FY23 ICAOS Compliance Audit

ANNOUNCED TO COMMISSION MEMBERS April 18th, 2022

In FY 2023, the national office will devote audit resources and capabilities to assessing the reliability and credibility of ICOTS data. The Commission has ICOTS data exchanges with local, state, and federal law enforcement agencies. Several states also use exchanges to import or compare ICOTS data with their state’s offender management applications. As a result, the Commission must ensure that the data extracts contain accurate, reliable, and up-to-date information for our internal and external partners.

Further, initiatives promoting dashboard usage among deputy compact administrators indicate little progress in identifying and resolving data entry errors. The number of duplicate and junk offenders continues to rise, implying that states are not taking the necessary steps to ensure the accuracy of ICOTS data. In accordance with Privacy Policy 4 (c) and at the direction of the Compliance and Executive Committee, the FY23 audit will focus on five areas outlined below:

Demographic Audit See ICOTS Privacy Policy, Section 15 (A)

• • Active Offender Report:
    • Race=NULL: XX# (XX%)
    • Social Security=NULL: XX# (XX%)
    • Social Security=invalid number (e.g., 999-99-9999): XX# (XX%)
    • FBI Number=NULL: XX# (XX%)
    • DOB=invalid number (e.g., Offender’s age < 14 yr. old) XX# (XX%)

Note :  Focus for this cleanup is the ensure no invalid or incorrect data exists on the records.  Therefore, if errors are identified after transfer of supervision and relocation of the client has occurred,  this means the sending state failed to identify these errors in their review of outgoing transfer documentation.  Remember the sending state is the supervising state until the transfer process is complete (NOA in a receiving state) and has the ability to correct any of these errors themselves via 'edit demographics' until then. 

In instances where errors are missed in outgoing activity review, sending states may need to reach out to the supervising state (receiving state) to correct erred data.  It is NOT expected receiving states are asked to add missing core demographic data (specifically FBI# and Race.)  

Photo Audit: Primary photo from transfer requests sent during FY22. See ICOTS Privacy Policy, Section 15(D)

Note:  Photos will be pulled from transfers reviewed by sending state during FY22.  Attempts to 'correct' bad primary photos at this point, will not affect the outcome of the audit.  

Junk/Duplicate Offender Profile Clean-up Audit: See ICOTS Privacy Policy, Section 15 (C) & 5 (A)

• • Junk Offender Record Report
    • Creation date > 45 calendar days
    • Created by ‘username’
  • Possible Duplicate Offender Report identifies matches on:
    • First name, last name & date of birth, or social security number (Report non-duplicates to the national office to ensure accuracy)
    • Pending request type & creation date > 45 days from report generation

Note:  REVIEW records to ensure appropriate offender management actions are taken.  https://support.interstatecompact.org/hc/en-us/articles/224745447-Merge-Move-and-Delete-Case-Requests

Rejected Case Clean-up Audit: See ICOTS Privacy Policy, Section 5 (A) & 8 (A)

• • Rejected Cases Never Transferred Report:
    • Rejected Date > 60 days from report generation.

Offenders Awaiting Retaking Audit: See ICOTS Privacy Policy, Section 5 (A) & 8 (A)

• • Offenders Awaiting Retaking Dashboard (Incoming Cases) identifies cases invoking Mandatory Retaking where ‘Availability’ indicates ‘Yes’
    • Receiving states to confirm report accuracy

Note:  Records showing in error on this report can be removed in 2 ways using a violation addendum. 

1. Indicating 'not available' for retaking
2. Noting 'retaking no longer required'