2023-001 Segregation of Duties
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2022
Compliance Requirement: 2 CFR 200.303 Internal Controls
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None.
Condition: During our audit, we obtained an understanding and tested LDSC’s internal
control for purposes of planning and performing our audit procedures. In obtaining our
understanding and testing LDSC’s internal controls, we determined there were inadequate
segregation of duties involving certain aspects of the financial reporting cycle.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the
same individual, as follows:
Initiate and approve vendor invoices for payment,
Write checks or initiating electronic disbursements,
Review and approve payroll, including the approver’s payroll
Initiate and approve reimbursements to themselves as the agency head,
Access to check stock, check signing authority, and approval authorization.
The following responsibilities over cash receipts are performed by the same individual:
Receive and open mail,
Prepare bank deposits and deposit monies received,
Invoices customers for services provided (host sites).
Effect: There is not adequate segregation of duties.
Recommendation: To the extent possible, we recommend that board members or the
contract accountant become further involved in the financial reporting process; such
examples include, but are not limited to:
Approve monthly financial statements,
Bank statements and reconciliations,
Reimbursements (travel, expense, etc.) made to agency head,
Credit card activity initiated by the agency head,
The board of directors should adopt an annual budget and monitor on a periodic
basis.
We further recommend that management incorporate these recommendations to their
financial policies and procedures handbook. This will ensure that financial policies are
conducted consistently and in accordance with the expectations set by management and
board governance. Additionally, such policies and procedures provide structure within
LDSC in the event of employee turnover or absenteeism.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-002 Approval of Living Allowance Payments
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR
2522.230
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: For two out of the thirteen living allowance periods tested, approval of the
payroll disbursements was not able to be provided. For one of the thirteen living allowance
payroll disbursement periods tested, approval was granted, however, the payment did not
appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed
approximately 68% of their hourly commitment in the program but was paid approximately
95% of their annual contracted amount. Our sample was not statistically valid.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).”
As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not
exceed that which would be incurred by a prudent person under the circumstances
prevailing at the time the decision was made to incur the cost.”
As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from
completing a term of service for compelling personal circumstances, as determined by the
program, or for cause.”
Cause: Internal controls over approval of living allowances are not operating effectively.
Effect: Disbursements under the program may not have been for allowable purposes.
Recommendation: LDSC should ensure internal controls over approval of living
allowances are implemented as designed.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-003 Compliance of Special Tests and Provisions – National Service Criminal History
Checks
Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and
National and ALN 94.006 COVID 19 -AmeriCorps State and National
Year Finding Originated: 2023
Compliance Requirement: 45 CFR 2540.205
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: Of the twenty-four National Service Criminal History Checks tested, we noted
the following exceptions:
For the first exception, the documented start date and adjudication date was before the Sex
Offender Registry Check was performed and the date the state of residence and state of
service criminal history check was performed for one individual. For the second exception,
the adjudication date for an individual was prior to the date of the FBI fingerprint-based
record check results. For the third exception, the name used for the name-based Sex
Offender Registry Check and state of residence and state of service criminal history check
did not agree to the name on the individual’s government issued identification. Our sample
was not statistically valid.
Criteria: As noted in 45 CFR 2540.205 certain tests “must be conducted, reviewed, and
an eligibility determination made by the grant recipient or subrecipient based on the results
of the National Service Criminal History Check before a person begins to work or serve in
a position as an AmeriCorps State and National member.”
Cause: Checks of the Sex Offender Registry, state of residence and state of service,
criminal history check, and FBI fingerprint-based checks (collectively, the National
Service Criminal History Check) were not performed in accordance with federal guidelines
consistently.
Effect: Individuals who may have not met eligibility requirements to serve as members
were permitted to perform service.
Recommendation: LDSC should ensure controls over review and adjudication of National
Service Criminal History Checks function properly.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-001 Segregation of Duties
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2022
Compliance Requirement: 2 CFR 200.303 Internal Controls
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None.
Condition: During our audit, we obtained an understanding and tested LDSC’s internal
control for purposes of planning and performing our audit procedures. In obtaining our
understanding and testing LDSC’s internal controls, we determined there were inadequate
segregation of duties involving certain aspects of the financial reporting cycle.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the
same individual, as follows:
Initiate and approve vendor invoices for payment,
Write checks or initiating electronic disbursements,
Review and approve payroll, including the approver’s payroll
Initiate and approve reimbursements to themselves as the agency head,
Access to check stock, check signing authority, and approval authorization.
The following responsibilities over cash receipts are performed by the same individual:
Receive and open mail,
Prepare bank deposits and deposit monies received,
Invoices customers for services provided (host sites).
Effect: There is not adequate segregation of duties.
Recommendation: To the extent possible, we recommend that board members or the
contract accountant become further involved in the financial reporting process; such
examples include, but are not limited to:
Approve monthly financial statements,
Bank statements and reconciliations,
Reimbursements (travel, expense, etc.) made to agency head,
Credit card activity initiated by the agency head,
The board of directors should adopt an annual budget and monitor on a periodic
basis.
We further recommend that management incorporate these recommendations to their
financial policies and procedures handbook. This will ensure that financial policies are
conducted consistently and in accordance with the expectations set by management and
board governance. Additionally, such policies and procedures provide structure within
LDSC in the event of employee turnover or absenteeism.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-002 Approval of Living Allowance Payments
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR
2522.230
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: For two out of the thirteen living allowance periods tested, approval of the
payroll disbursements was not able to be provided. For one of the thirteen living allowance
payroll disbursement periods tested, approval was granted, however, the payment did not
appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed
approximately 68% of their hourly commitment in the program but was paid approximately
95% of their annual contracted amount. Our sample was not statistically valid.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).”
As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not
exceed that which would be incurred by a prudent person under the circumstances
prevailing at the time the decision was made to incur the cost.”
As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from
completing a term of service for compelling personal circumstances, as determined by the
program, or for cause.”
Cause: Internal controls over approval of living allowances are not operating effectively.
Effect: Disbursements under the program may not have been for allowable purposes.
Recommendation: LDSC should ensure internal controls over approval of living
allowances are implemented as designed.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-003 Compliance of Special Tests and Provisions – National Service Criminal History
Checks
Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and
National and ALN 94.006 COVID 19 -AmeriCorps State and National
Year Finding Originated: 2023
Compliance Requirement: 45 CFR 2540.205
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: Of the twenty-four National Service Criminal History Checks tested, we noted
the following exceptions:
For the first exception, the documented start date and adjudication date was before the Sex
Offender Registry Check was performed and the date the state of residence and state of
service criminal history check was performed for one individual. For the second exception,
the adjudication date for an individual was prior to the date of the FBI fingerprint-based
record check results. For the third exception, the name used for the name-based Sex
Offender Registry Check and state of residence and state of service criminal history check
did not agree to the name on the individual’s government issued identification. Our sample
was not statistically valid.
Criteria: As noted in 45 CFR 2540.205 certain tests “must be conducted, reviewed, and
an eligibility determination made by the grant recipient or subrecipient based on the results
of the National Service Criminal History Check before a person begins to work or serve in
a position as an AmeriCorps State and National member.”
Cause: Checks of the Sex Offender Registry, state of residence and state of service,
criminal history check, and FBI fingerprint-based checks (collectively, the National
Service Criminal History Check) were not performed in accordance with federal guidelines
consistently.
Effect: Individuals who may have not met eligibility requirements to serve as members
were permitted to perform service.
Recommendation: LDSC should ensure controls over review and adjudication of National
Service Criminal History Checks function properly.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-001 Segregation of Duties
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2022
Compliance Requirement: 2 CFR 200.303 Internal Controls
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None.
Condition: During our audit, we obtained an understanding and tested LDSC’s internal
control for purposes of planning and performing our audit procedures. In obtaining our
understanding and testing LDSC’s internal controls, we determined there were inadequate
segregation of duties involving certain aspects of the financial reporting cycle.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the
same individual, as follows:
Initiate and approve vendor invoices for payment,
Write checks or initiating electronic disbursements,
Review and approve payroll, including the approver’s payroll
Initiate and approve reimbursements to themselves as the agency head,
Access to check stock, check signing authority, and approval authorization.
The following responsibilities over cash receipts are performed by the same individual:
Receive and open mail,
Prepare bank deposits and deposit monies received,
Invoices customers for services provided (host sites).
Effect: There is not adequate segregation of duties.
Recommendation: To the extent possible, we recommend that board members or the
contract accountant become further involved in the financial reporting process; such
examples include, but are not limited to:
Approve monthly financial statements,
Bank statements and reconciliations,
Reimbursements (travel, expense, etc.) made to agency head,
Credit card activity initiated by the agency head,
The board of directors should adopt an annual budget and monitor on a periodic
basis.
We further recommend that management incorporate these recommendations to their
financial policies and procedures handbook. This will ensure that financial policies are
conducted consistently and in accordance with the expectations set by management and
board governance. Additionally, such policies and procedures provide structure within
LDSC in the event of employee turnover or absenteeism.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-002 Approval of Living Allowance Payments
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR
2522.230
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: For two out of the thirteen living allowance periods tested, approval of the
payroll disbursements was not able to be provided. For one of the thirteen living allowance
payroll disbursement periods tested, approval was granted, however, the payment did not
appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed
approximately 68% of their hourly commitment in the program but was paid approximately
95% of their annual contracted amount. Our sample was not statistically valid.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).”
As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not
exceed that which would be incurred by a prudent person under the circumstances
prevailing at the time the decision was made to incur the cost.”
As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from
completing a term of service for compelling personal circumstances, as determined by the
program, or for cause.”
Cause: Internal controls over approval of living allowances are not operating effectively.
Effect: Disbursements under the program may not have been for allowable purposes.
Recommendation: LDSC should ensure internal controls over approval of living
allowances are implemented as designed.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-003 Compliance of Special Tests and Provisions – National Service Criminal History
Checks
Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and
National and ALN 94.006 COVID 19 -AmeriCorps State and National
Year Finding Originated: 2023
Compliance Requirement: 45 CFR 2540.205
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: Of the twenty-four National Service Criminal History Checks tested, we noted
the following exceptions:
For the first exception, the documented start date and adjudication date was before the Sex
Offender Registry Check was performed and the date the state of residence and state of
service criminal history check was performed for one individual. For the second exception,
the adjudication date for an individual was prior to the date of the FBI fingerprint-based
record check results. For the third exception, the name used for the name-based Sex
Offender Registry Check and state of residence and state of service criminal history check
did not agree to the name on the individual’s government issued identification. Our sample
was not statistically valid.
Criteria: As noted in 45 CFR 2540.205 certain tests “must be conducted, reviewed, and
an eligibility determination made by the grant recipient or subrecipient based on the results
of the National Service Criminal History Check before a person begins to work or serve in
a position as an AmeriCorps State and National member.”
Cause: Checks of the Sex Offender Registry, state of residence and state of service,
criminal history check, and FBI fingerprint-based checks (collectively, the National
Service Criminal History Check) were not performed in accordance with federal guidelines
consistently.
Effect: Individuals who may have not met eligibility requirements to serve as members
were permitted to perform service.
Recommendation: LDSC should ensure controls over review and adjudication of National
Service Criminal History Checks function properly.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-001 Segregation of Duties
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2022
Compliance Requirement: 2 CFR 200.303 Internal Controls
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None.
Condition: During our audit, we obtained an understanding and tested LDSC’s internal
control for purposes of planning and performing our audit procedures. In obtaining our
understanding and testing LDSC’s internal controls, we determined there were inadequate
segregation of duties involving certain aspects of the financial reporting cycle.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the
same individual, as follows:
Initiate and approve vendor invoices for payment,
Write checks or initiating electronic disbursements,
Review and approve payroll, including the approver’s payroll
Initiate and approve reimbursements to themselves as the agency head,
Access to check stock, check signing authority, and approval authorization.
The following responsibilities over cash receipts are performed by the same individual:
Receive and open mail,
Prepare bank deposits and deposit monies received,
Invoices customers for services provided (host sites).
Effect: There is not adequate segregation of duties.
Recommendation: To the extent possible, we recommend that board members or the
contract accountant become further involved in the financial reporting process; such
examples include, but are not limited to:
Approve monthly financial statements,
Bank statements and reconciliations,
Reimbursements (travel, expense, etc.) made to agency head,
Credit card activity initiated by the agency head,
The board of directors should adopt an annual budget and monitor on a periodic
basis.
We further recommend that management incorporate these recommendations to their
financial policies and procedures handbook. This will ensure that financial policies are
conducted consistently and in accordance with the expectations set by management and
board governance. Additionally, such policies and procedures provide structure within
LDSC in the event of employee turnover or absenteeism.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-002 Approval of Living Allowance Payments
Title and Assistance Listing Number of the Federal Program: ALN 94.006
AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and
National
Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR
2522.230
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: For two out of the thirteen living allowance periods tested, approval of the
payroll disbursements was not able to be provided. For one of the thirteen living allowance
payroll disbursement periods tested, approval was granted, however, the payment did not
appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed
approximately 68% of their hourly commitment in the program but was paid approximately
95% of their annual contracted amount. Our sample was not statistically valid.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain
effective internal control over the Federal award that provides reasonable assurance that
the non-Federal entity is managing the Federal award in compliance with Federal statutes,
regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal
Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO).”
As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not
exceed that which would be incurred by a prudent person under the circumstances
prevailing at the time the decision was made to incur the cost.”
As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from
completing a term of service for compelling personal circumstances, as determined by the
program, or for cause.”
Cause: Internal controls over approval of living allowances are not operating effectively.
Effect: Disbursements under the program may not have been for allowable purposes.
Recommendation: LDSC should ensure internal controls over approval of living
allowances are implemented as designed.
Views of Responsible Officials: See views of responsible officials on page 29.
2023-003 Compliance of Special Tests and Provisions – National Service Criminal History
Checks
Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and
National and ALN 94.006 COVID 19 -AmeriCorps State and National
Year Finding Originated: 2023
Compliance Requirement: 45 CFR 2540.205
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: Of the twenty-four National Service Criminal History Checks tested, we noted
the following exceptions:
For the first exception, the documented start date and adjudication date was before the Sex
Offender Registry Check was performed and the date the state of residence and state of
service criminal history check was performed for one individual. For the second exception,
the adjudication date for an individual was prior to the date of the FBI fingerprint-based
record check results. For the third exception, the name used for the name-based Sex
Offender Registry Check and state of residence and state of service criminal history check
did not agree to the name on the individual’s government issued identification. Our sample
was not statistically valid.
Criteria: As noted in 45 CFR 2540.205 certain tests “must be conducted, reviewed, and
an eligibility determination made by the grant recipient or subrecipient based on the results
of the National Service Criminal History Check before a person begins to work or serve in
a position as an AmeriCorps State and National member.”
Cause: Checks of the Sex Offender Registry, state of residence and state of service,
criminal history check, and FBI fingerprint-based checks (collectively, the National
Service Criminal History Check) were not performed in accordance with federal guidelines
consistently.
Effect: Individuals who may have not met eligibility requirements to serve as members
were permitted to perform service.
Recommendation: LDSC should ensure controls over review and adjudication of National
Service Criminal History Checks function properly.
Views of Responsible Officials: See views of responsible officials on page 29.