The Payment Integrity Information Act (PIIA) requires agencies to annually review and identify programs and activities that may be susceptible to significant improper payments, estimate the improper payment rates in agency programs, and report on their actions to reduce and recover those payments. For FY 2024, AmeriCorps met eight of ten PIIA compliance requirements. We made three findings relating to the two remaining requirements. We found that: (1) AmeriCorps reported an improper payment rate above the ten percent compliance threshold for one program, the Foster Grandparent Program (FGP); (2) AmeriCorps’ published improper payment estimates for AmeriCorps State and National (ASN) and FGP are not accurate, reliable, or consistent with OMB guidance; and (3) AmeriCorps’ published improper payment estimates for the National Service Trust (NST) are not accurate, reliable, or consistent with OMB guidance. AmeriCorps concurred with the first finding and agreed to continue to develop and implement actions to reduce improper payment rates below ten percent. AmeriCorps did not concur with our second and third findings. We made six new recommendations related to our second and third findings in this report on unmatched reporting errors, payments to ineligible recipients, and published improper payment estimates for the NST. AmeriCorps declined to implement all six recommendations. We will keep open the two prior year recommendations related to the first finding until AmeriCorps submits documentation to demonstrate the completion and sufficiency of the corrective actions. The six recommendations related to the second and third findings will remain open and be classified as unresolved (disagreed) in our Semiannual Report to Congress.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1 | Yes | $0 | $0 | ||
| Reconcile the differences between grantees’ internal accounting records and FFRs to determine the propriety of the component payments or require grantees to perform this reconciliation. Additionally, AmeriCorps should test and include the unmatched reporting errors as unknown payment errors in the projection of the improper payment estimate. | |||||
| 2 | Yes | $0 | $0 | ||
| Determine whether awardees associated with FFRs submitted for Seniors awards were submitted by eligible organizations during the FFR data pull process. If it is determined that any AmeriCorps Seniors grantees were ineligible to receive the grant, AmeriCorps should include the entire FFR as an improper payment. | |||||
| 3 | Yes | $0 | $0 | ||
| Implement additional quality control steps, proposed in response to NFR 2, to its improper payment data pulling and sampling process to ensure that all payments included are appropriate for the programs determined to be susceptible to improper payments. | |||||
| 4 | Yes | $0 | $0 | ||
| Publish improper payment and unknown payment estimates for NST in the accompanying materials provided with the FY 2025 annual financial statements in accordance with OMB guidance. | |||||
| 5 | Yes | $0 | $0 | ||
| Update its NST test plan to require the tester to verify that sampled education awards were only used to cover allowable COA expenses for members who earned the award (unless appropriately transferred). | |||||
| 6 | Yes | $0 | $0 | ||
| Improve its quality control procedures to ensure AmeriCorps selects its NST sample and extrapolates its NST improper payment estimates consistent with its NST SEMP. Specifically, its quality control procedures should ensure AmeriCorps: | |||||
