Finding Text
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.