In 2019, Congress enacted the Payment Integrity Information Act (PIIA) to update required reporting on agencies’ improper payments. PIIA requires agencies to review and identify programs and activities that may be susceptible to significant improper payments, estimate the improper payments rates in agency programs, and report on their actions to reduce and recover those payments. The Inspector General of each agency assesses compliance with these requirements annually.AmeriCorps implemented corrective actions in FY 2022 that improved its compliance with PIIA reporting requirements. The agency met eight of 10 PIIA compliance requirements. Of the two remaining requirements, the agency reported improper payment rates above the ten percent compliance threshold for the Foster Grandparent Program (FGP), Senior Companion Program (SCP), and Retired and Senior Volunteer Program (RSVP). The agency also reported improper payment rates that were not accurate, reliable, or consistent with Office of Management and Budget guidance for AmeriCorps State and National, FGP, SCP, and RSVP. Further, AmeriCorps incorrectly concluded that there was no need to assess the National Service Trust (NST) for improper payments.AmeriCorps grantees did not have sufficient internal controls in place to verify the allowability of payments made with AmeriCorps grant funds, or to maintain documentation to support the allowability of these payments. AmeriCorps noted that the main drivers of improper payments and unknown payments occurred due to issues with eligibility documentation, non-compliance with the National Service Criminal History Check requirement, and policy issues. Also, some grantees did not maintain documentation to support the allowability of the temporary pay allowances paid to volunteers who were unable to serve during the COVID-19 pandemic.Management agreed to include the NST to the list of programs susceptible to improper payments, add additional provisions to its grant terms and conditions that address the root cause of improper payments, and develop and implement actions to reduce the improper payment rates below ten percent for FY 2023.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1 | No | $0 | $0 | ||
| Include additional terms and conditions within future AmeriCorps General Grant and Cooperative Agreement Terms and Conditions policy documents to address the root causes of improper payments. Repeat recommendation for FY 2022. | |||||
| 2 | No | $0 | $0 | ||
| Implement financial consequences or additional reporting requirements for grantees that have confirmed improper payments. Repeat recommendation for FY 2022. | |||||
| 3 | No | $0 | $0 | ||
| Reconcile the differences between grantees’ internal accounting records and Federal Financial Reports (FFRs)to determine the propriety of the component payments or require grantees to perform this reconciliation; or treat unmatched reporting errors as unknown payment errors in the projection of the improper payment estimate. Repeat recommendation for FY 2022. | |||||
| 4 | No | $0 | $0 | ||
| Include NST as a program susceptible to improper payments for future risk assessments. (New) | |||||
| 5 | No | $0 | $0 | ||
| Publish improper payment and unknown payment estimates for NST in the accompanying materials provided with future annual financial statements in accordance with OMB guidance. (New) | |||||
