Annual Independent Review: An individual independent of the day-to-day background check process will conduct an annual review of employee background investigation files to ensure required documentation is complete and properly maintained. 2. Five-Year Renewal Tracking: The Human Resources will maintain a tracking system to monitor the five-year background investigation requirement and ensure investigations are renewed timely. 3. Adjudication Documentation: The Human Resources will continue to verify that each required background investigation has been reviewed and adjudicated by an appropriately trained and qualified adjudicating official and that the adjudicator has a current adjudicated background check on file. 54 LITTLE WOUND SCHOOL BOARD, INC. CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 4. File Documentation Checklist: The Human Resources currently has a standardized background investigation checklist to ensure required documentation is consistently included in each employee's file. 5. Ongoing Oversight: The Human Resources will establish a secondary review process so that compliance with background investigation requirements is not solely dependent upon one individual. Any deficiencies identified through the annual review will be documented and corrected in a timely manner. 6. Staff Training: All personnel responsible for background investigations and file maintenance will receive on-going training regarding applicable requirements, documentation standards, renewal requirements, and adjudication procedures. The School is committed to strengthening its internal controls and ensuring that employee background investigation records are complete, current, properly adjudicated, and maintained in accordance with applicable federal requirements. The School will use the annual independent review process to provide continued oversight and reduce the likelihood of similar findings in the future.