Open Recommendations

Limit types of projects undertaken by NCCC for activities that can be performed by other CNCS programs and track the time devoted thereto.

Develop comprehensive risk-based enrollment and retention strategy that includes identifying the characteristics that make individuals, including those from disadvantaged circumstances, successful; develop interview and application questions to identify...

Identify the support that would increase retention and provide it. Engage Foster Grandparents and other local community groups to provide support.

Develop granular information regarding root causes of attrition with better exit interviews of members and interviews of peers, sponsors and campus leaders; use the information for recruiting, selection and support.

Right-size NCCC and grow the program only after enrollment and retention have improved above a predetermined level

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.Pending since FY 2017

timely review and approval of SVs; and

Research and retain supporting documents required for any identified account balance differences derived from its abnormal balance review or the tie point analysis.Pending since FY 2017

timely review and approval of SVs; and

Detailed process to research significant balance fluctuations. CNCS should research and explain all significant balance fluctuations at the account and transaction level. Maintain and have the supporting documentation readily available.

Address fatal and non-fatal Government-wide Treasury Account Symbol Trial Balance edit failures.

Determining and maintaining relevant documentation to support each SV/JV;

Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary.

Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

Implement a peer review process to carry out the necessary quality control reviews of the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Determining and maintaining relevant documentation to support each SV/JV;

Timely review and approval of SVs/JVs for accuracy and propriety. (modified repeat)

Consider changes in conditions or programs that require further research and analysis. Update the assumptions when necessary.

Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

Implement a peer review process to carry out the necessary quality control reviews of the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Grantees' incurred but not reported (IBNR) reporting pattern from when the expenses have been incurred to the time those expenses are included the grantees' Federal Financial Reports (FFR). Grantee surveys may be conducted to confirm the…

Post-accrual analysis to compare the accrual (without the IBNR) and the expenditures reported in the FFRs for the same quarter. Thresholds should be established and documented based on materiality and the degree of risk that management is willing to…

Update the incurred but not reported estimation process as necessary to reflect changes in payment patterns. (repeat)

Implement a process to track patching of network devices and servers by the defined risk-based patch timelines in CNCS policy.

Replacement of information system components when support for the components is no longer available from the developer, vendor or manufacturer.

Monitor and record actions taken by the contractor to ensure vulnerability remediation for network devices and servers is addressed or the exposure to unpatchable vulnerabilities is minimized.

Enhance the inventory process to ensure all devices are properly identified and monitored.

Complete a detailed performance diagnostic and gap analysis on AmeriCorps’ financial management personnel, processes, and systems, including a root cause analysis, and then develop, design, and implement a plan toward short- and long-term goals.

Perform intermediate assessments of the effectiveness of its executed plans and final evaluations of its financial management operations to ensure desired results are achieved.

Develop a process to understand the root causes and conditions behind each control deficiency and the discrepancies between the control deficiencies identified by AmeriCorps’ internal control testing and those reported by the external auditors. The…

Require each department head to be responsible and accountable for timely developing and implementing CAPs and require each department’s staff to test the design and effectiveness of each CAP as implemented to ensure that it achieves the desired results.

Require each department head to be responsible and accountable for timely developing and implementing CAPs and require each department’s staff to test the design and effectiveness of each CAP as implemented to ensure that it achieves the desired results.

Revise the Business Process Narratives to incorporate significant changes in the current financial and control environment.

Develop and implement effective controls, including a quality assurance process, necessary to ensure that: (New)

Develop and implement effective controls, including a quality assurance process, necessary to ensure that: (New)

accounting and reporting are in accordance with U.S. GAAP and financial information is presented in compliance with OMB A-136.

account balances are accurate as of and through the reporting period.

the proper validation, review, and approval over financial reporting and the AMR compilation.

Develop, identify and make available the training necessary to ensure that staff obtain and update the skills necessary to ensure compliance with: (New)

FASAB concept and accounting standards.

FASAB concept and accounting standards.

OMB A-123.

OMB A-136.

GAO Disclosure checklist.

Treasury’s U.S. Standard General Ledger annual update.

the correct use of the Business Event Transaction Codes (BETC) when submitting transactions to Treasury.

Develop and implement financial reporting internal controls to analyze and address the root causes of the need for journal entries and the corrective actions in financial management systems to reduce the necessity of future journal entries.

Verify and validate the underlying input data to the TOLM.

After the verification and validation, reassess its assumptions and consider expanding the subjective elements of the calculation (i.e., those based on changes to the economy and the job market) to include changes in the way awards are utilized.

Update AmeriCorps' Information System Inventory to include external vendor systems such as Administrative Resource Center Financial System. (New)

Establish policies and procedures to perform an annual review of the inventory to ensure AmeriCorps' Information System Inventory includes all information systems used or operated by an agency, an agency contractor, or another organization on behalf…

Upgrade to a supported version of the application software and revise the references to the supported software in the Business Impact Analysis or accept the risk of not updating the software by documenting the exposure risk in a formal risk acceptance…

Develop and implement an effective monitoring mechanism to track the progress of Authorization to Operate letters within the three-year review window and ensure timely approval of the System Security Plans. (New)

Complete an authorization package that covers the Administrative Resource Center Financial System (New)

Enhance and implement core and specialized training to develop competencies in authorization packages for external vendor systems such as Administrative Resource Center Financial System. (New)

Finalize and issue the Incident Response Plan for FY 2023. (New)

Establish and implement a process and an effective monitoring mechanism to track the progress of Incident Response Plan annual reviews ensuring timely completion and updates, adapting the evolving cybersecurity threats, maintaining effective response…

Develop a comprehensive project plan and roadmap to meet the logging requirements in accordance with OMB M-21-31. (New)

Upgrade and configure its Security Information and Event Management tool to capture all log requirements in accordance with OMB M-21-31. (New)

Implement a tool to closely track the timely completion and review of an annual Disaster Recovery Exercise/Contingency Plan Test conducted to account for all information systems. (New)

Develop and implement standard operating procedures for Disaster Recovery Exercise/Contingency Plan Test coverage of external vendors systems including Administrative Resource Center Financial System. (New)

Enhance and implement core and specialized training programs targeted at the Authorizing Official, System Owner, and Information System Security Officer to develop competencies in contingency planning for external vendor systems. (New)

Complete the three steps in accomplishing Business Impact Analysis in accordance with NIST SP 800-34, Revision 1 and ensure the application adheres to the minimum requirements. (New)

Develop a contingency plan and perform Business Impact Analysis for Administrative Resource Center Financial System. (New)

Require, or verify that Serve DC has implemented, controls to obtain and maintain supporting documentation for all staff costs.

Disallow the $266,350 of match in-kind costs claimed on the Federal Financial Report related to the VGF grant (17VGHDC001). In addition, determine if Serve DC was able to meet the match requirement pertaining to the Federal costs claimed for the VGF…

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…

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 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.

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

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

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…

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…

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

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

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…

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

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.

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…

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…

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…

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.

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

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

Communicates subgrantee performance measures.

That charged consultant costs are consistent with professional service agreements.

Disallow and recover the $27,364 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Require the Commission to provide its subgrantees with additional training and guidance regarding how to appropriately exit members, including members with CPCs. This guidance should include procedures designed to ensure its subgrantees receive and…

Recover the $18,887 in questioned Federal costs on AmeriCorps Grant Number 16AFHPR001 from the Commission.

Recover the $5,377 in questioned Federal costs from the Commission and disallow the $1,445 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16TAHRP001, 19CAHPR001, 16AFHPR001, and 19AFHPR001.

Require the Commission and its subgrantees to implement additional internal controls and establish additional policies and procedures to ensure that they only charge allowable costs to AmeriCorps Commission support grants. The additional controls should…

Disallow and recover the $3,098 in questioned education awards on AmeriCorps Grant Number 19AFHPR001.

Require the Commission to periodically reconcile subgrantee member timesheets to verify that the subgrantees appropriately calculated the total hours recorded on the timesheets and, if the subgrantees did not appropriately calculate the hours, perform…

Conducting annual training sessions on financial reporting requirements for subgrantee personnel who are responsible for submitting PERs.

Reconcile the differences between grantees’ internal accounting records and FFRs to determine the propriety of the component payments or require grantees to perform this reconciliation. In addition, AmeriCorps should report any remaining unmatched…

Assess whether FFRs were submitted by eligible organizations during the FFR data pull process, as required by OMB. If it is determined that any grant recipients were ineligible to receive the grant, AmeriCorps should include the entire amount of FFR…

Publish improper payment and unknown payment estimates for NST in the accompanying materials provided with future annual financial statements in accordance with OMB guidance. (Modified FY 2022 Recommendation 5)