OFFICE OF THE INSPECTOR GENERAL

MONTGOMERY COUNTY MARYLAND

MEGAN DAVEY LIMARZI, ESQ.

INSPECTOR GENERAL

Review of MCPS Background Screening Office

Montgomery County Public Schools

Montgomery County OIG Publication #26-01

August 4, 2025

51 MONROE STREET, SUITE 600 | ROCKVILLE, MARYLAND 20850

240 777 8240 | MONTGOMERYCOUNTYMD.GOV/OIG
 EXECUTIVE SUMMARY
Montgomery County Public Schools (MCPS) is the largest school system in the state of Maryland with 211
schools and more than 24,400 employees, supporting the educational needs of over 160,000 students. Ensuring
the safety and protection of students, staff, and visitors is critical to MCPS’ success. As such, Maryland law and
MCPS regulations and procedures require various background checks for employees and others who may have
unsupervised access to students. These include criminal background and Child Protective Services checks.
During this review we found MCPS has more than 12,000 current employees who have outdated criminal
history checks and approximately 4,900 individuals that have not undergone a CPS check and may have access
to children. Additionally, while MCPS contractors and certain volunteers with unsupervised access to students
are required to have criminal history checks, we found that some began work prior to those checks being
completed. We also determined that MCPS does not have a process to ensure volunteers completed required
training regarding child abuse and neglect and that MCPS continues to monitor the criminal histories of persons
no longer employed or providing services to MCPS. Lastly, we observed that MCPS does not have formal
procedures governing suitability determinations when negative information is discovered through a criminal
history check.

OBJECTIVES- SCOPE AND STANDARDS-

Through this review we sought to determine Our review was conducted from October 2024
whether MCPS’ process for conducting through May 2025, in accordance with the
background checks for employees and Association of Inspectors General, Principles and
contractors that have access to students complies Standards for Offices of Inspectors General, Quality
with applicable laws, regulations, and policies. Standards for Inspections, Evaluations, and
Reviews (July 2024).

RESULTS-
• MCPS is not monitoring criminal histories for all employees.
• MCPS is not ensuring initial criminal history checks are conducted for contractors and volunteers prior to
them beginning work.
• Not all individuals with access to students have undergone a Child Protective Services check.
• MCPS has no formal procedures governing suitability determinations.
• MCPS does not consistently remove people from the criminal history monitoring program as required.
• MCPS does not consistently ensure volunteers have taken required child abuse and neglect training.

RECOMMENDATIONS-
• Take immediate action to eliminate the backlog of existing employees that have not been entered into
the criminal history monitoring program.
• Ensure applicable contractors and volunteers that may have unsupervised access to students have the
required criminal history check completed prior to starting work.
• Provide training for relevant staff on the requirements and process to initiate a criminal history check.
• Take immediate action towards eliminating the backlog of CPS checks.
• Implement regulations for investigating and making suitability determinations.
• Remove persons who have separated or are no longer providing services to MCPS from the monitoring
program.
• Ensure child abuse and neglect training is completed and tracked.
 TABLE OF CONTENTS

Executive Summary .....................................................................................................................i

Table of Contents ....................................................................................................................... ii

Background ................................................................................................................................ 1

Findings and Recommendations ................................................................................................ 3

OIG Comments to the Superintendent’s Response ................................................................... 9

APPENDIX A: SUPERINTENDENT’S RESPONSE...................................................................... 11

APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP ............................................. 18

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |i i

 BACKGROUND

Montgomery County Public Schools (MCPS) is the largest school system in the state of Maryland
with 211 schools and more than 24,400 employees, supporting the educational needs of over
160,000 students. MCPS’ operating budget in fiscal year (FY) 2025 exceeded $3.32 billion with more
than 60% of the funds being provided by Montgomery County. Underlying the services provided by
MCPS is the responsibility to ensure the safety and protection of students, staff, and visitors to
MCPS property and school-sponsored activities. This responsibility extends to implementing various
safety protocols.

The Maryland Annotated Code (MD Code), Education Article, § 6-113, states that schools may not
knowingly hire or retain any individual who has been convicted of certain criminal offenses, to
include specific crimes of a sexual nature, including child sex abuse, and any crime defined in the MD
Code, Criminal Law Article, § 14-101. The MD Code, Family Law Articles § 5-551 and 5-552, require
that school systems conduct criminal history checks of prospective employees and certain
contractors1 to help identify individuals that may be prohibited from having unsupervised access to
children. MCPS also conducts Child Protective Services (CPS) checks for applicants, contractors, and
certain volunteers to screen for other concerning behaviors that may also make the individual
ineligible for positions with access to students. Additionally, MCPS regulation IRB-RA, Volunteers in
Schools, requires certain volunteers to undergo criminal history checks and complete the online
training course, Recognizing and Reporting Child Abuse and Neglect (CAN). It is also MCPS’ practice to
complete CPS checks for volunteers who were identified as needing a background check.

The MCPS Background Screening Office (BSO) is charged with overseeing the background check
process for MCPS and therefore responsible for ensuring that every applicable person undergoes
all appropriate steps required by law and MCPS policy. Their oversight extends to prospective
staff, active employees, contractors, and volunteers who coach, participate in outdoor
environmental education programs, overnight field trips, and certain trips that require extended
hours or distances with students. 2

As part of the background check process, BSO staff (with the assistance of a contractor) process
fingerprints, conduct online database queries, and coordinate with other entities to complete
required steps.

In January of 2019, BSO began participating in the U.S. Federal Bureau of Investigation’s (FBI),
Record of Arrest and Prosecutions Back (Rap Back) program. Once BSO staff enroll an individual
in Rap Back, the system continuously monitors their criminal history and automatically alerts
MCPS to changes in the individual’s criminal history as reflected in the system. FBI policy requires
MCPS to remove individuals from Rap Back once they have separated from service or no longer

1
This refers to contractors with direct, unsupervised access to children.
2
Distances are measured from MCPS Central Office in Rockville, Maryland.

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |1

BACKGROUND

need to have their criminal history monitored by MCPS.

Objectives, Scope, and Methodology

Through this review we sought to determine whether MCPS’ process for conducting background
checks for individuals that have access to students complies with applicable laws, regulations, and
policies.

During this engagement we reviewed pertinent laws, regulations, policies, and procedures. The
scope of our review included MCPS applicants, employees, contractors, volunteer/chaperones,
and coaching staff. We interviewed MCPS staff, visited multiple schools, and analyzed relevant
documentation related to the receipt, processing, and adjudication of background checks.

This review was conducted from October 2024 through May 2025, in accordance with the
Association of Inspectors General, Principles and Standards for Offices of Inspector General, Quality
Standards for Inspections, Evaluations, and Reviews (July 2024).

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |2

 FINDINGS AND RECOMMENDATIONS

Maryland law requires that public schools conduct criminal history checks for all employees at the
time of hire. Additionally, MCPS requires applicants to undergo a CPS check as part of the hiring
process. Accordingly, MCPS conducts an initial criminal history check with fingerprints for
employees and certain contractors and volunteers, continuously monitors these individuals
through the Rap Back program, and submits a CPS query request at the time of hire for anyone
having unsupervised access to students. We found that the criminal histories of more than 12,000
MCPS employees are not being monitored and that 4,900 individuals who potentially have access
to MCPS students have not received initial CPS queries. We also found instances where some
contractors began work before their criminal history checks were completed. Similarly, we noted
that some volunteers who may have had unsupervised access to students did not always undergo
a criminal history check as required by MCPS regulations.

Additionally, we found that BSO has no formal written procedures governing how to make
suitability determinations when negative information is discovered through a criminal history
check for new applicants. 3 Furthermore, MCPS does not consistently remove people from Rap
Back when they are separated from MCPS service.

Lastly, we noted that MCPS regulations require volunteers who regularly support MCPS activities
must take the online training, Recognizing and Reporting Child Abuse and Neglect (CAN). We found
that MCPS is not ensuring compliance with this requirement.

Finding 1: MCPS is not monitoring criminal histories for all employees and is not ensuring initial
criminal background checks are conducted for contractors and volunteers prior to them
beginning work.

Employees

Recognizing the system’s responsibility to ensure student and staff safety, in 2018, MCPS’ chief
operating officer announced to MCPS employees that “as another level of security, this year we
will take the critical step of initiating an employee re-fingerprinting program for MCPS.” The
announcement discussed taking a phased-in approach based on hire date to implement the new
procedure, which would ensure all employees were routinely re-fingerprinted and their criminal
histories checked every three years. In memoranda to the Board of Education beginning in 2019
and thereafter, MCPS conveyed that they would use the FBI’s Rap Back Service in lieu of re-
fingerprinting.

In January 2019, MCPS began using the FBI’s Rap Back Service to check and monitor the criminal
histories of new employees, and applicable contractors and volunteers. The service provides real-
time notifications of criminal history information reported to the FBI. In November 2024, MCPS

3
BSO rejects applicants with disqualifying offenses as defined in the Annotated Code of Maryland, Education Article,
§ 6-113 but makes a suitability determination based on the underlying facts for those with other negative
information.

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FINDINGS AND RECOMMENDATIONS

reported that there were 12,655 employees who had still not been enrolled in Rap Back and thus
have not been subjected to a criminal history check since at least 2019.

We were told that MCPS management had been aware of the extensive backlog for over a year
prior to our review but determined it would be cost prohibitive to acquire the resources necessary
to immediately take action to enroll all employees into Rap Back. Given the seriousness of this
issue, on December 2, 2024, the Inspector General wrote to the Superintendent to ensure he was
aware of the issue and encourage him to take whatever immediate steps were warranted to
safeguard students and staff.

MCPS Contractors

When hiring an outside entity to provide a service, MCPS requires that staff submit a completed
“Authorization for Consultant/Independent Contractor Services” form to the Division of
Procurement (Procurement). Instructions on the form state that the authorization process should
begin at least 15 days prior to the anticipated start of work to allow sufficient time for processing.
The form requires the MCPS sponsor to answer the question “Will the vendor have direct,
unsupervised, or uncontrolled access to children while performing this work?” For any positive
response, Procurement provides the information to BSO for a background check.

We were told that even though all school staff should be aware of the clearance process for
contractors, some still submit the authorization form late. As a result, contractors have started,
and in some cases completed, their work prior to Procurement receiving the authorization form
and requesting a background check. We reviewed several instances in which the date of service by
a contractor preceded the date the form was received by Procurement. For example, one MCPS
sponsor indicated that the contractor would have unsupervised access to children but did not
submit the form until two weeks after the contractor was supposed to begin work. Procurement
staff also shared that they believe some schools hire contractors and never submit the required
authorization form.

Volunteers

MCPS regulations and guidance require that certain volunteers with unsupervised access to
students undergo a criminal background check. We noted that MCPS does not have controls in
place to ensure applicable volunteers completed the required check prior to volunteering. As was
the case with contractors, we found confusion and inconsistent practices with respect to who is
required to undergo these checks and the process to initiate them.

In discussions with administrators at one of the four schools that we visited, we were told that
they did not know there was a requirement to ensure volunteers with unsupervised access to
students undergo a criminal history check prior to volunteering. They also told us that they did
not know how to initiate an investigation if they determined one was warranted. As a result, the
school never submitted required forms to BSO to initiate criminal history checks. One of the
schools we visited claimed to be aware of the requirement and to have submitted notifications to

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |4

FINDINGS AND RECOMMENDATIONS

BSO. The remaining two schools claimed to be aware of the requirement but did not use
volunteers who had unsupervised access to students.

As we observed through our site visits, BSO may not always be notified when applicable
volunteers require a criminal history check. As such, staff and students may be exposed to
volunteers that have a criminal history or other concerning issues.

There are currently thousands of MCPS employees whose criminal histories have not been
updated since at least 2019. Relatedly, MCPS is not ensuring that contractors and applicable
volunteers are undergoing initial background checks prior to taking on roles that give them
unsupervised access to students. Background checks are critical to MCPS’ efforts to identifying
potential risks associated with those unfit to have access to children.

Recommendation 1

We recommend MCPS:

a) Take immediate steps towards eliminating the backlog of existing employees that
have not been entered into Rap Back.
b) Ensure all applicable contractors and volunteers that may have unsupervised access to students
have the required criminal history check completed prior to beginning work.
c) Provide periodic training for all relevant administrators and staff on the requirement
to obtain a criminal history check for individuals with unsupervised access to students,
and the process for initiating those checks.

Finding 2: Not all individuals with access to MCPS students have undergone a Child Protective
Services check.

Since 2013, MCPS has required a CPS check for new employees. In a 2020 memorandum to the
Board of Education, the then-superintendent of schools also committed to completing CPS
checks for all existing employees hired prior to September of 2013. Current MCPS practice also
includes conducting these checks for contractors and volunteers when BSO receives notification
that they require a background check. We learned that as of March 31, 2025, MCPS had a backlog
of approximately 4,900 individuals who may have access to students and never undergone a CPS
check.

The Montgomery County Department of Health and Human Services, Child Welfare Services
(CWS) is responsible for investigating allegations of child abuse and neglect within the County
(i.e. CPS investigations). CWS has processed MCPS’ checks since 2013, but due to the volume of
checks required, MCPS has had to assign staff to augment CWS.

We were told that in 2024 CPS checks identified 30 individuals at MCPS (applicants, employees,
contractors, or volunteers) that had an “indicated” finding of child abuse or neglect. Code of
Maryland Regulations 07.02.07.02 defines “indicated” as “a finding that there is credible evidence,

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |5

FINDINGS AND RECOMMENDATIONS

which has not been satisfactorily refuted, that child abuse or neglect occurred.” While
concerning, it is important to note that a CPS indicated finding is not the equivalent of being
convicted of a crime and does not necessarily mean a person poses a danger to students but
rather is something that should be subject to further review. The large number of outstanding
CPS checks is a vulnerability and presents a liability to MCPS.

Recommendation 2
We recommend MCPS take immediate action towards eliminating the backlog of CPS checks.

Finding 3: MCPS has no formal written procedures governing suitability determinations for
applicants with criminal histories.

The Annotated Code of Maryland, Education Article, § 6-113, Hiring Prohibition for Individuals
Convicted of Sexual Crimes or Crimes of Violence, states that a county board may not knowingly
hire or retain any individual who has been convicted of certain criminal offenses, to include certain
crimes of a sexual nature, child sexual abuse, and any violent crime as defined in the Annotated
Code of Maryland, Criminal Law Article, § 14-101.

BSO confirmed that any applicant with a disqualifying offense would not be offered a position.
However, they stated that if an applicant had other criminal convictions, but no disqualifying
offenses, BSO staff would use their own discretion to determine if the individual is suitable for
employment. Factors such as the length of time since last arrest or conviction, non-felony
convictions, mitigating circumstances, and overall criminal history are reportedly considered by
BSO staff to determine suitability. BSO staff shared that they do not have a formal process or
procedure for making a recommendation whether a person is suitable for employment. 4

The discretionary authority and lack of formal policy regarding suitability determinations could
create inequities and disparate treatment when evaluating applicants being considered for a
position at MCPS.

Recommendation 3
We recommend MCPS implement comprehensive regulations and associated procedures for
investigating and making suitability determinations for applicants with a criminal history but
no disqualifying offenses.

Finding 4: MCPS does not consistently remove individuals from Rap Back who have separated
from MCPS or otherwise no longer need to have their criminal history monitored.

FBI policy requires subscribers such as MCPS to remove an individual from Rap Back within five
days of the person separating from employment or no longer needing to have their criminal
history monitored. We found that MCPS employees, volunteers, and contractors enrolled in Rap
Back are not always removed when they have separated or are no longer providing services to

4
While BSO can make a recommendation, the Office of Human Resources is ultimately responsible for determining if
an offer of employment will be rescinded.

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FINDINGS AND RECOMMENDATIONS

MCPS. This was especially notable for volunteers and contractors, as BSO is rarely informed when
a contractor or volunteer is no longer providing services.

We found that BSO has no formal procedure for the removal of people enrolled in Rap Back. In
fact, BSO staff did not begin routinely removing individuals from Rap Back until approximately
mid-2023. Even then, BSO staff admitted that their process is limited to MCPS employees and
does not typically include volunteers or contractors.

As noted above, due to confusion at the school level about the requirement to obtain criminal
checks for volunteers, some may have never received the required checks. The lack of awareness
also resulted in schools not notifying BSO to remove volunteers from Rap Back when they are no
longer providing services at the school. As a result, these individuals remained in Rap Back and
continued to have their criminal history monitored. Similarly, Procurement was not routinely
notifying BSO when a contractor was terminated or completed their work. We were told that staff
from Procurement and BSO recently began discussions about implementing a formal process to
identify and remove contractors from Rap Back when appropriate.

There is no official need for MCPS to continue monitoring the criminal histories of individuals that
no longer have unsupervised access to MCPS students. Additionally, by not removing individuals
from Rap Back within five days of their separation date, MCPS is in violation of FBI policy and
potentially violating the privacy rights of individuals.

Recommendation 4
We recommend MCPS implement a formal process to identify and remove any individual they
enrolled in Rap Back that is no longer employed or no longer has unsupervised access to
students.

Finding 5: MCPS does not ensure volunteers have taken the required training, Recognizing and
Reporting Child Abuse and Neglect.

MCPS Regulation IRB-RA, Volunteers in Schools, requires all volunteers who regularly support
schools and school-sponsored activities, including chaperones and those attending field trips,
take the online training, Recognizing and Reporting Child Abuse and Neglect (CAN). The training is
required to be taken every three school years. Volunteers for large events, such as college or job
fairs and parents staffing concession stands or ticket booths, as well as volunteers for one-time
events under school staff supervision are not required to take the training.

During our visits to four schools, we conducted interviews with school administrators to learn how
they manage volunteers at their locations. We found inconsistencies related to their
understanding of the CAN training requirements and no formal process to ensure volunteers who
are required to take the training have done so. Of the four schools we visited, two were aware of
the CAN training requirement and said it was reflected in their current practice. Another school
we visited was aware of the training requirement but said that they do not have any volunteers and
therefore do not have a need for the training.

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FINDINGS AND RECOMMENDATIONS

The final school we visited was familiar with the CAN training requirement; however, they
mistakenly believed the requirement only applied to volunteers with unsupervised access to
children when, in fact, all those who regularly volunteer are required to complete the training.
Staff at this same school also shared that they were not proactively ensuring that volunteers were
indeed taking the training. They explained that the responsibility to refer a volunteer for CAN
training was assigned to the sponsor of the volunteer activity, which changes frequently. Staff
admitted they had no controls in place to ensure that all potential sponsors were aware of the
requirement and instructing volunteers to complete the online CAN training.

While MCPS regulation requires that the CAN training must be taken by applicable volunteers
every three years, there are no mechanisms in place to identify individuals that are overdue.
Additionally, the regulation does not mention that contractors are also required to take the CAN
training even though this requirement is highlighted on MCPS’ website.

All MCPS employees, contractors, and volunteers are required to report any suspected instance of
abuse or neglect of a child. By not having appropriate protocols in place to ensure that those
required to take CAN training have done so, individuals providing services to MCPS may not be
aware of the primary indicators of abuse and neglect or the appropriate actions to take if they
witness something of concern.

Recommendation 5
We recommend MCPS:

a) Take appropriate steps to ensure the completion and continual tracking of CAN
training for all applicable persons.
b) Clarify CAN training requirements for contractors.

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e |8

 OIG COMMENTS TO THE SUPERINTENDENT’S RESPONSE

The Superintendent’s response to this report is included in its entirety in Appendix A. Of note,
MCPS does not disagree with any of the findings contained in the report and indicates general
concurrence with the recommendations while highlighting the challenges of relying upon partner
agencies to address issues associated with CPS checks. Although the Superintendent asserts that
MCPS takes “full responsibility” for the deficiencies identified in the report, we find the response
perplexing and are disappointed by the apparent attempts to transfer blame to this office for his
administration’s “inability to act more swiftly” to address these serious issues that have been well
known at MCPS for years and yet have gone unaddressed.

As noted in the report, the Inspector General sent a memorandum to the Superintendent over
seven months ago to ensure he was aware of the significant backlog of criminal history checks for
existing staff. Since that time, we have worked closely with numerous individuals at MCPS to
assess the background check process which includes CPS checks

Contrary to assertions made by the Superintendent, OIG staff enjoyed an excellent working
relationship with numerous MCPS staff involved in the background check process. We found
these staff members and their counterparts to be open and forthcoming about the challenges in
their work, including their attempts to alert previous leadership about the criminal history and
CPS check backlogs. We had numerous conversations with staff from multiple MCPS offices
regarding the background check process and held collaborative discussions about best practices
and possible changes to process. We also note that near the end of our review, the former HR
Director met with CWS management, which we observed as a positive step for moving forward.
With that context, the allegations that the OIG failed to keep MCPS informed and failed to act
with transparency are unsupported and inaccurate.

In addition to our frequent discussions with MCPS staff during our review, in May we spoke with
management about our findings, and on June 6th we shared an initial draft of our report with the
Superintendent’s office. At that time, per our standard protocol, we requested MCPS to provide
technical comments or corrections. In the spirit of collaboration and transparency, we repeatedly
offered to answer questions and engage in dialogue regarding the draft; shared contact
information with senior leadership to facilitate informal conversations; and even agreed to an
extension for MCPS to provide a draft action plan.

OIG staff met with members of the Superintendent’s leadership team on June 25th and in
response to that meeting made corrections to address the concerns raised and provided a revised
draft report on July 7th. On July 16th we held another meeting to discuss MCPS’s proposed
corrective actions and address any other questions or issues. At no time during or after that
meeting did MCPS leadership request additional changes to the report, raise wording
discrepancies, or identify any inaccuracies. The Superintendent did not attend either of these

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OIG COMMENTS TO THE SUPERINTENDENT’S RESPONSE

meetings, and despite his claims, MCPS leaders did not exhibit or invite an authentic
collaboration. In fact, during our last meeting with MCPS leadership, they repeatedly refused to
discuss specifics of certain planned actions which would assist the OIG in determining if the
proposed steps would address observed deficiencies or offer alternative considerations. It was
only in the Superintendent’s July 25th formal response that we learned of the nature and extent of
discussions with the State regarding CPS checks.

Furthermore, although OIG draft reports are routinely kept confidential until public issuance in
order to protect the integrity of our work and ensure all parties have the opportunity to be fully
prepared to address the recommendations, a limited exception was provided in this case. In an
email dated June 20th OIG staff specifically told MCPS leadership that though the report itself
could not be shared, we recognized they may need to reference certain information contained in
the report while meeting with CWS to prepare their corrective action plan. There should have
been no ambiguity as we explicitly stated they were “welcome to discuss” the facts shared by our
office.

At no time did the OIG withhold the results of our work or stimy the actions of MCPS to begin
addressing the fact that there are thousands of individuals (employees, contractors, staff, and
volunteers) with access to schools and children who have not had an updated criminal history
check in over five years. Notably missing from the Superintendent’s response is mention of any
actions that MCPS may have taken since our December 2024 memorandum to reduce this
backlog or their efforts during the last budget season to identify the resources they believe
necessary to address this known failing. To insinuate MCPS had only three weeks to address these
issues is deceptive. The current administration has been aware of these issues for months, and
MCPS as an institution has been aware for years.

The accuracy of the OIG’s work is critically important and the processes and procedures we
adhere to strive for such an outcome in every project. Our standard protocols include multiple
quality assurance checkpoints, including independent referencing and engaging with
stakeholders to gain feedback, clarifications, and corrections. That is why we met with MCPS staff
repeatedly, made ourselves available to them, and made revisions following our discussions. After
thoroughly reviewing the Superintendent’s response and evaluating each assertion, the OIG is
confident that, as written, the report is factually correct and supported by evidence.

Lastly, in contrast to their statements, the actions by MCPS senior leaders do not demonstrate
either accountability or transparency. The fact remains that thousands of individuals with
unsupervised access to MCPS schools and students have not had a criminal history check in more
than five years and thousands more have not completed a CPS check. In the end, only one entity
is tasked with and has accepted the responsibility for obtaining these background checks to
safeguard employees and students, and that is MCPS.

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APPENDIX A: SUPERINTENDENT’S RESPONSE
The MCPS Superintendent provided the following response to our report:

OFFICE OF THE SUPERINTENDENT

July 25, 2025

Megan Davey Limarzi, Esquire

Inspector General
51 Monroe Street, Suite 600
Rockville, Maryland 20850

Dear Ms. Limarzi,

The Inspector General's Review of MCPS Background Screening Office highlights urgent
and unacceptable gaps in the Montgomery County Public Schools (MCPS) and County Government
pre-hire clearance processes. As MCPS' new superintendent, I was astonished to learn that such
a gap was even possible; this has been the deepest disappointment of my early tenure. You have
my most sincere gratitude for illuminating such a glaringly significant irregularity.

On behalf of the school system, nothing is more important to me than our duty of care for the students
we serve and for the families who entrust their children to Montgomery County Public Schools.
Since becoming aware of this issue, it has become our top priority for correction. Consequently, MCPS
is taking immediate and decisive action to strengthen background screening processes for all new hires
as well as for the employees, contractors, and volunteers currently serving in our system.

That said, given the seriousness of this report, I also am deeply disappointed by the lack of rigor
in your office's review. We would have preferred to work with you to arrive at a fully accurate repo1t
that both agencies could support. Instead, our efforts to authentically collaborate with your team
to resolve glaring inaccuracies and to take the time to address action steps of this magnitude were
not reciprocated. As a result, we find ourselves at odds over your team's process and work product,
while we are moving quickly to ensure a safe environment for our students, staff, and families.

Since receiving your initial draft report, my leadership team and their staff have been working around
the clock to accomplish the due diligence that, regrettably, your office failed to do.

• Clarify the nuances of the law regarding background screening (even identifying incorrect
sections of COMAR in previous versions of your report that needed to be corrected by MCPS);

• Determine the actual roles and authority of the multiple agencies involved. We have pointed
out numerous times that not all of the roles and authority fall under MCPS' jurisdiction,
yet your office's report seems intent on passing sole responsibility for all aspects of this process
to MCPS;

• Recognize existing processes, and identify specific areas within those processes that require
attention. For example, Recommendation le states that MCPS should provide training related
to volunteer and contractor screening requirements. While our existing training would benefit
from improvement, your report failed to acknowledge that we already provide it. This reflects
an incomplete review on your part, which we needed to reconstruct.

15 West Gude Drive Suite 400 Rockville, Maryland 20850 rnontgorneryschoolsrnd.org

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APPENDIX A: SUPERINTENDENT’S RESPONSE

Megan Davey Limarzi, Esquire 2 July 25, 2025

These concerns have been amplified by a tone from your office of allegations instead of collaboration
or problem-solving. Meetings between your team and my team working on corrections have been time
unproductively spent in addressing inaccuracies introduced by your team. To your team's credit, some
of those inaccuracies have been corrected in the final repo1t; however, many hours were spent
correcting your office's work, costing all of us substantial time that could have been dedicated
to addressing the core concerns.

While we appreciate that some of the factual errors we raised were corrected in the final version,
substantial inaccuracies and misrepresentations remain. Some examples include:

• The stated purpose of this review was to assess legal compliance, but no specific
law, regulation, or policy was set forth in the section regarding Child Protective Services (CPS)
clearances. Instead, the report vaguely references "vulnerabilities" and potential liability
for MCPS. A straightforward articulation of the statutory and legal requirements here seems
to be an essential pa1t of your objective. Despite numerous requests for this clarity, we still
are unclear on this critical point.

• The report claims that "CWS has processed MCPS' {CPS} checks since 2013, but due
to the volume of checks required, MCPS has had to assign staff to augment CWS."
This is inaccurate. Child Welfare Services (CWS) leadership confirmed that CWS staff
do not conduct the clearance checks; instead, all CPS clearance processing is handled
by MCPS-funded personnel (one employee and one contractor) with CWS involvement
limited to reviewing indicated findings for accuracy and signing off on all clearances once
completed. The contractor manages pre-2024 cases; the employee handles 2024-2025 cases.
This is not "augmentation," it is the sole dedicated effort.

• The report recommends that MCPS take immediate action to clear the CPS backlog.
It is not possible for MCPS to take direct action as you recommend. The state does
not permit MCPS access to the data, records, and systems needed to conduct
the CPS screenings. One MCPS employee has been granted access to the system; however,
recent communications from the state have indicated that only CWS employees are permitted
to conduct screenings and access the information. Following multiple communications
and in-person meetings between MCPS and Montgomery County Department of Health and
Human Services (DHHS) staff and leadership, MCPS requested authorization to establish
a satellite office and add capacity on-site to our Background Screening Office.
Staff in the Maryland Department of Human Services (DHS) formally denied that
request on July 8, offering instead only one hour per day of additional staff time (July & letter).

• Your report fails to acknowledge the structural barriers imposed by the state-a key omission
given that this recommendation cannot be implemented without state and local cooperation.
Your office did not share with us until later in the internal discussions that your team had been
in contact with CWS during the review process; however, the report does not reference
any interviews or findings from those conversations. As you shared with us verbally, these
interviews included an estimate from CWS staff that it would take years to eliminate
the backlog.

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e | 12

APPENDIX A: SUPERINTENDENT’S RESPONSE

Megan Davey Limarzi, Esquire 3 July 25, 2025

MCPS has engaged directly with the state in an effort to find solutions; fortunately, we have made
the following progress:

• On July 11, I elevated this matter to the Maryland Secretary of the Depai1ment of Human
Services, emphasizing the seriousness of the matter and urging swift action (July 1I letter).

• My team and I have also spoken directly with Secretary Lopez and met with leaders at various
levels of our local DHHS.

• As a result, we understand that the state plans to provide additional state and local
CWS resources to help screen MCPS employees more effectively.

We are supremely grateful for the state's understanding of the urgency of this issue and their timely
partnership and response.

I also question your stated intent to suppot1 institutional improvements when, at multiple points in this
process, your office has impeded our ability to act swiftly and transparently.

• While you raised concerns about the need to enter previously fingerprinted employees into
RapBack in December 2024, you did not find it important to escalate a much more extensive
breakdown in CPS screenings or to flag your understanding that contractors may have started
work prior to fingerprinting clearance-issues that warranted immediate attention.

• Indeed, as I have outlined above, we have taken immediate steps to address and make positive
movement on CPS screenings. This work could have taken place earlier and been fu11her along
in advance of the upcoming school year had you raised it with me or my leadership team.

• My office meets regularly with your staff, yet the severity of these findings was never
expressed until the months-long review was completed.

• When the initial draft report was shared with my leadership team, you expressly directed
them not to share the existence of the report with anyone, including those responsible
for CPS clearances. Your office prioritized internal confidentiality pending your report
announcement over student safety. Your restriction delayed our ability to fully convey the level
of urgency and extent of the problem to those on whom we rely to complete this work.
This would have been, in my view, an opportunity to grant a narrow exception in favor of what
is best for the community.

• Our swift and decisive actions taken in the last three weeks make all the more frustrating your
office's lack of sharing concerning findings with us sooner, and the insistence that we hold
on sharing the true urgency with critical partners.

At no point in the repo1t do you recognize the obvious fiscal impact outside of the budget process
on the school system and, ultimately, county taxpayers. Your findings and recommendations require
"immediate action" without consideration of the financial feasibility to find resources to support that
action. At this time, we estimate a minimum of $2 million will be needed for our immediate response,
but we do not fully know the cost of our sho1t- or long-term investments. We will prioritize funding

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APPENDIX A: SUPERINTENDENT’S RESPONSE

Megan Davey Limarzi, Esquire 4 July 25, 2025

for this effort from among our already budgeted items, given the critical imp01iance. At the same time,
we would appreciate an acknowledgement and your support with our funding partners on the county
council for adequate resources to assuage this issue and future recommendations in other areas.

Let me be clear: On behalf of the school system, we take full responsibility for the gaps
in our portion of this process. My administration already is moving quickly to implement stronger,
more consistent screening and monitoring systems for employees, contractors, and volunteers.
Our commitment to our students and their families is non-negotiable, and we are taking the steps
necessary to ensure full compliance and safe staffing across all schools and central offices.

Let me also be clear: We embrace transparency and accountability. However, when your office issues
a report of this magnitude, it must be accurate, thorough, and grounded in fact. Anything less does
a disservice to the community we are all entrusted to serve. Our shared obligation-to be transparent,
accountable, timely, and effective- must be upheld in both action and review. The public deserves
nothing less, and they certainly deserve better than the process that generated this repoti.

It is my expectation that this response will be published along with your findings and our corrective
action plan so that our community and constituents understand the full scope and context
of these issues.

Sincerely,

/{/:::ayl~~ti:
Superintendent of Schools

TWT:sln

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e | 14

APPENDIX A: SUPERINTENDENT’S RESPONSE

Enclosure

OIG Review of Background Screening Office

MCPS Action Plan

The Office of the Inspector General (OIG) has illuminated critical and concerning gaps in several areas
of the MCPS Background Screening processes that require immediate attention. MCPS is moving swiftly
to thoroughly examine this critical area of responsibility and to implement robust systems and processes
to ensure that the requirements are met for all employees and for those volunteers and contractors who work
most closely with our students. Full compliance with the legal requirements for background screening will
require equal commitment and urgency from our sister agency, the Montgomery County Department
of Health and Human Services (DHHS), that has responsibility for Child Protective Services.

Finding 1: MCPS is not monitoring criminal histories for all employees and is not ensuring initial
criminal background checks are conducted for contractors and volunteers prior to them beginning
work.

Recommendation la: We recommend MCPS take immediate steps towards eliminating the backlog
of existing employees that have not been entered into RapBack.
Response: MCPS concurs with this recommendation.
Corrective Actions:
Sort data of employees who need to be fingerprinted July-August 2025
and entered into RapBack.

Develop a prioritized re-fingerprinting plan for September 2025

employees who are not in RapBack, according to job
type and hire date.

Complete re-fingerprinting and RapBack enrollment of No later than end of School Year 2025- 2026
all MCPS employees.

Recommendation lb: Ensure all applicable contractors and volunteers that may have unsupervised access
to students have the required criminal hist01y check completed prior to beginning work.
Response: MCPS concurs with this recommendation.
Corrective Actions:
Working through the Division of School Leadership August 2025
and Improvement, set and communicate clear
expectations for schools to ensure all applicable
contractors and volunteers are fingerprinted and cleared
prior to beginning work.

Working through the Division of School Leadership August 2025 (and ongoing)
and Improvement, increase monitoring and
accountability for completing requirements.

Implement a real-time clearance tracker for contractors July 2025

and volunteers for confirmation before a contractor or
volunteer can begin work.

Formalize procedures by updating existing volunteer October 2025

regulations and developing new regulations for
contractors.

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APPENDIX A: SUPERINTENDENT’S RESPONSE

Recommendation le: We recommend MCPS provide periodic training for all relevant administrators and
staff on the requirement to obtain background checks for individuals with unsupervised access to students,
and the process for initiating those checks.
Response: MCPS provides periodic training as described. MCPS will increase monitoring of and
accountability for completion.
Clarification: The Office of Student Leadership and Extracurricular Activities currently takes the
following steps to provide training and information:
• Develops training presentations for school-based volunteer liaisons and principals;
• Provides vi1tual trainings at the stati of the school year and is available for direct support throughout
the school year through multiple modalities (in person, vi1tual meeting, phone, email);
• Sends information and reminders three times per school year to principals regarding the need to
provide training and conduct appropriate background screenings;
• Maintains a hub ofresource information for schools and volunteers to access;
• Provides guidance documents, FAQs, and other materials in multiple languages;
• Maintains approved volunteer list of individuals who have completed the required training and
screening requirements, and suppo1is schools in confoming approved individuals.

Corrective Action:
While the measures described above are in place, the rep01t indicates that school-based staff are not fully
aware of the requirements and how to implement them consistently. MCPS will work through the Division
of School Leadership and Improvement to set clear expectations; increase monitoring and accountability
for completing these requirements; and ensure regular, annual training.

Finding 2: Not all individuals with access to MCPS students have undergone a Child Protective
Services check.

Recommendation 2: We recommend MCPS take action towards eliminating the backlog of Child
Protective Services (CPS) checks.
Response: MCPS concurs that eliminating the backlog of Child Protective Services checks is a high priority
concern. However, MCPS has not, to date, been authorized to conduct or supervise CPS checks, nor to
have CPS checks conducted on MCPS prope1ties.
Corrective Actions:
While MCPS is committed to swift action to address this critical gap in background screening, the
recommendation does not acknowledge the reality that a separate agency has full authority and
responsibility for this process.

Work with Montgomery County Child Welfare Services to July 2025

transition away from a paper-based system transpo1ted
between agencies to a single online submission and
tracking system. This will reduce processing time and
improve cross-agency coordination.

Advocate with local Child Welfare Services and state Immediate and ongoing
Department of Human Services leadership to determine
what resources and processes can be brought to address
this gap.

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APPENDIX A: SUPERINTENDENT’S RESPONSE

Finding 3: MCPS has no formal procedures governing suitability determinations.

Recommendation 3: We recommend MCPS implement comprehensive regulations and associated

procedures for investigating and making suitability determinations for applicants with a criminal histoty
but no disqualifying offenses.
Response: MCPS concurs with the need for formal procedures.
Corrective Actions:
Establish procedures for reviewing applicants with criminal August 2025
histmy but no disqualifying offenses.

Review organizational structure and office with August 2025

responsibility for review and determination.

Review existing regulations for background screening, and Fall 2025

update to include suitability review procedures.

Finding 4: MCPS does not consistently remove individuals from RapBack who have been separated
from MCPS or otherwise no longer need to have their criminal history monitored.

Recommendation 4: We recommend MCPS implement a formal process to identify and remove any
individual they enrolled in RapBack that is no longer employed or no longer has unsupervised access to
students.
Response: MCPS concurs with this recommendation.
Corrective Action: MCPS will develop procedures to clear RapBack enrollment for employees,
contractors, and volunteers as part of the termination, separation, or other off-boarding processes. MCPS
will initiate these processes no later than December 15, 2025.

Finding 5: MCPS does not ensure volunteers have taken the required training, Recognizing and
Reporting Child Abuse and Neglect.

Recommendation Sa: We recommend MCPS take appropriate steps to ensure the completion and continual
tracking of CAN {child abuse and neglect} training for all applicable persons.
Response: MCPS does have a tracking mechanism for training of volunteers and contractors; however,
MCPS concurs that the monitoring process needs to be strengthened.
Corrective Action: Consistent with the response to recommendation le, MCPS will work through the
Division of School Leadership and Improvement to set clear expectations and increase monitoring and
accountability for completing these requirements.

Recommendation Sb: We recommend that MCPS clarify CAN {child abuse and neglect} training
requirements for contractors.
Response: MCPS concurs with this recommendation.
Corrective Action:
Formalize procedures by updating existing volunteer October 2025
regulations and developing new regulations for contractors.

MONTGOMERY COUNTY OIG PUBLICATION #26-01 P a g e | 17

 APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP
This Appendix provides a summary of the findings and recommendations presented in this report along with the OIG’s
assessment of the county’s progress towards addressing the recommendations. The OIG categorizes progress towards
implementation into the following 4 status groups:

• Open Unresolved: No management response, inadequate response, or no agreement on corrective action plan.
• Open In Progress: Agreed on planned action, auditee is in the process of implementing stated actions, but no evidence of
implementation has yet been provided to the OIG.
• Open Resolved: Auditee provided support to OIG indicating implementation was complete, OIG testing to ensure
implementation.
• Closed: Recommendation has been implemented.

Finding # Finding Recommendation Superintendent’s Response Status

1 MCPS is not monitoring criminal 1a) We recommend MCPS take • Sort data of employees who need Open – In Progress
histories for all employees and is not immediate steps towards to be fingerprinted and entered
ensuring initial criminal background eliminating the backlog of existing into RapBack (July-August 2025).
checks are conducted for contractors employees that have not been • Develop a prioritized re-
and volunteers prior to them entered into Rap Back. fingerprinting plan for employees
beginning work. who are not in RapBack,
according to job type and hire
date (September 2025).
• Complete re-fingerprinting and
RapBack enrollment of all MCPS
employees (No later than end of
school year 2025-2026).
- - 1b) We recommend MCPS ensure • Working through the Division of
all applicable contractors and School Leadership and Open – In Progress
volunteers that may have Improvement, set and
unsupervised access to students communicate clear expectations

Montgomery County OIG Publication #26-01 P a g e | 18

 APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP

have the required criminal history for schools to ensure all applicable
check completed prior to beginning contractors and volunteers are
work. fingerprinted and cleared prior to
beginning work (August 2025).
• Working through the Division of
School Leadership and
Improvement, increase
monitoring and accountability for
completing requirements (August
2025).
• Implement a real-time clearance
tracker for contractors and
volunteers for confirmation
before a contractor or volunteer
can begin work (July 2025).
• Formalize procedures by updating
existing volunteer regulations and
developing new regulations for
contractors (October 2025).
- - 1c) We recommend MCPS provide The report indicates that school-
periodic training for all relevant based staff are not fully aware of the
administrators and staff on the requirements and how to implement
requirement to obtain a criminal them consistently. MCPS will work Open – In Progress
history check for individuals with through the Division of School
unsupervised access to students, Leadership and Improvement to set
clear expectations; increase

Montgomery County OIG Publication #26-01 P a g e | 19

 APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP

and the process for initiating those monitoring and accountability for
checks. completing these requirements; and
ensure regular, annual training.
2 Not all individuals with access to We recommend MCPS take While MCPS is committed to swift
MCPS students have undergone a immediate action towards action to address this critical gap in
Child Protective Services check. eliminating the backlog of CPS background screening, the
checks. recommendation does not
acknowledge the reality that a
separate agency has full authority and
responsibility for this process.
• MCPS will work with
Montgomery County Child
Welfare Services to transition
away from a paper-based system Open – In Progress
transported between agencies to
a single online submission and
tracking system. This will reduce
processing time and improve
cross-agency coordination (July
2025).
• MCPS will advocate with local
Child Welfare Services and state
Department of Human Services
leadership to determine what
resources and processes can be

Montgomery County OIG Publication #26-01 P a g e | 20

 APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP

brought to address this gap

(immediate and ongoing).
3 MCPS has no formal written We recommend MCPS implement • Establish procedures for
procedures governing suitability comprehensive regulations and reviewing applicants with
determinations for applicants with associated procedures for criminal history but no
criminal histories. investigating and making suitability disqualifying offenses (August
determinations for applicants with a 2025).
criminal history but no disqualifying
offenses. • Review organizational structure
and office with responsibility for Open – In Progress
review and determination
(August 2025).
• Review existing regulations for
background screening, and
update to include suitability
review procedures (Fall 2025).
4 MCPS does not consistently remove We recommend MCPS implement a MCPS will develop procedures to
individuals from Rap Back who have formal process to identify and clear RapBack enrollment for
separated from MCPS or otherwise remove any individual they enrolled employees, contractors, and
no longer need to have their criminal in Rap Back that is no longer volunteers as part of the termination,
employed or no longer has Open – In Progress
history monitored. separation, or other off-boarding
unsupervised access to students. processes. MCPS will initiate these
processes no later than December 15,
2025.
5 MCPS does not ensure all applicable 5a) We recommend MCPS take Consistent with the response to 1c,
volunteers have taken the required appropriate steps to ensure the MCPS will work through the Division Open – In Progress
completion and continual tracking of School Leadership and

Montgomery County OIG Publication #26-01 P a g e | 21

 APPENDIX B: RECOMMENDATION STATUS AND FOLLOW UP

training, Recognizing and Reporting of CAN training for all applicable Improvement to set clear
Child Abuse and Neglect. persons. expectations and increase monitoring
and accountability for completing
these requirements.
- - 5b) We recommend MCPS clarify Formalize procedures by updating
CAN training requirements for existing volunteer regulations and
Open – In Progress
contractors. developing new regulations for
contractors (October 2025).

Montgomery County OIG Publication #26-01 P a g e | 22