ALTERNATIVE SEARCH PROCEDURE/PROCESS/PROTOCOL (ASP) Office on Volunteerism and Community Service

What is an ASP?  Substantially equivalent procedures or data requested if you wish to vary from any of the specific procedures for conducting background checks required by the regulations  In other words, getting permission before doing something different from what laid out in guidance

Why would you request one?  If you have a substantive part of your process that doesn’t match the OVCS 4-part background check guidance  Ex. Organization cannot maintain actual results because of state law, or part of organization conducting the check cannot allow for documents to be reviewed by CNCS/OVCS.

Not valid reasons to request an ASP  Your organization does background checks that aren’t 4-part checks, and you want to keep them all the same  Ex., just because you currently don’t do FBI checks for all of your volunteers and staff isn’t a valid reason to not do them for this program  You don’t want to do NSOPR checks  You MUST do NSOPR checks  It takes too long  It is important to start early and is definitely more burdensome if you don’t Typically needs to be a statutory reason, or a clearly better plan that still meets all requirements

Preparing a Request  Research the regulations and consult with OVCS about the need for an ASP  If procedures are different, but meet or exceed requirements, you may not need an ASP

Preparing a Request, Cont. Items to Prepare for Submittal Include:  An explanation of why you are requesting approval to use an alternative criminal history search. If prohibited by state law, attach a copy of the statute or prohibition along with any available legal analysis.  A description of what process/system you plan to use to verify the identity of the person whose criminal history is under review. You may attach your policies and procedures if the description is contained therein.  A description of the alternative process/system you plan to use to conduct a criminal history check. You may attach your criminal history check policy and procedures in lieu of a description if the description is contained therein.

Submitting your ASP By  Submit to your OVCS Program Officer  In the subject line, use “Alternative Criminal History Search Request”

What to include (from Page 8 of OVCS 4-part background check guidance) A Cover Letter that Includes:  Legal Applicant Name  Name of your Program(s)  Grant Number(s) that would be impacted  Individual to contact for further information (name, address, & telephone)  Detailed reasons for request from Slide 6

Key Points/Elements  Try to adhere to OVCS 4-part background check guidance. If you can’t:  Immediately work with your Program Officer  Thoroughly research and document why an ASP is necessary, and how your plan will meet or exceed requirements  Make your request as soon as possible This process will take at least a month, and sometimes much longer!