Performance Audit of AmeriCorps’ Grants Awarded to California Volunteers

Require California Volunteers to (a) update its FFR reconciliation procedures to track and reconcile matching contributions at the PER and FFR level, supported by standardized reconciliation templates and complete documentation prior to each FFR submission; (b) implement a formal, semi-annual reconciliation of subrecipient match amounts to supporting invoices and records, maintained in California Volunteers permanent grant files; and (c) assign designated personnel responsibility for reconciliation workpapers, establishing supervisory review prior to each FFR submission

Assess whether CivicWell has capacity to continue administering Federal awards

Require California Volunteers to request a pre-award audit or survey of high risk subrecipients as a mandate before issuing any new grants, including evaluation of financial management systems, internal controls, accounting practices, documentation procedures, and compliance with 2 C.F.R. Part 200 requirements, with award approval contingent upon the results

Require California Volunteers to request BACR to revise its travel reimbursement procedures to include a mandatory review step that compares submitted lodging rates against the applicable Federal per diem rate prior to payment processing and cost allocation

Require California Volunteers to request BACR to train finance and program staff responsible for travel reimbursements on the requirements of 2 C.F.R. § 200.475 and the fund-split obligations outlined in BACR's Accounting Policies and Procedures Manual

Require California Volunteers to direct BACR to provide a complete period-by-period reconciliation of in-kind contributions reported on each FFR to the corresponding in-kind table and general ledger entries

Require California Volunteers to direct BACR to implement period-end cut-off controls to ensure that in-kind contributions and expenditures are recorded and reported exclusively within the applicable reporting period

Require California Volunteers to direct Ampact to establish written procedures ensuring that contractual expenses are posted to the GL period corresponding to the service period identified on the invoice, regardless of when the invoice is received or approved. Procedures should explicitly address situations where internal approval is obtained after the service period closes and should specify the required accounting treatments such as recording an accrual entry in the service period and reversing it upon formal approval and payment in the subsequent period

Require California Volunteers to direct Ampact to implement a period-end reconciliation procedure: Require finance staff to reconcile invoice service periods against GL posting periods monthly, with supervisory review, to identify and correct any misalignments before financial reports are submitted to the Commission

Require California Volunteers to provide staff training on Federal requirements under 2 C.F.R. § 200.302 and 2 C.F.R. § 200.430, with specific emphasis on the obligation to track and document subrecipient cost sharing and match on a periodic basis, to maintain reconciliation workpapers as a standard component of grant administration independent of audit activity, and to ensure that all payroll charges to Federal awards are supported by contemporaneous time and effort records prior to disbursement

Require California Volunteers to implement a system-level control that prevents payroll disbursement when no corresponding timesheets or hours record exists for an employee in the applicable pay period, ensuring all payroll charges to Federal awards are supported by time and effort documentation prior to processing. In addition, periodic reconciliations should be performed between payroll disbursements and corresponding timesheets to ensure that all charges to Federal awards are fully supported

Require California Volunteers to establish a comprehensive, risk-based subrecipient monitoring program complying with 2 C.F.R. § 200.332 that includes: (a) formal written policies covering pre-award risk assessment, monitoring frequency and scope, reimbursement verification, corrective action, and follow-up; (b) an annual risk assessment tool requiring more frequent on-site visits for high-risk subrecipients; (c) Monitoring procedures that include general ledger reviews; verification of the segregation of federal and matching costs; expenditure testing covering a sufficient amount of reported costs to verify compliance with 2 C.F.R. § 200.332, 2 C.F.R. § 200.302, and 2 C.F.R. § 200.306; and reviews of timekeeping records and travel costs for allowability and compliance; (d) verification of complete supporting documentation before approving reimbursements, with payment withheld for deficiencies; and (e) assessment and hiring of qualified monitoring staff and mandatory 2 C.F.R. Part 200 training for both Commission and subrecipient personnel, and supplemented ongoing technical assistance.

Require California Volunteers to (a) maintain a centralized deficiency and corrective action tracking log, require written corrective action plans with timelines, and establish escalation procedures including payment withholding or subaward termination for unresolved noncompliance; (b) develop a questioned cost recovery plan distinguishing supportable from disallowed costs and require reimbursement of all disallowed amounts, ; and (c) submit quarterly reports to AmeriCorps on corrective action status, monitoring results, and cost recovery progress until all deficiencies are resolved

Require California Volunteers to suspend payments to high-risk subrecipients

Require California Volunteers to conduct on-site reviews of all active subrecipients identified as high-risk and report the results to AmeriCorps

Recover $4,827,195 in questioned Federal costs and disallow $6,016,927 in match costs

Determine whether CivicWell is a subrecipient under any other AmeriCorps grants and take appropriate actions so that additional Federal funds are not at risk