250 E Street SW

Washington, D.C. 20525

202-606-5000/ 800-942-2677

NSCHC Frequently Asked Questions

Effective May 1, 2021

Updated November 30, 2023
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Contents

Introduction .....................................................................................................................2

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

1.0 NSCHC Context.........................................................................................................3

2.0 NSCHC Applicability.................................................................................................4

3.0 Timing..........................................................................................................................7

4.0 Eligibility and Suitability...........................................................................................10

5.0 Budgeting NSCHC...................................................................................................10

6.0 Documentation.......................................................................................................13

7.0 Conducting NSCHC................................................................................................15

Introduction

AmeriCorps’ (the agency) National Service Criminal History Check (NSCHC) is a 

screening procedure established by law to protect the beneficiaries of national 

service. This guidance must be followed per the NSCHC requirements (45 CFR 

2540.200 -- .207). You may face enforcement remedies, including financial 

consequences, if you deviate from the requirements. This document outlines 

common questions related to NSCHC. For detailed information about grant 

recipient requirements, please review the NSCHC Manual Effective May 1 ,2021.

The agency will periodically update these FAQs.

For FAQs related to the AmeriCorps approved vendors Fieldprint and 

Truescreen, refer to the Using AmeriCorps Approved Vendors Fieldprint and 

Truescreen Manual.
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Change Log

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

# Date Section or Page # Change

1 11/1/21 Throughout Added pertinent FAQs from May 1 Rule Interim FAQs, 

noted by “Moved 11/1/21”.

2 11/1/21 Throughout Removed FAQs related to Fieldprint and Truescreen

and renumbered accordingly. Those FAQs are now 

located in the Using AmeriCorps Approved Vendors 

Fieldprint and Truescreen Manual.

3 4/1/22 2.0 NSCHC Applicability FAQ # 2.15 added.

4 11/18/22 5.0 Budgeting NSCHC FAQ #5.4 updated to include Public Health 

AmeriCorps and September 11th Day of Service 

grants.

5 11/23/22 5.0 Budgeting NSCHC FAQ #5.4 updated to include Public Health 

AmeriCorps and September 11th Day of Service 

grants.

6 1/31/23 5.0 Budgeting NSCHC FAQ #5.4 updated to clarify applicability to only 

VISTA Support and Program grants.

7 1/31/23 5.0 Budgeting NSCHC FAQ #5.4.1 added.

8 11/30/23 6.0 Documentation FAQ #6.6 updated.

9 11/30/23 7.0 Conducting NSCHC FAQ #7.6 updated.

1.0 NSCHC Context

1.1 How have NSCHC requirements changed over time?

November 23, 2007, agency regulations have required recipients to perform the 

NSCHC on individuals who have recurring access to a vulnerable population. 

Vulnerable populations include children 17 years of age or younger, persons 

age 60 and older, or people with disabilities.

On October 1, 2009, agency statutes expanded the requirements to check any 

person receiving a living allowance, stipend, national service education award, 

or salary through a grant recipient receiving AmeriCorps funds, regardless of 

their level of contact with a vulnerable population.

On January 1, 2013, the agency issued regulations to fully implement the 2009 

statutory changes that required a fingerprint-based FBI criminal history check for 

those individuals in covered positions who have recurring access to vulnerable 

populations.

On February 24, 2021, AmeriCorps issued updated regulations to clarify and 

simplify NSCHC requirements. These regulations became effective May 1, 2021.

The rule also required that within 180 days of the effective date of the rule, any 

individual who continues in an NSCHC-required position must have an NSCHC 

that complies with the May 1, 2021 effective rule. That is, each person in a 
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NSCHC-required position who continues to work or serve on or after November 

1, 2021 must have a check that complies with the May 1, 2021 regulation.

1.2 Is a background check the same as an NSCHC?

No. Background checks can mean many different things and have many 

different components, many of which may not be relevant to the NSCHC. For 

example, credit reports and interviews with personal references are examples of 

background checks that are not relevant to the NSCHC. In addition, not all 

background checks include all the necessary components of the NSCHC.

1.3 Does NSCHC enforcement change? (Moved 11/1/21)

The NSCHC Guide to Enforcement Action has been updated and now is part of 

the NSCHC manual (no longer a standalone document). 

2.0 NSCHC Applicability 

2.1 I am told that my organization is not eligible to receive criminal history 

checks because we are clearing people for employment. What do I do? 

You should provide the following explanation: An NSCHC is required for a person 

to serve/work in an AmeriCorps grant program. It is not a check to approve 

employment. You may employ someone, but they may be prohibited from 

serving in an AmeriCorps grant program. Contact your Portfolio Manager

immediately if you are not permitted to conduct required checks.

2.2 How can we determine if a staff person or national service participant, in a 

fixed-amount grant with no budget or FFR, is required to get NSCHC?

All AmeriCorps state and national members who are over the age of 18 on the 

first day of service are required to obtain NSCHC.

Staff on fixed-amount grants are not required to obtain NSCHC. However, grant 

recipients are strongly encouraged to incorporate suitability screening and 

institute a holistic framework for safeguarding beneficiaries of service.

2.3 Are employers of partner organizations who supervise members or volunteers 

required to conduct NSCHC?

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

match, under a cost reimbursement grant are required to obtain NSCHC.

2.4 Do hourly-wage staff (i.e. not salaried) need to undergo the NSCHC? 

NSCHC requirements do not change based on whether an individual is paid 

hourly or salaried. A person who receives an hourly wage directly attributable to 

a NSCHC-required grant must obtain NSCHC.
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2.5 Should my program perform checks on people who are otherwise not 

required to have an NSCHC? Will my grant cover the cost? 

Your program may choose to conduct NSCHCs on people in positions that do 

not require NSCHC compliance as an effective first step in prevention and 

safeguarding. You may include this as a grant operating cost or volunteer 

support expense in your grant budget proposal. 

Please note that access to FBI checks through AmeriCorps approved vendor, 

Fieldprint, is limited to those individuals in positions that require NSCHC who are 

required by law to undergo a National Service Criminal History Check. 

2.6 Some of our employees have not been in positions that require NSCHC, but 

we conducted checks on them anyway, anticipating they might one day be 

assigned to such duties. Do we have to re-check them once they are officially 

assigned? 

If you performed a compliant check on or after November 23, 2007, there is no 

need to perform a new check when that person starts working in a NSCHCrequired position, as long as he or she has not had a break in employment since 

the check was performed. You are required to maintain the results of the check

and to adequately document dates the person starts working in a NSCHCrequired position. 

However, if you only conducted some of the required components described in 

the May 1, 2021 NSCHC rule, then you must supplement the pre-existing checks 

with the additional required components.

2.7 Our program design involves job training and job creation, and we pay 

wages to people who are in training and initial phases of gainful employment. 

Are these beneficiaries of the program required to comply with NSCHC?

No. Even though the beneficiaries receive a form of financial benefit as part of 

the program’s design rather than a program activity. A beneficiary who receives 

some financial benefit through a national service grant but who is not otherwise 

engaged in grant activities is not required to comply with NSCHC.

2.8 Why don’t the NSCHC rules cover community volunteers who are recruited 

by national service recipients?

The NSCHC applies to AmeriCorps State and National members, stipended 

Foster Grandparents, stipended Senior Companions and individuals in positions 

that will receive a salary, directly or reflected as match under cost 

reimbursement grants. Community volunteers do not receive this kind of 

compensation. 
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2.9 A former VISTA member has been selected for a position in our national 

service program for which an NSCHC is required. Do we need to conduct a new 

NSCHC on this individual? 

Yes, you must conduct a completely new NSCHC. The criminal history checks 

that AmeriCorps does for VISTA members are not transferable to grant recipient 

organizations to satisfy the NSCHC requirements.

2.10 What happens when an AmeriCorps Senior project relinquishes a grant and 

it is awarded to a replacement sponsor? 

The volunteers’ criminal history checks may be transferred to the new sponsor 

with the volunteer files. The new sponsor is not required to recheck the 

volunteers if those files are complete and compliant. However, they must ensure 

that the checks met applicable regulations and correct any noncompliance 

they identify in order to avoid enforcement remedies, including financial 

consequences. 

2.11 My organization has a State and National operational grant that is a fixed 

amount award. Is NSCHC required?

All AmeriCorps State and National members on AmeriCorps State and National 

operational grants are required to comply with NSCHC.

Only individuals in positions in which they will receive a salary, directly or 

reflected as match, under a cost-reimbursement grant are required to comply 

by NSCHC. Staff on fixed amount grant awards are not required to comply with 

NSCHC. 

2.12 Are financial or non-programmatic staff required to conduct NSCHC?

(Updated 4/16/21)

Staff on an NSCHC-required grant who are in a position in which they will 

receive a salary, directly or reflected as match, under a cost reimbursement 

grant are required to comply with NSCHC. Please refer to your budget to see if 

financial or non-programmatic staff are paid with direct and/or match funds. 

Staff whose activities are entirely covered in the indirect cost rate or cost 

allocation plan are not required to comply with NSCHC. Staff working on a fixed 

amount grant are not subject to the NSCHC requirements after May 1, 2021. 

2.13 Are RSVP advisory board members, who receives a stipend per county 

code, required to comply with NSCHC? (Updated 4/16/21)

Only staff on an NSCHC-required grant who are in a position in which they will 

receive a salary, directly or reflected as match, under a cost reimbursement 

grant are required to comply with NSCHC. 
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2.14 Do AmeriCorps member supervisors at host sites count as staff? (Updated 

4/16/21)

Only staff on an NSCHC-required grant who are in a position in which they will 

receive a salary, directly or reflected as match, under a cost reimbursement 

grant are required to comply with NSCHC

2.15 Are Commission Investment Fund (CIF) Grants and Commission Support 

Grants (CSG) required to comply with NSCHC? (Added 4/1/22)

NSCHC is not required for CIF and CSG. These grants are not considered 

operational grants referenced in 45 CFR § 2540.200 (a). The purpose of an 

operational grant is to fund an organization that is ready to establish, operate, 

or expand an AmeriCorps program. 42 U.S.C. §12638 (h) specifically prohibits 

State Commissions from operating AmeriCorps State and National programs. 

However, Commission staff do require NSCHC if they receive any part of their 

salary, directly or reflected as match, under a cost reimbursement grant that is 

required to comply with NSCHC under in 45 CFR § 2540.200.

3.0 Timing

3.1 Is the recipient program required to conduct a second NSCHC on an 

applicant who defers service for a year? 

Candidates who are selected and have cleared their NSCHC may defer or 

delay their start of service without undergoing a new NSCHC. Service delay or 

deferral is permitted for up to one (1) year, but the approved program design 

must include this option. The agency recommends that programs develop a 

written policy on how to handle NSCHC for people who defer service. 

3.2 Our program receives thousands of applications to serve. Performing 

NSCHCs on everyone who applies for a position or to serve can be very 

burdensome and expensive. Is there a better way to manage this workload? 

Your program’s NSCHC policy and procedures should identify at which point 

applicants are checked. However, please note that all checks 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 service

3.3 Does administrative leave, sick leave, summer breaks, or not actively 

working with a client constitute a break in service? 

No. A break in service means that a person is no longer working or serving in a 

position for which they receive an education award, AmeriCorps Seniors stipend 

or salary under an applicable agency grant.
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3.4 How far in advance of participation in a recipient program should we 

conduct the NSCHC? (Updated 4/16/21)

Recipients may start conducting the NSCHC from the point of application. A

check conducted as close as possible to start date will provide the most 

accurate information. The regulations require all checks 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.

If grant recipients are experiencing delays with their state repository, AmeriCorps 

approved vendors have an average turnaround time of two to five days, 

depending on the type of check and source. 

For candidates who are selected and have cleared their NSCHC may defer or 

delay their start of service without undergoing a new NSCHC. Service delay or 

deferral is permitted for up to one (1) year, but the approved program design 

must include this option. The agency recommends that programs develop a 

written policy on how to handle NSCHC for people who defer service. Programs 

should also include a memo to the file explaining the deferment.

Grant recipients may also choose to conduct supplemental checks or rechecks. 

Please note that all costs will be disallowed if the individual is ineligible to serve.

3.5 What if the results of NSCHC are still pending but the individual is scheduled 

to start service/work imminently?

The individual may not begin work/service while NSCHC results are still pending. 

The regulations require all checks 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 service.

Grant recipients may face enforcement remedies, including financial 

consequences, if grant recipients deviate from the requirements.

3.6 When must I supplement checks? 

If an individual is serving a consecutive term and turns 18 before the start of the 

subsequent term of service, NSCHC must be conducted. 

3.7 Do we have to conduct an NSCHC every year for each participant? 

No. The NSCHC is required only once for any person who applies to work or 

serve in an NSCHC-required position. 
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If the break in service or work is less than 180 days, then no additional NSCHC is 

required, if the original NSCHC checks are compliant with the NSCHC regulation 

effective May 1, 2021.

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

service, NSCHC is required. Refer to NSCHC Manual for additional information 

about breaks in service.

3.8 A break in service of less than 180 days does not require an NSCHC recheck. 

Does the 180 days refer to calendar or business days? (Updated 4/16/21)

180 days refers to 180 calendar days.

3.9 Is there a limit to how long leave for staff/member/volunteer can be before 

considering it a break in service? (Updated 4/16/21)

Leave should be defined in the grant recipient policies and procedures. 

3.10 Is furlough considered a break in work? (Updated 4/16/21)

If the staff person is still employed at the grant recipient, there is no break in 

work.

3.11 A member/volunteer or staff person moved unexpectedly during the past 

few months and there has been no break in service/work. Do I need to do a new 

state of residence check? (Moved 11/1/21)

A new state of residence check is not required as long as there has been no 

break in service/work. The regulations require a state of residence check at the 

time of application

3.12 Do checks need to be conducted again after a certain amount of time? 

(Updated 4/16/21)

NSCHC is required to be conducted before the start of service/work and needs

to be redone if the break in service is more than 180 days or if the individual turns 

18 before a subsequent term. Grant recipients may choose to reconduct 

checks after a certain amount of time and must maintain original checks and all 

documentation.

3.13 Can you confirm if NSCHC must be conducted, reviewed, and an eligibility 

determination made "before the start of work" or "the day before the start date"?

(Updated 4/16/21)

NSCHC should be completed, reviewed and an eligibility determination made

no later than the day before the start date. 
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4.0 Eligibility and Suitability 

4.1 What does it mean to be required to be listed on a sex offender registry? 

In some situations, a person may have been convicted of an offense and 

ordered by the court to register as a sex offender, but he or she did not register. 

Since the NSOPW check only identifies people who have registered, programs 

must also use candidate’s criminal history information to check for any offenses 

for which the candidate was required to register under state law but did not. 

Individuals who are required to be listed on sex offender registry are ineligible to 

serve/work on AmeriCorps grants. 

4.2 My program involves people with criminal histories. Is there anything 

additional that I must do? 

In situations where an ex-offender applies to serve or work, officials may take 

into consideration the type of service or program activity the applicant would 

do, the specific crime they committed, and the various supervisory levels that 

exist to manage the risks associated with an ex- offender’s participation in the 

program. However, murder and conviction of any offenses that require 

registration on a sex offender registry are disqualifying offenses without 

exception. Refer to the NSCHC Manual for additional information about nondisqualifying convictions and the federal reentry policy.

4.3 If we de-select a person for an AmeriCorps position based on criminal 

history, can we refill that position? 

The refill policy applies. Recipients should consult the guidance in the Terms and 

Conditions referencing re-fill policy and changes in member positions.

Please note that grant recipients must provide a reasonable opportunity for the 

applicant to review and challenge the factual accuracy of a NSCHC result 

before action is taken to exclude the person from the position. An organization’s 

NSCHC policies and procedures should describe actions required to document 

challenges and determinations to exclude persons from participating.

5.0 Budgeting NSCHC

5.1 The cost of conducting an NSCHC can be a financial burden for a recipient. 

Can AmeriCorps pay for these checks? (Updated 4/16/21)

Yes. 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 

Check. 

The total cost of conducting NSCHC is an allowable program operating cost 

(called a “volunteer support expense in AmeriCorps Senior programs) and 

should be included in the budget. Recipients should project all cost 
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components such as fingerprinting, notarization, mailing, and state repository 

and FBI fees. 

5.2 Are recipients allowed to use current year grant funds to pay NSCHC costs 

for members who will be enrolled in the next program year? If not, may 

recipients defer the costs and charge them to the new grant year (as budgeted) 

even if the expense was incurred prior to the project start date? 

NSCHC costs are allowable costs that are not required to be associated with a 

particular program year. The funds that a recipient has budgeted for checks are 

not limited to use during a particular period. They can be used to perform 

checks on any person in a position who needs the NSCHC at that moment in 

time. The costs are allocable to the recipient at that moment in time because 

checks are required upon application to serve/work. Waiting for a future budget 

to start the checks is not an option and incurring the cost today and posting it 

against a future date would be improper accounting. 

5.3 Programs cannot charge an applicant for the cost of conducting the NSCHC. 

Does this mean that we can’t charge an applicant and later reimburse him or 

her for this cost? 

Programs are permitted to ask a candidate to pay for the check(s), as long as 

the program reimburses the applicant for the cost of conducting the check(s). 

The person who is serving or working in the position that requires NSCHC may not 

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

Check. An organization’s NSCHC policies and procedures should describe the 

actions required for paying for checks and, if applicable, the actions required to 

reimburse a candidate for the cost of conducting the checks.

5.4 I’m a VISTA sponsor who receives a VISTA support or program grant. The 

“Grantee Share” column of my grant budget reflects staff salaries. Do I have to 

conduct an NSCHC for staff whose salaries are reflected solely on the “Grantee 

Share” column of the VISTA grant budget and paid entirely from non-AmeriCorps

funds? (Updated 1/31/23)

No, you don’t have do an NSCHC for staff whose salaries are reflected solely on 

the “Grantee Share” column of the VISTA grant budget and paid entirely from 

non-AmeriCorps funds. While VISTA sponsors are not required to include the 

grantee share of costs in their budgets, AmeriCorps understands it may help with 

internal recordkeeping. If you elect to do so and your budget includes staff 

salaries that are funded solely by the “Grantee Share” of costs, these costs are 

not subject to the NSCHC requirement.

5.4.1 I’m a recipient of a Public Health AmeriCorps grant. The “Grantee Share” 

column of my grant budget reflects staff salaries. Do I have to conduct an 

NSCHC for staff whose salaries are reflected solely on the “Grantee Share” 
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column of the grant budget and paid entirely from non-AmeriCorps funds? 

(Added 1/31/23)

Yes, if the staff will be performing activities in support of the project for which the 

Public Health AmeriCorps grant is provided, then you must conduct NSCHC for 

those staff, regardless of whether their salaries are reflected solely on the 

“Grantee Share” column of the grant budget and paid entirely from nonAmeriCorps funds. In addition to Public Health AmeriCorps grants, this answer 

applies to September 11 Day of Service, some AmeriCorps Seniors 

Demonstration Programs, and any other grant types that do not require 

matching contributions, apart from VISTA grants as noted in FAQ 5.4. 

Public Health AmeriCorps grantees and September 11 Day of Service grantees 

who had staff performing activities on the grant but did not conduct NSCHC for 

those staff in reliance on FAQ 5.4 that was in effect from November 18, 2022 to 

January 31, 2023 must conduct NSCHC for those staff and make an eligibility 

determination no later than March 10, 2023. 

5.5 Are staff on cost allocation plans required to comply with NSCHC? (Updated 

4/16/21)

No, a NSCHC is not required for staff whose activities is entirely included in the 

grant recipient’s cost allocation plan. Such staff will be treated similarly as staff 

whose activities are entirely included the grant recipients indirect cost rate and 

are exempt from complying with NSCHC. 

Central service cost allocation plan (cost allocation plans) means the 

documentation identifying, accumulating, and allocating or developing billing 

rates based on the allowable costs of services provided by a state, local 

government, or Indian tribe on a centralized basis to its departments and 

agencies. (2 CFR §200.9) 

Indirect cost rate proposal means the documentation prepared by a nonFederal entity to substantiate its request for the establishment of an indirect cost 

rate as described in appendices III through VII and appendix IX to 2 CFR part

200. (2 CFR § 200.1)

5.6 What is an allowable cost associated with NSCHC? What is included in 

NSCHC components? (Updated 4/16/21)

NSCHC cost components can include costs directly associated with obtaining or 

rechecking an NSCHC such as the cost of checks themselves, additional 

fingerprinting fees, postage, etc.

Grant recipients may pay for additional costs such as mileage and time for 

existing members/volunteers/staff as allowed by their grant budget and 

policies/procedures.
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Grant recipients may pay for additional costs such as mileage for applicants as 

allowed by their grant budget and policies/procedures. They may not pay for 

time as the applicant is not yet associated with the program. 

5.7 Who is required to pay for the NSCHC if the individual wants to challenge the 

factual accuracy of their results? (Updated 4/16/21)

The grant recipient may pay for costs associated with challenging the factual 

accuracy of NSCHC, as their budget allows and as noted in their policies and 

procedures. 

6.0 Documentation

6.1 May we retain only electronic records rather than paper files? 

There is no rule requiring criminal history check records to be paper based. You 

may save scanned images of criminal history check results and the associated 

documents, rather than paper documents. A program using an electronic 

record system should make sure that it meets all expectations for verifiable and 

auditable records. Given the critical nature of the date when the NSCHC was 

performed and when the individual began work or service, the program should 

make sure that any record – whether paper or electronic – clearly and without 

doubt establishes when the checks were performed, by whom, from what 

sources the information was obtained, and by whom the results were reviewed 

and considered in selecting the individual. Refer to the NSCHC Manual for 

additional information on NSCHC documentation requirements.

6.2 How should we store, secure, and file the results of the NSCHC? 

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

information relating to the criminal history check, consistent with authorization 

provided by the applicant.

NSCHC information should be maintained in a secure location under the control 

of an authorized records custodian. Only people who have an official need to 

review the information should have access to the records. An organization’s 

NSCHC policies and procedures should describe practices for safeguarding 

information related to NSCHC.

6.3 Must I store NSCHC records at the service site, or may I centralize the records 

at our headquarters? 

Records (electronic or hard copy) may be stored at any secure location, so long 

as they are accessible for timely routine use by the recipient, and for oversight 

and monitoring by AmeriCorps monitoring officials, without undue cost or delay.
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6.4 When do I need to take the NSCHC eCourse? (Updated 4/16/21)

AmeriCorps grant terms and conditions require grant recipients to retain the 

eCourse certificate of completion and assign staff to retake the course annually 

prior to the expiration of the certificate. Grant recipients should not allow their 

training certificate to expire and should ensure they complete the NSCHC 

eCourse that is available in Litmos.

6.5 Who can we share NSCHC results with? (Updated 4/16/21)

Grant recipients need to abide by the terms and conditions of the check you 

obtained, whether that is from AmeriCorps approved vendors Truescreen and 

Fieldprint or the state repository. Grant recipients need to take reasonable steps 

to protect the confidentiality of any information relating to the criminal history 

check, consistent with authorization provided by the applicant.

6.6 If state law prohibits sharing check results, what can I do to be compliant? 

(Updated 11/30/23)

The NSCHC rule requires you to maintain documentation of the National Service 

Criminal History Check as grant records. If you are unable to provide the check

results to AmeriCorps for monitoring because of state law:

• For checks conducted on or after January 1, 2020, you can use 

AmeriCorps approved vendors, Truescreen and Fieldprint, whose results 

can be shared with AmeriCorps. Any checks conducted on or after

January 1, 2020 cannot be deemed compliant if you are unable to share 

the results with AmeriCorps under state law and did not use the 

AmeriCorps approved vendors or obtain a waiver.

• For checks conducted prior to January 1, 2020, AmeriCorps previously 

issued a blanket Alternative Search Procedure (ASP) covering grantees 

that were prohibited by state law from maintaining or sharing criminal 

history results of the state and/or FBI check. That ASP expired on 

December 31, 2019 and covers checks conducted on or before that 

date. 

6.7 I am an AmeriCorps State and National grant recipient and I am using an 

approved Waiver or pre-approved Waiver. What date should I enter into the 

AmeriCorps portal when prompted to certify that I have completed NSCHC? 

(Updated 5/1/21)

Enter the date that you conducted, reviewed, and adjudicated the results of 

the checks required for the individual. 

Example 1: If you are using the Pre-Approved NFF Waiver, enter the date the 

required checks (NSOPW, non-NFF state (if applicable), FBI checks) were 

conducted, reviewed, and adjudicated. 
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Example 2: If you are using an approved waiver that modifies the timing 

requirement for the state and FBI check, enter the date the check that is

required to be completed before the individual begins work or service (NSOPW) 

was conducted, reviewed, and adjudicated.

Example 3: If you are using an approved waiver that modifies the timing 

requirement for the FBI check, enter the date the check(s) that are required to 

be completed before the individual begins work or service (NSOPW, State(s)) 

were conducted, reviewed, and adjudicated.

7.0 Conducting NSCHC

7.1 What name should be checked when conducting a name-based criminal 

history check? (Updated 4/29/21)

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. 

Grant recipients will need to detail in their policies and procedures how the 

current first and last name are determined when conducting a name-based 

check. AmeriCorps will review the policies, procedures, and documentation the 

grant recipient used. Refer to agency guidance on name-based checks in the 

NSCHC Manual.

7.2 Does a name change require a re-check? (Updated 4/16/21)

If a member/volunteer/staff person has legally changed their name during their 

term of service/employment, and there is no break in service/work, there is no 

requirement to recheck NSCHC. Grant recipients are encouraged to add a 

memo to file describing the situation for future oversight activities. 

7.3 Will there be changes to grant terms and conditions? (Updated 4/16/21)

AmeriCorps will update their grant terms and conditions per the usual cycle. 

Please note that the order of precedence in the relevant authorities is reflected 

in the terms and conditions, with the statutory and regulatory requirements 

given precedence over other sources of authority.

7.4 Do checks need to be conducted again after a certain amount of time?

(Updated 4/16/21)

NSCHC is required to be conducted before the start of service/work and need 

to be redone if the break in service is more than 180 days. Grant recipients may 

choose to reconduct checks after a certain amount of time and need maintain 

original checks and all documentation.
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7.5 What identifying information needs to be submitted for a transgender 

individual or an individual in transition? (Updated 4/29/21)

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. 

Grant recipients will need to detail in their policies and procedures how the 

current first and last name are determined when conducting a name-based 

check. AmeriCorps will review the policies, procedures, and documentation the 

grant recipient used. Refer to agency guidance on name-based checks in the 

NSCHC Manual.

Also, be sure to refer to your NSCHC source (state repository or AmeriCorps 

approved vendor Fieldprint) for additional instructions on what name and 

supporting documentation is required to conduct the check.

7.6 Can I use Identogo or other vendors? (Updated 11/30/23)

Grant recipients may use AmeriCorps approved vendors Truescreen and 

Fieldprint. If you are not using the approved vendors, you should go directly to 

the NSOPW.gov website and the designated state repository to ensure your 

checks are in compliance with NSCHC regulations. Some state repositories 

contract state and FBI checks to vendors and other FBI channelers. If the state 

repository directs you to use their contracted channeler or vendor, that source is 

allowable.

7.7 Where can I find FAQs related to the AmeriCorps-approved vendors 

Fieldprint and Truescreen? (Added 11/1/21)

Please refer to the Using AmeriCorps Approved Vendors Truescreen and 

Fieldprint Manual, found on https://americorps.gov/grantees-sponsors/historycheck. FAQs specific to the AmeriCorps-approved vendors have been moved 

to Using AmeriCorps Approved Vendors Truescreen and Fieldprint Manual as of 

November, 1, 2021.

7.7 Can a prime grant recipient conduct all the checks for subgrant recipients?

(Updated 4/16/21)

A prime grant recipient may conduct all subgrant recipient or may delegate the 

task to subrecipients. The policy and process should be clearly defined. 

7.8 Is it required to complete NSCHC components using either the AmeriCorpsapproved vendors Truescreen and Fieldprint or NSOPW.gov and the state 

repository, or may programs use a combination of these approved sources?

(Added 11/1/21)
17

Grant recipients may use any combination of AmeriCorps-approved sources to 

complete the NSCHC components. For example, it is acceptable to complete

the NSOPW check through NSOPW.gov, conduct required state checks through 

the designated state repositories, and use Fieldprint to complete the FBIfingerprint check. Regardless of the combination of approved sources used, 

grant recipients must complete and document each component required 

under the NSCHC Rule. Refer to NSCHC Manual for additional information about 

NSCHC Documentation.