Louisiana Delta Service CorpsNon-Profit

Compliance Requirement: 2 CFR 200.303 Internal Controls Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None. Condition: During our audit, we obtained an understanding and tested LDSC’s internal control for purposes of planning and performing our audit procedures. In obtaining our understanding and testing LDSC’s internal controls, we determined there were inadequate segregation of duties involving certain aspects of the financial reporting cycle. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the same individual, as follows: • Initiate and approve vendor invoices for payment, • Write checks or initiating electronic disbursements, • Review and approve payroll, including the approver’s payroll • Initiate and approve reimbursements to themselves as the agency head, • Access to check stock, check signing authority, and approval authorization. The following responsibilities over cash receipts are performed by the same individual: • Receive and open mail, • Prepare bank deposits and deposit monies received, • Invoices customers for services provided (host sites). Effect: There is not adequate segregation of duties. Recommendation: We recommend LDSC to continue its practice of involving members of the board and its contract accountant to be involved in the financial reporting process to the extent practical to mitigate the risks related to limited segregation of duties. Views of Responsible Officials: See views of responsible officials on page 27.

Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2022 Compliance Requirement: 2 CFR 200.303 Internal Controls Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None. Condition: During our audit, we obtained an understanding and tested LDSC’s internal control for purposes of planning and performing our audit procedures. In obtaining our understanding and testing LDSC’s internal controls, we determined there were inadequate segregation of duties involving certain aspects of the financial reporting cycle. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the same individual, as follows: • Initiate and approve vendor invoices for payment, • Write checks or initiating electronic disbursements, • Review and approve payroll, including the approver’s payroll • Initiate and approve reimbursements to themselves as the agency head, • Access to check stock, check signing authority, and approval authorization. The following responsibilities over cash receipts are performed by the same individual: • Receive and open mail, • Prepare bank deposits and deposit monies received, • Invoices customers for services provided (host sites). Effect: There is not adequate segregation of duties. Recommendation: To the extent possible, we recommend that board members or the contract accountant become further involved in the financial reporting process; such examples include, but are not limited to: • Approve monthly financial statements, • Bank statements and reconciliations, • Reimbursements (travel, expense, etc.) made to agency head, • Credit card activity initiated by the agency head, • The board of directors should adopt an annual budget and monitor on a periodic basis. We further recommend that management incorporate these recommendations to their financial policies and procedures handbook. This will ensure that financial policies are conducted consistently and in accordance with the expectations set by management and board governance. Additionally, such policies and procedures provide structure within LDSC in the event of employee turnover or absenteeism.

2023-001 Segregation of Duties Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2022 Compliance Requirement: 2 CFR 200.303 Internal Controls Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None. Condition: During our audit, we obtained an understanding and tested LDSC’s internal control for purposes of planning and performing our audit procedures. In obtaining our understanding and testing LDSC’s internal controls, we determined there were inadequate segregation of duties involving certain aspects of the financial reporting cycle. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the same individual, as follows:  Initiate and approve vendor invoices for payment,  Write checks or initiating electronic disbursements,  Review and approve payroll, including the approver’s payroll  Initiate and approve reimbursements to themselves as the agency head,  Access to check stock, check signing authority, and approval authorization. The following responsibilities over cash receipts are performed by the same individual:  Receive and open mail,  Prepare bank deposits and deposit monies received,  Invoices customers for services provided (host sites). Effect: There is not adequate segregation of duties. Recommendation: To the extent possible, we recommend that board members or the contract accountant become further involved in the financial reporting process; such examples include, but are not limited to:  Approve monthly financial statements,  Bank statements and reconciliations,  Reimbursements (travel, expense, etc.) made to agency head,  Credit card activity initiated by the agency head,  The board of directors should adopt an annual budget and monitor on a periodic basis. We further recommend that management incorporate these recommendations to their financial policies and procedures handbook. This will ensure that financial policies are conducted consistently and in accordance with the expectations set by management and board governance. Additionally, such policies and procedures provide structure within LDSC in the event of employee turnover or absenteeism. Views of Responsible Officials: See views of responsible officials on page 29.

Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and NationalYear Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR 2522.230 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: For two out of the thirteen living allowance periods tested, approval of the payroll disbursements was not able to be provided. For one of the thirteen living allowance payroll disbursement periods tested, approval was granted, however, the payment did not appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed approximately 68% of their hourly commitment in the program but was paid approximately 95% of their annual contracted amount. Our sample was not statistically valid. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.” As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from completing a term of service for compelling personal circumstances, as determined by the program, or for cause.” Cause: Internal controls over approval of living allowances are not operating effectively. Effect: Disbursements under the program may not have been for allowable purposes. Recommendation: LDSC should ensure internal controls over approval of living allowances are implemented as designed.

2023-002 Approval of Living Allowance Payments Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR 2522.230 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: For two out of the thirteen living allowance periods tested, approval of the payroll disbursements was not able to be provided. For one of the thirteen living allowance payroll disbursement periods tested, approval was granted, however, the payment did not appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed approximately 68% of their hourly commitment in the program but was paid approximately 95% of their annual contracted amount. Our sample was not statistically valid. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.” As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from completing a term of service for compelling personal circumstances, as determined by the program, or for cause.” Cause: Internal controls over approval of living allowances are not operating effectively. Effect: Disbursements under the program may not have been for allowable purposes. Recommendation: LDSC should ensure internal controls over approval of living allowances are implemented as designed. Views of Responsible Officials: See views of responsible officials on page 29.

Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 45 CFR 2540.205 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: Of the twenty-four National Service Criminal History Checks tested, we noted the following exceptions: For the first exception, the documented start date and adjudication date was before the Sex Offender Registry Check was performed and the date the state of residence and state of service criminal history check was performed for one individual. For the second exception, the adjudication date for an individual was prior to the date of the FBI fingerprint-based record check results. For the third exception, the name used for the name-based Sex Offender Registry Check and state of residence and state of service criminal history check did not agree to the name on the individual’s government issued identification. Our sample was not statistically valid. Criteria: As noted in 45 CFR 2540.205 certain tests “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 in a position as an AmeriCorps State and National member.” Cause: Checks of the Sex Offender Registry, state of residence and state of service, criminal history check, and FBI fingerprint-based checks (collectively, the National Service Criminal History Check) were not performed in accordance with federal guidelines consistently. Effect: Individuals who may have not met eligibility requirements to serve as members were permitted to perform service. Recommendation: LDSC should ensure controls over review and adjudication of National Service Criminal History Checks function properly.

2023-003 Compliance of Special Tests and Provisions – National Service Criminal History Checks Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 -AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 45 CFR 2540.205 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: Of the twenty-four National Service Criminal History Checks tested, we noted the following exceptions: For the first exception, the documented start date and adjudication date was before the Sex Offender Registry Check was performed and the date the state of residence and state of service criminal history check was performed for one individual. For the second exception, the adjudication date for an individual was prior to the date of the FBI fingerprint-based record check results. For the third exception, the name used for the name-based Sex Offender Registry Check and state of residence and state of service criminal history check did not agree to the name on the individual’s government issued identification. Our sample was not statistically valid. Criteria: As noted in 45 CFR 2540.205 certain tests “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 in a position as an AmeriCorps State and National member.” Cause: Checks of the Sex Offender Registry, state of residence and state of service, criminal history check, and FBI fingerprint-based checks (collectively, the National Service Criminal History Check) were not performed in accordance with federal guidelines consistently. Effect: Individuals who may have not met eligibility requirements to serve as members were permitted to perform service. Recommendation: LDSC should ensure controls over review and adjudication of National Service Criminal History Checks function properly. Views of Responsible Officials: See views of responsible officials on page 29.

Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2022 Compliance Requirement: 2 CFR 200.303 Internal Controls Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None. Condition: During our audit, we obtained an understanding and tested LDSC’s internal control for purposes of planning and performing our audit procedures. In obtaining our understanding and testing LDSC’s internal controls, we determined there were inadequate segregation of duties involving certain aspects of the financial reporting cycle. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the same individual, as follows: • Initiate and approve vendor invoices for payment, • Write checks or initiating electronic disbursements, • Review and approve payroll, including the approver’s payroll • Initiate and approve reimbursements to themselves as the agency head, • Access to check stock, check signing authority, and approval authorization. The following responsibilities over cash receipts are performed by the same individual: • Receive and open mail, • Prepare bank deposits and deposit monies received, • Invoices customers for services provided (host sites). Effect: There is not adequate segregation of duties. Recommendation: To the extent possible, we recommend that board members or the contract accountant become further involved in the financial reporting process; such examples include, but are not limited to: • Approve monthly financial statements, • Bank statements and reconciliations, • Reimbursements (travel, expense, etc.) made to agency head, • Credit card activity initiated by the agency head, • The board of directors should adopt an annual budget and monitor on a periodic basis. We further recommend that management incorporate these recommendations to their financial policies and procedures handbook. This will ensure that financial policies are conducted consistently and in accordance with the expectations set by management and board governance. Additionally, such policies and procedures provide structure within LDSC in the event of employee turnover or absenteeism.

2023-001 Segregation of Duties Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2022 Compliance Requirement: 2 CFR 200.303 Internal Controls Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None. Condition: During our audit, we obtained an understanding and tested LDSC’s internal control for purposes of planning and performing our audit procedures. In obtaining our understanding and testing LDSC’s internal controls, we determined there were inadequate segregation of duties involving certain aspects of the financial reporting cycle. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Cause: Due to the size of LDSC’s administrative staff, certain duties are performed by the same individual, as follows:  Initiate and approve vendor invoices for payment,  Write checks or initiating electronic disbursements,  Review and approve payroll, including the approver’s payroll  Initiate and approve reimbursements to themselves as the agency head,  Access to check stock, check signing authority, and approval authorization. The following responsibilities over cash receipts are performed by the same individual:  Receive and open mail,  Prepare bank deposits and deposit monies received,  Invoices customers for services provided (host sites). Effect: There is not adequate segregation of duties. Recommendation: To the extent possible, we recommend that board members or the contract accountant become further involved in the financial reporting process; such examples include, but are not limited to:  Approve monthly financial statements,  Bank statements and reconciliations,  Reimbursements (travel, expense, etc.) made to agency head,  Credit card activity initiated by the agency head,  The board of directors should adopt an annual budget and monitor on a periodic basis. We further recommend that management incorporate these recommendations to their financial policies and procedures handbook. This will ensure that financial policies are conducted consistently and in accordance with the expectations set by management and board governance. Additionally, such policies and procedures provide structure within LDSC in the event of employee turnover or absenteeism. Views of Responsible Officials: See views of responsible officials on page 29.

Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and NationalYear Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR 2522.230 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: For two out of the thirteen living allowance periods tested, approval of the payroll disbursements was not able to be provided. For one of the thirteen living allowance payroll disbursement periods tested, approval was granted, however, the payment did not appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed approximately 68% of their hourly commitment in the program but was paid approximately 95% of their annual contracted amount. Our sample was not statistically valid. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.” As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from completing a term of service for compelling personal circumstances, as determined by the program, or for cause.” Cause: Internal controls over approval of living allowances are not operating effectively. Effect: Disbursements under the program may not have been for allowable purposes. Recommendation: LDSC should ensure internal controls over approval of living allowances are implemented as designed.

2023-002 Approval of Living Allowance Payments Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR 2522.230 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: For two out of the thirteen living allowance periods tested, approval of the payroll disbursements was not able to be provided. For one of the thirteen living allowance payroll disbursement periods tested, approval was granted, however, the payment did not appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed approximately 68% of their hourly commitment in the program but was paid approximately 95% of their annual contracted amount. Our sample was not statistically valid. Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.” As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from completing a term of service for compelling personal circumstances, as determined by the program, or for cause.” Cause: Internal controls over approval of living allowances are not operating effectively. Effect: Disbursements under the program may not have been for allowable purposes. Recommendation: LDSC should ensure internal controls over approval of living allowances are implemented as designed. Views of Responsible Officials: See views of responsible officials on page 29.

Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 45 CFR 2540.205 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: Of the twenty-four National Service Criminal History Checks tested, we noted the following exceptions: For the first exception, the documented start date and adjudication date was before the Sex Offender Registry Check was performed and the date the state of residence and state of service criminal history check was performed for one individual. For the second exception, the adjudication date for an individual was prior to the date of the FBI fingerprint-based record check results. For the third exception, the name used for the name-based Sex Offender Registry Check and state of residence and state of service criminal history check did not agree to the name on the individual’s government issued identification. Our sample was not statistically valid. Criteria: As noted in 45 CFR 2540.205 certain tests “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 in a position as an AmeriCorps State and National member.” Cause: Checks of the Sex Offender Registry, state of residence and state of service, criminal history check, and FBI fingerprint-based checks (collectively, the National Service Criminal History Check) were not performed in accordance with federal guidelines consistently. Effect: Individuals who may have not met eligibility requirements to serve as members were permitted to perform service. Recommendation: LDSC should ensure controls over review and adjudication of National Service Criminal History Checks function properly.

2023-003 Compliance of Special Tests and Provisions – National Service Criminal History Checks Title and CFDA Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 -AmeriCorps State and National Year Finding Originated: 2023 Compliance Requirement: 45 CFR 2540.205 Name of Federal Agency: Corporation for National and Community Service Pass-through Agency: State of Louisiana/Volunteer Louisiana Questioned Costs: None meeting the reporting threshold of $25,000. Condition: Of the twenty-four National Service Criminal History Checks tested, we noted the following exceptions: For the first exception, the documented start date and adjudication date was before the Sex Offender Registry Check was performed and the date the state of residence and state of service criminal history check was performed for one individual. For the second exception, the adjudication date for an individual was prior to the date of the FBI fingerprint-based record check results. For the third exception, the name used for the name-based Sex Offender Registry Check and state of residence and state of service criminal history check did not agree to the name on the individual’s government issued identification. Our sample was not statistically valid. Criteria: As noted in 45 CFR 2540.205 certain tests “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 in a position as an AmeriCorps State and National member.” Cause: Checks of the Sex Offender Registry, state of residence and state of service, criminal history check, and FBI fingerprint-based checks (collectively, the National Service Criminal History Check) were not performed in accordance with federal guidelines consistently. Effect: Individuals who may have not met eligibility requirements to serve as members were permitted to perform service. Recommendation: LDSC should ensure controls over review and adjudication of National Service Criminal History Checks function properly. Views of Responsible Officials: See views of responsible officials on page 29.