Produced and published at US taxpayer expense.

 Refer to the NSCHC Manual (available on the NSCHC webpage), ‘Administrative 

Remedies and Enforcement for Noncompliance’ section for details on NSCHC cost 

disallowance.

 This resource only summarizes key guidance around top areas of NSCHC 

noncompliance. See the NSCHC webpage and NSCHC Learning Path in Litmos

for complete guidance documents and resources.

Common Findings of National Service Criminal History Check 

(NSCHC) Noncompliance

AmeriCorps Office of Monitoring – created September 2023

1

NSCHC

Noncompliance

Grantee did not fully 

comply with all 

NSCHC requirements

45 CFR §2540.200-

207

Results in 

significant cost 

disallowance 
Produced and published at US taxpayer expense.

Pay special attention to avoid these common findings!

2

Missing checks / 

unallowable source

Wrong name on 

name-based checks / 

missing document to 

support name

Missing 

documentation of 

review & eligibility 

decision (adjudication)

Checks not completed 

& adjudicated before 

start (lateness)
Produced and published at US taxpayer expense.

All covered staff, members, 

and volunteers ...

Know the Who – What - Where!

Avoid missing checks / unallowable check source

3

require three check 

components: 

NSOPW, States (service and 

residence), and FBI ...

that must be completed 

through the specific sources

authorized by AmeriCorps.

Complete checks DIRECTLY through these compliant sources:

• NSOPW: NSOPW.gov or Truescreen

• State: AmeriCorps identified state repository or Truescreen

• FBI: AmeriCorps identified state repository or Fieldprint

WHO

needs NSCHC.

45 CFR §2540.201

WHAT

checks are needed.

45 CFR §2540.204

WHERE

to get each check.

Compliant sources only!

45 CFR §2540.204
Produced and published at US taxpayer expense.

Ace your S.A.T.s!

Avoid wrong name, missing adjudication, and lateness

4

Spelling

Adjudication

Timing
Produced and published at US taxpayer expense.

Ace your S.A.T.s!

Avoid wrong name on name-based checks / missing document to support name

5

SPELLING

 Spell first and last names on name-based 

checks correctly.

 Names must exactly match an allowable name 

document. See NSCHC Manual for allowable 

documents. 

 Maintain the allowable name document. 

 Document process to reconcile different 

names, if applicable.
Produced and published at US taxpayer expense.

Ace your S.A.T.s!

Avoid missing documentation of review & eligibility decision (adjudication)

6

ADJUDICATION

 Adjudicate: review all check results and make 

an eligibility determination.

 Clearly document your review and 

adjudication, including when it took place.

 Clearly document how you determined 

eligibility if Truescreen/Fieldprint result does 

not pass/clear the individual.
Produced and published at US taxpayer expense.

7

ADJUDICATION REMINDERS!

A complete NSCHC includes a final, documented adjudication decision from YOU, 

the grant recipient. You must document your grantee adjudication for each check 

regardless of which source you use.

Truescreen and Fieldprint:

 The approved vendors only 

provide an adjudication 

recommendation. 

 Use the vendor systems to 

document YOUR review and 

adjudication decision.

 Refer to Using AmeriCorps 

Approved Vendors Truescreen 

and Fieldprint Manual! 

NSOPW.gov and State Repositories:

 Refer to Using NSOPW and State 

Repositories Manual for details 

about documenting your review 

and adjudication using these 

sources!
Produced and published at US taxpayer expense.

Ace your S.A.T.s!

Avoid checks not completed/adjudicated before start (lateness)

8

TIMING

 Do it all on time!

 Review that checks are fully compliant and all 

requirements documented no later than the 

day BEFORE the individual’s start date.

 If you encounter significant delays or barriers 

outside your control, consider requesting an 

NSCHC waiver, described in NSCHC Manual.
Produced and published at US taxpayer expense.

9

Monitoring checks early is crucial to avoiding 

noncompliance and associated cost-based disallowance.

Self-monitoring resources:

• Overview of Uniform Monitoring Package (UMP) Section 9: NSCHC, on 

Office of Monitoring webpage.

• NSCHC Manual: ‘NSCHC Documentation’ and ‘Monitoring for 

Compliance’ sections.

• Truescreen/Fieldprint monitoring reports: available in your vendor 

client portal. Use them to monitor early!

Check your checks!