National Service Criminal History Checks (NSCHCs) help AmeriCorps programs minimize risk by protecting the public, employees, members and beneficiaries, preventing unflattering media exposure, and demonstrating program compliance with CNCS regulations.

A required element of the AmeriCorps member selection process all AmeriCorps programs must perform is to conduct criminal history checks on covered individuals. An individual is a “covered individual” if he/she, or his/her position or role:

• is listed as an estimated direct cost on the approved grant budget (whether as part of the federal or grantee (matching) share), as receiving salary, stipend, living allowance, national education award or similar, in return for providing service to the program; or
• the costs associated with the person (for salary, stipend, living allowance, etc.) will be included within amounts reported as expenditure of either federal or matching share on the program’s financial reports.

Regulations have been in effect since November 2007 requiring criminal history checks be performed on individuals whose positions require recurring access to a vulnerable population. Under the Serve America Act (SAA), expanded requirements went into effect on October 1, 2009, establishing coverage of all employees and participants, including those without contact with a vulnerable population. Since that time, all grantees must conduct at least a Two-Part National Service Criminal History Check on all CNCS covered individuals. A Two-Part check includes:

1. A National Sex Offender Public Registry check (NSOPR, also known as the NSOPW); and
2. A statewide criminal history repository check of both the state of residency/origin and the state where the individual will work/serve.

On April 21, 2011, the Two-Part check became a Three-Part National Service Criminal History Check requirement for individuals serving in or working for a program or project that allows for recurring access to a vulnerable population. Now, all covered individuals whose positions will involve recurring access to vulnerable populations must undergo:

1. A National Sex Offender Public Registry check (NSOPR, also known as the NSOPW); and
2. A statewide criminal history repository check of both the state of residency/origin and the state where the individual will work/serve (FBI checks do not substitute for state checks); and
3. A fingerprint-based FBI criminal history repository check.

CNCS requires that programs must conduct background checks using both the statewide repository for the state where the applicant resided upon application and the statewide repository for the state where the person will be assigned to work or serve. For applicants that both live and will serve in Connecticut,that means you will only run one state background check. For applicants that will be relocating from another state to Connecticut to serve with or work for your program, that means you will be running two different state background checks — one for Connecticut and one for the state of residence.

CNCS requires that state checks be initiated on or before the start of work or service. The “start of work or service” is the first day that hours may be logged for work, service or training. Initiation is one step further than requesting authorization to conduct the checks and must be documented. 

For a consecutive term, you do not need to conduct a new search if the break in service/employment is 120 days or less and the initial search(es) are compliant for the new position.