so appearing, is hereby amended by
269striking out clause (1) and inserting in place thereof the following clause:- (1) lacks a criminal
270record or history of disqualifying convictions directly related to the duties or practices of a
271speech-language pathologist or audiologist pursuant to section 172N.
272 SECTION 32. Section 144A of said chapter 112, as so appearing, is hereby amended by
273striking out clause (1) and inserting in place thereof the following clause:- (1) lack a criminal
274record or history of disqualifying convictions directly related to the duties or practices of an
275assistant to a speech-language pathologist or audiologist pursuant to section 172N.
276 SECTION 33. Section 152 of said chapter 112, as so appearing, is hereby amended by
277striking out clause (b) and inserting in place thereof the following clause:- (b) lack a criminal
278record or history of disqualifying convictions directly related to the duties or practices of an
279acupuncturist pursuant to section 172N.
280 SECTION 34. Section 169 of said chapter 112, as so appearing, is hereby amended by
281striking out, in line 2, the word “deny”.
282 SECTION 35. Said section 169 of said chapter 112, as so appearing, is hereby further
283amended by inserting after the second paragraph the following paragraph:- The board, pursuant
284to section 172N, may deny a license due to a finding of a conviction by a court of competent
285jurisdiction of a crime related to conduct which places into question the applicant’s competence 15 of 18
286to provide mental health and human services, including gross misconduct in the practice of
287mental health and human services on a particular occasion or negligence on repeated occasions.
288 SECTION 36. Subsection (f) of section 197 of said chapter 112, as so appearing, is
289hereby amended by striking out clause (3) and inserting in place thereof the following clause:-
290(3) lack a criminal record or history of disqualifying convictions directly related to the duties or
291practices of hearing instrument specialists pursuant to section 172N;.
292 SECTION 37. Section 203 of said chapter 112, as so appearing, is hereby amended by
293striking out, in lines 10 and 11, the words “of good moral character” and inserting in place
294thereof the following words:- lacks a criminal record or history of disqualifying convictions
295directly related to the duties or practices of a dietitian/nutritionist pursuant to section 172N.
296 SECTION 38. The first paragraph of section 205 of said chapter 112, as so appearing, is
297hereby amended by striking out clause (d) and inserting in place thereof the following clause:-
298(d) a criminal record or history of disqualifying convictions directly related to the duties or
299practices of dietitians and nutritionists pursuant to section 172N; or.
300 SECTION 39. Section 213 of said chapter 112, as so appearing, is hereby amended by
301striking out, in lines 7 and 8, the words “of good moral character” and inserting in place thereof
302the following words:- lacks a criminal record or history of disqualifying convictions directly
303related to the duties or practices of a perfusionist pursuant to section 172N.
304 SECTION 40. Subsection (d) of section 222 of said chapter 112, as so appearing, is
305hereby amended by striking out clause (i) and inserting in place thereof the following clause:- (i)
306lack a criminal record or history of disqualifying convictions directly related to the duties or
307practices of a home inspector pursuant to section 172N;. 16 of 18
308 SECTION 41. Subsection (a) of section 229 of said chapter 112, as so appearing, is
309hereby amended by striking out clause (4) and inserting in place thereof the following clause:-
310(4) he shall lack a criminal record or history of disqualifying convictions directly related to the
311duties or practices of a massage therapist pursuant to section 172N;.
312 SECTION 42. Said section 229 of said chapter 112, as so appearing, is hereby amended
313by striking out, in line 19, the words “or a crime involving moral turpitude”.
314 SECTION 43. Section 231 of said chapter 112, as so appearing, is hereby amended by
315striking out clause (3) and inserting in place thereof the following clause:- (3) lacks a history of a
316criminal record or history of disqualifying convictions directly related to the duties or practices
317of a massage therapist pursuant to section 172N;.
318 SECTION 44. Section 253 of said chapter 112, as so appearing, is hereby amended by
319striking out, in line 7, the words “of good moral character” and inserting in place thereof the
320following words:- lacks a history of a criminal record or history of disqualifying convictions
321directly related to the duties or practices of a genetic counselor pursuant to section 172N.
322 SECTION 45. Section 260 of said chapter 112, as so appearing, is hereby amended by
323striking out, in line 8, the words “is of good moral character” and inserting in place thereof the
324following words:- lacks a history of a criminal record or history of disqualifying convictions
325directly related to the duties or practices of a community health worker pursuant to section 172N.
326 SECTION 46. Section 269 of said chapter 112, as so appearing, is hereby amended by
327striking out, in lines 7 and 8, the words “and of good moral character” and inserting in place
328thereof the following words:- , lacks a history of a criminal record or history of disqualifying 17 of 18
329convictions directly related to the duties or practices of a naturopathic doctor pursuant to section
330172N.
331 SECTION 47. Subsection 9 of section 4 of chapter 151B of the General Laws, as so
332appearing, is hereby amended by inserting the following paragraphs after the last sentence:-
333 (a) An employer shall not deny employment to an individual because the person was
334convicted of one or more criminal offenses, or by reason of a finding of lack of good moral
335character or suitability, when such finding is based upon the fact that the applicant was convicted
336of one or more criminal offenses, unless:
337 (i) the nature of criminal conduct for which the person was convicted has a direct bearing
338on and affects such person’s fitness or ability to perform one or more of primary duties or
339responsibilities necessarily related to the employment sought; or
340 (ii) hiring or continued employment of the person would involve an unreasonable risk to
341property or to the safety or welfare of a specific individual or the general public.
342 (b) In making this determination, the employer shall undertake an individualized
343assessment of the applicant and shall consider the following factors:
344 (i) the type of work to be performed and the nature of the primary duties or
345responsibilities necessarily related to the employment sought;
346 (ii) whether the offense or offenses were recently committed, and whether the amount of
347time that has elapsed since the occurrence of the offense or offenses significantly diminishes the
348relevance of the offense or offenses; 18 of 18
349 (iii) the age of the person at the time of the occurrence of the criminal offense or offenses,
350including whether youth or lack of maturity related to the person’s age at the time of the offense
351is a mitigating circumstance;
352 (iv) the seriousness of the offense or offenses;
353 (v) any evidence that the person performed the same type of work after the offense or
354offenses with no known incidents of criminal conduct;
355 (vi) any evidence regarding the person’s rehabilitation, including but not limited to civic
356and community contributions, efforts at self-improvement, sobriety, education or training, and
357good conduct; and
358 (c) An employer shall, at the time of denial of employment, provide the applicant or
359employee with a written statement that sets forth specific reasons for the denial.