The following is an observation from an internal audit engagement performed by the Office of Internal Audit of New City Metro Government. The objective of the audit was to assess the administration of the Youth Protection Policy. Additionally, the internal controls related to compliance with policy were reviewed. This included policies, procedures, and related activity processed.
Human resources (HR) issued the Youth Protection Policy in June 2022, based on recommendations from an external consultant hired in 2021. Additionally, HR created the Youth Protection Policy Committee, established training, and initiated a youth protection educational campaign. HR maintains responsibility for administration of the Youth Protection Policy and related activities (for example, training).
The scope of the audit included activities, policies, and procedures from June 6, 2022 to August 16, 2024.
Volunteers and interns may be placed into an assignment without a background check. HR acknowledged that this is a “common” occurrence. All volunteers and interns over the age of 18 are required to undergo a background check. Section 1.24(5) of the Personnel Policies specific to the Youth Protection Policy states, “any person seeking to work with any youth program or activity administered by New City Metro Government shall … submit to the required background screening.” However, the Personnel Policies (Sections 1.19(4)b and 1.20(5)) concerning hiring volunteers and interns do not clearly mandate background checks for volunteers and interns over the age of 18. The policies state that volunteers and interns “may be subject to criminal background checks.” Noncompliance with volunteer and intern background check requirements is due to a combination of unclear policies and a lack of coordination with departmental volunteer coordinators and HR representatives during the selection and assignment process. There is an added risk to youth when volunteers are assigned without first undergoing the required background screening. HR should perform the following to increase departmental compliance with background screening on volunteers and interns: Communication should be made immediately to inform department directors, HR representatives, volunteer coordinators, and any other necessary parties of the volunteer and intern background screening requirements.
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