PERFORMANCE AUDIT OF THE CNCS's COMPLIANCE WITH IPERA FOR FY 2017

May 23, 2018

18-04

Audit

Despite a continuous focus on improving its Improper Payments Elimination and Recovery Act of 2010 (IPERA) compliance program, the Corporation for National and Community Service (CNCS) remains unable to reliably estimate the amount or the rate of improper payments in the AmeriCorps State and National Program (AmeriCorps), Foster Grandparent Program (FGP), Retired and Senior Volunteer Program (RSVP), and Senior Companion Program (SCP). Specifically, we noted that the improper payments information reported in CNCS’s fiscal year (FY) 2017 Annual Management Report (AMR) is unreliable and incomplete; CNCS therefore did not comply with IPERA. As in the past, we identified flaws in multiple stages of CNCS’s improper payments assessment process; many of these flaws resulted from insufficient time and personnel to perform the FY 2017 IPERA testing. CNCS implemented a new alternative sampling methodology in FY 2017, as well as other corrective actions to address findings noted in the FY 2015 IPERA audit report. As a result of this progress, CNCS has met an additional OMB criterion for IPERA compliance, with two prior audit findings fully resolved in FY 2017. CNCS’s efforts also reduced the severity of some the issues, which are mainly limited to the sufficiency and adequacy of documentation as of FY 2017. However, these partial improvements did not substantially improve CNCS’s IPERA compliance, as CNCS did not meet four of the six OMB IPERA compliance criteria. Specifically, we identified the following compliance issues and other matters, all of which are recurring from the prior years: • CNCS did not properly identify improper payments, and the published improper payment estimates are not statistically valid, complete, or accurate. Specifically, we noted significant errors in CNCS’s sampling selection for its stratified sample and found that CNCS did not always follow, or document how it followed, its OMB-approved alternative sampling methodology. • CNCS did not fully comply with the IPERA risk assessment requirements, as it did not maintain documentation to support that it had performed additional procedures to verify that the FY 2015 risk assessment results were still valid for FY 2017. • CNCS did not meet its annual improper payment reduction targets for AmeriCorps, as the actual improper payment error rate reported was nearly twice the reduction target rate. • CNCS published an improper payment estimate that was greater than the acceptable threshold for IPERA compliance, or 10 percent, for three of its four programs (i.e., AmeriCorps, FGP, and SCP). Our report also notes other matters relating to CNCS’s ability to reduce and recapture improper payments, as follows: • CNCS did not adequately report on high-dollar overpayments, as it did not specify the risk-susceptible programs subject to high-dollar overpayments included in its report. • CNCS did not complete a cost-benefit assessment for payment recapture audits. • CNCS did not complete the reporting required as a result of its programs not complying with IPERA for three consecutive fiscal years.

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