Has anyone completed a suitability policy for their county agency
in accordance with the new FTI requirements listed below that go into effect on
09/30/2017? If you have, could you please share a copy with me, as I am trying
to create one for our agency and am looking for guidance on how to do
this.
Thank you,
Melinda Robertson
Fiscal Officer
Lac qui Parle County Family Services
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Topic |
SIR MILO
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Title |
5908 Updated IRS Publication
1075 Requirements
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Body |
Updated IRS Publication
1075 Requirements
Background information and main point:
The Internal Revenue Service (IRS) Office of Safeguards recently
released Publication
1075, Tax Information Security Guidelines for Federal, State and Local
Agencies summarizing revisions it made from the
previous version including requiring background checks immediately for all
new hires with access to federal tax information (FTI) and by September 30,
2017 for existing employees with access.
The updated Publication
1075 became effective September 30, 2016 and supersedes the October 2014
publication.
Who is affected?
All
employees with access to FTI.
When will this happen?
Counties
must run background checks immediately on all new hires with access to FTI
and by September 30, 2017 on all existing employees with access.
What does the IRS require for its background check?
The
IRS is requiring FBI fingerprinting and criminal history
checks, local law enforcement checks, and citizenship or residency checks for
their required background check.
Why is the IRS requiring background checks?
The background checks will be the basis of a suitability
determination made by agencies in permitting employee access to FTI. The IRS requires all affected
agencies to have a suitability policy that will determine whether the
employee or applicant is suitable for employment or continued employment in
the position that requires access to FTI.
Other information:
·
These new
security requirements affect other divisions in the Minnesota Department of
Human Services (DHS) as well as other state agencies.
·
CSD will not
be leading the overall implementation process but CSD plans to actively
participate.
·
CSD will keep
county child support agencies informed of new developments and progress on
implementation efforts by publishing additional county messages.
·
The IRS
made additional minor security changes (besides the background check
requirements), so counties should review Publication 1075 in its
entirety.
·
The IRS
indicated it would be somewhat lenient in enforcing background check
deadlines, as they are aware legislation may be required. However, county
child support agencies need to review and begin implementing all the
requirements, as they are able.
If you have any other
feedback or additional questions, use your county's internal escalation
process to contact the CSD Help Desk.
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Publish Date |
11/9/2016
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Expires |
11/15/2016
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Business Area Home Page Heading |
PRISM
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Business Area Search |
PRISM
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1 comment:
Brown County understood this was put on hold so we are tabling it for now. See SIR email below: (maybe something happened in the 2017 legislature however I haven't heard anything)
Subject: FW: SIR announcement from DHS today.
Importance: High
Good morning:
In November of last year, our income maintenance supervisor received the e-mail at the bottom of this chain regarding new IRS requirements for background checks on current on prospective employees. I made some inquiries at the BCA regarding whether it’s even possible for us to comply with the requirement at this point. Below is the information I got from the BCA’s legal department this morning. Please feel free to share this with anyone else you think might benefit.
With respect to the new IRS requirement for background checks, those are not currently authorized. What has to happen is that the Minnesota Legislature must approve a state statute authorizing the background checks and that state statute must be approved by the US Attorney General. There are many people in Minnesota who will be subject to this background check requirement and so the legislation will need to cover all of them.
We are not certain if the Legislature will act in the 2017 session to authorize these checks. I do know that the Federal Bureau of investigation has communicated with the IRS about the process needed to implement these checks and so the IRS is aware that it may not be possible for agencies to comply with their current deadline.
If you have other questions, please let me know.
Katie Engler
KATHERINE A. (KATIE) ENGLER | SENIOR LEGAL ANALYST
BUREAU OF CRIMINAL APPREHENSION
1430 MARYLAND AVENUE EAST, ST. PAUL, MN 55106
651-793-2721 | katherine.a.engler@state.mn.us
From your January communication with Karen Roatch of the BCA:
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