General Policy and Miscellaneous - Cloud Object … Notice... · Web viewPosition Descriptions7 Background Check Process7 Temporary/Summer/Teen Employees9 Volunteers10 Installation

Post CNIC 1700 Notice Q&A, 10 MAY 2016

CNIC Notice 1700 is an interim policy while we implement the Central Suitability Office (CSO). By December 2016, we plan to have a full CNIC Instruction published, which will include the new responsibilities of the CSO. The following document outlines questions and answers concerning the interim policy published in CNIC Notice 1700. CSO will continue to update as questions are asked and answered.

Contents

General Policy and Miscellaneous...............................................................................................................2

Statement of Admissions Form...................................................................................................................4

Roles and Responsibilities...........................................................................................................................5

Documentation and Retention....................................................................................................................5

Position Descriptions...................................................................................................................................7

Background Check Process..........................................................................................................................7

Temporary/Summer/Teen Employees........................................................................................................9

Volunteers.................................................................................................................................................10

Installation Records Check (IRC)................................................................................................................13

CDH Providers............................................................................................................................................14

Contractors................................................................................................................................................15

CYMS.........................................................................................................................................................16

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General Policy and Miscellaneous

Q: When do I follow the Notice and when do I follow an operating manual? Does the date an OM was published make a difference?

A: It is important to always follow policy directives (DOD Instruction, OPNAV Instruction, CNIC Notice, etc.), regardless of the publishing date of an operating manual.

Q: How can I find the notice on the Elibrary?

A: The CNIC Notice 1700 is available on the Elibrary here. We will work to make sure that the tags are updated so that the Notice, and any further guidance, are easy to locate.

Q: According to CNIC Notice 1700, there is to be a 100% check on CYP files at the program, in the personnel folder, and at the Security Office. Is there specific guidance or a checklist on how to do this?

A: The CSO is currently developing specific guidance for performing a Background Check MDTI. All parties will be notified as soon as the guidance is available.

Q: When is guidance for CNICNOTE 1700 going to be promulgated?

A: The Central Suitability Office will be conducting 3 webinars during the month of February to go over CNIC Notice 1700, Q&A we've compiled since its release, and any questions that the Regions or Installations may have. We highly suggest participating in the webinars so that your installation specific questions are represented. Additionally, the CSO will be releasing Standard Operating Procedures for supplemental guidance.

Q: What is a CNACI?

A: CNACI stands for Child Care National Agency Check with Inquiries and is the OPM background investigation used to determine an individual’s suitability for a child care position. The scope of the CNACI includes the basic National Agency Check with Written Inquiries (NACI) and State Criminal History Repository (SCHR) checks for all states of residence. The NACI consists of a basic and minimum investigation consisting of a National Agency Check (NAC) with written inquiries and searches of records (e.g. Interstate Identification Index, Sex Offender Registry, etc.) covering specific areas of an individual’s background during the past five years, including a Federal Bureau of Investigations (FBI) fingerprint check of criminal history records, prior employment, education, schools of record, references, local law enforcement records, credit checks, immigration and naturalization service (if foreign born), and other sources. As part of a CNACI, the FBI National Criminal Information Center and FBI National Name Check Program databases are also checked.

Q: Are we going to be implementing the Advanced Fingerprint Check and how (if at all) would this speed up the process for CDH Providers getting cleared to operate?

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A: Yes, the CSO is currently identifying how the Advanced Fingerprint Check will be implemented.

Q: Can old dates be deleted from CYMS as long as there are current initiated and completed dates and next due dates?

A: Old dates that are incorrect should be updated. Historic data from previous NACIs/investigations, when correct, should not be removed. However, duplicative lines can be deleted.

Q: Do you want a note in CYMS in the Military Member Security Check that says how long their clearance is for (5, 7, or 10 years)?

A: This is not required as an audit point, however, entering this information in the comments/notes section in CYMS is a recommended best practice.

Q: Is it required that our programs add Military Family Life Consultants (MFLCs) background check data into CYMS (much like how we do for Camp Adventure)?

A: ALL CYP Personnel should be in CYMS. If the MFLC are supporting CYP then they should be in CYMS.

Q: To follow up with the MFLC question, do they come to CYP already cleared? If they are cleared when we get them, who would we get their clearance dates from?

A: Yes; they should be cleared when they arrive. However, all personnel should check in with the Security Manager because the clearance needs to be validated by the person on the Responsibility Ledger. That would be the time you would identify any issues/challenges with them being 'cleared'. There is always a risk that something happens along the way and by in-processing, the Security Manager can validate that they have a favorably adjudicated CNACI.

They get their clearances through a central effort at OSD (right now the army is supporting this effort).

Q: I have a question regarding Adjudication Training. In your future guidance/instructions, are you going to require that the Security Managers take the adjudicator's training as long as they follow OPNAV and CNICNOTE for local adjudication?

A: Beginning 31 May 2016 the Central Suitability Office (CSO) will serve as the delegated authority to make suitability adjudications and provide guidance to the field on local suitability determinations as necessary. Once the full CNIC Instruction is published the roles/responsibilities of CSO and action officers will be outlined.

Under title 5, Code of Federal Regulations, part 731 (5 CFR 731) OPM and agencies with delegated authority, can make suitability determinations and take suitability actions. Per OPM, the two week Essentials of Suitability Adjudication Program (ESAP) is accredited through the Federal Law Enforcement Training Accreditation (FLETA) and is compliant with the National Suitability Adjudicator Training Standards. ESAP certification authorizes personnel to make or approve suitability adjudications; this is falls into the CSO security officer requirements/responsibilities.

The Center for Development of Security Excellence (CDSE) offers a free alternative online suitability education/training course that is sufficient in preparing action officers who are designated in writing by

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the Region or installation commander to assist with carrying out suitability adjudications. Additionally there is also a 3-day suitability education/training course offered by the Graduate School-at a cost. Please see the attached for detailed information on both.

Statement of Admissions Form

Q: Should the DD2981 form be used in place of CNIC CYP 1700/09?

A: Yes. Per CNIC Notice 1700, effective 8 January 2016, the DD Form 2981 should be used in place of CNIC CYP form 1700/09. For inspection purposes, the CNIC CYP form 1700/09 will be accepted for Statement of Admissions completed for the 2016 calendar year. However, please begin implementing DD Form 2981 immediately.

To avoid confusion, the CNIC CYP 1700/09 form has been removed from the E-Library.

Q: How often is the DD Form 2981 to be completed?

A: The DD 2981 must be certified annually so that individuals working with children may self-admit any automatic or presumptive qualifiers. The form will also be completed every five years as part of the reinvestigation process, regardless of the date the yearly certification was signed.

Q: On the DD2981, block 9, there is a double-negative that makes the question confusing for applicants as well as those administering the form. How should we handle this issue?

A: You are correct that there is a confusing double-negative in block 9. The question asks, "In the past year, I have not been arrested, charged, or held by law enforcement in regard to anything mentioned in block 8 above." If the individual answers "yes," then they are to explain their answer in the space provided, which doesn't make sense given the mistake in block 9.

First, the intent of this question is to find out if the person has indeed been arrested/charged/held for any of the offenses outlined in block 8. A "yes" answer is meant to confirm such activity. Those who administer the form should direct users to cross out NOT in block 9: "In the past year, I have [not] been arrested." Thus, if the individual marks "yes," it now makes sense for them to explain with specifics of their arrest/charge.

Second, this issue was brought to the DoD Manual working group meeting on 21 Jan. They are aware of the error and are working to revise the form. Unfortunately, the approval process for form edits is quite lengthy, so we must deal with the inconsistency of the form in the interim. We understand that manually editing the form isn't an optimal solution and will inform you as soon as the form updates have been completed through the DoD process.

Q: Who signs the Annual Certifications section in blocks 9a-9e?

A: Because this is a self-admission statement, the individual in child care service would sign and date the form. The initial date and signature would be in block 9a. Then each consecutive year, the individual would again sign and date in blocks 9b through 9e.

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Q: Does a Statement of Admission have to be completed for children 12 and older? Or is that only for 18 and older?

A: The DD-2981 is currently required annually for providers and family members ages 18 and older. (This requirement may change with the future CNIC Instruction, but these are the current inspection requirements.)

Roles and Responsibilities

Q: Can you clarify the Region Commanders Responsibilities found in paragraph 6b of the Notice?

A: REGCOMs will provide oversight to ensure compliance, manpower necessary to support the effort at the installation level, and guidance on suitability decisions once a recommendation has been made. For OCONUS regions, the foreign background check equivalency ledger (Enclosure 3 of the Notice) is a priority. REGCOMs should work to identify these, along with the associated action officers, and provide the completed ledger to Child and Youth Programs (CYP) HQ.

Documentation and Retention

Q: The Notice states: Installation Human Resource Officer (HRO) must maintain the background check records in the OPF for all CYP employees selected for positions that involve working with children under the age of 18 for 2 years following termination of their service in accordance with reference (e) and enclosure (1). Is the HRO required to maintain provider files as well?

A: No, the HRO is not required to maintain provider files as well. At the installation, the Child Development Home (CDH) Monitor, CDH Director, or the CYP Director for a very small program would be responsible for retaining the provider files.

However, per the HR RAB meeting on 3/29/16, the HRO is now required to support the initiation of the provider background checks.

Q: Who has the identified responsibility for maintaining documentation on completed background checks for those outside CYP?

A: NAF HR should maintain the documentation on completed background checks for employees outside CYP in the employee's Official Personnel File (OPF) (Morale and Welfare (MW), Fleet and Family Support Center (FFSC), etc.) and APF HR (via Defense Civilian Personnel Data System (DCPDS)/eOPF).

Q: Concerning two-year background check documentation retention, does this mean to maintain the email from the process owner, or the background check findings? A: Document retention applies to both the emails and background check documentation. The emails from the Action Officer(s) should be kept in the designated file by both the HR Manager and Installation CYP. Background check documentation (outlined in Enclosure 1, 8b) should be kept in the HR OPF.

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Q: What is the policy for retaining an OPF after an employee separates?

A: The information is required to be maintained in both the CYP employee folder (with no Personally Identifiable Information (PII)) and OPF and unfortunately, you will have to provide the guidance to retain longer than the standard HR requirement of 6 months. Documentation Retention was an audit readiness concern. The two years was provided in response to NAVAUDSVC and that is the new CNIC / Navy requirement for background check documentation for all individuals working with Children (greater than CYP). This is the interim solution as we work to stand up the CSO. Once this is in place, the CSO will maintain the retention for audit readiness and serve as the single location for processing review.

Q: Is the HRO still required to use the CYP Background Clearance Form for this requirement or has/will this form be discontinued if email documentation will suffice?

A: The CYP Background Clearance Form should still be used for now. The emails are confirmations from the action officers, and should also be held / retained in both the OPF and the CYP Employee file.

Q: Are the supervisor's personnel files standardized across the Navy in the way that employee staff files are to be set up to include the documentation required in the file?

A: The CSO had a team meeting with HR to help standardize this process across the enterprise. When the CSO reaches full operating capacity, this requirement will be removed from CYP, as the CSO will be the central audit point. The OPF, however, will still be in place with HR.

Q: Who is responsible for maintaining documentation of non-CYP contractor background checks?

A: Once the CSO is at full operating capacity it will maintain all background check documentation. A solution for the interim is still under development and all parties will be notified as soon as the guidance is available.

Q: What background check paperwork from the Action Officers is required in the CYP folder? For example, for a FAP check?

A: According to the CNIC Notice 1700, all that is needed in the CYP file for IRCs is a memo (signed by the appropriate Action Officer listed in the ledger for the assigned check) that says the date the check was run and noting it as favorable. Because we've had issues getting installations into compliance, we noted in the Q&A that an encrypted email from the Action Officer is also acceptable to place in the folder, provided that it gives the date run and notes it as favorable.

If the person running the checks is doing more than one at a time, he/she can send an encrypted email with multiple individuals' listings (with dates run and noted favorable). This email can be placed in each person's CYP folder and will serve as the Action Officer Memo for that check.

If the issue is timing of the emails, then yes, the form signed by the person doing the check is also fine. Again, that is assuming it is signed by the Action Officer listed in the ledger, notes the date the check was run, and notes the favorable determination. Those are the key data points for the folder, regardless of format.

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Q: The SARP office uses their own form to complete the check, however, it contains PII. Is it okay if the HR Assistant makes a copy of the form, blacks out the PII, and sends the form to the Director for their files?

A: Appreciate that you are keeping PII out of the CYP folders. Yes, that would be fine, as long as you comply with the previous answer and the CYP folder requirements for each check: signed by the action officer, date the check was run, and favorable determination.

Position Descriptions

Q: HR raised the issue that many of the position descriptions (PD) of those outside CYP do not state that background checks are required.

A: PDs will have to be updated so that everyone with regular contact with children gets the appropriate background check per the Notice. We are currently in the process of identifying the requirement for other individuals who have “regular contact” to be incorporated as part of the CNIC Instruction.

Background Check Process

Q: We have stopped letting new staff begin work until the Child Care National Agency Check with Inquiries (CNACI) is initiated. Initiation from the Security Manager to the Office of Personnel Management (OPM) has been taking more than the 10 day requirement.

A: Make notes in Child and Youth Management System (CYMS) of when items were provided to the Security Manager and when they were sent to OPM to create a record of the timeline. As we fully implement the Central Suitability Office over the next few months, these issues will be ironed out.

Q: There have been a few new staff selections with open NACI investigations. Now that they have been selected for a CYP position, they need the additional coverage of a CNACI. Do we have to wait until the original NACI closes to initiate a CNACI?

A: The Security Manager should be able to call OPM about an open investigation and put in an upgrade request saying the subject requires additional verification. In this case, requesting the extra coverage code "8" in block "B". We shouldn't have to wait until the NACI results come back. If that is impossible, instead of initiating a full CNACI after the NACI comes back, they can initiate a Special Agreement Check (SAC) which includes just the childcare-specific portions of the CNACI (FBI fingerprint check plus SCHR plus National Sex Offender Registry).

Q: CYMS shows five closed CNACIs that are not yet adjudicated. We are still waiting on results not completed in 120 days.

A: Generally a closed investigation with no adjudication means that either DoD Central Adjudication Facility (DoDCAF) is still processing the investigation results or that local adjudication is required but no notification has been provided. One option is for the security manager to request the file for local adjudication from DODCAF if there has been no change in status for an extended period of time. There is

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also an option in JPAS for the security manager to submit an "RRU (Recertify Research Upgrade) request". This is a way to communicate with the CAF to make requests and/or check adjudication status.

Everyone is measured against the same 120-day criteria and is facing the same issues. The best way to resolve this long term is to maintain complete and accurate records in CYMS that will help the CSO to justify a change to the criteria and/or changes to how OPM and DoDCAF process CNACIs.

Q: SAC agreements sent by the security manager have been returned to sender, now what?

A: The Security Manager should call OPM to resolve the issue. The CSO is working now to hire Security Managers. Once onboard, they can reach out to the Installation Security Manager directly and work through investigation issues.

Q: We are requesting updates on the background investigation results from the Security Officer every two weeks. They report that it is taking a long time for states to process the SCHRs, and they are getting a backlog.

A: States have 60 days to return the SCHRs. Make sure that you are updating the comments field in CYMS to include the submitted date (the date that the Security Officer sent the background check package to OPM). Also, the CYMS comments field should always reflect any delays in the clearance process. In this example, you would input: “Delays in processing due to Security Officer backlog.”

Q: For 5-year reinvestigations, does the individual need to complete another OF-306?

A: No, but they will need an updated eQIP package, which includes a resume, fingerprints, and an updated SF-85.

Q: Do I treat my instructor just like my staff and do the CNACI /IRC every 5 years, or am I to follow the guidance in the YSF manual?

A: Yes, instructors are required to complete a CNACI/IRC every 5 years in accordance with CNICNOTE 1700. The YSF OM will be updated to reflect the most recent guidance.

Q: How can you fast track background checks to support staff working programs with extended hours?

A: Unfortunately, there is no way to fast track a background check. As the CSO is in place, we will reduce and gain efficiencies with the internal timelines, but the external processing timeline will most likely remain 90-120 days. Encourage you to ensure CYMS information is reflective of the processing timelines and any items returned to the Security Manager/HR (via notes in Comments field). Cases that are taking longer than 120 days processing at OPM should be reviewed with your Security Manager/HR and elevated for review with DoDCAF/OPM as necessary. Please feel free to reach out to CSO for interim support on any extraordinary cases.

Q: What is the normal timeline for a Security Offer to send the background check package to OPM and to get the results? As a Director, when should I start calling the Security Officer to see if there’s a problem?

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A: It takes between 5-10 days for OPM submission, but we encourage you to discuss this with the Security Manager. In the next few months, the CSO will be taking over this function. We will be publishing a CYP Background Check SOP that will outline all of the steps involved in completing a background check including a corresponding timeline for each step and contact information for any questions and/or concerns about the process.

For CNACI results, we encourage you to wait 90 days after submission before reaching out to the Security Manager. Again, communication with the Security Manager is key, as some installations have a tracking system for this function. The CSO will eventually take over this function as well.

Q: Does this timeline apply to our OCONUS foreign national employees as well?

A: Per CNIC Notice 1700, Region Commanders of OCONUS locations will complete the foreign national background equivalency ledger to identify checks equivalent to those required at CONUS locations. Local installations will be coordinating these checks. The timeline for completion of this comparable check, will depend on the specific set of circumstances faced by each OCONUS location.

Q: A CYP Manager had an investigation in 2009, and her secret clearance is good for 10 years. What must be done for a reinvestigation at the 5 year mark? Is it the same as the answer for active duty volunteers? Is it only a "JPAS check" that must be done at the 5 year point, and if so, what exactly is a "JPAS check" and how is it documented by the Security Manager? Is there a screen they print off as proof or do they just provide an email that says they looked at JPAS and Mary is still current? Do they have to run a SAC to get the verification?

A: The scenario is slightly different for CYP Employees. At the 5 year point, they will need a SAC (OFI86C) with new fingerprints to add the Child Care portion of the check as well as updated IRCs. If the check is late, she should remain in red until the Favorable IRCs, Fingerprint and SAC is returned.

For active duty volunteers, the Security manager would provide an email with the clearance information to the Volunteer Coordinator and they would use the Volunteer Active Duty code in CYMS to enter the dates provided at the 5 year point with 5 years or when the Existing Clearance will expire as the Due Date (whichever is sooner).

Please note that printing JPAS screens is prohibited by DoD.

Temporary/Summer/Teen Employees

Q: Can you speak on temporary employees (returning seasonal employees) and how they can keep their clearance so they can be brought back during the holidays?

A: One alternative to reduce the processing time for seasonal employees would be for them to stay on board as a flex employee. This would allow for an individual to ensure there is no break in service. The existing CNACI background check should be validated in JPAS, and a new IRC should be completed when they return. This would also reduce onboarding timelines.

Q: For summer hires, it would be difficult to have a CNACI completed before the summer is over.

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A: We recommend that you work to identify any managers that will work with summer hires under the age of 18 well in advance. For example, if you know you will be hiring teen lifeguards for the summer months, begin to identify the supervisors in January / February timeframe. That way the CNACI can be processed in time.

Q: Do Teen Employment Program supervisors working directly with teen employees require a childcare suitability clearance? For instance, the Aquatics Director is a Teen Employment supervisor with a teen employee working at the pool. Does the Aquatics Director require all components of the suitability check (IRC, CNACI)?

A: Yes. Per DODI 1402.05 and CNIC Notice 1700, an IRC, and a CNACI are required for any individual whose duties require “regular contact with children under 18 years of age”.

Q: Can Camp Adventure employees be cleared with a letter from their previous Security Officer regarding a current CNACI investigation?

A: No. First, the Camp A employee must in-process with the current installation Security Officer. Their file must contain an email/memo from the Action Officer in the Responsibility Ledger showing favorable adjudication. If they have a current investigation, the Action Officer will check this information in JPAS and make a note of the favorable adjudication date on the email/memo sent to the program.

Volunteers

Q: How do we define “over a period of time” for specified volunteers and “shorter in duration” for non-specified?

A: We are currently working to define "regular contact" for volunteers that will include frequency and duration of contact. This will be outlined in the CNIC Instruction. However, 90-days should not be the benchmark for designating volunteers specified vs. non-specified. In Enclosure 1 of the Notice, 12. d. 2., the examples of shorter duration are "one-day class trip or class party". The concern is that regardless of the amount of time, a non-cleared individual should not be alone with a child without LOSS.

Q: What background checks are needed for volunteers who want to volunteer in the CDCs? And which office is responsible for initiating/completing them?

A: Specified volunteers (those who are alone with, or have regular contact with children) are required to successfully complete an IRC, FBI Advanced Electronic Fingerprint Check and a CNACI. Non-specified volunteers are required to successfully complete an IRC only. Non-specified volunteers may operate under LOSS of a cleared individual. Each background checks has been assigned an action officer by the Installation Commander. These action officers are responsible for the initiation and completion of their assigned background check.

Q: We have problems with coaches. Sometimes we are recruiting up until the last minute, especially for Assistant Coaches. If we have a CYP employee attending the practices and games, is it okay for the Asst. coaches to start helping before their background check is completed?

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A: Yes. All individuals who have not completed their CNACI investigation can work under Line of Sight Supervision (LOSS). To be eligible to work under LOSS, an individual must successfully complete the IRC.

Q: Some of our coaches volunteer for a few months, and then don't coach again until the following year. How long are the investigations good for?

A: A favorable CNACI is good for 5 years. IRCs must be re-run if there is a break in volunteer service (i.e., a period greater than 6 months).

Q: In CYMS we are only putting in active volunteers. Is this correct? Is it required to still input everything into NAYS also?

A: Correct, please place your CURRENT specified and non-specified volunteers’ background check and training information in CYMS. Also, if you know of any coaches/officials that are returning, you can place them in CYMS now, or you can wait until that specific season begins. Lastly, programs are NOT required to update their coaches'/officials' training or background check information in the NAYS Chapter Management Website any longer. NAYS will simply be the vehicle to initiate the required training (e.g. NYSCA, NYSOA) for coaches and officials. Lastly, NAYS is leaving the platform as is for now. At a later date, the training and background check fields in NAYS will be turned off, but CYP HQ is waiting a little longer so people can transfer the information to CYMS.

Q: In CYMS are they ever going to add a volunteer management tab so volunteers can be separate from CYP staff?

A: Yes, when establishing a volunteer CYMS file, programs will need to select "Volunteer" in the classification field and also select the applicable volunteer code or job title:- VOL-SP - Volunteer Specified,- VOL-NOSP - Volunteer Non-Specified, or- VOL-SPAD - Volunteer Specified-Active Duty.

When adding a Staff file for a Volunteer on the Core Information Screen:

1. 'Volunteer' must be selected for the 'Classification' field (drop down, right below the Staff ID)

2. A Volunteer code must be selected for the 'Job Title' field (right-click the 'Job Title' field to launch the 'Staff Job Title Code Picklist' pop-up window, press 'V' on your keyboard, then select appropriate Volunteer code).

3. Friendly Reminder - The Training section does have Volunteer specific training codes.

Q: What date should we enter into CYMS to verify the clearances of active duty military volunteers and how?

Volunteers who are active duty military need to have their clearance verified as active by the Installation/Region Security Manager (through a Joint Personnel Adjudication System (JPAS) check). The

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person responsible for the JPAS check can be found on the Installation’s Background Check Screenings Action Officer Responsibility Ledger under “Completed CNACI Final Results Review”.

The following date from the Responsibility Ledger Action Officer memos must be logged into CYMS: dates of JPAS verification checks (using the Military Member Security Check (MMSC) code).

The Military Member Security Check is now available in all CYMS databases, including Volunteer Specified-Active Duty, appearing as the following:

NACLC - MilitaryMemberSecurityCheck (VOL-SPAD)

Q: We are not able to conduct SACs on volunteers due to not having access to that information. This is a base issue that is out of our control. We are able to check NACIs though. Is it okay to have the NACI but not the SAC?

A: The Special Agreement Check (SAC) is no longer necessary for specified or non-specified volunteers. Specified volunteers are required to undergo an IRC and a CNACI. Non-specified volunteers are required to undergo an IRC.

Q: My biggest problem is ultimately that most of my coaches only volunteer for one season since they are here on deployment (6-9 months). I have very few (if any) parent volunteers. My sports seasons are 10 weeks in length, so how do I classify these volunteers?

A: If most of your volunteers are active duty and have existing clearances, you would need to validate their clearance with you Security Manager and run an IRC. Once favorable results are returned, they could then function outside of line of sight supervision (LOSS).

Q: My active duty volunteers have current IRCs and current security clearances; however the security clearance is more than 5 years old. My understanding is a security clearance is good for 10 yrs. Am I just verifying every 5 years that the clearance is still current, or do I need to do a CNACI or other check since it is more than 5 years old?

A: In addition to completing a new IRC, active duty volunteers only need to have their clearance verified every 5 years by the Installation/Region Security Manager (through a JPAS check), regardless of the age of the security clearance. Only at such time that their clearance is no longer current will a CNACI be required.

Q: If a civilian volunteer has a clearance, does a CNACI check have to be completed as well? Or is the equivalency only for Active duty volunteers?

A: The DoDI does not give guidance for this type of individual, but it will be addressed in the upcoming CNIC Instruction to be released no later than December 2016. For now, treat them like you would any other civilian using the categories of non-specified and specified volunteers.

Q: We have a rule that we need to have a staff member with a favorable CNACI at all practices. Does this mean that a coach only needs an IRC and can operate under line of sight supervision (LOSS)?

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A: Yes. If volunteers (unspecified) have had a favorable IRC completed and have completed the DD-2981, they may operate under LOSS of a cleared individual.

Q: If we have minors volunteering with our Youth Sports program (officiating, time keeping, etc.) do we have to have IRCs on them? These are teens that most times are actually registered users of our teen program. Same question in reference to minors on contracts. We frequently put high school kids on contract for officiating, time keeping, etc.

A: All minors between ages of 12-17 (regardless if volunteering or on a contract), must have IRCs and be under LOSS when functioning in our (CNIC) programs where other minor children are located.

Q: We have a volunteer that helps out at only one CDH home a couple times a week. She has all background checks completed. How should we input her into CYMS?

A: She should be put into CYMS as a family member (as she will need all the same checks completed as a family member) with a note in the comments field that she is the CDH Volunteer. Right now the volunteer option is not turned on in CYMS. We do not want to put her into the system as a volunteer because we could lose visibility of her requirement / timeline, which is different than other CYP specified volunteers. In this approach, she is subject to all the same family member over 18 requirements in the home and we need to track her like those action items (background checks) are being completed iaw prescribed policies and timelines.

Installation Records Check (IRC)

Q: Who completes the NCIC check?

A: N-3. Many installations use the SECNAV5512 form.

Q: Is a NCIC check different than a CLEOC check?

A: Yes. The National Crime Information Center (NCIC) is the United States’ central database for crime related information and is maintained by Federal Bureau of Investigation (FBI). The NCIC is most commonly used for local law enforcement checks. The Naval Criminal Investigative Service (NCIS) Consolidated Law Enforcement Operations Center (CLEOC) consists of Navy-wide searches for information access control data, functions as the Pass and ID, Law Enforcement Desk Journal, and Comm log Navy-wide, and compares the access control list against the Terrorist Watch List. The NCIS CLEOC is most commonly used for Navy base checks.

Q: Who administers the IRC for active duty personnel that volunteer with children temporarily for the summer?

A: The same Action Officer identified on the installation’s Action Officer Responsibility Ledger for each IRC check is responsible for its completion, regardless of the type of individual.

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Q: The CNIC Notice does not have any ages listed to tell us who receives IRC checks. Would this be a requirement for individuals ages 12-17 as in the OPNAV?

A: Yes; the intention is to run IRCs for Family members 12 or older.

Q: When should IRCs be initiated for annual recertification? Should they be initiated within 30 days of CDH Certification date expiring or 30 days priors to anniversary of the actual IRC check?

A: Within 30 days of the anniversary of the actual IRC check.

Q: For children of providers 12-17, what form should be used to get permission to conduct IRCs on minors?

A: For now, have parents sign the release form for minors (12-17) and make a note that they are the parent or guardian signing on behalf of the child. We are currently in the process of redesigning the IRC release form and we have taken this comment for action.

Q: Does the Local Law Enforcement Check only need to be run for providers and family members over the age of 18 with no prior DoD affiliation? And for Initial Certification only?

A: Providers and family members 18 years of age or older who are not active duty military and have no prior or current Department of Defense (DoD) affiliation will need to receive a favorable Local Law Enforcement Agency Check (LEAC). DoD affiliated personnel will receive a full Installation Records check (IRC).

The LEAC requirement would be for initial certification only, as at yearly re-certification, individuals would be DoD affiliated and would receive a full IRC.

CDH Providers

Q: How do we handle the family background checks when the provider is cleared but the spouse is deployed?

A: Work with the deployed individual at their location. Their command can send the release forms for the IRC.

Q: I have an active provider with a 10 year clearance. The provider's husband is active duty and also has this 10 year clearance. Is the provider required to get a CNACI? I do understand there are some differences between the checks, just not sure if it is enough to have her get a CNACI.

A: As a Provider with an active security clearance, they would need to get a Fingerprint SAC (for child care check) and an IRC (with confirmation from the Security Manager that the clearance is still active).

Q: If the provider is no longer active reserve and the clearance is no longer active, then the program would initiate a NACI?

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A: Yes; if at any time the provider no longer has the Clearance (based on the JPAS) review, the individual will need to do the necessary background investigation for working with children (CNACI- which is a NACI - Tier1 investigation with child care Suitability).

Q: We have two related questions dealing with military members who deploy prior to annual recertification:

a. Can the SAC be filled out prior to the member deploying and then submitted closer to the actual 'due date'? I ask because there are many members who may be deployed 9 months or more in advance of when the next check is due.

b. Another scenario- the military members who are deployed on short notice (i.e. two day notice or less) would not have time to initiated the SAC prior to deployment. What do you recommend is the guidance for this scenario?

A: We can work these situations on a case-by-case basis. For these scenarios, we would complete the JPAS check, and if possible, work with the member for the SAC. If it is not logistically possible while deployed, the SAC will be completed as soon as the military member returns home.

Q: When should IRCs be initiated for annual recertification? Should they be initiated within 30 days of CDH Certification date expiring or 30 days priors to anniversary of the actual IRC check?

A: Within 30 days of the anniversary of the actual IRC check.

Q: For children of providers 12-17, what form should be used to get permission to conduct IRCs on minors? Previously the 'old' 1700/09 SOA had space for the provider to add family members and authorize these checks. What do you recommend programs do now?

A: IRC release forms: For now, have parents sign the release form for minors (12-17) and make a note that they are the parent or guardian signing on behalf of the child. We are currently in the process of redesigning the IRC release form and we have taken this comment for action.

For the DD 2981: Parents should sign the release form for minors (12-17) and make a note that they are the parent or guardian signing on behalf of the child.

Q: What is the definition of 'initiate'? Is it the date that the program requests the IRC from the responsible action officer or is it the date that the action offer actually begins the investigation?

A: The initiation date for the IRC (recorded as “open date” in CYMS) would be the date the IRC request was received by the action officer.

When we talk about CNACIs or SACs, the investigations are “initiated” when they are submitted to OPM.

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Contractors

Q: If MWR contracts with a person, for gymnastics services for example, does that person have to have a CNACI?

A: Yes, per DoDI 1402.05 and CNIC Notice 1700, a CNACI is required for all individuals (including contractors) with regular contact with children on a DoD installation. All individuals who have not completed their CNACI investigation can work under Line of Sight Supervision (LOSS). To be eligible to work under LOSS, an individual must successfully complete the IRC.

Q: Once the CNACI is complete for a contractor, can they be alone with children?

A: Yes, assuming that they have also received a favorable IRC, and have completed the DD-2981, a contractor may be alone with children following the favorable adjudication of the CNACI.

Q: Who is responsible for maintaining documentation of non-CYP contractor background checks?

A: Once the CSO is at full operating capacity it will maintain all background check documentation. A solution for the interim is still under development and all parties will be notified as soon as the guidance is available.



CYMS

Q: Can old dates be deleted from CYMS as long as there are current initiated and completed dates and next due dates?

A: Old dates that are incorrect should be updated. Historic data from previous NACIs/investigations, when correct, should not be removed. However, duplicative lines can be deleted.

Q: Do you want a note in CYMS in the Military Member Security Check that says how long their clearance is for (5, 7, or 10 years)?

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A: This is not required as an audit point, however, entering this information in the comments/notes section in CYMS is a recommended best practice.

Q: Is it required that our programs add Military Family Life Consultants (MFLCs) background check data into CYMS (much like how we do for Camp Adventure)?

A: ALL CYP Personnel should be in CYMS. If the MFLC are supporting CYP then they should be in CYMS.

Q: In CYMS we are only putting in active volunteers. Is this correct? Is it required to still input everything into NAYS also?

A: Correct, please place your CURRENT specified and non-specified volunteers’ background check and training information in CYMS. Also, if you know of any coaches/officials that are returning, you can place them in CYMS now, or you can wait until that specific season begins. Lastly, programs are NOT required to update their coaches'/officials' training or background check information in the NAYS Chapter Management Website any longer. NAYS will simply be the vehicle to initiate the required training (e.g. NYSCA, NYSOA) for coaches and officials. Lastly, NAYS is leaving the platform as is for now. At a later date, the training and background check fields in NAYS will be turned off, but CYP HQ is waiting a little longer so people can transfer the information to CYMS.

Q: In CYMS are they ever going to add a volunteer management tab so volunteers can be separate from CYP staff?

A: Yes, when establishing a volunteer CYMS file, programs will need to select "Volunteer" in the classification field and also select the applicable volunteer code or job title:- VOL-SP - Volunteer Specified,- VOL-NOSP - Volunteer Non-Specified, or- VOL-SPAD - Volunteer Specified-Active Duty.

When adding a Staff file for a Volunteer on the Core Information Screen:

1. 'Volunteer' must be selected for the 'Classification' field (drop down, right below the Staff ID)

2. A Volunteer code must be selected for the 'Job Title' field (right-click the 'Job Title' field to launch the 'Staff Job Title Code Picklist' pop-up window, press 'V' on your keyboard, then select appropriate Volunteer code).

3. Friendly Reminder - The Training section does have Volunteer specific training codes.

Q: What date should we enter into CYMS to verify the clearances of active duty military volunteers and how?

Volunteers who are active duty military need to have their clearance verified as active by the Installation/Region Security Manager (through a Joint Personnel Adjudication System (JPAS) check). The person responsible for the JPAS check can be found on the Installation’s Background Check Screenings Action Officer Responsibility Ledger under “Completed CNACI Final Results Review”.

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The following date from the Responsibility Ledger Action Officer memos must be logged into CYMS: dates of JPAS verification checks (using the Military Member Security Check (MMSC) code).

The Military Member Security Check is now available in all CYMS databases, including Volunteer Specified-Active Duty, appearing as the following:

NACLC - MilitaryMemberSecurityCheck (VOL-SPAD)



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Documents

General Policy and Miscellaneous - Cloud Object … Notice... · Web viewPosition Descriptions7 Background Check Process7 Temporary/Summer/Teen Employees9 Volunteers10 Installation