August 4, 2011

Ms. Amy Borgstrom
Docket Manager
Corporation for National and Community Service
1201 New York Avenue, NW
Washington, DC 20525

Dear Ms. Borgstrom:

I am submitting these comments on behalf of the membership of the National Association of RSVP Program Directors (NARSVPD) in response to the solicitation from the Corporation for National and Community Service (CNCS) concerning its proposed rule with respect for comments relating to the National Service Criminal History Check regulations to require grantees to conduct and document criminal history checks and FBI fingerprint checks on Retired Senior Volunteer Program (RSVP) grant-funded staff.

We appreciate that this rule is the result of enactment of the Kennedy Serve America Act and understand support its intent to protect vulnerable populations from abuse. We also appreciate the fact that the proposed rule does not cover the nation’s 400,000 RSVP volunteers and covers only those RSVP staff hired after April 21, 2011 who have recurring access to vulnerable populations.

However, we believe it is important to note that there is a cost associated with these checks and that the Kennedy Serve America Act assumed a modest upward trajectory in federal spending on the RSVP program. Unfortunately, that assumption has not been borne out. Rather, RSVP programs have had to absorb the 20 percent reduction included in the most recent Continuing Resolution for FY 2011.

Therefore, we urge the Corporation to provide as much relief as possible under the statute from the costs associated with implementing these provisions of the Serve America Act.

Sincerely,

Betty Ruth,
President