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Fiscal Year 2020 Performance Audit of AmeriCorps’ Internal Control Program and National Service Trust Liability Model

Date Issued
Report Number
OIG-AR-21-02 (AmeriCorps OIG)
Report Type
Beginning in FY 2017, independent auditors have been unable to render an opinion on the consolidated financial statements of AmeriCorps and the National Service Trust. The audits resulted in disclaimers of opinion and identified numerous material weaknesses that remained uncorrected. In lieu of financial statements audits for FY 2020, the OIG engaged CliftonLarsonAllen LLP (CLA) to assess AmeriCorps’ progress in resolving two areas of material weakness: AmeriCorps’ internal control program (ICP) and the National Service Trust Liability Model. Our auditors found that AmeriCorps’ internal control program testing was substantially incomplete and that key controls in many areas could not be tested due to a combination of internal and external limitations. In addition, because AmeriCorps did not complete the planned corrective actions for significant aspects of the Trust Model, we rescoped the objectives to focus on the process by which AmeriCorps validated the underlying data about member enrollment, terms of service, and entitlement to education awards. The audit found that AmeriCorps’ review process was flawed in design and could not support its stated conclusion about the accuracy of the data used in the Trust Model. AmeriCorps agreed with our recommendations to develop policies and procedures and update narratives and testing attributes to properly reflect its current ICP operations. AmeriCorps also agreed to renew focus on the FY 2019 financial statement audit recommendations and to develop and implement a detailed corrective action plan that aligns directly to the Trust Model recommendations. In addition, AmeriCorps agreed to assess and document errors and corrections in the Trust Model. AmeriCorps Management’s Response can be found in Appendix C of the report.
Joint Report
Agency Wide
Questioned Costs
Funds for Better Use

Open Recommendations


Finalize the Grant Operations policies and procedures to reflect the current state and post‐reorganization.


Update the testing of design and effectiveness attributes to be consistent with the new policies and procedures.


Assess and document the known errors in the Trust Model and whether or not they could lead to material misstatements if not corrected. Document the rationale and procedures used to correct the data in the Trust Model.