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Performance Audit of AmeriCorps Seniors Grantees’ Financial Management Systems

Date Issued
Report Number
OIG-AR-23-06
Report Type
Audit
Description
The audit of 15 AmeriCorps Seniors grantees found that their financial management systems did not comply with Federal regulations and grant terms and conditions. As a result of these deficiencies, we identified $268,627 in questioned Federal costs and $377,199 in non-compliant match costs reported on AmeriCorps grants. AmeriCorps waived match requirements for AmeriCorps Seniors grants during the COVID-19 pandemic, which was within our audit scope, so we could not question the $377,199 in unsupported match costs. We made recommendations for AmeriCorps to ensure that grantees strengthen their financial management systems and appropriately monitor costs reported on AmeriCorps grants. AmeriCorps agreed with our findings and recommendations and plans to evaluate the questioned costs through its audit resolution process.
Joint Report
No
Agency Wide
Yes
Questioned Costs
$268627
Funds for Better Use
$0

Open Recommendations

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Recover the $216,861 in questioned Federal costs that were not supported by the grantees’ financial management system records

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Conduct Federal and match grant close-out reconciliations for all grantees whose financial management systems did not support the Federal or match costs reported within their Federal Financial Reports. If the grantee’s financial management system records do not reconcile to the amounts reported or appear to include costs that are not allocable, reasonable, or allowable, take action accordingly

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Require that grantees revise their existing financial management systems to ensure that the grantees can identify and reconcile all Federal and match costs reported within their Federal Financial Reports and that they can differentiate between expenses paid using Federal funds and expenses paid using other funding sources.

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Increase its monitoring activities for the Federal Financial Reports reporting process to ensure that AmeriCorps Seniors grantees’ Federal Financial Reports are appropriate.

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Instruct AmeriCorps portfolio managers to provide grantees with sufficient guidance and training on how to:
a. Ensure that all costs reported on Federal Financial Reports submitted to AmeriCorps are sufficiently supported and reconcile to the grantees’ financial management systems.
b. Appropriately track and report Federal and match costs to support that the grantees used the funds for authorized purposes.

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Develop training and guidance for AmeriCorps Seniors grantees related to:
a. Documentation required to support costs reported on Federal Financial Reports, including how to ensure amounts reported are accurate and reconcile to the grantees’ financial management systems.
b. AmeriCorps Seniors grantees’ responsibilities with regard to retaining records and providing required documentation, responses, or information necessary to demonstrate that the documentation complies with Federal or AmeriCorps requirements.
c. Requirements for financial management systems to separately identify expenses that the grantees paid using Federal funds or matching funding sources.

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Issue clear instructions regarding match cost reporting and documentation requirements, including how these requirements may differ in extenuating circumstances or when grantees are eligible for a waiver.

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Recover the $42,945 in questioned Federal expenses that were not allowable, appropriately allocated, or adequately supported.

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Recover the $8,821 in questioned Federal expenses associated with employees and volunteers for whom the grantees did not appropriately perform National Service Criminal History Checks.

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Require AmeriCorps Seniors grantees to develop and implement additional procedures and internal controls to ensure that costs are allowable, allocable, and adequately supported.

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Require AmeriCorps Seniors grantees to develop and implement additional procedures and internal controls to ensure they appropriately and timely perform National Service Criminal History Checks

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Develop and provide guidance to AmeriCorps Seniors grantees regarding the requirements for indirect costs to ensure the grantees appropriately apply their Federally negotiated indirect cost rates and claim indirect costs.

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Coordinate with the Office of Regional Operations to work with its AmeriCorps Seniors grantees to strengthen their administrative and management controls and processes over the timeliness of financial reporting

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Verify that AmeriCorps Seniors grantees revise their financial management systems to ensure that the financial management systems can support comparisons of actual expenditures to amounts budgeted for each AmeriCorps Seniors grant.

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Develop and implement guidance and training for AmeriCorps Seniors grantees that addresses the use of financial management systems to create and maintain documentation to support that the grantees have compared actual expenditures to amounts budgeted for each AmeriCorps Seniors grant.

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Work with its grantees to revise their written policies and procedures to address Federal payment requirements and 2 C.F.R. § 200, Subpart E – Cost Principles.