The Investigations Section within the OIG is responsible for the detection and investigation of fraud, waste, and abuse within AmeriCorps programs and operations. Special Agents conduct various criminal, civil, and administrative investigations. Some of our criminal investigations are conducted in conjunction with other federal, state or local law enforcement agencies. Criminal investigations are presented to the U.S. Attorney and, in some cases, the local prosecutor, for criminal prosecution and/or civil recovery.
The Investigations Section also conducts fraud awareness briefings and provides a pamphlet entitled "OIG Investigations and You" which discusses AmeriCorps employees rights and responsibilities regarding investigations. Also, See;
The Investigations Section also maintains the Fraud Hotline which can be used to report fraud, waste and abuse involving AmeriCorps programs and operations.
Prohibited Activities – AmeriCorps Members Directed to Transport Individual for Abortion Services
CNCS management alerted CNCS-OIG of an allegation concerning Prohibited Abortion Activity directed by an AmeriCorps grantee employee with the International Institute of Metropolitan St. Louis (IISTL), St Louis, MO.
CNCS-OIG investigators found that an AmeriCorps supervisor violated 42 USC § 12584a(a)(9), providing abortion services or referral for receipt of such services, and CNCS implementing regulation 45 C.F.R.§ 2520.65(a)(10), when she directed an AmeriCorps member to transport a client to an abortion clinic for an abortion.
In addition, IISTL’s AmeriCorps State Position Description (PD) contemplated that AmeriCorps members will, in addition to their direct service activities, provide administrative support services on an as-needed basis. The PD gave rise to the possibility of violations of 45 CFR 2540.100(f), Nondisplacement. The language would seem to allow the grantee to award service hours for unallowable activities.
CNCS management reported they concurred with CNCS-OIG recommendations and the Missouri Commission immediately directed all IISTL staff to complete the CNCS refresher training eCourse on Prohibited Activities. All staff completed the eCourse and follow up discussion on allowable/unallowable and prohibited activities. IISTL reviewed and redrafted member PDs under the supervision of the Commission to clarify any ambiguous language that might be interpreted to allow a member or IISTL staff to contemplate displacement. Also, any costs associated with the prohibited activity were considered de minimis (less than $10), and that it would not be practical to pursue collection because the administrative costs associated with the collection action would far outweigh any recovery.
Case ID: 2016-021
VISTA Project Ended After Duplication of Service
CNCS-OIG completed its investigation into Hotline allegations that VISTA members (VISTA) assigned to Programa de Apoyo y Enlace Comunitaro (PAEC), Rincon, PR, were directed to perform duties ordinarily performed by a paid employee.
The investigation found that several VISTAs were directed by the executive director to renovate a kitchen, paint offices, and clean the exterior of a building all operated by PAEC. The time used to perform these tasks were counted as service hours. The investigation found that the time counted towards their VISTA service was minimum and did not affect their education awards. Additionally, VISTAs performed direct service as part of their VISTA service when they taught classes.
During the CNCS-OIG site visit it was discovered that two VISTAs and two AmeriCorps members manipulated the time keeping machine with the intent of leaving early and receiving service hours not earned. The members involved admitted to the manipulation of the time keeping machine, but denied submitting fraudulent timesheets or counting hours they had not served.
CNCS management reported that action had been taken against the individuals involved with tampering with the time clock. Additionally, CNCS management issued a Notice of Non-Renewal to PAEC, ending PAEC’s VISTA program, which duplicated some of the AmeriCorps program grant.
Case ID: 2016-008
Duplicate and Improper Enrollments Leads to Changes by National Direct Grantee
CNCS management reported that it discovered anomalies with the National Service Participants (NSP) accounts in the National Service Trust (NST) database in which AmeriCorps members had been enrolled in Teach for America (TFA) Idaho and Chicago AmeriCorps programs between Grant Years (GY) 2013 - 2017 under multiple NSP accounts with different Social Security Numbers.
The CNCS-OIG investigation found that a TFA Regional Operations Manager improperly enrolled TFA members at its Chicago, IL, and Nampa, ID, sites between 2013 and 2017. The investigation also found that in two instances duplicate accounts were included in drawdown calculations for the National Direct enrollment fees, which TFA used to cover its administrative grant costs. This allowed TFA to receive $1,600 ($800 per member) it was not entitled. Further, the TFA Regional Operations Manager improperly certified several members to receive dual education awards for the same grant period based on the duplicate enrollments.
TFA management, working with CNCS management, corrected the members’ accounts and implement internal controls and training to ensure future compliance. TFA management reported that it had terminated the employee involved for failing to follow their internal policies. None of the members who improperly received a second award used their duplicate award.
Case ID: 2017-005
Fraudulent Claims Result in Reimbursement and “High Risk” Oversight
A Hotline complainant reported that Senior Resources of Guilford (SRG), Greensboro, NC, officials fraudulently claimed that the Foster Grandparent Program (FGP) Project Director worked a percentage of her time on the Retired Senior Volunteer Program (RSVP), for which the grantee sought reimbursement.
CNCS-OIG completed its investigation into allegations SRG fraudulently used Federal program funds from the SRG RSVP grant, for the salary of the FGP Project Director. Investigators discovered SRG drew down $4,168 of Federal RSVP salary funds and verbally provided false information about the FGP Project Director’s work to CNCS staff . Investigators also found many individuals listed as current RSVP volunteers were either no longer volunteers, or were not aware their service was related to the RSVP or even SRG.
CNCS management reported SRG repaid the $4,168 in disallowed costs. CNCS coordinated with SRG and updated the RSVP volunteer roster. CNCS also developed a long-term mitigation plan to ensure SRG remained in full compliance of CNCS policies.
Case ID: 2016-010
Grant Reviewer Plagiarized Work Product
CNCS management discovered a temporary CNCS employee hired to serve as a panel member for the 2016 AmeriCorps State and National Grant Review process submitted work products that appeared to have been plagiarized from her follow panel reviewers. CNCS staff reported the temporary employee may have falsely certified her timesheets that included time she did not perform her assigned work.
The CNCS-OIG investigation found that the temporary employee in question submitted individual review forms to CNCS that were identical or almost identical to her follow panel reviewers. The temporary employee admitted to CNCS-OIG investigators she copied portions of her fellow reviewers’ evaluations after completing her own work to reflect combined ideas/findings, if the other reviewers’ points were better or mentioned other ideas to support their consensus. There was insufficient evidence to prove that the temporary employee falsely certified her timesheets, and the temporary employee is no longer employed by CNCS.
Case ID: 2016-017
Grantee Debarred for Misuse of VISTA Members and Required to Repay $527,000 in Disallowed Costs
Corporation management reported VISTA Project Sponsor Georgia Center for Nonprofits (GCN), Atlanta, GA, improperly utilized its VISTA members when it directed members to perform staff functions and changed clients for their services.
CNCS-OIG investigators found GCN staff misused their VISTAs and assigned them tasks unrelated to eradicating poverty. GCN staff repeatedly and improperly assigned VISTAs to perform direct service projects and required them to perform staff functions. This activity took place from at least 2009 until early 2014.
Interviews of VISTAs and GCN staff, along with a review of program documents by CNCS-OIG investigators revealed GCN officials violated (1) 45 CFR § 2540.100(f) (prohibits program participants from performing staff functions) when they tasked multiple VISTAs to perform staff functions and other administrative tasks; (2) 42 USC § 5044(c) (prohibits sponsors from receiving compensation for provision of VISTA service) when they collected fees for the VISTAs’ service; and (3) 42 USC § 12584(a)(8)(A) (prohibits national service participants from providing a direct benefit for a business organization for-profit) when VISTAs provided benefits to for-profit businesses that paid for memberships with GCN.
CNCS management issued a debt letter to GCN in the amount of $527,185 and debarred GCN for a period of two years.
Case ID: 2014-015
Improper Oversight Results in Fraudulent Timesheets / Members Serving from Home without Accountability of Service Performed
A Hotline complainant reported that members serving with the St. Bernard Project (SBP), Wall Township, NJ, were unsupervised, falsely reporting service hours, and working in unsafe working conditions.
The CNCS-OIG investigation found that some members had falsified their timesheets when they reported inaccurate hours when they arrived late or departed early from their service site due to the lack of a site supervisor. SBP site supervisors relied on the honor system to verify the hours served by the members since supervisors were not present daily at the construction service sites. CNCS-OIG also discovered two members regularly performed service from home and SBP did not have a procedure to verify the hours served or the service preformed. CNCS-OIG investigators observed that the allocation of members between the service sites and the SBP main office was disproportionate and did not align with the grant terms. Investigators found no evidence that the members were serving in unsafe working conditions.
As a result of the CNCS-OIG investigation SBP immediately increased supervision at the construction service sites and implemented a requirement that the AmeriCorps program managers at all of the SBP operating sites conduct a monthly review of member timesheets to detect fraud or errors. Additionally, SBP prohibited its members from routinely serving from home. CNCS acknowledged there were fewer members at the construction sites than originally planned, however believed the allocation of members aligned with the grant terms.
Case ID: 2016-014
AmeriCorps Members Declined to Engage in Political Activities for Grantee
CNCS-OIG completed its investigation into Hotline allegations that AmeriCorps members assigned to the Martha O'Bryan Center (MOBC), Nashville, TN, a sub-grantee of the Volunteer Tennessee (Commission), Nashville, TN, may have engaged in prohibited activities when MOBC senior management sent an email to the MOBC staff and volunteers (including AmeriCorps members), that encouraged them to participate in a political campaign for a local school board election.
CNCS-OIG investigators interviewed members who confirmed they received the e-mail encouraging them to campaign for select school board candidates; however, they declined the offer and did not participate in any political campaigning. There was no evidence that members engaged in prohibited activity.
Case ID: 2016-028
Prohibited Political Activity Leads to Removal of VISTA Site
This investigation was initiated based on a Hotline allegation concerning a VISTA member who may have engaged in political activities as part of his VISTA service.
CNCS-OIG completed its investigation into allegations that a VISTA assigned to Forest Grove VISTA Service to Southeast Oklahoma (SSEO), Idabel, OK, engaged in prohibited political activity and displacement as part of his VISTA service.
The CNCS-OIG investigation found that on at least one occasion the VISTA, serving at the Oklahomans for Responsible Water Policy Association (ORWPA), Broken Bow, OK, site distributed political material (bumper stickers) involving a pending state legislation issue on the 2016 Oklahoma state ballot in violation of 45 CFR § 2556.780 (Prohibited Activities), while serving at a Labor Day event promoting water conservation.
CNCS management reported that ORWPA was terminated as a VISTA service site and the VISTA resigned.
Case ID: 2016-031
Fraudulent Certification of Education Awards Leads to Debarment and Disallowed Costs
This investigation was initiated based on a Hotline allegation that Ms. Meghan Olinger, former AmeriCorps Program Coordinator, Synergy, Education, and Empowerment of West Monroe (SEE), West Monroe, LA, falsely certified education awards for members who had not completed their service hours over the course of her tenure at SEE.
CNCS-OIG investigated the allegations of false certifications of Segal Education Awards by program officials by SEE, a sub-recipient of a grant awarded by CNCS to Volunteer Louisiana (Commission). The investigation determined that Ms. Olinger falsely certified the Segal AmeriCorps Education Awards for 97 AmeriCorps members. Ms. Olinger’s actions allowed $117,202.12 in unearned education awards to be obligated by the CNCS National Service Trust. The investigation also found that the former AmeriCorps Program Director of SEE was negligent in performing her duties as the program director and demonstrated a lack of oversight of the SEE AmeriCorps Program. The Program Director’s negligence and lack of oversight allowed for the false certification of 97 Segal Education Awards.
A review of relevant documents and interviews of Ms. Olinger, the Program Director, and SEE staff, and members revealed between 2012 to 2016, Ms. Olinger disregarded the required service hours and allowed ineligible members to receive an unearned education award. During the time in question, the Program Director failed to perform any meaningful oversight of the SEE program, which allowed the mismanagement of the AmeriCorps program to go undetected for several years.
CNCS management informed CNCS-OIG that it disallowed $117,202.12 for 97 falsely certified education awards and debarred Ms. Olinger for a period of two years. The Commission also disallowed $37,512.84, for grant years 2012-2014, in match funds.
Case ID: 2016-011
Senior Corps Grantee Debarred After Scamming CNCS Grant Funds
CNCS management reported possible fraud involving RSVP grantee TCU Community Partnership Inc. (TCU), Conyers, GA, after its management drew down $20,750 of Federal grant funds and failed to enroll any volunteers and fulfill the terms and conditions of the grant.
Investigation determined Ms. Luvina Beckley-Knight, CEO, M.H.M. and Associate Enterprise (M.H.M.), Glendora, CA, knowingly obtained a Federal grant utilizing TCU, a “virtual” non-profit organization, which Ms. Beckley-Knight used to funnel funds back to her for-profit business.
In her grant application to CNCS, Ms. Beckley-Knight hid the relationship between M.H.M. and TCU in which TCU contracted with M.H.M. to provide management services under the grant. After being awarded the Senior Corps grant, Ms. Beckley-Knight drew down funds, but was unable to support the cost or demonstrate the funds were authorized under the grant terms. Additionally, Ms. Beckley-Knight directed the submission of fabricated IRS 990's to CNCS-OIG Investigators, claimed an individual was providing training to volunteers, when in fact he was not, and claimed she was paid with matching funds, when in fact she was paid by Federal grant funds.
The CNCS-OIG recommended CNCS recoup the $20,750, Ms. Beckley-Knight draw down from the TCU RSVP grant. CNCS-OIG also recommended debarment of M.H.M., TCU, and Ms. Beckley-Knight.
CNCS management concurred with the CNCS-OIG findings and required Ms. Beckley-Knight to repay the $20,750. Additionally, CNCS management debarred M.H.M., TCU, and Ms. Beckley-Knight for a period of three years.
Case ID: 2015-009
Allegations of Improper Personnel/Hiring Practices (Unfounded)
A disappointed job competitor alleged that an individual selected for a senior (SES-equivalent) position overstated her qualifications and embellished her prior work experience and responsibilities, and that the hiring official (also SES-equivalent) failed to verify her prior employment. The complainant also alleged that the same official promoted another CNCS employee without competition.
CNCS-OIG investigators determined that the allegations were based on incomplete information and incorrect assumptions. The selected official’s work history was accurate, and the hiring official followed the appropriate procedures, including verifying past employment. The other employee had not in fact been promoted as alleged, but was instead reassigned within the same series and pay band.
Case ID: 2016-018
Former AmeriCorps Member Submitted Fraudulent Claim for Childcare Benefits
A former AmeriCorps member submitted fraudulent claims for childcare benefits after ending her service. The United States Attorney’s Office declined criminal prosecution, and CNCS recouped $1,047 from the former member.
Case ID: 2016-013
Foster Grandparent Program Volunteer Arrested Allegations of Sexual Abuse of a Child (Unfounded)
CNCS management reported a Foster Grandparent Program (FGP) volunteer was arrested by Tooele Police Department, Tooele, UT, on allegations of sexual assault of a minor, while serving at a FGP school site.
Investigation by Tooele detectives determined eye witnesses observed no inappropriate behavior and found no evidence to support the allegation. The local prosecutor dismissed the charges against the volunteer.
CNCS-OIG reviewed the grantee’s criminal background check and sexual offender checks procedures and found the grantee had followed the required procedures when the FGP volunteer began his service.
Case ID: 2016-015
VISTA Site Discontinued after Members Served Outside Scope of Grant and Performed Staff Duties
Acting on a Hotline complaint, CNCS-OIG investigators determined that VISTA participants at Community in Schools of Hernando County (CIS-Hernando), Brooksville, FL, were assigned direct service tasks beyond the scope of the grant, and displaced employees by performing staff functions. The VISTAs were supposed to improve the conduct and academic performance of at-risk youth by recruiting volunteers to serve as tutors and mentors. Instead, CIS-Hernando assigned them to collect and distribute food, clothing, and school supplies to students and their families. One VISTA regularly served in the school office, answering phones, undertaking general office work and filing discipline reports. Another VISTA was paid to advise an unrelated organization, without CIS-Hernando’s approval.
Overall, CIS-Hernando staff did not provide proper oversight to ensure that the VISTAs’ time was used for the intended purposes and consistent with program requirements. Investigators also found project records to be in disarray, missing or incomplete.
As a result of this investigation, CIS-Florida did not renew its agreement to assign VISTAs to the Hernando site. The agreement terminated on August 22, 2016.
Case ID: 2016-020