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Registering as a leader vs as a merit badge counselor

Looking for the official guidance on a couple Questions.

First one: at what point does an adult need to be registered? Is it if they are a direct youth contact? Is it if they are on a 72 hour activity? Is that 72 hour threshold cumulative? Can they camp every month as long as they don’t exceed 72 hours each time.

Second: as long as we have the minimum number of registered adults, could every other adult be a merit badge counselor and not have to pay the fee? Could all these merit badge counselor adults camp monthly with the troop?

This is a money thing. The troop has been covering adult registrations. It’s not really fair to ask them to pay to volunteer. But with over 20 adults that is expensive. Fundraising is way down obviously. Why float that many leaders if we can just call them MBCs and be done with it. Again, just looking to be directed to official rules or guidance. Since there is disagreement among the committee members abut how to move forward, we need the policy. If it exists, can you direct me to it?

The Guide to Safe Scouting answers this question:

All adults accompanying a Scouting unit who are present at the activity for 72 total hours or more must be registered as leaders. The 72 hours need not be consecutive.

Merit Badge Counselors are required to take Youth Protection Training and complete the criminal background check but check with your council to see if they feel MBCs fulfill the registration requirement. I have heard some councils will allow an MBC registration for adults present more than 72 hours while others do not.

Also remember that MBCs are Council Positions, not Unit Positions. They are approved by the Council (or District) Advancement Committee, not your COR and Committee Chair. You need to make sure you have enough adults to constitute a Troop Committee to recharter, and technically none of the adults registered as MBCs have any rights of participation in the Troop Committee, since they aren’t registered with the Troop.


are we reading it correctly that this refers to any participation that cumulatively equals 72 total hours?

72 hours applies to the duration of the event. So a Scouts BSA Summer Camp is obviously over 72 hours. But Councils also consider a 5 day Cub Day camp over 72 hours even though the majority of the time is the cubs alone at their own house.

The 72 hours applies to a single event. Troop meetings are multiple events so the clock starts with the start of each meeting. A 2 night campout is less than 72 hours but a 3 night campout could be more or less depending upon start and end times.

The example I use for the non-consecutive rule is an adult stays 2 nights at summer camp, returns home for 1 night then returns for 2 more nights. This adult needs to be registered because the total time at the event was more than 72 hours.

It is official that the clock restarts with each separate activity, or is the 72 hours cumulative? is there any documentation that clarifies this? the line from the GSS is the only thing we have found it is being interpreted both ways by our committee members.
All adults accompanying a Scouting unit who are present at the activity for 72 total hours or more must be registered as leaders. The 72 hours need not be consecutive.

I’m not sure how “at the activity” [emphasis added] is interpreted as anything other than a single activity. I could see how it would be confusing if the phrasing was “at activities”, but it’s clearly singular.

I’m not aware of a written clarification to this anywhere. If you feel you need an official clarification, there’s a national form here:

but I would probably start by reaching out to my District Executive or another council professional for clarification. Odds are, you’re not the first unit to ask.

It applies to each activity separably, that is why it says “the activity”. For example, my Council typically runs an Arrow of Light camp with optional Outpost. Outpost is an extra night on the Scouts BSA side of the camp. This is considered a different activity so, even though the total time at both AOL camp and Outpost is over 72 hours, parents can attend with their Scouts and not be registered.

One interpretation was that “national considers camping to be an activity.” Meaning one activity that happens in 12 parts. Based on that, one activity could be all 365 days of the year. Or as many years as anyone wants. That doesn’t make sense to me, but that was his take on it.
BSA will say register them all because they want the fees. But I need documentation.

If you want something more official than what is in the Guide to Safe Scouting, you will need to contact your council or ask the question via the link Charley provided. The BSA has not published any clarifications.

One other thing that @SteveCagigas alluded to peripherally, your chartering organization may require that they vet all adults who will be working directly with the youth, beyond the BSA registration/YPT/background check requirements. I know of several that do. Your committee might also consider whether or not your charter would want these adults to be registered adult leaders at the unit level (whether ASMs, MCs or other roles) whom they have also vetted, if they are going to be in routine contact with the scouts. Chartering organizations do not review MBC applications, as these are council and/or district positions, depending on how your council manages the program. They would not receive (I suspect) any notice of an MBC applicant who failed the BSA’s background check.


According to my council, I tell my volunteers that in order to be covered under the council insurance during Scouting activities they should be registered as part of the unit. If anything happens to them and they are only registered as a merit badge counselor they are not covered under the insurance.

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That seems odd at first glance, at least to me. As a registered counselor, if they’re doing (for example) first aid merit badge counseling at a troop merit badge day, wouldn’t that be within the normal scope of work for a merit badge counselor? I would expect that BSA insurance would cover all currently registered volunteer adults, when acting in their registered volunteer capacity. It seems strange that it would matter whether thy are counseling at a council summer camp, a district merit badge weekend, or a unit-level merit badge event for BSA insurance purposes.

I could easily see how a unit or chartering organization’s insurance wouldn’t necessarily cover someone who is not registered with the unit, depending on the terms of that insurance.\

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“ The insurance provided to unregistered Scouting volunteers through the general liability insurance program is excess over any other insurance the volunteer might have to his or her benefit, usually a homeowners, personal liability, vehicle, or watercraft policy. ”

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I think we’re splitting hairs here regarding how the adult is registered. The point of the requirement is safety so that an adult is known to BSA, has been vetted, background checked, and Youth Protection Trained. Any adult that completed that process, in your unit, another unit, another council, or MBC is registered.

This doesn’t negate the expressed concerns about unit registered leaders or vetting by the chartered org which are both valid.

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The other part of it, that hasn’t really been discussed, is this is dumping the cost of the background check on your Council, instead of asking the unit or the individual to pay for it.

2 items:
GSS “All adults accompanying a Scouting unit who are present at the activity for 72 total
hours or more must be registered as leaders.” - This was explained to me as “Leaders” is defined as “Unit Leaders” or unit registered. I did point out to the DE saying it that he has Council registered and therefore should not be at the Day Camp if that is the definition.

Does anyone 100% know that Councils pay for MBC registration? or does National?

There is no national fee for a MBC. However there are overhead costs paid for by the council.

  • My council does have a overhead cost of a background investigation (now every four years).
    • Member registration: A signed new “ADDITIONAL DISCLOSURES & BACKGROUND CHECK AUTHORIZATION” form (2019) is required for individual age 18-plus years old BSA membership.
  • There is also an annual volunteer overhead of vetting and renewing my merit badge counselor information.
    (Does your unit have volunteers willing to serve on the council or district advancement committee to do the annual MBC review and approval? If so, contact your council advancement committee chair.)


written for council registrar, ©2019 Boy Scouts of America


Adult Application Approval

Unit Adults. The chartered organization representative is approved by the head of the chartered organization. All other adult leader applications must be accepted and approved by the head of the chartered organization or the chartered organization representative. The Scout executive or designee must approve all adults who answer “yes” to any Additional Information question on the adult application.

Council and District Adults. The Scout executive or designee must approve all council and district adults.


No-Fee-Required Registrations

Merit badge counselors, STEM Nova counselors, and religious emblem coordinators are registered adult leader positions that require a completed BSA adult application, Youth Protection training, and a criminal background check, but no registration fee is required unless they choose to pay to receive Scouting magazine.

Executive officer and Lion and Tiger adult partner positions do not require a registration fee because they are not registered adult leader positions. These positions also do not require a completed BSA adult application and are not submitted for a criminal background check. While Youth Protection training is not required for adults holding these positions, it is recommended for all participating adults.

PAGES 24-25:

Merit Badge Counselors

In order to register, merit badge counselors (position 42) must be at least 18 years old and must complete an adult application including a criminal background authorization form, complete the Merit Badge Counselor Information form (No. 34405, see Appendix) specifying which merit badges they are qualified to teach, and take Youth Protection training. See the Guide to Advancement for qualifications of counselors.
Merit badge counselors who wish to receive Scouting magazine must pay a registration fee and be registered as position 42F—Merit badge counselor—with fee.

Adult applications are required of all new counselors whether they are currently registered in another position or not. Merit badge counselors are registered and approved on the district level and all applications must be approved by the district merit badge counselor coordinator before the application is entered into the BSA membership system.

Reregistering merit badge counselors must complete a new Merit Badge Counselor Information form annually for approval, but a new application is not required.

The Cub Scouting. Scouts BSA and other BSA programs are organized differently.

My interpretation is that it means that a DE cannot be counted as a unit leader for purposes of enforcing barriers to abuse.

In my district the day camp is organized at the council level but is a district event. The DE is the chair of the district k-3 leader committee and advisor for the district committee which includes the district program committee.

If the DE is also assigned as the advisor to the council day camp program, the DE may be required as part of his or her job to be at each day camp.

Each council/district may be organized differently. This is a local council issue.