VITA · TCE · Tax-Aide

The volunteer role where the risk is not physical

A free tax prep volunteer sees an entire household's Social Security numbers, bank routing details, income records and photo ID — for filers who are disproportionately elderly or low-income. The IRS requires conduct certification, not a criminal check. That part is yours. Screen every volunteer for $5.

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National criminal + federal watchlists + all 50 state registries · Results in minutes · FCRA-compliant

What the IRS requires, and what it does not

This gets misreported constantly, so it is worth being precise. The IRS runs a rigorous conduct and certification program for VITA and TCE volunteers. It does not run a vetting program.

The IRS requires

Volunteer Standards of Conduct certification: Every VITA and TCE volunteer must pass the VSC test with a score of 80% or higher before taking any other certification test and before working at a site.
A signed Form 13615, every year: The Standards of Conduct agreement is an annual requirement, not a one-time onboarding step. Last season’s signature does not carry forward.
Identity confirmation by a named person: Form 13615 is not valid until a site coordinator, sponsoring partner, instructor or IRS contact confirms the volunteer’s identity, name and address, and signs it.
Conduct standards with teeth: The standards explicitly bar criminal, dishonest or notoriously disgraceful conduct, and bar accepting payment or refund funds from taxpayers.

It leaves to your organization

The criminal background check itself: The IRS does not require a criminal background check for all VITA and TCE volunteers. Individual sponsoring organizations may choose to run one — and most that handle serious volume do.
Deciding what a record means: If something surfaces, the IRS gives you no adjudication matrix. Your organization decides which findings are disqualifying for a role that touches financial data, and writes it down before the season starts.
FCRA consent and adverse action: Running a check makes you a user of consumer reports, with a legal obligation to obtain standalone written authorization and to follow the pre-adverse and adverse action sequence if you act on a result.
Re-verifying returning volunteers: The conduct agreement renews annually. Whether the background check does is your policy call — and a five-year-old clearance on someone handling SSNs is a thin defense.

What is actually on the table

Write out everything a volunteer handles in a single appointment and the screening question tends to answer itself.

Social Security numbers

The filer, the spouse, and every dependent child

Bank routing & account numbers

For direct deposit of the refund

W-2s, 1099s and income records

Employer, wages, and full mailing address

Dependent details

Children’s names, ages and Social Security numbers

Refund amounts and timing

Exactly how much is arriving, and when

Photo ID

Driver’s license or state identification card

And who is sitting across from them

Elderly filers

Tax Counseling for the Elderly exists precisely because older adults need the help. It is also the demographic most targeted for financial exploitation, and the one least likely to notice a fraudulent return filed in their name.

Low-income households

A refund with the Earned Income Tax Credit attached can be the largest single sum a family receives all year. That makes it a target, and it makes the person preparing the return unusually powerful in that family’s life.

People with no fallback

A filer at a free tax site typically has no accountant, no attorney, and limited ability to unwind identity theft once it happens. The consequences of getting this wrong land entirely on them.

Identity verification is a separate question from criminal history. The IRS already recognizes this — Form 13615 is invalid until a coordinator confirms the volunteer's name and address in person. A background check tells you whether a person has a record; it does not tell you the person in front of you is that person. Both matter more here than almost anywhere else. See how identity verification works alongside the check.

The season, in order

The single most useful change most sites make is moving screening ahead of certification training rather than after it.

Oct – Nov
Recruit and screen
Screen before certification training rather than after. There is no sense investing training hours in someone your own policy would not place at a site.
Dec – early Jan
Certify
Volunteers pass the Standards of Conduct test and any tax-law certification their role requires, then sign Form 13615 for the new season.
Mid-January
Coordinator verification
Your site coordinator confirms each volunteer’s identity, name and address, and signs the form — the step that makes it valid.
Late Jan – Apr 15
The season runs
Add mid-season volunteers on the same track, not a shortened one. February recruits handle exactly the same data as January ones.

Running checks makes you a user of consumer reports. That brings real obligations: a standalone written disclosure, separate written authorization, and the pre-adverse and adverse action sequence before you act on a result. It is not onerous, but it is not optional either — FCRA compliance covers it, and the workflow is built into the dashboard.

Site coordinator questions

Does the IRS require background checks for VITA volunteers?

No. The IRS does not require a criminal background check for all VITA and TCE volunteers — it requires Standards of Conduct certification and an annual signed Form 13615, validated by a coordinator who confirms the volunteer’s identity. Individual sponsoring organizations may choose to run criminal checks on their own, and many do, because the IRS minimum is a floor rather than a complete vetting program.

So why screen tax volunteers at all?

Because of what is on the table. A tax prep volunteer sees Social Security numbers for an entire household, bank routing and account numbers, income records and a photo ID — for filers who are disproportionately elderly or low-income. It is the one volunteer role where the realistic harm is financial rather than physical, and where a single bad actor can do quiet damage to dozens of families across a season.

What should a tax volunteer background check include?

A national criminal search across county, state and federal sources plus federal watchlist screening is the practical baseline; fraud, theft and financial crimes are the findings most relevant to this role. Every $5 VolunteerBadge check includes that, along with all 50 state sex-offender registries and the national registry — useful because many sites also see unaccompanied minors and vulnerable adults.

Is identity verification different from a background check?

Yes, and this role needs both. A background check asks whether a person has a record; identity verification asks whether they are who they say they are. The IRS already built identity confirmation into Form 13615 by requiring a coordinator to verify name and address in person. A document-and-selfie verification does the same job with an audit trail attached.

Do we need to re-screen returning volunteers every year?

The Standards of Conduct agreement is explicitly annual. Whether the background check renews annually is your organization’s policy, but given the data involved, a one- or two-year cycle is a reasonable standard and is what most sponsoring organizations settle on.

How much does it cost to screen a tax site’s volunteers?

$5 per volunteer, charged only when someone completes their application. A site running twenty volunteers costs $100 for the season. There is no subscription or platform fee, and unused credits never expire.

What if a volunteer has an old financial conviction?

Decide the standard in writing before the season, not case by case in February. Consider how long ago it was, whether it relates to fraud or theft, and whether the role can be structured with supervision. If you take adverse action based on the report, FCRA requires a pre-adverse action notice with a copy of the report and a summary of rights before the final decision.

Screening other adult-serving programs? See Meals on Wheels screening and veterans organization screening, or plan the year with the volunteer screening calendar.

Screen before certification, not after

Create your organization free, screen the roster in the fall, and start the season knowing who is cleared to sit at that table. $5 a volunteer, credits never expire.

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