Open Recommendations

We recommend that the Cherokee Nation develop and implement policies and procedures to ensure that: all individuals, including contractors and volunteers, in contact with Indian children are fingerprinted prior to starting employment, illegible fingerprints are retaken and resubmitted to FBI until a background investigation is completed in accordance with the requirements of the ICPFVPA, background investigations of contractors, including HHS employees, are reviewed or performed as required by the ICPFVPA and Tribal policies, and criminal history results are assessed to verify that applicants meet the required minimum character standards.

We recommend that the Cherokee Nation request and review agency contractor background investigations that comply with the ICPFVPA, including documentation that confirms HHS employees met all background investigation requirements of the ICPFVPA, or perform background investigations on these individuals that comply with the ICPFVPA.

We recommend that the Cherokee Nation identify employees and volunteers outside our sample who lack evidence that a background investigation was performed, as required by the ICPFVPA, and who currently have contact with Indian children and perform the required background investigation and determine whether these individuals meet the required minimum character standards.

We recommend that the Cherokee Nation perform background investigations, as required by the ICPFVPA, on the employees and volunteers we identified as not having complete background investigations who currently have contact with Indian children and determine whether these individuals meet the required minimum character standards.

We recommend that the Choctaw Nation develop and implement policies and procedures that ensure that the Tribe follows the requirements of the ICPFVPA to: collect information about the applicants' previous 5 years of residency, conduct FBI fingerprint background investigations using FBI-approved procedures for all individuals in contact with Indian children, conduct inquiries to State and Tribal law enforcement agencies about the applicants' previous 5 years of residency, and assess criminal history results to verify that applicants meet the required minimum character standards.

We recommend that the Choctaw Nation request and review agency contractor background investigations that comply with the ICPFVPA, including documentation that confirms HHS employees met all background investigation requirements of the ICPFVPA, or perform background investigations on these individuals that comply with the ICPFVPA.

We recommend that the Choctaw Nation perform background investigations, as required by the ICPFVPA, on all employees and temporary employees who currently have contact with Indian children and determine whether these individuals meet the required minimum character standards.

Require Serve DC to implement, or verify that Serve DC implemented, internal controls ensuring timecards are signed by employees and supervisors and retained to support the payroll costs charged and claimed on the AmeriCorps grants.

Recover the total payroll questioned costs of $433,625 in Federal costs and disallow $308,090 in match costs related to missing timecards, missing supervisory signatures, and missing employee signatures related to CAH grants (16CAHDC001 and 19CAHDC001), TTA grant (16TAHDC001), and VGF grant (17VGHDC001). Also disallow $43,349 in match costs for the ACH grant (18ACHDC001) claimed by JumpStart.

Require, or verify that Serve DC has since implemented, policies and procedures that appropriately cite or reference CFR Cost Principles to claim allowable, reasonable, and allocable costs.

Require, or verify that Serve DC has implemented, controls to obtain and maintain supporting documentation for all staff costs.

Require Serve DC to develop and implement policies and procedures to appropriately track in its accounting system and obtain supporting documentation for all in-kind match costs associated with AmeriCorps grants and from within the DC government and third parties.

Disallow the $266,350 of match in-kind costs claimed on the Federal Financial Report related to the VGF grant (17VGHDC001). In addition, determine if Serve DC was able to meet the match requirement pertaining to the Federal costs claimed for the VGF grant (17VGHDC001) upon Serve DC’s submission of the final Federal Financial Report and recover those Federal costs for which match costs were not provided.

Require that Serve DC implement policies and procedures that require documentation identifying the source and use of funds by batch and for each transaction.

Recover $297,407 in Federal costs and disallow $131,302 in match costs due to unsupported other direct costs.

Require Serve DC to implement controls to verify that subgrantees are performing the National Sex Offender Public Website Program (NSOPW) searches, including FBI Fingerprint, and documenting their verification of the government-issued photo IDs for all required individuals.

Recover the total questioned Federal costs of $66,605 and disallow match costs of $3,284 for payroll and administrative costs for grant (18AFHDC001) due to no National Sex Offender Public Website Program Search.

Recover the total questioned Federal costs of $6,159 and disallow match costs of $650 for payroll and administrative costs for grant (18AFHDC001) due to no DC Criminal Background Check.

Recover the total questioned Federal costs of $35,496 for payroll and administrative costs for grant (18AFHDC001) due to No FBI Fingerprint Check.

Require Serve DC to implement controls to prepare reports that support and reconcile to the amounts reported to AmeriCorps eGrants. Serve DC should also establish controls to reconcile and document costs recorded in the accounting record to the costs reported on the Federal Financial Report for each grant.

Recover $82,345 in questioned Federal costs and disallow $83,796 in claimed match costs not supported by the accounting records.

Require that Serve DC develop and implement a mandatory training program including a tracking system to ensure that all subgrantees’ staff have training, capability, and assistance to enter their budgets and costs into its reporting system to meet reporting requirements timely.

Instruct Serve DC to develop and implement procedures and controls to prevent future drawdowns in excess of incurred costs.

Recover the questioned Federal costs of $8,418 for member living allowance and support for grant (18AFHDC001).

Verify that Serve DC implements controls to ensure that subgrantees are applying costs for member living allowance in accordance with the approved budget in their accounting records and in PERs.