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TO:
CNCS Grantees Contracting Channelers for Departmental Order FBI Checks
RE:
Use of FBI Channelers for Departmental Order FBI Checks; Temporary Exemption
CNCS
was notified that FBI Channelers were directed by the FBI to cease processing
Departmental Order (DO) FBI checks for CNCS grant recipients. The abrupt nature
of this change has created a great burden and unanticipated cost for many
grantees, particularly coming at the peak of enrollment. We are following
up on the matter and will provide updates on our website.
Application. This temporary
exemption applies to all grantees and subgrantees (“grantees”) using
FBI Channelers for Departmental Orders (DO), as described below.
FBI
Check Exemption.
Effective March 25, 2015, any grantee using an FBI Channeler to obtain Departmental Order (DO) FBI
checks for individuals in covered positions is temporarily exempt
from the requirement to obtain the FBI check for individuals who begin work or
service on or after that date.
State
Check Exemption.
If your organization was conducting state checks prior to March 25, 2015, you
must continue to do so. In all other cases, grantees are temporarily
exempt from the state check requirement based on the burden,
unanticipated cost, and timing associated with implementing such checks on such
short notice. If your program is able to conduct any state checks we
strongly recommend you do so.
Documentation requirement.
You are required to have each individual in a covered position who
begins work or service on or after March 25, 2015, self-certify that they have
not been convicted of murder and maintain the documentation in the files of any
covered individuals. This self-certification is the only documentation
required by CNCS for grantees relying on these exemptions. Model self-certification
language is available on our website.
NSOPW
Check.
Grantees must still conduct the NSOPW check before an
individual in a covered position begins work/service.
Accompaniment. If your
organization was conducting accompaniment as part of its program design, you
must continue to do so until state checks have cleared. In all other
cases, grantees are exempt from accompaniment requirements based on the burden,
unanticipated cost, and late notice.
Further
safeguards.
CNCS strongly recommends recipients to screen individuals in
covered positions in a prudent manner consistent with an individual serving or
working in a position of great trust. Likewise, grantees should
immediately assess the feasibility of conducting state checks through CNCS-designated
state repositories or alternatives.
These
exemptions expire on December 31, 2015, unless specifically revoked or extended
in writing by CNCS. Please contact your CNCS program officer with any
questions.
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