Open Recommendations

Require the Commission to provide its subgrantees with additional training and guidance regarding how to appropriately exit members, including members with CPCs. This guidance should include procedures designed to ensure its subgrantees receive and maintain a detailed justification that documents the reason(s) for the member’s exit and verifies that the circumstances causing the member to exit represent an allowable CPC prior to certifying that the member is eligible for an education award.

Require the Commission and its subgrantees to implement additional internal controls and establish additional policies and procedures to ensure that they only charge allowable costs to AmeriCorps Commission support grants. The additional controls should ensure that: (a) The Commission and its subgrantees calculate all payroll expenses charged to AmeriCorps grants using a rate commensurate with the employee’s established salary and the level of effort the employee dedicated to the AmeriCorps program. (b) Employees understand how to document trip costs to demonstrate that costs did not increase due to combining personal and business travel.

Require the Commission to determine whether AmeriCorps members who served at MI in 2016 and 2019 should receive $20,794 in additional living allowance payments.

Require the Commission to verify that MI begin tracking its Federal awards and expenditures within its general ledger accounting system. Specifically, MI’s accounting system should enable MI to identify all Federal costs and match costs reported in the PERs submitted to the Commission.

AmeriCorps’ Office of General Counsel perform a comprehensive review of all Federal Statutes and Federal Regulations to identify inconsistent guidance, make appropriate corrections to the Federal Regulations, and provide the results to AmeriCorps OIG and AmeriCorps Office of Monitoring.

AmeriCorps issue consistent, direct, and transparent communication to all AmeriCorps grantees to provide clarification on the current matching requirements for member living allowance and member support costs.

Recover from YouthBuild $520,827 of education awards that were paid to members for subgrantees within the audit scope.

Require that YouthBuild pay the $3,087,791 outstanding AmeriCorps Education awards yet to be distributed to the members of subgrantees within the audit.

Assess the remaining $9,042,686 of at-risk funds to determine if sufficient supporting documentation for the hours claimed exists. If sufficient documentation does not exist, recover from YouthBuild the $1,349,717 already paid by the Trust and require that YouthBuild pay the $7,692,969 outstanding AmeriCorps Education awards yet to be distributed to members.

Require YouthBuild to update its member timekeeping policy and procedures to align with Federal regulations and AmeriCorps grant terms and conditions to include adequate internal controls and documentation to provide reasonable assurance that YouthBuild and its subgrantees are adequately managing AmeriCorps funds.

Disallow and recover all grant funds associated with AmeriCorps funding received by SJCC through YouthBuild during the audit period.

Assess all current AmeriCorps funding to SJCC for the same violations noted in this report.

Direct YouthBuild to perform a comprehensive assessment of YouthBuild’s subgrantees and determine whether any of their other subgrantees are following the same non-compliant practices as SJCC and provide the results to AmeriCorps Office of Monitoring and AmeriCorps OIG in a timely manner.

Provide additional training to YouthBuild on AmeriCorps policies and subgrantee monitoring.

Disallow and recover $1,590 in Federal costs from YouthBuild due to staff timekeeping errors at Crispus Attucks Charter School that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

Require YouthBuild to verify that Crispus Attucks Charter School, and all YouthBuild subgrantees, do not use grant funding received from DOL grants to meet matching requirements. If DOL grant funds were used to meet matching requirements, AmeriCorps should disallow the match costs and recover the associated Federal costs from YouthBuild.

Disallow and recover $40,384 in Federal costs from YouthBuild due to ineligible living allowance payments and insufficient member exit procedures at Philadelphia Youth for Change Charter School that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

Disallow and recover $7,533 in Federal costs and disallow $8,242 in match costs and recover the associated Federal costs from YouthBuild due to errors at Change Inc. that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

Require YouthBuild to determine the allowability, allocability, and reasonability of Change Inc.’s occupancy expenses and ensure that staff salary costs reported as Match costs are charged by grant activity or specific cost objective.

Require YouthBuild to verify that all subgrantees’ policies align with Federal regulations for training limitations.

Communicate any impacts to customers when permanently moving processing operations of a three-digit ZIP Code to another processing facility.

Update Handbook PO-408 to include the definition of service area, and clearly define when Mail Processing Facility Reviews are required.

OIG recommends that the Bureau of International Security and Nonproliferation include requirements to report on progress, challenges encountered, and other pertinent details, as suggested by 14 FAH-2 H-522.1, "Progress or Status Report," in contract task order terms and conditions for its assistance to Ukraine.

Rec. 2: The DoD OIG recommended that, until the Navy completes its migration to the Navy Enterprise Resource Planning system, the Assistant Secretary of the Navy (Financial Management and Comptroller), in coordination with the Department of the Navy Chief Information Officer, develop and implement effective internal controls to prevent over-execution in the Navy Standard Accounting, Budgeting, and Reporting System.

The Chief Management Officer should update purchase card, convenience check, and travel card program policies and procedures to ensure training, reporting, and micro-purchase threshold requirements are accurate.