Open Recommendations

Verify that the data reported to eGrants is accurate prior to submission.

Calculate the member’s daily service hours based on the times the member signs in and out each day.

Track and monitor member service hours to ensure that members do not spend more than 20 percent of their service hours performing training activities.

Require the Commission to implement controls regarding the submission of drawdown requests. Specifically, the Commission should perform timely reconciliations of its financial records and ensure that it only draws down funds once the reconciliation is complete, such that cash on hand from drawdowns does not exceed its existing expenditures.

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.

Require that the Commission strengthen its administrative and management controls and processes for the timeliness of financial reporting. Processes should include:

Implementing updated procedures to ensure it submits FFRs to AmeriCorps on a timely basis.

Requiring reporting extensions from AmeriCorps if the Commission does not believe that it will be able to meet established FFR due dates.

Require that the Commission strengthen its administrative and management controls and processes over the timeliness of subgrantee financial reporting. Processes should include:

Contacting subgrantees that are consistently non-compliant with AmeriCorps grant reporting requirements and discussing the reporting requirements outlined in their grants.

Issuing waivers for or enforcing actions on, subgrantees that do not provide accurate financial reports on a timely basis.

Conducting annual training sessions on financial reporting requirements for subgrantee personnel who are responsible for submitting PERs.

AmeriCorps’ Office of General Counsel update all applicable Federal Regulations addressing Federal share limitations and matching requirements for member living allowance and member support costs to align with the NCSA, as amended by the Serve America Act.

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.