AmeriCorps' Compliance with the Payment Integrity Information Act of 2019 for Fiscal Year 2024
Open Recommendations
Reconcile the differences between grantees’ internal accounting records and FFRs to determine the propriety of the component payments or require grantees to perform this reconciliation. Additionally, AmeriCorps should test and include the unmatched reporting errors as unknown payment errors in the projection of the improper payment estimate.
Determine whether awardees associated with FFRs submitted for Seniors awards were submitted by eligible organizations during the FFR data pull process. If it is determined that any AmeriCorps Seniors grantees were ineligible to receive the grant, AmeriCorps should include the entire FFR as an improper payment.
Implement additional quality control steps, proposed in response to NFR 2, to its improper payment data pulling and sampling process to ensure that all payments included are appropriate for the programs determined to be susceptible to improper payments.
Publish improper payment and unknown payment estimates for NST in the accompanying materials provided with the FY 2025 annual financial statements in accordance with OMB guidance.
Update its NST test plan to require the tester to verify that sampled education awards were only used to cover allowable COA expenses for members who earned the award (unless appropriately transferred).
Improve its quality control procedures to ensure AmeriCorps selects its NST sample and extrapolates its NST improper payment estimates consistent with its NST SEMP. Specifically, its quality control procedures should ensure AmeriCorps:
a. Excludes only records in the payment population that do not represent applicable disbursements, as justified in its SEMP.
b. Extrapolates its improper payment estimate only on the payments included within the sampling frame, unless otherwise justified and approved by OMB.
c. Documents the methodology used to extract the NST payment population used for sampling and the procedures used to verify the payment population is complete and accurate.