Open Recommendations

Communicates subgrantee performance measures.

Evaluates subgrantee performance against communicated performance measures.

Require the Commission to update its AmeriCorps State Policy and Procedure Manual to state that the Commission must base its subgrantee monitoring plans on each subrecipient’s risk of noncompliance, including risks regarding potential fraud and conflicts of interest.

Recover the $52,919 in questioned Federal costs from the Commission and disallow the $259,225 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 19CAHPR001, and 19AFHPR001.

Require the establishment of clear guidance regarding how to evaluate and document the allowability of costs, including in-kind contributed costs, reported on AmeriCorps grants, and provide the Commission and its subrecipients with training on the guidance. Updated guidance should address how to document:

Personnel and fringe benefit costs, including that they are consistent with organizational policies, the employee’s salary appointment, and the amount of effort the employee dedicated to the grant.

The benefit and value of in-kind contributions claimed as match costs, including other operating cost contributions such as office space, utilities, parking costs, and donated supplies.

That charged consultant costs are consistent with professional service agreements.

The benefit and value received of training activities.

The business purpose of trips taken.

Disallow the $100,409 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001

Require the Commission to update its PER review process to include verifying grantees only claim match costs for costs directly assignable to AmeriCorps grants.

Require the Commission to provide subrecipients with further guidance on the nature of F&A costs and conduct training to ensure subrecipients claim and report F&A costs consistent with AmeriCorps’ Terms and Conditions.

Recover the $69,756 in questioned Federal costs from the Commission and disallow the $23,869 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 16TAHPR001, and 19AFHPR001.

Require the Commission to implement a process for reconciling its accounting system records to the costs reported on its FFRs on a quarterly basis and work with AmeriCorps to identify and resolve any discrepancies as necessary.

Require the Commission to ensure MI provides detailed accounting records from its general ledger to support the costs reported in its PERs before the Commission reimburses MI for the costs. This requirement should remain in place until MI updates its general ledger accounting system to appropriately identify Federal funds received and expended, as required per Federal regulations.

Recover the $38,148 in questioned Federal costs from the Commission and disallow the $1,500 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Disallow and recover the $23,499 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Require the Commission and its subgrantees to obtain and document the required components of the NSCHCs using agency-approved vendors, consistent with 45 C.F.R. §2540.204(b).

Disallow and recover the $27,364 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

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.

Recover the $18,887 in questioned Federal costs on AmeriCorps Grant Number 16AFHPR001 from the Commission.

Require that the Commission update its subgrantee monitoring policies to include procedures to verify that subgrantees appropriately enroll and exit all ASN members.

Require that the Commission create templates and member training resources designed to ensure that subgrantees appropriately enroll and exit ASN members. Subgrantee resources should include:

Detailed procedures regarding how to document that a member meets the education requirements.