Finding Text
2022-008 Character Investigations This is a repeat finding. The prior-year’s auditing finding number is 2021-008. Condition: The Housing Authority is not performing or documenting character investigations (background checks) on employees. Criteria: The OMB’s Compliance Supplement states, “The Indian Child Protection and Family Violence Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFR part 63). Cause: No written policies and procedures to guide Human Resources personnel. Effect: Individuals with criminal histories that would preclude them from being hired into certain positions (with access to cash, access to personally identifiable information and/or close proximity to children and the elderly) may be hired for such positions. Recommendation: Adopt and implement policies over the performance of character investigations, the filing of character investigations and the criteria to be used to preclude the hiring of individuals for certain positions. Views of Responsible Officials: See Corrective Action Plan.