Criminal Background Checks

Can the cost assessed from a private vendor (e.g., HireRight) to perform criminal background checks be applied to sponsored projects (e.g., grants, contracts, agreements)?

Yes, IF… the individual hired is fully funded on the sponsored project and dedicated to the project for at least one full year*.

Note: If the individual hired is fully funded across multiple sponsored projects and dedicated to those multiple projects at the same effort levels for at least one year, the cost would then be shared financially between the multiple projects at the effort distribution levels.

This interpretation would be consistent with cost principles applied to costs such as visas and recruitment costs on sponsored projects, allowable under OMB circular A-21, and under state purchasing guidelines.

Example 1:
A scientist is recruited for Dr. Jones’ NIH research award 144-ABCD.
Three individuals are ranked as possible hires.
Individual 1 — a criminal background check is performed; an offer is made; the offer is declined.
The cost associated with individual 1 may not be assessed to Dr. Jones’ 144-ABCD award.
Individual 2 — a criminal background check is performed; an offer is made; the offer is accepted.
The cost associated with individual 2 may be assessed to Dr. Jones’ 144-ABCD award.

Example 2:
A scientist is recruited for a shared position, 50% on Dr. Jones’ NIH research award 144-ABCD and 50% on Dr. Smith’s NSF research award.
The cost for a criminal background check on the individual hired may be assessed 50/50 to the two awards.

 

* If an individual resigns within the one year period, or their funding changes within the one year period, cost assessed for the criminal background check would need to be removed from the sponsored project to an unrestricted fund.

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