Open Recommendations

We recommend that the Secretary for the U.S. Department of the Interior or a designee coordinate with the U.S. Department of Agriculture to assign responsibility for the required annual report and ensure that each annual report is completed and that all components required in the report are addressed after the publication of the performance metric mentioned in Recommendation 2, as established in IIJASection 40206(f), "Annual Reports."

Implement a baseline of technologies that sustain and do not erode privacy protectionsrelating to the use, collection, and disclosure of information.

Implement the EDR tool that was previously acquired for privacy protection.

Identify and implement other technologies that will bring the FCC into fullcompliance with the requirement for continuous auditing of compliance with statedprivacy policies and practices.

Update its business case for the MySBA investment in accordance with SOP 90 44 SBA Information Technology and Capital Planning and Investment Control Standard Operating Procedures.

Ensure the architecture review board reviews new investments to confirm compatibility with agency systems and ensure the Business Technology Investment Council approves new investments prior to purchase, as required by SOPs 90 52 1 and 90 44.

Ensure program offices create business cases prior to approval of the investment to ensure project scope, risks, and costs are fully vetted as required by SOP 90 44.

Update procedures to provide specific guidance to agency investment managers on how to utilize earned value principles to measure investment progress against both the current approved baseline and the original baseline for all major investments as required by SOP 90 52 1 and OMB Circular A-130.

Establish and implement controls to ensure all investments in the control phase are rated by the Chief Information Officer monthly using baseline factors, such as contractor cost oversight and schedule performance, and apply corrective measures as necessary as required by SOP 90 44.

Perform oversight procedures as required in OMB Circular A-11 and SOP 90 44. Specifically, ensure that post-implementation reviews, business case closeouts, TechStat sessions, operational analyses, and lessons learned are completed.

Instruct its Office of Regional Operations to implement an oversight mechanism to ensure that the Commission: (a) Performs and documents the results of subgrantee risk assessments. (b) Performs and documents annual subgrantee monitoring activities. (c) Communicates subgrantee performance measures. (d) Evaluates subgrantee performance against communicated performance measures.

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.

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.

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.

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

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Illinois to direct any LEAs that have not yet applied but plan to apply for ARP ESSER funds, to submit their ARP ESSER grant applications and plans to Illinois as soon as possible.

We recommend that in order to address the heightened risk associated with ARP ESSER funds, the Assistant Secretary for the Office of Elementary and Secondary Education require Illinois to design and incorporate into its documented procedures for reviewing LEA reimbursement requests protocols to sample LEA expenditures charged to ARP ESSER and review supporting documentation to ensure that applicable Federal, State, and local requirements are met.

Document the current RCS configuration that shows formulas for calculations performed by the system and data sources.

Finalize the process document for conducting a baseline review of all passenger railroads subject to 49 C.F.R. 228.407 and complete the baseline review.

Develop a plan for future similar programs to leverage applicable existing SBA data sources when determining eligibility and monitoring awards. The plan should include requirements to evaluate effectiveness of the use of the data as controls to reduce risk of improper payments.

Validate historical sales for 47,565 awards designated or treated as Tier 2 that failed or did not receive IRS validation. Recover any excess funds paid that are attributable to unverified historical sales data.

Review the 3,443 applicants awarded funds totaling $376,583,100 that self-certified as a brewery or inn, to determine if they met the 33 percent onsite sales eligibility requirement and recover any funds from applicants that did not meet the requirement.

In accordance with Public Law 117-2, § 5003(a)(4)(A)(i) take immediate action to review and recover improper payments from the 14 affiliated business groups disclosed by RRF applicants for a total of $55,067,326 in excess funds paid, beyond the $10 million limit per affiliated group.

Review the 16,345 applicants that disclosed having an affiliated business to determine if the amounts collectively awarded to the applicant and affiliates exceeded the $10 million maximum and recover any excess awards.

We recommend that the FWS require the Department to resolve the Federal share ($1,497,008) of unallowable questioned costs related to the acquisition of an aircraft.

We recommend that the FWS require the Department to implement policies and procedures to ensure the costs of capital assets are properly allocated to WSFR grants based on the proportional benefits the grants receive.

We recommend that the FWS require the Department to resolve the Federal share ($33,728) of questioned costs related to unallowable merit-based incentive pay charged to WSFR grants.

We recommend that the FWS require the Department to implement policies and procedures to ensure merit-based incentive benefits allocated to a grant code do not exceed the value of the benefits earned on that grant.

We recommend that the FWS require the Department to implement policies and procedures to ensure costs of tuition reimbursements receive prior written approval from the FWS.

We recommend that the FWS require the Department to resolve the Federal share ($16,021) of questioned costs related to unallowable administrative leave costs.

We recommend that the FWS require the Department to require the Department to implement policies and procedures to ensure administrative leave costs are scrutinized for relation to grant purpose.