Agreed-Upon Procedures for Corporation Grants Awarded to the Kentucky Commission on Community Service and Volunteerism

The Office of Inspector General awarded a contract to RSM US, LLP to perform agreed-upon procedures to the Kentucky Commission on Community Volunteerism and Service (KCCVS) grants. KCCVS receives funding from CNCS and the Kentucky General Assembly. KCCVS administered AmeriCorps funds approximating $9.3 million awarded between January 1, 2013 and September 1, 2016 under five grant agreements ($5.4 million under cost-reimbursable awards and $3.9 under fixed-type awards). KCCVS made subgrants to eight organizations (under the cost-reimbursable awards) and was responsible for programmatic and financial oversight. Our AUP review of KCCVS and two of its subgrantees—Northern Kentucky University Research Foundation Kentucky Service Corps and ATEAM/AmeriCorps for Barren County School Board—found questioned costs totaling $851,954 and compliance findings. The majority of the questioned costs result from deficiencies in the procedures used by KCCVS and its subgrantees to conduct the National Service Criminal History Checks for their staff and members. These deficiencies resulted in questioned cost of $758,414. RSM’s testing found the following: Inadequate Program Monitoring • Grantee did not adequately monitor and/or document subgrantees compliance with program requirements • Subgrantees compliance over member matters was lacking and/or not fully documented for end-of-term evaluations, performance interviews, and member service agreements National Service Criminal History Check Findings (NSCHC) • Grantee did not perform NSCHC on grant-funded staff • Subgrantees had incomplete or insufficient member NSCHC and National Sex Offender Public Website checks and supporting documentation Member Service Issues • Members performed unapproved remote service • Members performed service activities that were not in accordance with the subgrant objectives Program Income • Subgrantee earned excess program income but did not apply it back to the Federal program Support for In-Kind Contributions • Subgrantee could not adequately support the in-kind contributions reported for cost share under the grant KCCVS concurred with most of the compliance findings but not the amounts questioned. The Corporation will resolve the reports findings and recommendations.