250 E Street SW

Washington, D.C. 20525

202-606-5000/ 800-942 2677A

National Service 

Criminal History Check (NSCHC) 

Manual

Effective May 1, 2021 

(Updated January 26, 2022)
2

Contents

Change Log................................................................................................................................ 3

National Service Criminal History Checks (NSCHC)................................................................. 4

Grant Recipients or Subrecipients Required to Comply with NSCHC .................................... 5

Individuals Required to Comply with NSCHC........................................................................... 5

Individuals Exempt from NSCHC................................................................................................ 6

Individuals Deemed Ineligible Due to NSCHC ......................................................................... 7

Suitability ............................................................................................................................... 7

False statements under NSCHC .......................................................................................... 9

NSCHC Check Components ..................................................................................................... 9

State of Residence..............................................................................................................10

Unreadable Fingerprints for FBI Checks.............................................................................11

Conducting the NSCHC........................................................................................................... 11

Name-based Checks..........................................................................................................12

NSCHC Timing ........................................................................................................................... 12

Break in Service ...................................................................................................................13

Changing National Service Programs...............................................................................13

NSCHC Documentation........................................................................................................... 13

NSCHC Grant Costs.................................................................................................................. 15

NSCHC Waiver .......................................................................................................................... 15

NSCHC Pre-Approved Waivers..........................................................................................16

Monitoring and Enforcement .................................................................................................. 16

Monitoring for Compliance................................................................................................17

Administrative Remedies and Enforcement for Noncompliance...................................18

Guide to Enforcement Actions and Remedies ................................................................21

Appendix A: Pre-Approved NSCHC Waivers.......................................................................... 23

1. Use of Truescreen for NSOPW and/or State Checks .................................................23

2. National Fingerprint File States....................................................................................25

3. Disability Accommodation Exemption for FBI Fingerprint Checks...........................26

Appendix B: Who is required to conduct NSCHC? Graphic................................................. 27
3

Change Log

This table lists all the changes made in the most recent revision of this document. See 

Previous Change Logs, found on https://americorps.gov/grantees-sponsors/history-check, 

for a full list of changes. 

# Date Section and Page # Change

16 5/1/21 Throughout Links updated to reflect new site: 

https://americorps.gov/grantees-sponsors/historycheck

17 5/13/21 Throughout Previous Change log moved to external document

18 5/13/21 Throughout Links updated to reflect regulations: 

https://ecfr.federalregister.gov/current/title45/subtitle-B/chapter-XXV/part-2540/subpart-B

19 6/29/21 Appendix A: National 

Fingerprint File States 

Pre-Approved Waiver

NFF Pre-approved waiver was updated to reflect 

that Vermont participates in the NFF. 

20 8/31/21 Appendix A: National 

Fingerprint File States 

Pre-Approved Waiver

NFF Pre-approved waiver was updated to reflect 

that Connecticut participates in the NFF.

21 10/15/21 Appendix A: National 

Fingerprint File States 

Pre-Approved Waiver

NFF Pre-approved waiver was updated to reflect 

that Michigan participates in the NFF.

22 1/26/22 NSCHC Check 

Components

Incorporated guidance on unreadable fingerprints 

and possibility of name-based FBI checks.

23 1/26/22 NSCHC Waiver Clarified NSCHC waivers, including examples of 

waiver parameters.

24 1/26/22 Monitoring and 

Enforcement

Section renamed from Enforcement.

Identification of Noncompliance subsection 

moved up from Guide to Enforcement Actions and 

Remedies section and renamed Monitoring for 

Compliance. Clarified parameters for expansion of 

scope.

25 1/26/22 Administrative Remedies 

and Enforcement for 

Noncompliance

Cost-based disallowance: added reference to 

Awardee Guide NSCHC Enforcement of CostBased Disallowance for further guidance on costbased disallowance.

Clarified that disallowed costs are based on actual 

expenditures.

Required Use of AmeriCorps Approved Contract 

with Truescreen and Fieldprint subsection moved 
4

up from Other Administrative Remedies table.

Clarified vendor requirement in most cases.

26 1/26/22 Guide to Enforcement 

Actions and Remedies

Clarified expectation of prime grantees to 

implement cost-based disallowance for NSCHC 

noncompliance of subrecipients.

Nature of Noncompliance table: reordered 

enforcement actions to reflect level of escalation. 

Clarified possibility of rechecks in vendors, as 

applicable.

27 1/26/22 Appendix A: Use of 

Truescreen for NSOPW 

and/or State Checks

Use of Truescreen Pre-approved waiver was 

updated to include New Hampshire.

National Service Criminal History Checks (NSCHC)

The NSCHC is a screening procedure established by law to protect the beneficiaries of 

national service. NSCHCs have three components:

• A nationwide name-based check of the National Sex Offender Public Website 

(NSOPW). The NSOPW (https://www.nsopw.gov/) is a centralized system that 

identifies people who are registered as sex offenders in states, territories, and with 

many federally recognized Tribes,

• A name- or fingerprint-based search of the statewide criminal history registry in the 

candidate’s state of residence and in the state where the person will serve or 

work, and 

• A fingerprint-based FBI check

NSCHC requirements are baseline screening procedures. Organizations should institute a 

holistic framework for safeguarding beneficiaries of service. 

Safeguarding beneficiaries involves more than screening for criminal history. It includes 

taking additional actions to ensure the health and safety of beneficiaries, such as having 

clear guidelines on interactions between individuals, policies, and procedures on 

appropriate behavior and how to respond to noncompliance with those policies. 
5

Grant Recipients or Subrecipients Required to Comply with

NSCHC

Organizations that receive one of the following grants, as a recipient or subrecipient, 

must conduct NSCHCs:

• Operational grants provided by AmeriCorps State and National

• Foster Grandparent Program Grants

• Retired Senior Volunteer Program Grants

• Senior Companion Program Grants

• Senior Demonstration Program Grants that receive funding from AmeriCorps

• Martin Luther King, Jr. Day of Service Grants

• September 11th Day of Service Grants

• Social Innovation Fund Grants

• Volunteer Generation Fund Grants

• AmeriCorps VISTA Program Grants

• AmeriCorps VISTA Support Grants

All grant program provisions, laws and regulations, including the requirement to perform 

the NSCHC, applies to any subrecipients or of grant recipients identified in the 

aforementioned list. This requirement applies no matter how large or small the dollar 

amount of the sub-award, or whether the costs are covered by AmeriCorps federal funds 

or, in the case of cost-reimbursement grants, non-federal matching funds.

Individuals Required to Comply with NSCHC

The following individuals, who serve or work under a grant subject to NSCHC 

requirements, must have an NSCHC:

o AmeriCorps members serving in State and National programs

o AmeriCorps Seniors volunteers serving in the Foster Grandparent program who

receive a stipend

o AmeriCorps Seniors volunteers serving in the Senior Companion program who 

receive a stipend

o Individuals in positions in which they will receive a salary, directly or reflected as 

match, under a cost reimbursement grant
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Individuals Exempt from NSCHC

The following individuals are exempt from NSCHC:

• Individuals who are under the age of 18 on the first day of work or service who 

serve on an NSCHC required grant.

• Individuals whose activity is entirely included in the grant recipient’s indirect cost 

rate or cost allocation plan.

AmeriCorps Seniors volunteers serving in the RSVP program and AmeriCorps members 

serving in the VISTA program are not required to comply with NSCHC. AmeriCorps 

members serving in the VISTA program will undergo a separate criminal history check 

process managed by the AmeriCorps VISTA program. Grant recipients may choose to 

conduct criminal history checks on AmeriCorps Seniors volunteers serving in the RSVP 

program.

Contractors: In most cases, contractors are not covered by NSCHC.

AmeriCorps applies the NSCHC requirements based on the legal distinctions between 

subawards (also known as subgrants) and contracts as defined in the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. 

See 2 C.F.R. § 200.2. Organizations may colloquially refer to subawards as contracts.

However, the two are legally distinct and the NSCHC requirements apply to subawards, 

not contracts. Guidance on how to determine whether you have entered into a 

subaward or a contract with another entity is available at 2 C.F.R. § 200.331, 

“Subrecipient and contractor determinations.”

Subaward: The NSCHC requirement does apply to individuals who work or serve under

subawards, as defined under 2 C.F.R. § 200.2. This is because subrecipients are 

responsible for adherence to applicable Federal requirements specified in the original 

federal award, as stated in 2 C.F.R. § 200.331(a)(4).

Contractor: The NSCHC requirement does not apply to individuals who provide services 

under a contract, as defined under 2 C.F.R. § 200.2. If your organization enters into a

contract with an entity to provide services, the NSCHC requirements do not apply to the 

contractor because payments made by your organization to the contractor are not 

grant-funded living allowances, stipends, or salaries.

If the services for which you contracted involve ongoing contact between contractor 

personnel and service beneficiaries, then even though the specific requirements of the 

NSCHC do not apply to those contract personnel. AmeriCorps strongly recommends that 

your organization use prudent and reasonable screening procedures of contractor 

personnel to protect service beneficiaries from the risk of harm. You may obtain free and 
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immediate results of a sex offender search through https://www.nsopw.gov/. The costs of 

additional screening for contractors with ongoing contact with service beneficiaries are 

allowable grant costs.

Please note that this guidance only clarifies existing rules related to the NSCHC. It does 

not authorize or change a recipient’s ability to subaward or contract. By regulation, 

AmeriCorps Seniors recipients are prohibited from making subawards or from contracting 

out project management requirements necessary to accomplish the purposes of the 

grant, as described in 45 C.F.R. § 2551.22, 2552.22, and 2553.22. Social Innovation Fund 

subrecipients may not make further subawards.

Individuals Deemed Ineligible Due to NSCHC

Under the regulation and statute, an individual is ineligible to serve or work on an 

AmeriCorps grant if they:

o refuse to consent to NSCHC;

o make a false statement in connection with NSCHC;

o is registered, or is required to be registered, on a state sex offender registry 

or the National Sex Offender Registry; or

o has been convicted of murder, as defined in 18 U.S.C. 1111.

Grant recipients must maintain adequate documentation that the individual has 

consented to NSCHC and understands that selection into the program is contingent 

upon the organizations’ review of the individuals NSCHC component results, if any. An 

organization’s policy should describe actions required to inform an individual of their 

rights related to NSCHC, as well as privacy practices to ensure confidentiality of any 

information related to NSCHC, consistent with the authorization provided by the 

applicant.

If the applicant is found to be ineligible because of NSCHC component results, grant 

recipients must provide a reasonable opportunity for the individual to review and 

challenge the factual accuracy of the results before action is taken to exclude the 

individual from the position.

Suitability

Suitability is determined by the grant recipients and subrecipients, or service sites. An 

individual may be eligible to work or serve in a position under the NSCHC regulation, but 

a grant recipient, subrecipient, or service site may determine that an individual is not 

suitable to work or serve in such a position based on criteria that the grant recipient or 

subrecipient or service site establishes. 
8

The suitability criteria must be consistent with state and federal Civil Rights and 

nondiscrimination laws, including Titles VI and VII of the Civil Rights Act of 1964 (and 

AmeriCorps’ implementing regulations under Title VI). Additional screening criteria should 

be clearly described and adhered to within grant recipient and subrecipient or service 

site policy.

Arrests vs. Convictions: The requirements do not disqualify applicants on the basis of 

arrest. In certain states, there are legal constraints on how an arrest record may be 

considered, and some statewide criminal repositories do not include arrest information in 

the records they release. Recipients should recognize that they have a dual status under 

the Civil Rights Act of 1964, depending on the nature of their relationship with a 

candidate.

Grant recipients, because they get federal financial assistance, must comply with the 

Civil Rights Act of 1964 and its implementing regulation. These regulations prohibit 

discrimination, including selection and placement of volunteers and members, on the 

basis of race, color, and national origin, in AmeriCorps-funded programs and activities. 

And as employers, recipients must also comply with VII of the Civil Rights Act of 1964 , 

which prohibits discrimination in employment decisions. The Equal Employment 

Opportunity Commission (EEOC) has issued guidance explaining when consideration of 

arrest and conviction records violates Title VII. In addition, grant recipients must comply 

with the nondiscrimination provisions of the NCSA and the regulations at 45 CFR 

§2540.210.

As the EEOC guidance outlines, recipients should be mindful that arrests alone are mere 

allegations, and that actual criminal convictions, or actual evidence of conduct 

underlying an arrest, are the relevant indicators of a person’s suitability, or in some cases, 

eligibility, to serve with, or work for, an AmeriCorps grant recipient. Recipients should 

make sure that their screening practices are narrowly tailored in a manner that complies 

with these federal nondiscrimination requirements, in addition to applicable state laws 

governing the consideration of criminal history records.

Non-disqualifying Convictions: If the NSCHC returns results other than those above, the 

recipient has the discretion – subject to any federal civil rights law and state law 

requirements – to decide if the results of a criminal history background check disqualify a 

candidate from service. Recipients should consider the factors set forth in the EEOC’s 

guidance under Title VII, including the nature and gravity of the offense, the time that has 

passed since the conviction or completion of the sentence, and the nature of the 

position. Recipients should have written policies on their disqualification criteria and be 

consistent in how those criteria are applied. 

Additionally, organizations must use national service criminal history check results in 

combination with other information obtained through the grant recipient’s selection 

process to make an informed choice before selecting an individual for work or service.

Recipients should maintain documentation of the evidence used in making suitability

determinations for individuals with non-disqualifying convictions.
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Grant recipients should be aware of federal reentry policy, which aims, among other 

goals, to reduce post prison barriers to employment. Participation in national service 

programs funded by AmeriCorps could help people who have been in prison successfully 

re-enter society. Therefore, we encourage agencies to minimize barriers to service –

without putting their program beneficiaries at genuine risk – for former prisoners who are 

eligible under the law.

False statements under NSCHC

A false statement in connection with NSCHC is made when an individual intentionally 

provides false information required to conduct national service criminal history check 

components found at section 45 CFR §2540.205. This would arise when an individual 

intentionally provides the following to conduct the components of the NSCHC: 

• A false name,

• A government-issued identification belonging to another person,

• A false identification, or 

• Fingerprints of another individual. 

The intentionally false statements, as listed above regarding information required to 

conduct NSCHC components found at 42 USC 12645g(b), render an individual ineligible 

to serve under 42 USC 12645g(c).

As reminder, suitability criteria independent of the NSCHC ineligibility criteria may be 

established by recipients and subrecipients or service sites, subject to any federal civil 

rights law and state law requirements. 

Considerations Around Grantee-mandated Disqualification Determinations: In cases 

where individuals provide false information requested for a grantee-mandated 

disqualification determination, grant recipients have discretion in how to deal with the 

situation, again consistent with federal civil rights law and state law requirements. 

Grantee-mandated disqualification determinations, and false statements related to such 

determinations, have no effect on an individual’s eligibility under the statute.

NSCHC Check Components

NSCHC check components include three distinct components:

• a nationwide check of the National Sex Offender Public website through 

www.NSOPW.gov;

• a check of the state criminal history record repository or agency-designated 

alternative for the individual’s state of residence and state of service; and 
10

• a fingerprint-based check1 of the FBI criminal history record database through the 

state criminal history record repository or agency-approved vendor.

State of Residence

NSCHC regulations require organizations to search (by name or fingerprint) the state 

criminal history record repository.

The state where a candidate “resides” is the location the individual identifies as their

place of residence at the moment in time they applied to serve or work. 

There is no measure of how long the individual has resided at a location that a program is 

required to validate to establish the correct state of residence – even a single day as a 

resident would meet the test for where an individual has made a home. 

College Students: For the purpose of AmeriCorps requirements, an individual applying to 

serve or work who is enrolled as a full-time college student is deemed to be residing in the 

state where they live for the purpose of attending the school without regards to whether 

or not that home is on- or off-campus, and whether or not that home is in the same state 

as the college is located. 

The state to check does not change because a student is on semester or summer breaks 

or temporarily residing elsewhere. There is no test needed to measure duration of 

residence while attending school. 

Programs may not opt to use any other basis for identifying the student’s state of 

residence, e.g., such as the student’s family home. 

Foreign Residents: For those living abroad, the individual’s last state of residence in the 

United States, as well as the state where the program operates, must be checked. If the 

individual never lived in the United States, then only the state where they will be serving is 

required to be checked. Programs are also strongly encouraged to perform additional 

checks, including making contact with appropriate sources in other countries, whenever 

possible. 

Documentation: While AmeriCorps does not dictate specifics with regard to 

documentation for establishing state of residence, programs must ensure that the totality 

of information is accurate and logical. For example, when a government-issued ID 

address does not match the indicated state of residence address, programs should 

document the reason for the variance. Programs should have clear, written policies and 

1 It is possible for FBI checks to be conducted as name-based checks in certain circumstances. 

See Unreadable Fingerprints for FBI Checks, below.
11

procedures establishing protocol for discerning state of residence for all covered 

individuals. 

Unreadable Fingerprints for FBI Checks

The required FBI check is a fingerprint-based check. However, it is possible that an 

individual’s fingerprints may be unreadable and rejected by the check source. 

If using the state criminal history repository to conduct the FBI check, grantees should 

follow the repository’s protocols for handling rejected fingerprints. This may consist of 

conducting a name-based check of FBI records. Grantees must maintain documentation 

of the attempts to obtain the check, the rejection notifications, any state repository 

protocol guidance regarding unreadable fingerprints, and, if applicable, documentation 

that a name-based FBI check was conducted with the individual’s other NSCHC files as 

grant records.

If using Fieldprint to conduct the FBI check, Fieldprint will automatically initiate a namebased check with the FBI after two separate sets of fingerprints are rejected. Grantees 

should maintain documentation of the rejection notification and name-based search 

(listed in the case’s activity log in Fieldprint) with the individual’s other NSCHC files as 

grant records.

Regardless of the source used, if the unreadable fingerprints necessitate the FBI check be 

name-based, the Name-based Checks guidance applies as described below.

Conducting the NSCHC

NSCHCs can be conducted in the following ways:

NSOPW checks: Use the agency approved vendor (Truescreen) or go directly to 

www.NSOPW.gov.

State of Residence and State of Service checks: Use the agency approved vendor

(Truescreen) or go directly to the appropriate state criminal history repository or 

AmeriCorps approved alternative statewide source.

FBI checks: Use the agency approved vendor (Fieldprint) or go directly to the 

appropriate state criminal history repository or AmeriCorps approved alternative 

statewide source. Please note: the FBI authorizes Fieldprint to conduct FBI checks only for

those who are required to comply with NSCHC. 

An organization’s written procedures should specify the AmeriCorps approved sources to 

be used for conducting the required checks and the actions required to conduct the 

required checks using each approved source, including how to document adherence 

with NSCHC timing requirements. One way for grant recipients or subrecipients to obtain 
12

and document the required components of the NSCHC is through the use of agencyapproved vendors.

For information on how to conduct agency approved vendor checks see the Using 

Fieldprint and Truescreen Manual under the How to Conduct NSCHC header.

For information on how to conduct NSOPW/state repository checks see the Using NSOPW 

and State Repositories Manual under the How to Conduct NSCHC header.

Name-based Checks 

AmeriCorps expects that grant recipient staff will undertake reasonable due diligence to 

determine the current first and last name to conduct name-based checks. It is prudent, 

but not required, to check any other names that the person has used or is/was known by. 

Use of the first name and last name reflected on the following sources is acceptable:

• First and last name reflected on a signed Employee's Withholding Certificate W4 form

• First and last name reflected on a signed USCIS Employment Eligibility 

Verification I-9 form

• First and last name reflected on any document on the USCIS Form 1-9’s List of 

acceptable documents

• First and last name reflected on benefit or income documentation from SSA, 

including but not limited to Social Security Benefit statement, SSA-1099, 

Supplemental Security Income (SSI) documentation, Social Security Disability 

Insurance (SSDI)documentation

If the individual provides grant recipients with documents that reflect different names, the 

grant recipient should obtain additional information from the individual to determine the 

first and last name of the applicant that will obtain the most accurate criminal history 

records. The process to reconcile documentation reflecting different names to determine 

the first and last name to be used on a name-based check should be recorded in the 

grant recipients’ policies and procedures and any additional documentation should be 

maintained as grant records.

NSCHC Timing

The NSCHC must be conducted, reviewed, and an eligibility determination made by the 

grant recipient or subrecipient based on the results of the NSCHC no later than the day 

before a person begins to work or serve on a NSCHC-required grant.

Work or service hours include AmeriCorps funded orientation and training activities. 
13

Break in Service

If a person serves consecutive terms of service with the same organization and has a 

break in service longer than 180 calendar days, then an additional NSCHC is required. A 

break in service means that a person is no longer providing service through or receiving 

salary from a recipient or subrecipient. Temporary interruption of work or service without 

termination of employment or expiration of the agreement under which service is being 

provided is not a break in service.

It is not necessary to redo the NSCHC for individuals who serve consecutive terms of 

service with the same organization if the break in service or work is less than 180 calendar 

days and the original NSCHC checks are compliant.

However, If the person turns 18 before the start of the subsequent term of service, NSCHC 

is required prior to the individual beginning a subsequent term of work or service.

It is a best practice to document any break in service and retain that documentation as 

a grant record. For example, if an AmeriCorps Seniors volunteer who receives a stipend 

has run out of leave and is on leave without pay, the grant recipient should maintain 

documentation to show that the person is on leave status rather than terminated from 

the program.

Changing National Service Programs

When someone leaves one national service grant program and begins serving or working 

in different grant program, the grant program receiving the employee or participant 

must conduct a new NSCHC, even if there has been no break in service.

However, if an individual moves from one position to another position within the same

organization and there has not been a break in service that is longer than 180 calendar 

days, a recheck is not needed. 

NSCHC Documentation

The grant recipient must maintain adequate documentation of their NSCHC process and 

practices as well as documentation of individual NSCHC grant records.

• Evidence of adopted NSCHC Policies and Procedures

o Describes how grant recipient will address all NSCHC requirements, 

including the AmeriCorps approved sources to be used for conducting 

NSCHC and practices for documenting adherence to NSCHC eligibility 

determination and timing requirements

o Describes practices for protecting information related to NSCHC. Grant 

recipients must take reasonable steps to protect the confidentiality of any 
14

information relating to the criminal history check, consistent with 

authorization provided by the applicant.

o Describes adopted procedures for informing individuals of their rights 

related to NSCHC and how NSCHC results will be used by the program

o Where applicable, describes process for monitoring NSCHC of subrecipients and/or service locations

o Describes how notice is provided to an individual that selection into the 

program is contingent upon the organization’s review of the individual’s 

NSCHC component results, if any; and

o Describes how the program complies with the requirements to provide a 

reasonable opportunity for the individual to review and challenge the 

factual accuracy of the result before action is taken to exclude the 

candidate from the position

o Describes how the program ensures that any applicant seeking to serve or 

work in a position that requires NSCHC is not charged for the cost of any 

component of a NSCHC, unless specifically approved by AmeriCorps.

• Evidence of required annual staff training by retaining certificate of completion of 

the AmeriCorps e-course training

o Ensure staff retake the course prior to expiration of the certificate. Retain 

certificates of completion from each year as grant records.

The grant recipient must maintain adequate documentation of their NSCHC process and 

practices as well as documentation of individual NSCHC grant records.

• Evidence that all required components (NSOPW, State(s), and FBI checks) were 

completed and on file (45 CFR §2540.206)

o All required components (NSOPW, State(s), and FBI) were conducted on 

time (45 CFR §2540.205) and documentation reflects evidence of when 

checks were reviewed (adjudicated) and considered when making an 

eligibility determination

• All required components ((NSOPW, State(s), and FBI checks) were conducted 

through sources authorized by AmeriCorps (45 CFR §2540.204) and are consistent 

with the sources described in the grant recipient’s adopted NSCHC policies and 

procedures

• Evidence that NSOPW results include searches from all States, Territories, and 

Indian Tribes (45 CFR §2540.204)

• Evidence that First and Last Names used on name-based checks reflect the

current name of the individual

o Documents used to determine an individual’s first and last name must be 

consistent with sources described in the grant recipient’s adopted NSCHC 

policies and procedures. Refer to agency guidance on name-based

checks. 

• Documentation of consent from the candidate to conduct State and FBI checks 

(45 CFR §2540.206) and of notice provided to the candidate that selection into the 

program is contingent upon the organization’s review of the individual’s NSCHC 

component results, if any (45 CFR §2540.206); 

• Documentation that the candidate is eligible to serve/work if a vendor returns a 
15

“do not recommend” result for the candidate (45 CFR §2540.206)

o NOTE: A vendor’s adjudication recommendation not to "recommend” the 

candidate indicates that the selecting organization needs more information 

before it can make a final determination as to the fitness of the individual to 

work or serve. It does not mean that an individual is ineligible for work or 

service.

o Grant recipients must maintain adequate documentation of the process 

implemented to make an eligibility determination and may include a 

contemporaneously dated memo to the file documenting determination of 

the individual’s eligibility.

Please note that many documentation requirements are obtained and maintained by 

agency approved vendors. More information on agency approved vendor usage can 

be found in the Using Fieldprint and Truescreen Manual.

NSCHC Grant Costs

Applicants seeking to serve or work in a position that requires NSCHC may not be 

charged for the cost of any component of a National Service Criminal History Check.

NSCHC Waiver

If the grant recipient or subrecipient is unable to abide by the NSCHC rule, the agency

can waive requirements for good cause or any other lawful basis. Contact

NSCHCWaiverRequest@cns.gov for a waiver request form and more information.

Note that waivers are granted on an individual or a time-limited basis, and waivers are 

not retroactive. Grant recipients should evaluate and implement methods for completing 

all check components prior to the day an individual begins work or service. This includes 

incorporating check processing times and anticipating possible check processing delays 

of up to 30 days.

Grantees experiencing recurring delays or accessibility challenges that regularly impact 

an applicant’s start date may consider requesting a waiver for such recurring challenges.

In rare circumstances of significant check processing delays that are outside the control 

of the grant recipient, grant recipients may request a waiver for an applicant impacted 

by such delays.

Additionally, waivers may only be requested by prime grantees; prime grantees may 

submit requests on behalf of a subrecipient.
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NSCHC Pre-Approved Waivers

Pre-Approved NSCHC Waivers are waivers that grant recipients can use without 

additional written approval from AmeriCorps. Grant recipients may use these PreApproved Waivers at any time, provided they abide by the conditions described below. 

However, AmeriCorps strongly encourages all grant recipients that intend to use a pre‐

approved NSCHC Waiver to first consult with their Portfolio Manager to ensure that they 

understand its requirements. Noncompliance with the NSCHC regulations or with the 

requirements of a pre‐approved NSCHC Waiver may result in a financial impact for the 

grant recipient. 

AmeriCorps may add or remove pre‐approved NSCHC Waivers at any time. Maintaining 

awareness of current pre‐approved NSCHC Waivers is the responsibility of grant 

recipients. Once revoked, an organization may no longer use a pre‐approved NSCHC 

Waiver. When a pre-approved NSCHC Waiver is revoked, the Waiver does not apply to 

any individuals who begin work or service after the expiration date of the pre-approved 

NSCHC Waiver. The use of pre-approved NSCHC Waivers should be clearly described 

within NSCHC policies and procedures, including actions for maintaining awareness of 

the active AmeriCorps pre-approved NSCHC Waivers. Refer to Appendix A for active PreApproved Waivers.

Monitoring and Enforcement

AmeriCorps will apply administrative enforcement related to findings of NSCHC 

noncompliance identified through oversight and monitoring of grant records, such as 

Payment Integrity Information Act (PIIA) sampling, formerly the Improper Payments 

Elimination and Recovery Improvement Act (IPERIA), compliance assessments 

conducted by the Office of Monitoring, and Office of Inspector General audits, reviews,

or investigations. 

This guidance does not change the legal requirements for the NSCHC, nor does it 

prevent AmeriCorps or AmeriCorps-OIG from pursuing other civil or criminal enforcement 

or preventive remedies available by law. 

This guidance will be used by AmeriCorps monitoring officials. This guidance uses the term 

“monitoring officials” to collectively refer to this group of AmeriCorps individuals 

(excluding personnel of the Office of Inspector General) and the term “recipients” to 

refer to AmeriCorps prime grant recipients and subrecipients, unless specifically 

differentiated. 

AmeriCorps will also refer and abide by this document in circumstances where grant 

recipients appeal determinations of NSCHC noncompliance. 

This guidance is effective on May 1, 2021 for the following individuals:
17

• individuals who start service/work on NSCHC-required grants on May 1, 2021 or 

later and

• individuals who are serving/working on NSCHC-required grants as of May 1, 2021 

and continue to serve/work on or after November 1, 2021.

Any NSCHC noncompliance for individuals who are serving/working on NSCHC-required 

grants as of May 1, 2021 and exit service/work before November 1, 2021 or exited 

service/work before May 1, 2021 must refer to the July 1, 2019 National Service Criminal 

History Check Guide to Enforcement Action for enforcement action.

Ineligibility: Ineligible individuals are barred from working or serving in a covered position 

on a grant-funded program. All costs associated with an ineligible individual will be 

disallowed. Costs include any salary/stipend/living allowance (as applicable), FICA, and 

education award. These requirements apply whether the associated costs were paid 

with Federal funds or with matching funds. 

If AmeriCorps is made aware of an ineligible individual that the recipient failed to report, 

AmeriCorps may place the grant’s funding on manual hold and/or take additional 

action. 

AmeriCorps employees will, without delay, notify the Office of Inspector General, the 

Office of the Chief Risk Officer, and the Office of the General Counsel of suspected 

instances of ineligibility arising from disqualifying criminal histories. 

Monitoring for Compliance

AmeriCorps monitoring officials conducting NSCHC review will conduct a file review. For 

grant recipients with fewer than 25 individuals serving or working in covered positions 

during the period of assessment monitored, AmeriCorps monitoring officials will conduct a 

review consisting of 100% of these files. A period of assessment is the period of grant 

activity being reviewed for compliance, which is specified in advance by AmeriCorps or 

other reviewers. 

For grant recipients with more than 25 individuals serving or working in covered positions, 

AmeriCorps monitoring officials conducting NSCHC review will conduct a review 

consisting of 25 files or 10% of the files for individuals working or serving in covered 

positions during the period of assessment monitored, whichever is greater. If an ineligible 

individual is detected within the review of sampled files for those who worked or served 

during the period of the assessment, additional files from the period being monitored will 

be reviewed, up to 100% of applicable files. In addition, AmeriCorps reserves the right to 

expand the scope of the review to additional files from the period being monitored in 

instances of egregious, pervasive, or systemic noncompliance, or where expansion of 

scope may support identifying the extent of noncompliance. AmeriCorps may direct the 

prime grant recipient, as applicable, to conduct the expanded scope review.
18

NSCHC Records Compliance: A compliant NSCHC record consists of the following 

elements: 

• All required components (NSOPW, State(s), and FBI) were completed and on file 

(45 CFR §2540.204); 

• All required components (NSOPW, State(s), and FBI) were conducted on time (45 

CFR §2540.205); 

• All required components (NSOPW, State(s), and FBI) were conducted through 

sources authorized by AmeriCorps (45 CFR §2540.204); 

• NSOPW is complete (all States, Territories, and participating Indian Tribes were 

reporting when the search was performed) (45 CFR §2540.204);

• First and Last Name on name-based checks match the name as reflected in grant 

recipient policy and procedures

• NSOPW, State(s), FBI checks reviewed and an eligibility determination 

documented by the grantee (adjudicated) (45 CFR §2540.205); 

• Documentation of consent from the candidate to conduct State and FBI checks 

and share results (45 CFR §2540.206); 

• Documentation that notice is provided to individual that the national service 

position is contingent upon the organization’s review of the individual’s NSCHC 

component results, if any (45 CFR §2540.206); 

• Documentation that the program complies with the requirement to provide a 

reasonable opportunity for the individual to review and challenge the factual 

accuracy of the result before action is taken to exclude the candidate from the 

position (45 CFR §2540.206);

• Documentation that the candidate is eligible to serve/work if a vendor check’s 

adjudication recommendation does not endorse the candidate for service (45 

CFR §2540.205).

Administrative Remedies and Enforcement for Noncompliance

Noncompliance refers to a situation in which an individual in a covered position is eligible 

to serve, but the recipient did not fully comply with all NSCHC requirements. 

Remedies and enforcement actions will apply to the grant(s) on which noncompliance is 

identified. AmeriCorps will disallow costs and may engage in other enforcement activities 

with respect to a prime recipient if the prime recipient or its subrecipients are found to be 

out of compliance with NSCHC requirements and the prime recipient has not correctly 

applied disallowance and/or has failed to identify and correct noncompliance prior to 

AmeriCorps’s monitoring of the prime recipient. If the noncompliant grant recipient has 

other AmeriCorps grants, AmeriCorps will expand the NSCHC review as applicable. 

AmeriCorps may also direct the prime grant recipient to expand the scope of the review. 

The remedies and enforcement actions in this section apply solely to those taken 

administratively by AmeriCorps. Nothing in this guidance is intended to limit any other 

available civil or criminal enforcement measures, which may be pursued in addition to 
19

the administrative remedies herein. The remedies and enforcement actions below may 

be applied singly or in combination, depending on the type of noncompliance found. 

Cost-based Disallowance: Cost-based disallowance refers to the disallowance of costs 

associated with an eligible individual’s work or service during the period of 

noncompliance, including salary/stipend/living allowances (as applicable) and FICA. 

Where costs were paid with matching funds, the disallowance of those matching costs 

may also result in disallowance of the related Federal funds. Refer to the Awardee Guide 

NSCHC Enforcement of Cost-Based Disallowance for guidance on calculating and 

documenting NSCHC disallowance. 

Cost-based disallowance will be applied to noncompliance. In general, the cost of 

disallowance will not exceed six months; however, if the period of work or service is less 

than six months or the period of noncompliance is less than six months, the cost will be 

adjusted to coincide with the period of service, work, or period of noncompliance. 

Moreover, AmeriCorps may disallow costs for more than six months, if facts and 

circumstances support that a different period of disallowance will further AmeriCorps’s 

compliance objectives. 

Cost-based disallowance will not include the disallowance of AmeriCorps member hours. 

The actual expenditures that shall be considered for disallowance for each 

noncompliant file are salary/stipend/living allowance (as applicable) and FICA during 

the period of noncompliance for which costs are disallowed. These cost categories 

reflect substantive grant costs. The maximum disallowance amount of the federal share 

cannot exceed the value of the federal awarded amount. 

Required Use of AmeriCorps Approved Contract with Truescreen and Fieldprint: 

AmeriCorps has contracted with Fieldprint, Inc., (Fieldprint) to provide FBI fingerprintbased checks and Truescreen to provide State and National Sex Offender Public Website 

(NSOPW) checks to recipients. In most cases, a grant recipient at which NSCHC 

noncompliance is found will be required to establish accounts through the AmeriCorps 

contracts with Truescreen and Fieldprint and may be required to recheck noncompliant 

and other files through these vendors, if not already completed through the vendor. In 

most cases, recipients will also be required to use these vendors to conduct NSCHC for 

the remainder of the grant period (2 CFR §200.339, 2 CFR §200.208).

Manual Hold: In response to NSCHC noncompliance, specifically circumstances that 

require corrective action to be taken, AmeriCorps may place grant funds on manual 

hold review or restriction of funds until the grant recipient demonstrates that it has 

satisfactorily implemented required corrective action, which may include conducting 

NSCHC using the AmeriCorps-approved contract with Truescreen and Fieldprint. 

AmeriCorps may use either of these remedies as it deems appropriate. 

A manual hold may include a manual review of expenses prior to reimbursement or a full 

restriction of grant funds. 
20

1. Manual Hold Review (2 CFR §200.339): This includes a review of expenses by 

AmeriCorps staff prior to the release of funds. The inspection/review of 

reimbursement or advance requests submitted by a grant recipient is performed 

prior to the release of funds to the grantee to ensure that all fund requests are 

necessary, allowable, allocable, and reasonable with Uniform Guidance 

regulations and grant terms and conditions. 

2. Restrictions of Funds (2 CFR §200.339): This action will prevent a grant recipient 

from accessing Federal funding from AmeriCorps. For these cases, a letter to 

Health and Human Services Payment Management System will be processed and 

forwarded to HHS and the AmeriCorps grant funds will be inaccessible to the 

recipient. 

Manual hold review or restrictions of federal grant funds will be applied to the specific 

grant(s) on which NSCHC noncompliance is identified. For NSCHC noncompliance 

identified on a State Commission subrecipient, the Commission will be directed, to the 

extent possible, to apply the manual hold review or restriction of funds to the 

noncompliant subrecipient. NSCHC noncompliance detected in multiple State 

Commission subrecipients may result in a manual hold review or restriction of funds 

against the State Commission. For non-Commission direct grant recipients, including 

Social Innovation Fund grantees, manual hold review, or restriction of funds will be 

applied against the direct grant. 

Other Administrative Remedies: AmeriCorps will employ other administrative remedies as 

deemed appropriate. These other administrative remedies include: 

Remedy Definition Example 

Grant Suspension A grant suspension includes a 

hold on all grant activities, 

including participant service, 

and funding (2 CFR §200.338). 

Grant suspension may be used in 

response to NSCHC 

noncompliance. Grant suspension 

may also be applied in cases of 

noncompliance for zero-dollar 

grants. 

Grant 

Termination 

Grant termination refers to the 

ending of the award, in whole 

or in part, at any time prior to 

the planned end of period of 

performance (Grant and 

Cooperative Agreement Terms 

and Conditions, Section III.O; 2 

CFR §200.340).

Grant termination may be used in 

response to NSCHC 

noncompliance. Grant 

termination may also be applied 

in cases of noncompliance for 

zero-dollar grants. Suspension may 

precede termination proceedings; 

not all suspensions will result in 

termination. 
21

Remedy Definition Example 

Impact Future 

Awards 

Noncompliance with NSCHC 

may be considered as a factor 

in the agency’s future funding 

determinations (2 CFR 

§200.205).

AmeriCorps may consider NSCHC 

noncompliance part of its 

awarding considerations for future 

funding. 

Guide to Enforcement Actions and Remedies

AmeriCorps response to NSCHC noncompliance will conform to the chart below. 

AmeriCorps reserves the right to impose enforcement actions and remedies at its 

discretion in accordance with applicable laws. In instances of egregious, pervasive, 

systemic noncompliance of any element, AmeriCorps reserves the right to impose all 

available remedial measures. AmeriCorps expects prime grantees to implement this 

guidance for cost-based disallowance when findings of NSCHC noncompliance are 

identified with subrecipients.

Nature of Noncompliance Enforcement Action and Remedy (as applicable) 

Missing NSCHC component (NSOPW, 

State(s), and/or FBI)

Noncompliant NSCHC source 

NSOPW incomplete (missing state, 

territory, or Indian country) 

Name-based check not conducted on 

the legal name of the individual, as 

reflected on documentation used to 

verify the identity of the individual

• Corrective action to cure deficiency and 

ascertain eligibility

• Cost-based disallowance 

• Required use of AmeriCorps-approved 

contract with Truescreen and Fieldprint (if 

not already used) for the remainder of the 

grant period. This may include rechecks of 

all NSCHCs through the vendors. If 

vendors already used, rechecks required 

for noncompliance other than lateness. 

• Manual hold review or restriction of funds 

pending completion of corrective action

Late NSCHC component (NSOPW, 

State(s), and/or FBI) 

Grant recipient did not review results and 

document the individual is cleared to 

serve (NSOPW, State(s), and/or FBI) 

• Corrective action to cure deficiency and 

ascertain eligibility

• Cost-based disallowance

• Required use of AmeriCorps-approved 

contract with Truescreen and Fieldprint (if 

not already used) for the remainder of the 

grant period. This may include rechecks of 

all NSCHCs through the vendors. If vendors 
22

As noted above, noncompliance with NSCHC may also be considered as a factor in the 

agency’s funding determinations and may impact an organization’s future grant awards. 

In applicable cases, based on facts and circumstances, AmeriCorps may suspend or 

terminate the grant in response to NSCHC noncompliance. 

already used, rechecks required for 

noncompliance other than lateness.

Nature of Noncompliance Enforcement Action and Remedy (as applicable) 

Missing documentation of consent from 

the candidate to conduct State and FBI 

checks

Missing documentation of notice 

provided to the candidate that the 

national service position is contingent 

upon the organization’s review of the 

individual’s NSCHC component results, if 

any 

Missing documentation that the program 

complies with the requirement to provide 

a reasonable opportunity for the

candidate to review and challenge the 

factual accuracy of the result before 

action is taken to exclude the candidate 

from the position 

Missing documentation the grant 

recipient paid for the cost of the NSCHC 

Missing documentation that the 

candidate is eligible to serve/work if a 

vendor check’s adjudication 

recommendation does not endorse the 

candidate for service 

• Corrective action to cure deficiency

• Required use of AmeriCorps-approved 

contract with Truescreen and Fieldprint (if 

not already used) for the remainder of the 

grant period. This may include rechecks of 

all NSCHCs through the vendors. If vendors 

already used, rechecks required for 

noncompliance other than lateness.

• Manual hold review or restriction of funds 

pending completion of corrective action
23

Appendix A: Pre-Approved NSCHC Waivers

AmeriCorps may add or remove pre‐approved NSCHC Waivers at any time. Maintaining

awareness of current pre‐approved NSCHC Waivers is the responsibility of grant 

recipients. Once revoked, an organization may no longer use a pre‐approved NSCHC 

Waiver. When a pre-approved NSCHC Waiver is revoked, the Waiver does not apply to 

any individuals who begin work or service after the expiration date of the pre-approved 

NSCHC Waiver.

The use of pre-approved NSCHC Waivers should be clearly described within NSCHC 

policies and procedures, including actions for maintaining awareness of the active 

AmeriCorps pre-approved NSCHC Waivers.

Noncompliance with the NSCHC regulations or with the requirements of a pre‐approved

NSCHC Waiver may result in cost disallowance.

1. Use of Truescreen for NSOPW and/or State Checks

Effective May 1, 2021: In July 2018, AmeriCorps contracted Truescreen to provide State 

and NSOPW checks to grantees for individuals who are required to comply with NSCHC. 

Grantees who use Truescreen must set up an account with Truescreen through 

https://applicationstation.truescreen.com with the AmeriCorps specific agreement code. 

Truescreen does not provide information for the following states and territories: 

States Territories 

California Guam

Delaware Northern Mariana Islands

Louisiana Puerto Rico

Nevada New Hampshire (added 1/26/2022)

New Mexico

Virginia

Massachusetts (added 12/20/2018)

Mississippi (added 6/1/2019)

Between 11/15/18 to 8/12/19, Truescreen did not provide information for New Hampshire. 

From 8/12/2019 to 1/25/2022, New Hampshire was accessible by Truescreen and was not 

on this pre-approved Waiver.
24

Between 11/15/18 to 8/21/19, Truescreen did not provide information for American 

Samoa and Virgin Islands. As of 8/21/19, American Samoa and Virgin Islands are 

accessible by Truescreen and was removed from this pre-approved Waiver.

Grantees using Truescreen will not be required to get a check from an unavailable 

state/territory for individuals required to comply with NSCHC if they have:

1) obtained an NSOPW check from Truescreen, 

2) obtained any required state checks that are available from Truescreen, and 

3) conducted a fingerprint-based FBI check. 

Please note: 

This pre-approved Waiver does not apply to grant recipients who obtain NSCHC from 

Truescreen through an account not established with the AmeriCorps specific agreement 

code. Such checks are noncompliant. 

Example 1: One state check is not available from Truescreen 

An individual required to comply with NSCHC will serve in California (state of service is not

available from Truescreen) and is residing in Alabama at the time of application (state of 

residence is available from Truescreen). The grantee must conduct a Truescreen NSOPW 

check, a fingerprint-based FBI check, and a Truescreen Alabama state criminal history 

check. The grantee does not need California state criminal history check. 

Example 2: Both state checks are not available from Truescreen 

An individual required to comply with NSCHC will be serving in Virginia (state of service is 

not available from Truescreen) and is residing in Puerto Rico at the time of application 

(state/territory of residence is not available from Truescreen). The grantee must conduct 

a Truescreen NSOPW check and a fingerprint-based FBI check. No separate state and 

territory checks are required. 

Example 3: All state checks are available from Truescreen 

An individual required to comply with NSCHC will serve in Illinois (state of service is 

available from Truescreen) and is residing in Indiana at the time of application (state of 

residence is available from Truescreen). The grantee must conduct a Truescreen NSOPW 

check, a fingerprint-based FBI check, a Truescreen Illinois state criminal history check, 

and a Truescreen Indiana state criminal history check.
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2. National Fingerprint File States

Effective May 1, 2021: The National Fingerprint File (NFF) is an electronic information 

sharing system maintained by the Federal Bureau of Investigation (FBI). The NFF allows the 

FBI and the States to exchange criminal history records for noncriminal justice purposes 

authorized by federal or state law, such as background checks for governmental 

licensing and employment. 

States that participate in the NFF respond to record requests for all authorized 

noncriminal justice purposes and, as such, the FBI ceases to maintain duplicate criminal 

history data for these states. When a state participates in the NFF system, an FBI 

fingerprint check is duplicative of the search of a state’s criminal history record repository. 

An FBI fingerprint check eliminates the need for grantees to conduct duplicative state 

criminal history record checks in states that participate in the NFF system. 

Therefore:

• If a required state check is from a state that participates in the NFF, then the 

grantee does not need to conduct the check in that NFF state if they have 

conducted a fingerprint-based FBI check. 

• If a required state check is from a state that does not participate in the NFF, then 

this pre-approved Waiver is not applicable, and the grantee must obtain the 

appropriate NSCHC state check(s). 

The following states participate in the NFF program. States beginning participation in NFF

after May 1, 2021 are listed with their effective date. NSCHCs for those states conducted 

on or after the effective date listed may apply this waiver.

Connecticut

(as of 7/25/2021)

Colorado Florida Georgia Hawaii

Idaho Iowa Kansas Maryland Michigan

(as of

9/15/2021)

Minnesota Missouri Montana North Carolina New Jersey

New York Ohio Oklahoma Oregon Tennessee

Vermont

(as of 6/16/2021)

West Virginia Wyoming

Example 1: One state participates in NFF

An individual who is required to comply with NSCHC will serve in Maine (state of service 

does not participate in NFF) and resides in Colorado at time of application (state of 

residence does participate in the NFF). The grantee must conduct an NSOPW check, a 
26

fingerprint-based FBI check, and a Maine state criminal history check. The grantee does 

not need a separate state of residence criminal history check from Colorado. The 

Colorado criminal history record information is included in the fingerprint-based FBI

check.

Example 2: Both states participate in the NFF 

An individual who is required to comply with NSCHC will serve in Ohio (state of service 

does participate in NFF) and resides in Iowa at time of application (state of residence 

does participate in the NFF). The grantee must conduct an NSOPW check and a 

fingerprint-based FBI check. No separate state checks are required. Ohio and Iowa 

criminal history record information is already in the fingerprint-based FBI check.

Example 3: No states participate in the NFF 

An individual who must comply with NSCHC will serve in Wisconsin (state of service does 

not participate in NFF) and resides in New Mexico at time of application (state of 

residence does not participate in the NFF). The grantee must conduct an NSOPW check, 

a fingerprint-based FBI check, a Wisconsin state criminal history check, and a New 

Mexico state criminal history check.

3. Disability Accommodation Exemption for FBI Fingerprint Checks

Effective May 1, 2021: AmeriCorps will exempt the fingerprint FBI check requirement for 

individuals who are required to comply with NSCHC, if conducting a fingerprint check is a 

physical impossibility as a result of disability, such as the absence of limbs. The grantee is 

still required to conduct NSOPW and name-based state check(s) on the individual.
27

Appendix B: Who is required to conduct NSCHC? Graphic