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Performance Audit of AmeriCorps Grants Awarded to YouthBuild USA

Date Issued
Report Number
OIG-AR-24-05
Report Type
Audit
Description
The audit of AmeriCorps grants awarded to YouthBuild USA found that AmeriCorps was aware of inconsistencies between Federal Statute and Federal Regulations concerning limitations on Federal share of member living allowance and member support costs beginning in 2009 and neither updated its Federal regulations nor effectively explained the inconsistencies to grantees. In addition, YouthBuild did not comply with Federal or AmeriCorps requirements, resulting in $3,604,355 of questioned Federal and match costs. The audit identified an additional $3,087,791 in funds put to better use. The questioned costs and funds put to better use stem from YouthBuild’s ineffective system of internal controls over timekeeping that failed to provide reasonable assurance that it and its subgrantees are adequately managing AmeriCorps funds. YouthBuild’s weak internal controls allowed a subgrantee to recruit prospective and existing employees as AmeriCorps members and permit them to earn and receive education awards for the same hours worked fulfilling their normal employment duties. In addition, YouthBuild’s timekeeping and member training hours policies significantly deviated from Federal regulations and AmeriCorps’ policy; and YouthBuild did not sufficiently monitor its subgrantees to detect instances of non-compliance with its policies. AmeriCorps agreed to disallow $3,083,528 in questioned costs due to the YouthBuild subgrantee recruiting employees as AmeriCorps members and other instances of subgrantee non-compliance undetected by YouthBuild’s monitoring. However, AmeriCorps did not agree with recommendations to disallow the remaining $520,827 of questioned costs related to noncompliant timekeeping practices and to require YouthBuild to pay $3,087,791 in outstanding education awards. These decisions by AmeriCorps increase the likelihood that grantees will adopt fraudulent timekeeping practices and put a significant amount of AmeriCorps funds at risk.
Joint Report
No
Agency Wide
Yes
Questioned Costs
$3604355
Funds for Better Use
$3087791
View report on Oversight.gov

Open Recommendations

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AmeriCorps’ Office of General Counsel update all applicable Federal Regulations addressing Federal share limitations and matching requirements for member living allowance and member support costs to align with the NCSA, as amended by the Serve America Act.

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AmeriCorps’ Office of General Counsel perform a comprehensive review of all Federal Statutes and Federal Regulations to identify inconsistent guidance, make appropriate corrections to the Federal Regulations, and provide the results to AmeriCorps OIG and AmeriCorps Office of Monitoring.

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AmeriCorps issue consistent, direct, and transparent communication to all AmeriCorps grantees to provide clarification on the current matching requirements for member living allowance and member support costs.

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Recover from YouthBuild $520,827 of education awards that were paid to members for subgrantees within the audit scope.

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Require that YouthBuild pay the $3,087,791 outstanding AmeriCorps Education awards yet to be distributed to the members of subgrantees within the audit.

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Assess the remaining $9,042,686 of at-risk funds to determine if sufficient supporting documentation for the hours claimed exists. If sufficient documentation does not exist, recover from YouthBuild the $1,349,717 already paid by the Trust and require that YouthBuild pay the $7,692,969 outstanding AmeriCorps Education awards yet to be distributed to members.

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Require YouthBuild to update its member timekeeping policy and procedures to align with Federal regulations and AmeriCorps grant terms and conditions to include adequate internal controls and documentation to provide reasonable assurance that YouthBuild and its subgrantees are adequately managing AmeriCorps funds.

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Disallow and recover all grant funds associated with AmeriCorps funding received by SJCC through YouthBuild during the audit period.

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Assess all current AmeriCorps funding to SJCC for the same violations noted in this report.

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Direct YouthBuild to perform a comprehensive assessment of YouthBuild’s subgrantees and determine whether any of their other subgrantees are following the same non-compliant practices as SJCC and provide the results to AmeriCorps Office of Monitoring and AmeriCorps OIG in a timely manner.

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Provide additional training to YouthBuild on AmeriCorps policies and subgrantee monitoring.

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Disallow and recover $1,590 in Federal costs from YouthBuild due to staff timekeeping errors at Crispus Attucks Charter School that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

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Require YouthBuild to verify that Crispus Attucks Charter School, and all YouthBuild subgrantees, do not use grant funding received from DOL grants to meet matching requirements. If DOL grant funds were used to meet matching requirements, AmeriCorps should disallow the match costs and recover the associated Federal costs from YouthBuild.

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Disallow and recover $40,384 in Federal costs from YouthBuild due to ineligible living allowance payments and insufficient member exit procedures at Philadelphia Youth for Change Charter School that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

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Disallow and recover $7,533 in Federal costs and disallow $8,242 in match costs and recover the associated Federal costs from YouthBuild due to errors at Change Inc. that were not identified by YouthBuild during monthly ARR reporting or subgrantee site visits.

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Require YouthBuild to determine the allowability, allocability, and reasonability of Change Inc.’s occupancy expenses and ensure that staff salary costs reported as Match costs are charged by grant activity or specific cost objective.

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Require YouthBuild to enhance member timekeeping policies to align with Federal regulations for training limitations.

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Require YouthBuild to verify that all subgrantees’ policies align with Federal regulations for training limitations.