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BBBSA Comment on Proposed Rulemaking for the Child Protection Improvements Act of 2018 (CPIA)
September 27, 2023 by Elisabeth Gehl

BBBSA has just submitted a comment in reaction to the Department of Justice’s (DOJ) recently issued advance notice of proposed rulemaking on the Child Improvement Protection Act (CPIA).  The CPIA was signed into law in 2018 to establish a program at the FBI that would ensure entities working with vulnerable populations can access fingerprint-based background checks if they wish to use them as part of their screening practices for staff and volunteers. The eventual outcome of this rulemaking process will be the framework for how DOJ implements the CPIA.

The CPIA is very important to BBBS agencies because it will help to protect the safety and well-being of the children we serve, and doing fingerprint background checks is mandated for all Youth Mentoring Grant sub-recipients. Right now, fingerprint checks are not universally available in every state and the costs associated with them can be prohibitive. 

BBBSA is aware of the affordability and accessibility challenges that agencies receiving Youth Mentoring Grant funds have been facing when trying to do fingerprint checks for their volunteers. Having a streamlined national background check process will hopefully help in solving some of these challenges, which is why BBBSA is strongly advocating that the DOJ implements CPIA in a way that will be most beneficial for the nonprofit sector, and our agencies specifically.

The next step will be the DOJ issuing a proposed rule sometime within the next six months and BBBSA will submit another comment in reaction to what DOJ proposes in that stage of the process. 

To view BBBSA's comment letter in reaction to the advanced notice of proposed rulemaking, please click here

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