2021-006 – Special Tests and Provisions – Background Checks
Corrective Action: In August 2021, CBNHC recruited and hired an experienced Human Resources Director. Filling this position allowed CBNHC to make progress in rectifying prior human resources weaknesses and improve processes. The position ag...
2021-006 – Special Tests and Provisions – Background Checks
Corrective Action: In August 2021, CBNHC recruited and hired an experienced Human Resources Director. Filling this position allowed CBNHC to make progress in rectifying prior human resources weaknesses and improve processes. The position again became vacant in September 2022 and was most recently filled in March 2023. The addition of a Human Resources Assistant was approved in May 2023 and filled in January 2024. Filling these two positions has allowed CBNHC to further address gaps and delays in human resources operations and meeting compliance requirements. CBNHC is implementing the following corrective action plan to ensure compliance with the background check requirements of the Indian Self-Determination program.
• Complete Human Resources Onboarding checklist recording all policies and background checks completed for every new employee to be stored in personnel files.
• Build, maintain, and review (monthly) spreadsheets that record all CBNHC employees, contractors, and student interns, required background checks by vendor, date submitted/requested, date results received, and date next background check is required.
• Audit of all employee background check files to identify and address any current deficiencies.
• Develop and implement HR Standard Operating Procedures to ensure that processes for completing background checks are clearly documented for ease of execution.
• Continue to monitor and reassess performance against current HR compliance requirements.
• Monitor workload of HR staff in relation to continued organizational growth to determine if additional positions are necessary to ensure continued regulatory compliance.
Person Responsible: Several individuals will be responsible for the corrective action plan, by area, as follows:
• HR Standard Operating Procedures: The Human Resources Director (Christina Chavez) will create and maintain the detailed instructions for carrying out the functions and duties of the HR Department, to include the procedures for completing all required background checks in a timely manner to ensure compliance.
• Background Check Spreadsheet: The Human Resources Director (Christina Chavez) will create the spreadsheet to include all CBNHC employees, contractors, and student interns, required background checks by vendor, date submitted/requested, date results received, and date next background check is required. The Human Resources Director (Christina Chavez) and Human Resources Assistant (Tiffany Begay) will jointly review the spreadsheet monthly, typically within the first 10 days of each month, to determine any necessary action. Both will participate in maintaining the data as appropriate.
• Audit: The Human Resources Director (Christina Chavez) and Human Resources Assistant (Tiffany Begay) will complete an initial audit of all existing background check files to identify and address any current deficiencies. Going forward, the Human Resources Assistant (Tiffany Begay) will conduct a full audit of these files biannually, with the Human Resources Director (Christina Chavez) auditing three (3) random samples quarterly.
Completion Date: Work in progress as of March 15, 2024. The HR Department staff meet daily to discuss progress on successes and challenges. The target date for completion of the background check spreadsheet and initial audit of existing files is April 26, 2024. The target date for completion of the HR Standard Operating Procedures is within six (6) months of this response (September 15, 2024).