Nff national fingerprint file

For these non-NFF states, there is no measurement for the percent of duplication between the state and FBI databases, and therefore both are required. Additionally, searches of non-NFF state criminal history repositories are required if the individual has resided in a non-NFF state within the past five years. More information on the NFF, including the list of participating states, can be found online.

Interstate background check. OCC has received questions about the CCDBG Act background check requirements, including questions about the applicability of the requirements, as well as questions about the health and safety training requirements. Question: Are license-exempt child care providers that are not receiving CCDF funds required to meet the background check requirements? Answer: No, child care providers are not subject to background check requirements if they: 1 are not licensed, regulated, or registered; and 2 do not receive CCDF funds.

In accordance with section H i 1 , the background check requirements in the CCDBG Act apply to all licensed, regulated, or registered child care providers, regardless of whether they receive CCDF funds, and all license-exempt providers that receive CCDF with the exception of individuals who are related to all children for whom child care services are provided.

States have the flexibility to determine which providers are considered licensed, regulated, or registered. As an example, if a faith-based provider is not licensed, regulated, or registered and does not serve CCDF children, that provider would not be subject to the background check requirements of the CCDBG Act.

In addition, the list of disqualifications for employment specifically do not apply to child care staff members of licensed providers that do not serve children receiving CCDF subsidies. This gives States the flexibility to determine employment disqualifications, if any, for child care providers who may be licensed, regulated, or registered, but do not receive CCDF funds. Question: If public school pre-k programs in the State are not licensed, regulated, or registered by the Lead Agency and do not serve any children receiving CCDF subsidy, are they required to meet the background check requirements?

Answer: No. In addition, our understanding is that many States do not consider public school pre-k programs to be child care providers, and these programs would not be subject to the background check requirements. States have the flexibility to define whether other child care providers are also included in this definition. Question: What should a State do if all background check components are not completed within 45 days? Answer: While we expect checks to be completed in the timeframe established by the Act, Lead Agencies may create their own procedures in the event that one or more of the components of a background check are not complete within the required 45 days.

Likewise, States also have the flexibility to make employment decisions in the event that not all background check components are completed within 45 days.

For NFF states, the FBI always reaches out to the state to respond to all inquiries, ensuring that all information available at the state level is included in the reply. While 34 states have ratified the Compact with an additional 10 states and territories signing the MOU , only 20 states fully participate in the NFF. States with older, legacy AFIS systems might not be able to meet the fingerprint identification standards required for full participation, and states may not be willing to undertake a very expensive AFIS upgrade or replacement project simply to participate in the NFF.

As noted earlier, in order to become an NFF state, a state must be able to respond to all requests for CHRI for records originating from within the state.

In many cases, even though a state has ratified the Compact, the FBI still maintains pseudo-pointer records for the state. Pseudo-pointer records refer to CHRI records that originated from a state, but the state does not maintain the biometric information at the state identification bureau to support the CHRI record.

Pseudo-pointer records may exist because records were submitted directly to the FBI before the state established its own repository. Additionally, many years ago, when fingerprints were primarily captured through an ink-and-roll process on physical fingerprint cards, it was common practice to capture three sets of fingerprints — one for the local arresting agency, one for the state, and one to be forwarded to the FBI.

This meant that often the FBI was able to classify fingerprints, but the state was unable to classify them as they did not receive the highest quality set of fingerprint impressions. This may have resulted in the creation of a biometrically supported record at the FBI, but not the state.

The FBI encourages states to take control of all their own records to promote participation in the NFF and will work with states to provide the necessary fingerprint image files so that pseudo-pointers can be replaced with state pointers within the III. This can be a time-consuming process, however, so not all Compact states have been able to take control of all their records.

In some cases, states may simply prefer not to take control of what are typically very old records, and it is easier to simply allow the FBI to continue to maintain them and provide responses on behalf of the state when there is a hit on a pseudo pointer record.

Since , this has been the vision of SEARCH, and we invite any states wishing to learn more to please contact us for additional information or assistance. Belair and Paul L. Robert R. Belair, Paul L. Woodard, and Eric C. The approval process for signing an MOU is quicker than the process of ratifying the Compact.