INVESTIGATIONS

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.

Closed Investigations

Closed Investigations

Texas OneStar Foundation (State Commission) Monitors AmeriCorps Grantee for Displacement

A Hotline complainant reported that program officials at a Texas grantee were using AmeriCorps members to fill staff positions.  CNCS-OIG referred this matter to the Texas State Commission for follow up.

 

Commission personnel conducted an inquiry into the allegation.  Commission personnel reported they conducted a review of the member’s position description and interviewed AmeriCorps and school staff personnel.  Based on their review, Commission personnel determined a weakness in the grantee’s policy and procedures regarding AmeriCorps members that members had been placed in staff roles for short periods of time during the momentary absence of the teacher.  There was no evidence to quantify the time members served in the staff rolls; however, Commission personnel placed the grantee on a corrective action plan and are monitoring their compliance.    

 

-Case ID: 2015-001

Executive Director Embezzles Federal Program Funds / Improper Criminal History Checks Result in Disallowed Costs / Former Commission Employee Debarred for Collusion, Conflict of Interest

A Hotline complaint alleged that the Executive Director of Luz Community Development Coalition (Luz), Las Vegas, NV, used AmeriCorps program funds to pay for a family vacation trip to Europe.  The investigation determined that the executive director used a credit card charged to the AmeriCorps grant to pay $8,451.08 of these personal expenses.

 

In the course of investigating these expenditures, investigators also discovered that Luz personnel improperly disbursed $169,500 in living allowances and certified education awards totaling $95,804 for individuals who were allowed to serve without the required checks of the National Sex Offender Public Website (NSOPW).  Moreover, grantee staff presented investigators with altered NSOPW results to conceal their untimely completion.  Luz also paid $13,500 in living allowances to 10 members after they had left the program.

 

Further, due to a conflict of interest, an employee of the Nevada Volunteer Commission had falsely declared the program to be “in full compliance,” even though he learned during a site visit that the NSOPW checks had not been completed.  At the time of the site visit, the Commission employee was in employment discussions with Luz, and he subsequently joined its staff.

 

In March 2015, CNCS management disallowed $177,232 in grant costs, representing living allowances and education awards for those members who did not undergo NSOPW checks or where Luz personnel altered the date of the results.  Notwithstanding its written policy to disallow costs incurred prior to completion of NSOPW checks, CNCS did not disallow the costs related to the late-performed checks and did not address the $13,500 in living allowance overpayment.  CNCS debarred the former Executive Director for a period of three years and debarred the former Commission employee for one year.  In the interim, Luz had ceased operations. 

 

Recent Activity - On April 24, 2015, CNCS management informed the OIG that it has received additional documentation from the Nevada Volunteer Commission, which showed that five of the former members’ NSOPW checks were properly performed prior to service.  The Commission personnel also located one of the missing NSOPW checks.  Based on the documentation CNC management reduced the disallowed costs to $130,290.

 

 - Case ID: 2012-012

Education Award Treasury Checks Stolen, Forged and Negotiated

A CNCS manager notified OIG that unknown person(s) had stolen and negotiated 12 U.S. Government Treasury checks, totaling $6,692.47, representing education awards paid by the U.S. Treasury and mailed to a Miami Florida College to pay the education expenses of former AmeriCorps members.  An additional 55 checks from the same batch had apparently also been stolen; some of them have since been negotiated.  This matter was referred to the United States Secret Service, Miami, FL, for investigation.

 

– Case ID 2015-016

Agency Employee’s Lack of Oversight of VISTA Project Resulted in Waste of $700,000

Due to the carelessness of a CNCS State Program Specialist, the Corporation disbursed more than $700,000 in Federal funds for unallowable and/or otherwise impermissible service activities.  OIG found evidence that the employee provided inaccurate guidance that allowed VISTA members to serve in staff position(s).  Additionally, the employee approved 13 VISTA Assignment Descriptions (VADs) that impermissibly allowed the sponsor to assign VISTA members to perform direct service.  When members complained about these assignments, she made no meaningful effort to resolve their concerns and instead withheld information about the complaints from her supervisors and from the VISTA project site.  The employee was allowed to retire prior to imposition of disciplinary action.

 

Case ID: 2014-021

Improper Use of Federal Contracting Funds (Unfounded)

A Hotline complaint alleged that CNCS National Civilian Community Corps (NCCC) officials violated Federal procurement regulations when they spent $675,000 to renovate a campus cafeteria at a for-profit university.  Our investigation disclosed that the information provided by the complainant was incomplete. The renovations added new kitchen units to be used by groups of NCCC members.   The Corporation had determined that installing kitchens and requiring members to prepare their own group meals would promote team work and reduce the overall food costs of the program.

 – Case ID: 2015-006

Allegation of Misuse of Federal Grant Funds/ Unallowable Service

A Hotline complaint alleged that an AmeriCorps Site Director at Notre Dame Mission Volunteers (NDMV) San Francisco, CA, had used AmeriCorps funds to pay for lavish dining for members, as well as the Director’s spouse. The complainant also reported that the Director authorized members to claim service hours for unallowable activities and for activities outside their AmeriCorps service.

Because NDMV’s grant was a fixed amount grant, no Federal funds were associated specifically with the meals and other program expenses. The grantee confirmed that the expenses recorded by the Site Director were consistent with its organizational policies and the program’s budget.

Further, the investigation found that the allegations regarding unallowable activities were inaccurate and based on incomplete information. CNCS-OIG concluded that the grantee operated within the purview of the AmeriCorps guidelines and found no evidence to substantiate the allegations. The results of the CNCS-OIG investigation were provided to CNCS management.

 

– Case ID: 2015-004

Fraudulent Timesheet Results in Denial of Education Award for AmeriCorps Member

The CNCS-OIG received a Hotline complainant alleging that a former AmeriCorps member of Change a Heart Franciscan Volunteer Program (Change a Heart), Pittsburgh, PA, (an AmeriCorps sub-grantee of Catholic Volunteer Network, Takoma Park, MD), submitted inflated AmeriCorps timesheets during his term of service. The complainant alleged that the former member was a part-time employee for ENEC and counted his employment hours towards his AmeriCorps service, which allowed him to earn an education award.

The CNCS-OIG investigation determined that the former member submitted inflated timesheets that allowed him to be eligible for an education award; however, Change of Heart officials never awarded him an education award because he violated Change a Heart and AmeriCorps policies. There was no financial loss to the Government.

 

– Case ID: 2015-002

Allegations of Prohibited Use of Social Innovation Fund Grants to Support Lobbying Efforts (Unfounded)

A Hotline complaint alleged that a Social Innovation Fund (SIF) grantee used Federal funds for lobbying in support of legislation to ban smoking in public places. The complainant claimed to have witnessed grantee volunteers distributing flyers that urged citizens to vote for an anti-tobacco law in St. Joseph, Missouri.

CNCS-OIG investigators determined that the grantee had a robust program of compliance to avoid lobbying and was in fact using the grant funds to promote healthy lifestyles, including education regarding obesity, nutrition and smoking cessation. The lobbying activities were conducted by an independent organization with a similar name. Investigators found no evidence that the grant-funded organization engaged in lobbying activities.

 

 – Case ID: 2014-022

Allegations of Alteration of Documents and Violation of 45 CFR § 2540.203 (Sex Offender Checks)

CNCS-OIG received a Hotline complaint from a former AmeriCorps member who alleged that an employee of East Bay Community Action Program, Providence, RI, (East Bay), an AmeriCorps grantee, instructed him to alter non-AmeriCorps program documents and students’ test scores. While those allegations were not substantiated, investigators discovered that East Bay did not conduct complete criminal history checks for two AmeriCorps members. The grantee thus allowed two members to serve a combined 491 hours in the community, without a nationwide search to assure that they were not registered sex offenders or murderers. CNCS Director of the Grants Management Office allowed the questioned costs for their service even though the checks were incomplete when the members began service. CNCS later amended its policy to require grantees to ensure that their search of the National Sex Offender Public Website includes results from all United States jurisdictions before a member begins AmeriCorps service.

 

– Case ID: 2014-014

Settlement of Qui Tam Action Results in Largest Recovery Ever by CNCS

Concurrent with CNCS-OIG’s own investigation of allegations concerning fraud in Project Ayuda, an AmeriCorps program at Paradise Valley Community College (PVCC), Phoenix, AZ, a former employee filed a qui tam action, alleging that the project’s Executive Director engaged in forgery and false statements. Our investigation disclosed that between 2007 and 2010, the Executive Director allowed certain pre-professional students to receive AmeriCorps credit for performing clinical services independently required by their academic programs. As a result, the community received no additional benefit from the AmeriCorps funds expended. By approving false timesheets and certifying false education awards, the Executive Director induced AmeriCorps to disburse $2,960,684.05 in Federal funds: $2,036,084.05, in education awards paid to ineligible AmeriCorps members and $924,600 in administrative fees paid to PVCC for expenses related to implementing the grant. Criminal prosecution was declined. The grantee recently settled the civil proceedings for $4,083,304 in damages and penalties, an unprecedented recovery for the AmeriCorps program.

 

– Case ID: 2013-001

Allegations of Fraudulent Timesheets and Displacement

An anonymous complaint alleging that unnamed AmeriCorps members at Cantera Capital, Cantera, PR, submitted fraudulent timesheets and that program officials assigned members to serve in staff position(s). The investigation found insufficient evidence to substantiate the allegations regarding displacement of staff. Although multiple members alleged that others had submitted false timesheets, each of them refused to name the offenders for fear of physical retaliation. The remaining evidence was inconclusive, leaving CNCS-OIG unable to determine whether false timesheets had been submitted. The results of this investigation were provided to the Puerto Rico Commission.

Unallowable AmeriCorps Service Results in Disallowed Hours and Corrective Actions

A Hotline complaint alleged that program officials of the Austin Independent School District (AISD), Austin, TX, were requiring AmeriCorps members to fill in as substitute teachers. CNCS-OIG referred this matter to the OneStar Foundation (Texas State Commission), Austin, TX, for review and resolution. The Commission determined that 13 out of the 14 members assigned to the school district were asked to serve as substitute teachers, grade assignments and perform other unallowable activities and disallowed the claimed service hours. Further it required the school district to update its procedures and policies and provide training to staff to ensure that members were not required to perform unallowable activities.

Unauthorized Service Results in Disallowed Service Hours

A Hotline complaint alleged that an individual enrolled as an AmeriCorps member serving at Northern Ohio Medical University (NEOMED), Rootstown, OH, was not performing AmeriCorps service but was instead managing the AmeriCorps program as a member of NEOMED’s staff. CNCS-OIG discovered that NEOMED’s personnel directory listed the individual as the “AmeriCorps Manager, Family & Community Medicine,” and referred the matter to CNCS management for further action, which in turn directed the Serve Ohio Commission on Service & Volunteerism (Commission), Columbus, OH, to look into the matter. The Commission found no irregularities except for a discrepancy of three hours in time reporting. Although the most serious allegations were unsubstantiated, the Commission advised that it had taken steps to improve grantees’ documentation of member service hours and establish a well-defined separation between individuals serving as AmeriCorps members and becoming AmeriCorps program staff. CNCS management concurred with the Commission’s findings.

Improper Use of AmeriCorps Members Results in Disallowed Costs

The New York State Commission informed CNCS-OIG that, during a monitoring visit to sub-grantee Green City Force, Inc. (Green City) Brooklyn, NY, they were made aware of allegations regarding alteration of AmeriCorps members’ timesheets and unallowable service activities beyond the scope of the grant. Following up on these allegations under the direction of CNCS-OIG, the Commission concluded that 36 percent of the service hours claimed for the grant year 2013-2014 were unallowable, constituting service outside the scope of the grant, activities performed outside the United States and impermissible displacement of staff from which the grantee benefited directly. As a result, the Commission disallowed $23,788.54 in education award costs.

 

Allegation of Displacement-Improper use of AmeriCorps Members

The OIG received a Hotline complaint from a former AmeriCorps member alleging allegations of fraud, abuse, and non-compliance involving AmeriCorps grantee employees, Our House, Little Rock, AR, a site for the Community Initiative of Arkansas (CIA) grant administered by the Arkansas Service Commission (Commission).  The complainant reported that during her service as a member, she performed duties ordinarily performed by staff employees.  The complainant further alleged other members were also serving in staff capacity.  Additionally, the individual reported she was treated differently than other members, and did not perform meaningful service claiming it did not amount to anything more than babysitting at the daycare center.

 

The OIG investigation determined there was insufficient evidence to prove some of the allegations made by complainant.  It appeared the complainant herself may have engaged in questionable service when she claimed she periodically watched children during evening events.  However, the individual was unable to quantify the amount of time she engaged in such activities.  In regards to other members performing staff functions, there was no evidence to support the allegations.  The OIG provided the results of this investigation to the Arkansas Commission.