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Consent-General Government # 9.
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| Board of Supervisors |
County Administrator |
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| Subject |
| Approve IRS Background Investigation Requirements Policy and Procedure and authorize staff to take actions necessary to implement the policy. (No general fund impact) (Rowland) |
| Recommended Action |
- Approve attached IRS Background Investigation Requirements - Access to Federal Tax Information Policy and Procedure;
- Add Background Requirements language to existing class specifications that will have or may have access to Federal Tax Information and where incumbents are subject to initial and recurring background investigations pursuant to Internal Revenue Service Publication 1075; and
- Affirm that employees hired into specified job classes after Board approval of the Policy shall be subject to the background requirements as a condition of employment.
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| Strategic Plan Goal(s) |
| Operational Excellence |
| Fiscal Impact |
| The cost to implement the IRS background investigation requirements include fingerprinting fees charged by the Federal Bureau of Investigation and the Department of Justice which currently amount to $49 per person. The maximum cost for every employee, currently fifty-five (55) identified authorized positions, to be re-fingerprinted is approximately $2,695 every ten (10) years. |
| Reason for Recommended Action/Background |
On September 30, 2016, the Internal Revenue Service released Publication 1075 which contained new background investigation requirements that apply to prospective and existing employees who have access to Federal Tax Information (FTI) during the course and scope of their job assignment with the County. FTI includes tax return information received directly from the IRS or obtained through a secondary source, such as the Social Security Administration, Federal Office of Child Support Enforcement, or Centers for Medicare and Medicaid Services. FTI also includes any information created by the County that is derived from federal return or return information received from the IRS or obtained through a secondary source.
Publication 1075 (Tax Information Security Guidelines for Federal, State and Local Agencies) requires that local agencies establish a personnel security program that ensures a background investigation is completed for any individual who will have access to FTI. This background investigation is to be completed prior to any employee access to FTI, and re-completed at least every 10 years.
The County departments with employees who access FTI include Child Support Services, the Health and Human Services Agency and General Services. Human Resources has worked closely with these departments over the past year and a half to develop the attached written policy and procedures. In addition, the following County class titles have been identified as having access to federal tax information:
| Administrative Clerk I |
Child Support Officer II |
Public Assistance Spec III-IEVS |
| Administrative Clerk II |
Emp & Soc Svc Prog Sup |
Sr. Child Support Officer |
| Admin Services Analyst |
HHSA Manager I |
Sup Child Support Officer |
| Child Support Assistant |
IT Manager |
Systems Software Spec I |
| Child Support Attorney IV |
Network Systems Spec I |
Systems Software Spec II |
| Child Support Attorney V |
Network Systems Spec II |
Systems Software Spec III |
| Child Support Officer I |
Network Systems Spec III |
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As part of the implementation of the requirements of Publication 1075, the class specs for these titles will be updated to include language that an initial and recurring (every 10 years) FBI background check is required as a condition of employment.
The meet and confer process with all affected bargaining units has been completed, and the policy recommended for approval by the Board of Supervisors reflects the changes agreed to during this process. |
| Collaborations (including Board advisory groups and external partner agencies) |
Child Support Services
General Services
Health and Human Services Agency
Human Resources met and conferred with the following affected bargaining units who concur with the recommended action:
- Attorneys Association
- General Unit
- Management Association
- Supervising Attorneys Association
- Supervisory and Professional Employees Association
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