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Audits, Evaluations and Reviews
Audits, Evaluations and Reviews
Kearney & Company, P.C. (Kearney) performed a performance audit of grant costs and compliance testing of the Corporation for National and Community Service’s Federal assistance grant to the Student Conservation Association (SCA). This performance audit covered nine separate federally funded grants from grant year 2009 through 2013 awarded to SCA. The following issues were found:
- Finding #1: Criminal History Check (CHC) Not Updated.
- Finding #2: Unallowable Travel Cost Charged to Grant.
- Finding #3: Late National Sex Offender Public Website (NSOPW) Search.
- Finding #4: Member End-of-Term Evaluations Not Completed.
The audit found the following:
- The financial statements present fairly, in all material respects, in accordance with accounting principles generally accepted in the United States of America.
- Two significant deficiencies (Integrity Assurance Program and Information Technology) in the Corporation’s internal control over financial reporting; and
- One instance of noncompliance (Federal Information Security Modernization Act of 2014) with applicable provisions of laws, regulations, contracts.
The two significant deficiencies are a repeat condition from Fiscal Year 2014.
The audit of the Corporation for National & Community Service Trust Financial Statements found the statements present fairly in all material respects in accordance with accounting principles generally accepted in the United States of America.
Hoopa Valley Tribe (Hoopa) received grants totaling approximately $2.8 million from the Corporation for National and Community Service (Corporation) for its Tribal Citizen Community Corps (TCCC) and Hoopa AmeriCorps Native Land (ANL) programs between June 2012 and June 2014.
The Office of Inspector General (OIG) audited the costs incurred by Hoopa during this period and as a result, questioned $184,885 or approximately 7.4 percent, of the $2.5 million in Federal costs charged against these grants, as of July 2014. The questioned costs stem from non-compliance with applicable laws, regulations, and grant provisions, specifically attributed to the fact that the grantee did not perform and document required background checks for its AmeriCorps members and grantee’s staff.
To address these findings, we recommend that the Corporation disallow and recover the questioned costs. To improve compliance, we also recommend that Hoopa: (1) develop and implement procedures to ensure that required background checks are conducted for its AmeriCorps members and staff; and (2) familiarize staff with the grant agreement terms and applicable laws and regulations.
Evaluation of the Corporation’s Information Security and Privacy Program found these were not compliant in a number of respects with FISMA legislation, Office of Management and Budget guidance and applicable National Institute of Standards and Technology security publications. Evaluations testing found controls were ineffective in eight of 11 areas. In two of the eight areas, Continuous Monitoring Management and Risk Management, the deficiencies were severe enough to constitute a significant deficiency.
Cotton & Company LLP conducted a performance audit of cooperative agreements awarded to AFYA Incorporated (AFYA) and Education Northwest, formerly known as Northwest Regional Education Laboratory.
- Assessed the effectiveness of the Corporation for National and Community Service (Corporation)’s monitoring and oversight of the quality of the training provided by Education Northwest.
- Assessed the effectiveness of the Corporation’s fiscal monitoring and oversight of the cooperative agreements with both entities.
- Determined whether Corporation-funded Federal assistance provided to AFYA and Education Northwest was expended in accordance with cooperative agreement terms and conditions, laws, and regulations.
For fiscal year (FY) 2014, the Corporation for National and Community Service (CNCS) did not perform a reliable assessment of the susceptibility of its programs and activities to improper payments, nor did it did it reliably estimate the amount or the rate of improper payments in the AmeriCorps Program. As a result, the improper payments information reported in CNCS’s FY 2014 Agency Financial Report (AFR) is unreliable and is also incomplete in other respects. We found significant flaws at every stage of CNCS’s improper payments assessment process. Some of those flaws had a tendency to understate CNCS’s improper payments.
Given the weaknesses discovered in this evaluation, we believe that CNCS has not met its obligation to perform a susceptibility analysis in FY 2014 and should not wait two years before performing a reliable analysis. Instead, CNCS should use the information in this evaluation to conduct a more accurate risk assessment in FY 2015, develop a better estimate of improper payments in the AmeriCorps Program, and accurately report the results.
During the period 2011-2013, the Corporation awarded $963,062 to the Massachusetts Campus Compact (MACC), a coalition of colleges and universities that encourage student involvement in organizations that assist low-income communities. VISTA provided 88.6 percent of the funds, with the remainder coming from AmeriCorps.
Our audit found:
- VISTA unknowingly renewed its grant to MACC one day after AmeriCorps terminated its grant for cause. The Corporation treats each grant in isolation and lacks systems or processes for sharing critical information about grantees between programs.
- MACC charged the VISTA grant for student labor that was unsupported and unvalidated by a responsible supervisor.
- Twelve MACC workers were paid $115,976 from the VISTA grant without ever undergoing required criminal history background checks.
- MACC failed to oversee the sites and activities to which its 28 VISTA members were assigned.
- MACC overdrew the AmeriCorps grant for more members than it enrolled.
Overall, more than 13 percent of MACC’s claimed costs were overcharges. It lacked effective internal controls to ensure that costs charged to grants were correct in amount and properly supported and verified. We recommend that the Corporation disallow and recover the questioned costs identified in our audit. Any further dealings with MACC should be conditioned on significant improvements in its financial management practices, record keeping and host site monitoring.
We also recommend that the Corporation develop systems and procedures for timely sharing of information across grants and programs and consider transitioning its monitoring and oversight from a grant-centered approach to a grantee-centered approach. There is no justification for unknowingly awarding a grant to a grantee terminated by a sister program because of its failure to remedy grant management deficiencies. Here, the lack of communication between the programs resulted in a missed opportunity for the Corporation to prevent further waste of Federal funds, as evidenced by the questioned costs identified in this audit report.
Finally, the Corporation should determine why the Massachusetts State Office, which conducted a site visit to MACC during the period covered by our audit, failed to uncover the problems identified by our auditors. It is particularly hard to understand how the complete absence of host site monitoring records escaped their notice.
The Trust financial statements present fairly, in all material respects, the financial position of the Trust as of September 30, 2014 and 2013, and its net cost of operations, changes in net position, cash flows, and budgetary resources for the years then ended, in accordance with accounting principles generally accepted in the United States of America.
Audit of the Corporation’s Financial Statements found the statements presented fairly the financial position of the Corporation as of September 30, 2014 and 2013.
The auditors also identified two significant deficiencies and one instance of noncompliance with the Federal Information Security Management Act.
- Integrity Assurance Program - The Corporation does not yet have a fully functioning internal control monitoring process in place to determine the effectiveness of internal controls and support management’s required annual assurance statement under the Federal Managers Financial Integrity Act.
- Information Technology – The Corporation’s information technology internal control structure did not support a sound internal control environment in five categories: security management, access controls, configuration management, segregation of duties, and contingency planning.
Kearney & Company, P.C. has concluded that the Corporation's Information Security and Privacy Program was not compliant in a number of respects with FISMA legislation, OMB guidance, and applicable NIST security publications as of September 30, 2014. Their testing found the controls were ineffective in seven of the 12 areas. In four of the seven areas, the deficiencies were severe enough to constitute a significant deficiency; these areas were Continuous Monitoring Management, Risk Management, Plans of Action and Milestones (POA&M), and Privacy.
After auditing a total of 12 task orders issued under four consulting BPAs, the Office of Inspector General found shocking waste of taxpayer funds, lax oversight, unauthorized contractual commitments and widespread noncompliance with rules, regulations and sound contracting practices. Among the highlights:
- The Corporation wasted taxpayer funds on deliverables that were not used, were canceled after incurring substantial costs, or were never received.
- CNCS spent nearly $900,000 (of the $3 million in our sample) on five projects that it never used.
- Program officials exceeded their authority and violated Federal procurement requirements with impunity by directing consultants to deviate from contract terms.
- Procurement officers charged with sole legal authority to enter into, modify and terminate government contracts were kept in the dark.
- Instead of terminating a longitudinal study and returning the unspent funds to the Treasury, program officials diverted the funds to unrelated case studies.
- The Corporation abdicated its fiduciary responsibility regarding payments to consultants and other contract monitoring.
- Program officers relied excessively on the trustworthiness of contractors, including approving $2,427,463 in invoices for labor without obtaining timesheets.
- Procurement officers did not adequately review contractor proposals to protect the government's interests.
- Contracting officers did not review the qualifications, eligibility or cost proposals of subcontractors.
- Chronic documentation problems interfere with transparency and accountability of contractual actions.
- Contract files lacked basic documents plans for acquisition, monitoring and subcontracting.
- The procurement files did not document the reasons for critical decisions or identify the persons responsible for unauthorized changes to the scope and nature of consulting assignments.
Poor documentation practices and turnover at the staff and executive levels have created substantial gaps in the Corporation's institutional memory regarding consulting engagements.
The Corporation's operational units (grant programs and functional components, such as External Affairs) engage consultants under existing BPAs with little or no supervision at the enterprise level. Many of the problems that OIG detected here are longstanding and have not received sufficient attention or oversight. There has been no meaningful accountability for continuing waste and mismanagement of consulting services procured through BPAs.
The Corporation for National and Community Service (Corporation) Office of Inspector General (OIG) contracted with CliftonLarsonAllen LLP, an independent certified public accounting firm, to perform agreed-upon procedures (AUP) on grant costs incurred by the Nevada Volunteers (NV) and three of its subgrantees. NV is the State Commission through which AmeriCorps State grants are administered. NV also received State Administrative, Program Development Assistance and Training (PDAT), and Disability (DISAB) grant funds to support AmeriCorps State programs. CLA also tested NV’s compliance with Corporation policies and applicable regulations for Corporation-funded Federal assistance. In addition to reviewing NV’s administration of these grant funds, we selected the following NV subgrantees for detailed testing:
* United Way of Southern Nevada (UWSN)
* The Children’s Cabinet (TCC)
* Great Basin Institute (GBI)
These subgrantees were judgmentally selected based on an assessment of overall risk to NV and the Corporation. The assessment included consideration of several factors, namely the amount of costs claimed by each subgrantee, the results of subgrantee monitoring reports, and findings, if any, contained in Circular A-133 single audit reports for each entity.
Our procedures performed by CLA resulted in total questioned grant costs of $207,226, consisting of $141,760 in Federal costs, NV subgrantee match costs of $44,673 and education award costs of $20,793. CLA also identified eight instances of noncompliance with the United States Code of Federal Regulations; the Corporation’s grant requirements, and the subgrantees’ own policies and procedures or lack thereof.
This is the third consecutive year in which OIG has questioned the validity of the Corporation’s IPERA analysis. In Fiscal Year (FY) 2011, the Corporation’s AFR reported that none of its programs was susceptible to significant improper payments and reported improper payments in the AmeriCorps Volunteers in Service to America (VISTA) program of only $2.14 and projected improper payments of $3,947, results that were on their face unreasonable. The Corporation reached these results because it failed to examine whether the Corporation’s expenditures were used for their intended purpose, a key IPERA criterion.
Penquis Community Action Program (Penquis) of Bangor, Maine, received grants totaling approximately $2.4 million from the Corporation for National and Community Service (Corporation) for its Retired and Senior Volunteer Program (RSVP) and Foster Grandparent Program (FGP) between May 2010 and May 2013.
The Corporation's Office of Inspector General (OIG) audited the costs incurred by Penquis during this period, and, as a result, questions $394,401, or approximately 21 percent, of the nearly $1.9 million in Federal costs charged against these grants. The questioned costs stem from non-compliance with applicable laws, regulations, and grant provisions. The audit gave rise to key findings that the grantee:
- Did not perform required background checks for volunteers and verify/document their eligibility before enrolling them.
- Did not conduct and document required background checks for Penquis' staff.
- Did not maintain adequate documentation of service agreements between the grantee and volunteer stations.
- Made longevity awards to long-serving FGP volunteers without adequate transparency, in excessive amounts and by misreporting service hours.
To address these findings, OIG recommend that the Corporation disallow and recover the questioned costs. To improve compliance, OIG also recommend that Penquis:
develop and implement procedures to ensure that required background checks are done for volunteers and staff;
- improve monitoring of its volunteer stations to ensure that required documentation is properly prepared and retained;
- update its policies and procedures to include volunteer longevity awards; and
- familiarize staff with the grant agreement terms and applicable laws and regulations.