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: (a) Performs and documents the results of subgrantee risk assessments. (b) Performs and documents annual subgrantee monitoring activities. (c) Communicates subgrantee performance measures. (d) Evaluates subgrantee performance against communicated performance measures.

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.

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.

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.

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 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: (a) 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. (b) Employees understand how to document trip costs to demonstrate that costs did not increase due to combining personal and business travel.

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 determine whether AmeriCorps members who served at MI in 2016 and 2019 should receive $20,794 in additional living allowance payments.

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 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.

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.

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.

Conducting annual training sessions on financial reporting requirements for subgrantee personnel who are responsible for submitting PERs.

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.

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.