Addressing ‘Business Interests’ and the Funding Myth

Written by Mike Cariola, President & CEO, Bode Technology, and Co-Founder of FCJA

This is the 2nd article in response to the recent CFSO Position Paper opposing private laboratory access to CODIS. While the paper raises several concerns, many are without merit, and in some instances, misrepresent the proposed legislation (H.R. 7916).

The bill itself can be found here.

This paper addresses two specific claims: the supposed risk of private business interests and the claim that this bill would redistribute federal funds away from public labs.

I. Business Interests

The paper suggests that because private labs are businesses, they are inherently less trustworthy than government entities.

Specifically, they argue that:

1.      The operation and governance of CODIS are appropriately treated as core governmental functions. Public laboratories are not motivated by profit margins or financial investors and exist solely to protect the safety of the public and the integrity and security of the data.

2.      Public laboratories are not influenced by the pressures of competition within the industry that can lead to shortcuts in process and quality assurance and control.

To suggest that government employment is a shield against misconduct is historically inaccurate. Consider names like Robert Hanssen, Aldrich Ames, Edward Snowden, and Julius Rosenberg. These individuals, ranging from federal employees to contractors, were entrusted with some of the nation’s most sensitive security information. All compromised national security for various personal or financial motives.

Businesses and governmental organizations are neither inherently good nor bad. Ethics and integrity are built by individuals. Organizations, both government and corporate, are reflective of their people.

Regarding the concern that competition leads to shortcuts, it ignores the current utilization of the private sector by public labs and a key provision of the bill:

1.      Public laboratories already place a tremendous amount of confidence in private labs. Outsourcing of criminal casework by public labs has been common practice for over 25 years. If private labs were routinely taking shortcuts, public agencies would have ceased the practice long ago. You cannot simultaneously argue that a private lab is trustworthy and qualified to test the evidence and testify to it in court but is unqualified to enter the DNA profile into the CODIS database.

2.      Second, in the unlikely event that granting CODIS access to private labs results in an erosion of quality, the bill includes a safeguard, specifically that private labs must have been accredited for 5 consecutive years. This provision, which is not a requirement for public labs, is a powerful measure to ensure quality. Once gained, if a private lab were to lose CODIS access for more than 5 years, it would likely be a death blow.

II. The Threat to Federal Funding is a Mischaracterization of the Bill

The opening of the CFSO paper reads as follows:

The Consortium of Forensic Science Organizations (CFSO) opposes H.R.7916 or any legislation granting private laboratories direct access to the Combined DNA Index System (CODIS) or to redistribute federal government grants currently designated for public laboratory DNA purposes(emphasis added).

Let’s be clear: The bill seeks NO funding.

Existing grant programs such as CEBR and SAKI explicitly prohibit private laboratories from applying. We have been transparent from the start that we are not seeking any funding or redistribution of existing grant programs designated for public labs. We are seeking the ability to do our jobs more efficiently.

If anything, the bill protects public resources. By allowing private labs to upload directly, redundant work would be eliminated, allowing public labs to complete more casework (and perhaps even reducing the amount of casework that is outsourced).

Why has CFSO elected to mischaracterize the bill? We can only surmise that by framing it as a threat to funding, they hope to rally opposition. I encourage my colleagues and lab directors to read the actual text of the bill to form your own opinion.

Looking Ahead

In the meantime, I encourage lab directors to share their challenges with the CFSO, the FBI or directly with me. Regardless of the outcome of this bill, I am optimistic that this initiative has started a vital conversation about how we can improve forensic services in support of public safety.

This article was originally posted on LinkedIn on April 9, 2026.

Forensic Criminal Justice Alliance Applauds FBI Advancement of Rapid DNA Technology

The Forensic Criminal Justice Alliance (FCJA) applauds the Federal Bureau of Investigation's (FBI) recent actions to expand the use of Rapid DNA technology within the national CODIS framework. By approving the first Rapid DNA cartridge for qualifying forensic crime scene samples eligible for national CODIS searches, the FBI has taken an important step toward accelerating investigative leads while maintaining the rigorous quality standards that underpin the nation's DNA database.

As an organization dedicated to advancing forensic science and supporting criminal justice professionals, FCJA believes that responsibly implemented changes have the power to strengthen investigations, improve public safety, and deliver answers to victims and their families more quickly. The FBI's continued advancement of Rapid DNA technology reflects the same principles that drive FCJA's mission: fostering innovation, promoting collaboration, and supporting the responsible adoption of technologies that improve forensic outcomes.

"Progress in forensic science depends on our willingness to conscientiously embrace change," said Mike Cariola, Co-Founder of the FCJA. "The FBI's decision demonstrates that new technologies can be integrated into existing forensic systems without compromising scientific integrity. By implementing advancements like these, we can help investigators generate answers faster while maintaining the quality and integrity that victims, families, and our justice system deserve."

"The FBI's advancement of Rapid DNA is another example of how thoughtful innovation can strengthen the forensic community," said Allison Nunes, Co-Founder of the FCJA. "Our mission is to advocate for policies and technologies that remove unnecessary barriers, expand access to proven forensic capabilities, and help investigators find investigative insights sooner. Whether it's supporting advancements like Rapid DNA or advocating for broader access to CODIS for qualified laboratories, we believe in making changes that help the community solve more crimes and serve victims more effectively."

About the Forensic Criminal Justice Alliance

The Forensic Criminal Justice Alliance (FCJA) is committed to advancing the future of forensic science through advocacy, education, and collaboration. By bringing together experts across the forensic and criminal justice communities, FCJA supports the responsible adoption of innovative technologies, promotes policies that strengthen forensic practice, and works to accelerate the delivery of reliable answers for investigators, victims, and the communities they serve.

Addressing Inaccuracies and Misleading Information In Recent CFSO Position Paper

Written by Mike Cariola, President & CEO, Bode Technology, and Co-Founder of FCJA

The recent CFSO (Consortium of Forensic Science Organizations) position paper opposing private laboratory access to CODIS is unfortunately littered with distracting inaccuracies and strawman arguments. Rather than rebut every misstatement in the paper, I will address the most glaring. And rather than responding in an overly long single post, I will post over time.

We are happy to address any questions people may have about this topic and why we fervently believe that significant changes are needed to the current system to improve the forensic science system. You can learn more about our initiative at FCJA.

Today I will address the false statements about private labs overall. The paper expresses concern about the overall instability of private DNA lab companies and that this potentially creates follow-up issues for cases. Specifically, the paper says:

Many private DNA laboratories providing DNA casework and DNA database work have gone out of business.  Notable laboratories that have done work in the forensic DNA space that have gone out of business, been sold, or left the forensic industry entirely are: Myriad Genetics, Relative Genetics, Orchid, Cellmark, Sorenson Forensics, Orchid Cellmark, NMS DNA Laboratory, Intermountain Forensics, Forensic Analytical Specialties, Genescreen, and Reliagene among others.

Firstly, being sold is akin to a public lab getting new executive leadership and is not the same as ‘going out of business’. Let’s address each one individually:

• Myriad Genetics. Company is alive and well. In the early 2000s, Myriad provided forensic databasing services and exited forensics over 20 years ago because biotechnology was a much better business (personal conversations). They developed one of the earliest genetic tests for breast cancer (testing for the BRCA gene) and have continued to focus on early detection of many types of cancer. In the unlikely event that data from 20 years ago, generated on Macintosh G4s, is ever needed, they can be reached. I am happy to facilitate introductions.

• Relative Genetics. In my 25+ years of working at a private DNA laboratory, I have never heard of this company and there is no indication that they ever provided forensic services. According to Wikipedia, they provided genealogy services and were bought by AncestryDNA in 2007.

• Orchid. Never existed. See Orchid Cellmark.

• Cellmark. Same entity as Orchid Cellmark. See below.

• Sorenson Forensics. Still exists and currently provides forensic science services.

• Orchid Cellmark. In 2011, LabCorp bought Orchid Cellmark. In 2014, LabCorp bought Bode and renamed the merged entity Bode Cellmark Forensics. In 2019, I executed a management buyout from LabCorp. We maintain the records for Orchid Cellmark, regularly provide discovery materials and testify for Orchid Cellmark cases.

• NMS DNA Laboratory. NMS is a thriving forensic science provider. While they made the business decision to exit DNA services, most public laboratories utilize their other services and I am confident they can provide their DNA records if needed.

• Intermountain Forensics. Acquired by DNA Labs International in 2024. DLI maintains the records.

• Forensic Analytical Specialties. Cannot locate any records for a company by this name. Perhaps this refers to Forensic Analytical Crime Lab? If so, we are happy to inform you that they have been operating since 1994 and are a member of our coalition. 

• Genescreen. Was part of Orchid Cellmark. Bode maintains the records.

• Reliagene. Was part of Orchid Cellmark. Bode maintains the records.

The CFSO position paper goes back more than 25 years in an apparent attempt to show that the private DNA labs have come and gone, and the associated forensic data has disappeared. As outlined above, this is wholly inaccurate.

Most of the labs in our coalition have been continuously providing accredited forensic DNA testing for decades, including SERI (>30 years), Forensic Analytical Crime Lab (>30 years), Bode (>30 years), and DNA Labs International (>25 years).

Furthermore, the NDIS Procedures Manual already addresses how data should be handled in the event that a laboratory closes. Specifically, Section 2.6, titled ‘NDIS Laboratory Ceases Operations – Transfer of Ownership of DNA Records at NDIS’, addresses in detail how to handle DNA records should an NDIS laboratory cease operations. This clause likely was inserted due to public crime labs such as the Houston Police Department and the Detroit Police Department ceasing operations. Thankfully the stewards of CODIS figured out a way to preserve the data.

Data stewardship is an important issue; however, I am confident that it can be properly addressed for private labs through open discussions and controls within the NDIS Procedures Manual.

Next I will address the CFSO statement that ‘Public laboratories are not motivated by profit margins or financial investors and exist solely to protect the safety of the public…’.

This article was originally posted on LinkedIn on April 2, 2026.

Forensic Science Should Help Lead Investigations, Not Trail Them: The Case for Private Lab CODIS Upload Access

Written by Mike Cariola, President & CEO, Bode Technology, and Co-Founder of FCJA

The latest census on publicly funded labs shows almost 50% of labs utilize outsourcing, the majority of which is for DNA [1]. Data from Project Foresight shows that from 2017 to 2023, backlogs increased by 13% and turnaround times in DNA increased by 88% [2]. During this same time, private laboratories led the way in dramatically reducing backlogs of sexual assault cases around the country, including large efforts in North Carolina, Massachusetts, Oklahoma, Texas, Missouri, San Diego and Utah. With over 20 years of data and hundreds of thousands of criminal cases worked, it is clear that outsourcing is an essential pillar of the forensic DNA network. Yet, despite our technological advancements, we are still operating under a regulatory model that creates avoidable bottlenecks, delays justice and leaves viable leads on the table.

A recently introduced bill in Congress aims to change this by granting qualified, accredited private labs the ability to upload DNA profiles directly to CODIS. As a member of the Forensic Criminal Justice Alliance (FCJA), I believe this critical modernization effort for our industry will reduce turnaround times, increase capacity and, ultimately, solve more cases.

This article demonstrates that the current model is broken and why private lab CODIS upload access is a critical need.

Technology Mirroring: A Barrier to Innovation and Efficiency

CODIS is an amazing tool, allowing NDIS-participating labs to speak a common language (STR core loci) and obtain investigative leads across jurisdictions. The NDIS Procedures manual very clearly lays out the ways NDIS participating labs can achieve CODIS-eligible profiles (i.e. approved STR kits, approved platforms, etc). Each NDIS participating lab is then free to choose how to achieve that end goal.

Conversely, the existing public lab oversight model for private labs requires that the private lab must mirror the procedures of the NDIS lab from where the case originates.  The concept is fundamentally flawed, overly prescriptive, and limiting in the ability to apply the best technologies available for each case. To be more specific, if we receive four sexual assault cases from four different jurisdictions, we are often required to use four different STR kits to reach the exact same end result. This has profound negative operational impacts.

• The Workflow Burden: To upgrade a piece of software (like STRmix) or change a thermalcycler model, a private lab will have to conduct 4x the validations to satisfy different jurisdictional requirements. This results in higher costs to the submitting agency and the federal government (if federally funded).

• Potential Quality Concerns: When analysts are forced to toggle between sporadic, jurisdiction-specific workflows rather than mastering a consistent, optimized process, it increases the risk of errors. This is a concept that any process engineer would recognize as problematic.

With CODIS access, private labs would follow established NDIS Procedures, under agency contractual oversight, while maintaining the autonomy to use the most effective, validated path to a DNA profile.

Choosing the Best Technology for the Case

The current model often prevents private labs from using the best tools available for difficult evidence. Here are a few examples and the estimated number of cases affected by each:

• Probabilistic Genotyping (PG): Recent data shows roughly 40% of the labs we work with do not allow the use of PG. This directly results in fewer CODIS-eligible profiles from complex mixtures. This affects thousands of cases annually.

• Highly Degraded Samples: Technologies like Minifiler or PowerPlex 35GY and other upcoming 8-dye chemistries are far superior for compromised evidence, rootless hairs or degraded bone, yet they are rarely utilized due to the difficulty of public-lab validation and upload. This affects hundreds of cases annually.

• Mitochondrial DNA & Missing Persons: With only a handful of public labs online for mtDNA (estimated at less than 10), the options for entering data into CODIS for missing persons cases are severely hampered. This affects thousands of cases annually.

How Outsourcing Impacts Public Lab Efficiency: 100% Technical Review

Oversight is vital, but 100% technical review of vendor data by public labs is a solution that has become its own problem. It creates a massive administrative burden on public lab directors and staff, and delays the entry of profiles, sometimes for over a year after the work is completed (publicly available examples can be provided upon request).

Private labs must already meet rigorous FBI Quality Assurance Standards and, if passed, the bill would require private labs to meet the FBI’s CODIS access requirements as well. This bill maintains those high standards while streamlining the data-sharing process.

Public laboratories that contract with private labs also enter into contractual agreements, allowing them to determine how to best utilize the capabilities of the private labs while also performing their contractual oversight responsibilities. True oversight can be achieved more effectively through blind QC, audits, and subset reviews, allowing investigative leads to be generated in days rather than months.

Why Now?

For me, the tipping point was when the Washington, D.C. laboratory unfortunately lost its accreditation in 2021. When a lab loses accreditation, it loses access to CODIS and the ability to perform casework. Nobody can fill the void this creates except private labs and from 2021-2023, private labs were utilized extensively to conduct DNA testing on criminal casework. However, private labs could not assist with vital CODIS uploads, resulting in CODIS entries dropping by 91% and CODIS hits falling by 61% while crime in the District was spiking. By 2023, over 1,200 cases had been processed but not entered into CODIS [3]. With private lab CODIS access, this situation could have been largely prevented.

We saw a similar situation recently in Colorado, where a backlog of 1,300 sexual assault kits quickly developed. The Common Sense Institute conducted an analysis on the cost of delayed DNA testing [4], stating that clearing a backlog of 1,300 kits could prevent over 1,000 future sexual assaults and save the economy hundreds of millions of dollars. Critically, they noted that the longer the authorities waited, the larger the costs and the smaller the savings. The state ultimately elected to utilize private labs to work through the backlog expeditiously. However, inevitably, this unexpected influx of cases requiring technical review by the already burdened public lab resulted in a reduction in their own casework capacity (thereby increasing their internal backlog).

The above examples are in no way criticisms of public labs. They are real life examples of the challenges faced by all forensic DNA labs and the added public safety consequences of private labs not having CODIS upload access.

The Bottom Line

There are risks to any major change. Increased competition, slippery slope concerns and the costs of CODIS compliance are real considerations. But the risk of maintaining the status quo is higher. We cannot continue to let administrative bottlenecks stand between a DNA profile and a break in a case.

Streamlining this process could help public labs maximize limited resources, reduce duplicative efforts, and direct more time and funding toward additional testing, case support, and investigative priorities. Most importantly, it would help prevent investigative delays and reduce opportunities for recidivism by violent offenders.

Forensic science has the potential to lead and expedite investigations. It’s time we have the legislative framework to match.

Articles cited:

[1] https://bjs.ojp.gov/library/publications/publicly-funded-forensic-crime-laboratories-2020

[2] https://thecfso.org/presentations/2026/02/2026-aafs-presentation/

[3] D.C. Council. (2024, January 29). FY23 Oversight Pre-Hearing Questions – Department of Forensic Sciences. https://dccouncil.gov/wp-content/uploads/2024/08/DFS-FY23-Oversight-Pre-Hearing-Questions_1.29.24.pdf

[4] https://www.commonsenseinstituteus.org/colorado/research/crime-and-public-safety/the-benefits-of-eliminating-colorados-sexual-assault-kit-backlog

This article was originally posted on LinkedIn on April 23, 2026.

Press Release: Rep. Troy E. Nehls Introduces CODIS Access Modernization Act

March 12, 2026

WASHINGTON, D.C. —Today, Congressman Troy E. Nehls (R-TX-22) introduced the CODIS Access Modernization Act, which would allow privately-owned and operated forensic evidence DNA testing laboratories to directly upload qualifying DNA profiles to the National DNA Index System (NDIS), so long as they meet certain requirements. 

Currently, accredited private forensic DNA laboratories, meeting the same Federal Bureau of Investigation (FBI) Quality Assurance Standards and  ISO/IEC 1025 requirements as public laboratories, are barred from directly uploading DNA profiles to the Combined DNA Index System (CODIS), resulting in redundant reviews that delay investigations and impose significant costs on public agencies. 

“By limiting CODIS access to public laboratories, glaring national security and public safety bottlenecks have been created,” said Congressman Nehls. “My bill would grant CODIS access to eligible private laboratories and accelerate case resolutions, increase DNA matches and arrests, reduce the burden on public laboratories, and prevent additional offenses, resulting in getting more violent offenders off our streets and put behind bars.” 

Supporting organizations of the CODIS Access Modernization Act include the International Homicide Investigators Association, National Center for Missing and Exploited Children, Federal Law Enforcement Officers Foundation, Southeastern Homicide Investigators Association, Miami-Dade County Association of Chiefs of Police, North Aurora Police, Pasco Police Department, Louisville Metro Police Department, Beverly Hills Police Department, Project Cold Case, Season of Justice, Joyful Heart Foundation, H-E-A-R-T (Hope Exists After Rape Trauma), Project Beloved, Not Just Me Foundation, Lavinia Masters, Bode Technology, DNA Labs International, Signature Science, Pure Gold Forensics, Serological Research Institute, DNA Solutions, and Forensic Analytical Crime Lab. 

“A CODIS hit is a vital piece of information in a criminal investigation,” said Tracy Matheson, President and Founder of Project Beloved. “They may identify an unknown perpetrator or they may reveal the serial nature of a known perpetrator.  It is absolutely essential that the CODIS hits are uploaded in a timely and efficient manner so that justice may be served. Giving private labs access to upload CODIS hits directly is a much needed step to streamline this process and protect future victims.”

“Justice delayed is justice denied. By leveraging the high-throughput workflows and innovative technologies of private labs, together we can expedite the identification of criminals before they strike again,” said Kameran Wong, Communications Director for the Forensic Criminal Justice Alliance. "I would like to thank Rep. Nehls for introducing this important legislation."

Read Congressman Nehls’ bill HERE.

Original press release posted HERE on March 12, 2026.

Balancing access and integrity: A policy analysis on private laboratory direct access to CODIS

1Mission Strategies analyzes the Forensic Criminal Justice Alliance initiative in the article below, addressing a pressing challenge on restricted access to CODIS, which may contribute to forensic backlogs and delayed investigations. This summary presents a policy compromise that could empower accredited private laboratories to directly upload qualifying DNA profiles, while maintaining public sector control over legal checks, confirmation, and expungements.

Read the full article here.

Why direct upload to CODIS for private DNA labs is long overdue

For over three decades, accredited private forensic DNA laboratories have played a crucial role in assisting law enforcement, public government laboratories, prosecutors, defense attorneys, medical examiners, and coroners with expeditious and specialized testing of cases. As demands for forensic DNA testing on crime scene evidence increase, so does the pressure on typically under-resourced public laboratories to meet the needs of the criminal justice system. Limited funding and staffing make it nearly impossible to sustain operations, let alone validate and implement newer technologies. Additionally, when quality issues arise or significant backlogs of violent crime cases are identified, there is often minimal bandwidth for public labs to respond without negatively impacting current caseloads or creating downstream issues, ultimately affecting public safety.

As such, the routine use of fully accredited private forensic DNA labs serves a vital role in keeping public labs operational. By handling select casework, they allow public labs to focus on core casework despite limited resources. Private labs also can adopt advanced technologies that are often too costly or burdensome for public labs to implement. Together, the complementary use of private forensic labs can help reduce backlogs, address quality issues, and improve case outcome with the use of cutting-edge technologies.

Additionally, private labs are designed to handle high volumes of cases which allows them to assist multiple jurisdictions at once. For example, to date there have been more than 300,000 cases processed by private forensic labs, comprising more than three million offender or arrestee samples and over 900 forensic investigative genetic genealogy cases. Like public labs, private forensic DNA labs are also accredited to the same standards, such as ISO/IEC 17025:2017 for Forensic Testing and Calibration Laboratories by ANSI National Accreditation Board (ANAB). This ensures the same quality of work is maintained from lab to lab, upholding the safety and protection of the evidence and data generated from it.

Public-private partnerships help generate more robust and probative DNA profiles in a timely manner, providing more investigative information and helping increase public safety. However, there is one major obstacle preventing true efficiency and significant cost savings- private DNA laboratories cannot directly upload eligible profiles to CODIS.

The inability of private labs to upload eligible DNA profiles directly to the combined DNA index system (CODIS) has detrimental downstream effects that are not only economically wasteful, but also negatively impact public safety. Currently, every CODIS-eligible profile that is generated by a private DNA lab must undergo an additional technical review by the submitting agencies’ state or local lab before being uploaded to CODIS.

This has several serious implications:

Justice gets delayed. It can take the state or local lab weeks to years to conduct these reviews, especially when large volumes of cases are outsourced as often happens with sexual assault kit backlogs.

Cases go untested. State or local labs may choose not to work with any private labs, which means the case cannot be outsourced and remains stagnant, or it can be outsourced but any eligible CODIS profiles obtained will not be uploaded to CODIS. The latter is a decision that falls to the submitting investigative agency to make but can have serious ramifications that impact an investigation. Law enforcement are therefore left with few to no options for advancing their investigations.

Public safety is compromised. There is an increased chance for recidivism, or the tendency of a convicted criminal to attack again, to occur during the time between when the private lab issues their DNA reports and when the state or local lab conducts a repeat technical review and upload to CODIS.

Innovation is stifled. In order to comply with the current CODIS requirements, private laboratories must utilize the same technology as the public laboratory, even if a more effective option is available in the private lab. However, most state and local laboratories do not have the funding or manpower to implement and maintain newer and more effective technologies. As a result, private labs are forced to use older methodologies on evidentiary samples. This has serious consequences collectively as the forensic DNA industry is unable to invest in new technologies which could provide more robust DNA profiles and leads on cases, improve efficiency, and lower costs.

Costs go up. There are significant costs associated with this redundant but currently mandatory technical review. A realistic estimate for the additional technical review is $500 per case. One of the most well-known federal grant programs is the National Sexual Assault Kit Intiative (SAKI), in which almost 40,000 profiles have been uploaded to CODIS to date. Approximately 90% of all SAKI cases are outsourced to private DNA labs, meaning the cost alone for this additional technical review under SAKI is approximately $18 million. That figure is staggering when you consider that the same dollar amount could have paid for the testing of approximately 13,000 sexual assault kits.

The original governing language pertaining to CODIS uploads was outlined over 30 years ago in the DNA Identification Act of 1994. Minimal amendments have been made since that time despite the immense changes in the field of forensic DNA, its increased application to violent crimes, and the critical role that private DNA labs play in processing evidence from across the country.

It is time that changes were made to allow accredited forensic DNA labs to upload directly to CODIS. In permitting the direct upload of profiles, we can ensure the efficient provision of investigative leads to submitting agencies, prevent additional acts of violence, save millions of dollars that can be better directed towards improving state and local labs, and help solve more cases.