Audit of AmeriCorps Grants Awarded to the Puerto Rico Commission for Volunteerism and Community Service

Instruct its Office of Regional Operations to implement an oversight mechanism to ensure that the Commission:

Performs and documents the results of subgrantee risk assessments.

Performs and documents annual subgrantee monitoring activities.

Communicates subgrantee performance measures.

Evaluates subgrantee performance against communicated performance measures.

Require the Commission to update its AmeriCorps State Policy and Procedure Manual to state that the Commission must base its subgrantee monitoring plans on each subrecipient’s risk of noncompliance, including risks regarding potential fraud and conflicts of interest.

Recover the $52,919 in questioned Federal costs from the Commission and disallow the $259,225 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 19CAHPR001, and 19AFHPR001.

Require the establishment of clear guidance regarding how to evaluate and document the allowability of costs, including in-kind contributed costs, reported on AmeriCorps grants, and provide the Commission and its subrecipients with training on the guidance. Updated guidance should address how to document:

Personnel and fringe benefit costs, including that they are consistent with organizational policies, the employee’s salary appointment, and the amount of effort the employee dedicated to the grant.

The benefit and value of in-kind contributions claimed as match costs, including other operating cost contributions such as office space, utilities, parking costs, and donated supplies.

That charged consultant costs are consistent with professional service agreements.

The benefit and value received of training activities.

The business purpose of trips taken.

Disallow the $100,409 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001

Require the Commission to update its PER review process to include verifying grantees only claim match costs for costs directly assignable to AmeriCorps grants.

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.

Recover the $69,756 in questioned Federal costs from the Commission and disallow the $23,869 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 16TAHPR001, and 19AFHPR001.

Require the Commission to implement a process for reconciling its accounting system records to the costs reported on its FFRs on a quarterly basis and work with AmeriCorps to identify and resolve any discrepancies as necessary.

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.

Recover the $38,148 in questioned Federal costs from the Commission and disallow the $1,500 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Disallow and recover the $23,499 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Require the Commission and its subgrantees to obtain and document the required components of the NSCHCs using agency-approved vendors, consistent with 45 C.F.R. §2540.204(b).

Disallow and recover the $27,364 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

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.

Recover the $18,887 in questioned Federal costs on AmeriCorps Grant Number 16AFHPR001 from the Commission.

Require that the Commission update its subgrantee monitoring policies to include procedures to verify that subgrantees appropriately enroll and exit all ASN members.

Require that the Commission create templates and member training resources designed to ensure that subgrantees appropriately enroll and exit ASN members. Subgrantee resources should include:

Detailed procedures regarding how to document that a member meets the education requirements.

Contract, enrollment form, exit form, and end-of-term evaluation templates that subgrantees can use to ensure appropriate enrollment, evaluation, and exiting of ASN members.

Training on how to appropriately complete member enrollment and exit procedures, including how to verify that the subgrantee has appropriately completed the templates.

Recover the $5,377 in questioned Federal costs from the Commission and disallow the $1,445 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16TAHRP001, 19CAHPR001, 16AFHPR001, and 19AFHPR001.

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:

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.

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 train its subgrantees on best practices to avoid claiming unallowable costs. The training should include how to ensure the subgrantees appropriately disburse member living allowances and do not report duplicate payments for reimbursement.

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.

Disallow and recover the $3,098 in questioned education awards on AmeriCorps Grant Number 19AFHPR001.

Require the Commission to periodically reconcile subgrantee member timesheets to verify that the subgrantees appropriately calculated the total hours recorded on the timesheets and, if the subgrantees did not appropriately calculate the hours, perform corrective actions in a timely manner.

Require the Commission to provide a training session for all current and future AmeriCorps members and site supervisors that discusses timekeeping procedures to ensure members and supervisors appropriately report hours to AmeriCorps. Specifically, training activities should include information regarding how to:

Verify that the data reported to eGrants is accurate prior to submission.

Calculate the member’s daily service hours based on the times the member signs in and out each day.

Track and monitor member service hours to ensure that members do not spend more than 20 percent of their service hours performing training activities.

Require the Commission to implement controls regarding the submission of drawdown requests. Specifically, the Commission should perform timely reconciliations of its financial records and ensure that it only draws down funds once the reconciliation is complete, such that cash on hand from drawdowns does not exceed its existing expenditures.

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.

Require that the Commission strengthen its administrative and management controls and processes for the timeliness of financial reporting. Processes should include:

Implementing updated procedures to ensure it submits FFRs to AmeriCorps on a timely basis.

Requiring reporting extensions from AmeriCorps if the Commission does not believe that it will be able to meet established FFR due dates.

Require that the Commission strengthen its administrative and management controls and processes over the timeliness of subgrantee financial reporting. Processes should include:

Contacting subgrantees that are consistently non-compliant with AmeriCorps grant reporting requirements and discussing the reporting requirements outlined in their grants.

Issuing waivers for or enforcing actions on, subgrantees that do not provide accurate financial reports on a timely basis.