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

Ensure the CNCS GSS Information System Owner establishes and enforces the policy for mobile devices that do not connect to the CNCS GSS to include usage restrictions, configuration and connection requirements, and implementation guidance. (New);

Disallow and recover $1,663,952 in Federal costs awarded to Madison;

Rec No. 2(d): Disallow and, if already used, recover education awards made to members who did not serve the minimum required service hours.

Rec. No. 2: CNCS VISTA should develop a standard for capturing capacity building and measuring sustainability during and after the VISTA project is completed.

Rec No. 5: VISTA should specifically measure the effectiveness of the policy allowing VISTA members to take classes while serving in the VISTA program. CNCS VISTA should build performance measures into all policy/procedure changes as a means to...

The process to determine and document CNCS’s balance fluctuation expectations should be based on a combination of internal and external operating factors, and program and financial relevant information available.

Pending since FY 2017

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors and consistent with the materiality thresholds used by the OCRO (as part of the...

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.

Pending since FY...

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

Address fatal and non‐fatal Government wide Treasury Account Symbol Trial Balance (GTAS) edit failures.

Pending since FY 2017

Address all balance differences and retain supporting documentation of related research.

Pending since FY 2017

Develop a plan to upgrade its financial system to include OC codes which should be associated with USSGL in accordance with OMB Circular No. A‐11.

Pending since FY 2017

Provide mandatory training to CNCS accounting staff on the proper use of OC, sub general ledger accounts, and document/transaction types on all obligation and expense transactions.

tracking the sequence of SVs for completeness;

appropriate use of SVs;

determining and maintaining relevant documentation to support each SV;

use of specific and accurate SV descriptions;

timely review and approval of SVs; and

review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation) and age are accurately reflected in the status of the obligation to confirm their validity;

Pending since FY 2017

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

Pending since FY 2017

perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved.

Pending since FY 2017

Develop a succession plan to ensure the required expertise is available in the event of employee turnover. Such succession planning is key to helping CNCS continue achieving its internal and external reporting objectives. CNCS needs to:

Pending since FY...

Train, mentor, and work to retain qualified employees;

Pending since FY 2017

Institute continued cross‐training so that knowledge of the model will reside with multiple staff rather than with one person; and

Pending since FY 2017

Implement a peer review process to carry out the necessary quality control reviews of the TSAL model.

Pending since FY 2017

Strengthen controls to ensure the TSAL modelling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources;

Review and ensure the reasonableness of assumptions used and document the rationale behind these assumptions;

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

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Coordinate with the program and grant officers to gather and analyze key grant programs’ (AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending pattern to develop factors relevant for grant accrual estimation....

Centralize storage of all procurement documents in contract files and maintain them electronically.

Strengthen internal control to ensure procurement documents are properly approved and retained.

Analyze procurement UDO balances quarterly to verify that balances are still valid for those without financial activities for an extended period.

Research, resolve and document the disposition of any abnormal UDO transactions/balances.

Correct the financial system’s posting logic to ensure all future transactions are recorded properly in accordance with USSGL.

Develop, document and implement an accounts payable accrual methodology to include the recognition and reporting of the IBNR. The methodology should also document key controls related to review and approval process of the accrual estimation.
Pending...

Conduct validation assessment of amounts accrued for the IBNR on a periodic basis. As part of the validation, CNCS should consider the following:

Subsequent activities against the amount estimated to determine the level of precision in the estimation;

Trend the validation results and adjust the IBNR estimation process to address any recurring significant fluctuations; and

Update the IBNR estimation process as necessary to reflect changes in payment patterns.

Analyze contractor‐developed‐software costs that were expensed but not capitalized in accordance with accounting standards. CNCS should record appropriate adjustments to correct the IUS balance based on its analysis.

Update CNCS policy to recognize and record capitalized costs during the period they are incurred.

Determine the root causes and resolve discrepancies in the grant award amounts recorded in the NGA in eGrants and in Momentum to prevent such differences from occurring in future.

Determine the root causes and resolve expenditure differences between PMS and Momentum.

All financial, performance and other required reports are submitted no later than 90 calendar days after the end date of the period of performance.

Document justifications for all required reports submission extensions granted to the grantee.

Update the CNCS transaction code posting logic for recording grant expenditures to comply with the USSGL guidance.

Require the program and grant officers who perform the grant close‐out in Momentum to certify that all required grantee information has been received and reviewed; and any final notices or changes to grant funding have been communicated and accepted by...

Reconcile the amounts reported in Other Liabilities to supporting documents to verify that Other Liabilities is supported by valid transactions and properly classified.

Develop a financial reporting checklist to ensure completeness and recording of all transactions.

Develop a multi‐year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls.

Enforce the agency‐wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities.
Pending since FY 2017

Strengthen and refine the process for communicating CNCS facility specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies.
Pending since FY 2017

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems....

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems.
Pending since FY 2017

Implement all detailed recommendations in the FY 2018 FISMA Evaluation report.
Pending since FY 2017

Reconcile the AR subsidiary ledger to the general ledger monthly.

Reevaluate the policies and procedures for calculating the allowance for doubtful accounts. Related policies and procedures should include: (a) CFO Office’s staff’s periodic review of the accounts receivable aging report, (b) assessment of the...

Revise the Allowance for Doubtful Accounts methodology to be consistent with the Debt Management Policy.

Track and revise collection efforts based on data analysis. A reasonable timeframe for writeoffs should be established for accounts receivable without any activity. Once an outstanding receivable is deemed uncollectible, it should be written off in...

The process to determine and document CNCS’s balance fluctuation expectations should be based on a combination of internal and external operating factors, and program and financial relevant information available.
Pending since FY 2017

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors and consistent with the materiality thresholds used by the OCRO (as part of the...

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.
Pending since FY...

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

Address fatal and non‐fatal Government wide Treasury Account Symbol Trial Balance (GTAS) edit failures.
Pending since FY 2017

Address all balance differences and retain supporting documentation of related research.
Pending since FY 2017

Develop a plan to upgrade its financial system to include OC codes which should be associated with USSGL in accordance with OMB Circular No. A‐11.
Pending since FY 2017

Provide mandatory training to CNCS accounting staff on the proper use of OC, sub general ledger accounts, and document/transaction types on all obligation and expense transactions.

tracking the sequence of SVs for completeness;

appropriate use of SVs;

determining and maintaining relevant documentation to support each SV;

use of specific and accurate SV descriptions;

timely review and approval of SVs; and

review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation) and age are accurately reflected in the status of the obligation to confirm their validity;

Pending since FY 2017

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

Pending since FY 2017

perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved.

Pending since FY 2017

Develop a succession plan to ensure the required expertise is available in the event of employee turnover. Such succession planning is key to helping CNCS continue achieving its internal and external reporting objectives. CNCS needs to:

Pending since FY...

Train, mentor, and work to retain qualified employees;

Pending since FY 2017

Institute continued cross‐training so that knowledge of the model will reside with multiple staff rather than with one person; and

Pending since FY 2017

Implement a peer review process to carry out the necessary quality control reviews of the TSAL model.

Pending since FY 2017

Strengthen controls to ensure the TSAL modelling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources;

Review and ensure the reasonableness of assumptions used and document the rationale behind these assumptions;

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

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Develop a multi‐year strategy to better strategically prioritize and allocate resources to address the new and continuing weaknesses identified and work towards automation, continuous monitoring and consistent application of controls.

Enforce the agency‐wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities.

Pending since FY 2017

Strengthen and refine the process for communicating CNCS facility specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies.

Pending since FY 2017

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems....

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems.

Pending since FY 2017

Implement all detailed recommendations in the FY 2018 FISMA Evaluation report.

Pending since FY 2017

Recover the $43,626 in questioned Federal costs and $19,390 in education awards and address any impact to Federal costs of the $33,720 in questioned match costs for American Red Cross of Indiana for grant No. 15ACHIN001.

Require that SGC provide Sanctuary with the requirements of an adequate financial management system and ensure that Sanctuary implements an adequate system. The documentation provided should include guidance on how to determine the allowability of grant...

Require Serve Guam Commission to submit an updated Financial Federal Report for the 14AH award that removes the $18,761 of questioned match costs.

Require SGC, as part of its subgrantee monitoring processes, to perform periodic testing of subgrantees’ other direct costs to ensure that they incurred and claimed all costs in accordance with grant provisions, laws, and regulations.

Ensure DGCCVS revises and implements its policies and procedures for assessing the financial capability of the subgrantee applicants. DGCCVS should verify the applicant’s financial management responses from the AmeriCorps Readiness Self-Assessment.

Verify that DGCCVS revise its subgrantee monitoring procedures to ensure it complies with pass-through entity responsibilities for sub-recipients’ Single Audits and includes the following procedures:

Review the single audit report for all subgrantees with CNCS expenditures for each fiscal year for findings that affect CNCS grants to determine if DGCCVS records require an adjustment and take enforcement action against noncompliant subgrantees;

Develop a documented process to determine if subgrantees accurately presented CNCS awards on the Schedule of Expenditures of Federal Awards (SEFA);

Ensure DGCCVS implements a process to determine whether the results of the subgrantee’s audit or other monitoring indicate conditions that necessitate an adjustment to its own records; and

Retain documentation of DGCCVS monitoring and reviews of subgrantee audit reports, along with management decisions made or corrective actions implemented.

Require DGCCVS to revise its subgrantee monitoring procedures to include formal and timely subgrantee feedback to address: When the monitoring site visit took place; What the monitoring covered; The monitoring results; Required corrective actions; and...

Require DGCCVS to revise its subgrantee monitoring procedures to include formal reporting of follow-up conducted on any outstanding corrective actions.

Verify that DGCCVS is performing on-site monitoring of its subgrantees in accordance with its revised internal policies and procedures.

Verify DGCCVS has controls in place to ensure fees collected for grant-supported events were used to cover the cost of those events.

Verify DGCCVS used the fees collected for the event to reduce the Federal share charged to the grant or were used as match.

Ensures DGCCVS strengthens its monitoring to verify subgrantee compliance with CNCS best practices for member NSOPW check.

Confirm DGCCVS has established and implemented a procedure to have all staff involved in conducting subgrantee on-site monitoring to have a NSCHC.

Ensure DGCCVS revises its Program Director Handbook to include guidance on how to address and document a change in member living allowance when a member’s term is changed to ensure living allowance payments after conversion is correct.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with member living allowance requirements.

Work with DGCCVS to resolve the living allowance underpayments to DPR members.

Ensure DGCCVS strengthens its monitoring to verify subgrantee compliance with DGCCVS approval requirement for changes in a member’s term of service.

Ensures DGCCVS strengthens and implements its monitoring tools to verify subgrantee compliance with timekeeping requirements.

Require DGCCVS put procedures in place to ensure that DGCCVS is providing reporting guidance and reporting templates to the subgrantees before the end of the first month of the subgrantee’s program year and all subgrantees are reporting its costs in...

Require DGCCVS to obtain PERs from DPR covering the Federal and match costs incurred during the program year 2017-2018 as of March 31, 2018, along with transaction-level detail, so that CNCS can test those costs for allowability.

Calculate and recover the questioned Federal costs, match costs, and related administrative costs. Also, determine the impact on Federal costs due to questioned match costs.

Develop comprehensive policies and procedures for the financial statements preparation process and related internal controls. The policies and procedures should address, among other subjects:

The process to determine and document CNCS’s balance fluctuation expectations. Expectations should be documented based on a combination of internal and external operating factors, and program and financial relevant information available.

The materiality threshold used to determine significant balance fluctuations that require further research should be more conservative than that used by external auditors.

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.

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

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

Address all balance differences and retain supporting documentation of related research.

Document and maintain support for all prior period adjustments and changes to Net Position accounts, Cumulative Result of Operations, and Unexpended Appropriations. (repeat)

Monitor outstanding balances resulting from financial system configuration issues and fix these issues prior to data migration to the future shared service provider (Department of Treasury’s Administrative Resource Center) in FY 2021. While waiting to...

Coordinate with the future shared service provider to ensure that its accounting platform is compatible with CNCS’s operations and the type of accounting transactions that the CNCS process. (new)

Develop a plan to clean up CNCS’s balances prior to migration to the shared service provider’s system (Department of Treasury’s Administrative Resource Center). The plan should include coordination with the future service provider to review CNCS...

Validate and ensure standard vouchers/journal vouchers are properly supported, documented, and are readily available for examination. (modified repeat)

Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

Develop and implement policies and procedures for the standard vouchers/journal vouchers (SV/JV) process that include:

Tracking the sequence of SVs/JVs for completeness;

Appropriate use of SVs/JVs;

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

Use of specific and accurate SV/JV descriptions; and

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

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds...

Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service...

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources.

Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

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

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Document and implement policies and procedures to include the following:

Establish a thorough and robust quality control process to ensure that the Trust Obligation and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by qualified CNCS personnel prior to relying on its outputs...

Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

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

Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

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

Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of key controls. (modified repeat)

Develop a succession plan to ensure the required expertise is available in anticipation of planned employee turnover, particularly with respect to the complex trust calculations. CNCS needs to:

Train, mentor, and work to retain qualified employees;

Cross-train employees so that knowledge of the model will reside with multiple staff rather than with one person; 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)

Enforce the agency-wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities. (repeat)

Strengthen and refine the process for communicating CNCS facility-specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies. (repeat)

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems. (...

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems. (repeat)

Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. (repeat)

Develop, implement and document procedures to identify all CNCS grantees that are required to submit single audit reports with their due dates. (new)

Develop, implement and document procedures on timely follow-up for those grantees whose audits have become past due, and to ascertain why report submission was late, when the audit report will be submitted to the Federal Audit Clearinghouse, and what...

Develop a practice to capture the single audit data to assess the effectiveness of the single audit report submission for all its grantees. (new)

Develop, implement and document procedures for implementing Office of Budget and Management (OMB) approved single audit report submission extensions, so that OMB approved extension approvals are documented and tracked as part of the single audit...

Update the Single Audit Resolution Policy to: Reflect the current monitoring process to track all audit findings related to CNCS-funded grants, and   Address CNCS’s responsibilities as the cognizant/oversight agency and how these responsibilities would...

Develop and implement procedures to monitor the effectiveness of the single audit monitoring process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 Responsibilities, (a) (3) (iv), related to monitoring the...

Strengthen coordination between Accounting and Financial Management Services and the Office of Budget to ensure that transactions are recorded accurately and timely. (modified repeat)

Tracking the sequence of SVs/JVs for completeness;

Appropriate use of SVs/JVs;

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

Use of specific and accurate SV/JV descriptions; and

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

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including establishing control activities; finalize materiality thresholds...

Develop for a more standardized, secure, and automated method to estimate the Trust obligations and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing CNCS’s transition to shared service, coordinate with the service...

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

Conduct detailed analysis and validation of data sources.

Review and ensure the reasonableness of assumptions used and document the rationale behind estimation assumptions.

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

Compare estimates with subsequent results to assess the reliability of the assumptions and data used to develop estimates.

Document and implement policies and procedures to include the following:

Establish a thorough and robust quality control process to ensure that the Trust Obligation and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by qualified CNCS personnel prior to relying on its outputs...

Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to ensure the accounting information is valid and proper;

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

Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in the obligation);

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

Perform complete reconciliations of all outstanding obligations monthly, and ensure any discrepancies identified are promptly researched and resolved. (repeat)

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of key controls. (modified repeat)

Develop a succession plan to ensure the required expertise is available in anticipation of planned employee turnover, particularly with respect to the complex trust calculations. CNCS needs to:

Train, mentor, and work to retain qualified employees;

Cross-train employees so that knowledge of the model will reside with multiple staff rather than with one person; 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)

Coordinate with the program and grant officers to gather and analyze key grant programs’ (AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending pattern to develop the following key factors for grant accrual estimation:

Percentage of CNCS grantees who drawdown funds in advance versus those on a reimbursable basis and their related grant amounts to its grant spending as a whole. If different key programs have different spending patterns, perform this analysis at the...

An inventory of relevant and reliable grant data to be used for the grant accrual assumptions and documentation to support what data is considered relevant and reliable;

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...

Revise and implement policies and procedures for the grant accrual methodology so that:

A validation process is established for management to verify the accuracy of the grant accrual, so that management can make any necessary adjustments to improve the precision of the grant accrual and to account for grant advances and payables to ensure...

It addresses how the calculations are used to arrive at the Grants Payable and Advances to Other line items in the financial statements. (modified repeat)

Develop a process to validate grant advances, incurred but not reported and payable estimates. Such validation should be performed for all program elements included in the estimation process and over a few years to show a trend of the estimates. Unusual...

Strengthen internal control to ensure procurement documents are properly approved and retained. (repeat)

Analyze procurement undelivered orders balances quarterly to verify that balances are still valid for those without financial activities for an extended period. (repeat)

Research, resolve and document the disposition of any abnormal undelivered orders transactions/balances. (repeat)

Conduct validation assessment of amounts accrued for the incurred but not reported on a periodic basis. As part of the validation, CNCS should consider the following:

Subsequent activities against the amount estimated to determine the level of precision in the estimation;

Trend the validation results and adjust the incurred but not reported estimation process to address any recurring significant fluctuations; and

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

Evaluate the materiality thresholds used in the accrual estimation to ensure it is appropriate to prevent misstatements. The materiality threshold used should be appropriate that, in the aggregate, identified misstatements would not rise to a level that...

Implement controls to ensure that transactions interfaced from eGrants are reflected in Momentum for the correct amounts, accounts, and number of transactions. (new)

Update CNCS policy to recognize and record capitalized costs in the period incurred. (repeat)

Update CNCS policy to include requirements for compliance with accounting standards; track direct labor and other indirect costs, including hours, worked and payroll costs dedicated to existing and new software-in-development projects; track and amortize...

Consult with the future shared service provider and other stakeholders to determine the feasibility of procuring and using project management software to track project costs from the inception to completion. The results of the analysis should be...

Determine the root cause behind the differences noted in the Undelivered Orders balance between Momentum and the Undelivered Orders balance derived from the net of grant award amount from the Notice of Grant Award and the grant expenditures from the...

Determine the root causes and resolve discrepancies in the grant award amounts recorded in the NGA in eGrants and in Momentum to prevent such differences from occurring in the future. (repeat)

Determine the root causes and resolve expenditure differences between the Payment Management System and Momentum. (repeat)

Strengthen controls around the review of expired grant obligations by ensuring that:

All financial, performance and other required reports are submitted no later than 90 calendar days after the end date of the period of performance.

Document justifications for all required reports submission extensions granted to the grantee. (repeat)

Update the CNCS transaction code posting logic for recording grant expenditures to comply with the United States Standard General Ledger guidance. (repeat)

Establish a requirement for Grant Officer/Portfolio Managers to provided documented certification that all required grantee information has been received, accepted, and documented before the grant is closed out. (repeat)

Establish a control requiring the Grant Officer/Portfolio Manager to provide documented certification, upon grant closeout, verifying the total award amount to total award expenses for the deobligated recovery amount. (repeat)

Inform all Grant Officers/Portfolio Managers to ensure that a reduction in funding to the award of a grant should be documented in eGrants which would result in modified Notice of Grant Awards. (new)

Reconcile the amounts reported in Other Liabilities to supporting documents to verify that Other Liabilities are supported by valid transactions and properly classified. (repeat)

Strengthen financial reporting internal controls and ensure that financial statements accounting line items are reviewed and reconciled to supporting documents prior to recording. The internal control activities should ensure proper posting of Member...

Enforce the agency-wide information security program across the enterprise and improve performance monitoring to ensure controls are operating as intended at all facilities. (repeat)

Strengthen and refine the process for communicating CNCS facility-specific control deficiencies to CNCS facility personnel, and coordinate remediation of the control deficiencies. (repeat)

Strengthen and refine the process for holding system owners and information system security officers accountable for remediation of control deficiencies and ensuring that the appropriate security posture is maintained for CNCS information systems. (...

Strengthen and refine the process for holding contractors accountable for remediation of control deficiencies in CNCS information systems. (repeat)

Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. (repeat)

Develop, implement and document procedures to identify all CNCS grantees that are required to submit single audit reports with their due dates. (new)

Develop, implement and document procedures on timely follow-up for those grantees whose audits have become past due, and to ascertain why report submission was late, when the audit report will be submitted to the Federal Audit Clearinghouse, and what...

Develop a practice to capture the single audit data to assess the effectiveness of the single audit report submission for all its grantees. (new)

Develop, implement and document procedures for implementing Office of Budget and Management (OMB) approved single audit report submission extensions, so that OMB approved extension approvals are documented and tracked as part of the single audit...

Update the Single Audit Resolution Policy to: Reflect the current monitoring process to track all audit findings related to CNCS-funded grants, and   Address CNCS’s responsibilities as the cognizant/oversight agency and how these responsibilities would...

Develop and implement procedures to monitor the effectiveness of the single audit monitoring process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 Responsibilities, (a) (3) (iv), related to monitoring the...

Ensure that OIT monitors and promptly installs patches and antivirus updates across the enterprise when they are available from the vendor. Enhancements should include:

Pending since FY 2017

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.

Ensure that OIT evaluates if the internet connections at the National Civilian Community Corps Campuses and Regional Offices are sufficient to allow patches to be deployed to all devices within the defined risk-based patch timeline in CNCS policy. If...

Develop and implement a written process to ensure manual updates to the CMDB inventory and FasseTrack system are made simultaneously when the inventory is updated.

Develop and implement a written process to perform periodic reconciliations between CMDB and the FasseTrack system.

Perform and document analysis to determine the feasibility of completely automating the inventory management process.

Physically or mechanically disable the networking capability of the laptop used for member badging at the NCCC Pacific Region Campus.

Document and implement a process to validate that physical counselor files from the NCCC Southwest Region Campus are disposed of within six years after the date of the member’s graduation in accordance with the AmeriCorps NCCC Manual.

Disallow and recover $603,476 ($231,806 in Federal and $374,861 in match costs) from Sauk-Rapids Rice due to the lack of support for employee's time worked on the grant and $3,192 for other Federal costs claimed because of insufficient match...

Disallow and recover $673,178 ($336,062 in Federal and $337,116 in match) from Guadalupe Alternative Programs due to being unable to verify the accuracy of employees' time worked on the grant because of the lack of time being segregated by project/...

Disallow and recover $11,681 ($5,681 in Federal from Amherst H. Wilder, and $6,000 in match from Sauk-Rapids Rice) due to unsupported costs in its financial management systems

Complete the process of configuring the scanning tool to account for the approved deviations for the standard baseline configurations.

Ensure all personnel whose responsibilities include access to PII complete annual privacy-role based training.

Disallow the $592,737 in questioned match costs to recover the $254,014 in Federal costs from LearningWorks for the program years 2017 and 2018 due to inadequate documentation to support its in-kind match contributions: donated classroom and office space...

Conduct an assessment of LearningWorks’ match contribution for its third-year funding to determine whether it met its match requirement, disallow any unsupported match contributions and recover any Federal funds that were overpaid as a result of...

Oversee the Maine Commission when coordinating with LearningWorks to revise its policies to define supporting documentation for the usage and valuation of donated spaces for in-kind contributions;

Instruct the Maine Commission to evaluate compliance of LearningWorks procedures on internal controls for time recordkeeping for donated personnel time at its service sites to provide reasonable assurance that charges are accurate, allowable, and...

Provide training to the Maine Commission staff and offer training to LearningWorks and other subgrantees concerning acceptable valuation and documentation of in-kind match costs.

Require the Maine Commission to develop and implement oversight or quality control of all fiscal monitoring performed by its staff.

Coordinate with the Maine Commission to develop guidance explaining and illustrating what constitutes acceptable documentation to support in-kind contributions;

Finalize the Grant Operations policies and procedures to reflect the current state and post‐reorganization.

Update the testing of design and effectiveness attributes to be consistent with the new policies and procedures.

Assess and document the known errors in the Trust Model and whether or not they could lead to material misstatements if not corrected. Document the rationale and procedures used to correct the data in the Trust Model.

Develop and implement a plan of corrective actions to promptly address outstanding accounting and processing issues related to the transition to ARC. These issues include capturing all Federal Award Identification Numbers from Momentum in Oracle to...

Update the DATA Act Business Process Guide to include documenting the data inventory/mapping for Files A, B, C, D1 and D2 to ensure that standardized data elements and OMB and Treasury definitions per the DATA Act Information Model Schema (DAIMS) are...

Work with ARC to ensure correct and complete Object Class and Program Activity codes are programmed in the source systems in accordance with OMB A-11, Section 83.

Establish and implement processes to reconcile and maintain adequate documentation of the reconciliation of the data file linkages. In addition, the processes should include performing monthly completeness, accuracy, and timeliness tests of the data...

Establish and comply with a timeliness standard for resolving DATA Broker warnings addressing data quality issues. Detailed corrective actions with milestones, deadlines, and responsible staff should be established.

Establish and implement effective internal control to ensure that adequate documentation is maintained and is readily available to support procurement contracts and financial assistance awards (grants).

Establish and implement controls to require that awardees (financial and procurement) register in SAM at the time of award.

Develop, document, and implement a process to ensure that de-obligations of grants with canceled funds are reported to Financial Assistance Broker System (FABS), when they occur and not when they are administratively closed-out.

Perform a risk assessment over the current state of the conversion to ARC and work jointly with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by the risk to develop a mitigation strategy and execute a realistic and...

Continue coordinating with ARC to ensure that its accounting platform is compatible with AmeriCorps’ operations and the type of accounting transactions that AmeriCorps processes. (Modified Repeat).

Conduct a review of transactions processed in Momentum and already migrated to Oracle through interface or reported in Oracle using journal entries, to ensure that correct object class codes were applied. (New)

Establish controls and training to ensure that each functional office/unit performs an independent assessment of internal controlsto inform the CEO’s statement of assurance, even if unfavorable outcomes are expected. This proactive approach will promote...

Develop and implement audit readiness procedures to ensure that audit information is complete, accurate, has undergone proper quality control procedures, and readily available or can be retrieved timely. The audit readiness procedures should include...

Continue working with Administrative Resource Center to review and correct AmeriCorps’ balances in detail to ensure they are properly supported and that balances migrated to the ARC platform are complete, accurate, and reliable. (Modified Repeat)

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

A process to track the sequence of JE transactions for completeness.

A policy as to when it is appropriate to use a JE and approval procedures for JEs recorded to ensure segregation of duties.

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

Documentation needed to support JEs and how it will be maintained. (Modified Repeat).

Validate and ensure JEs are properly supported, documented, and are readily available for examination. (Modified Repeat)

Validate that the underlying data used in the accrual methodology, such as the use of grantee Undelivered Order balances to allocate accrual amounts, is reliable by ensuring previously reported conditions are remediated and recommendations are...

Perform a risk assessment over the current state of the conversion to ARC and work jointly with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by the risk to develop a mitigation strategy and execute a realistic and...

Continue coordinating with ARC to ensure that its accounting platform is compatible with AmeriCorps’ operations and the type of accounting transactions that AmeriCorps processes. (Modified Repeat)

Conduct a review of transactions processed in Momentum and already migrated to Oracle through interface or reported in Oracle using journal entries, to ensure that correct object class codes were applied. (New)

Establish controls and training to ensure that each functional office/unit performs independent assessment of internal controls to inform the CEO’s statement of assurance, even if unfavorable outcomes are expected. This proactive approach will promote...

Develop and implement audit readiness procedures to ensure that audit information is complete, accurate, has undergone proper quality control procedures, and readily available or can be retrieved timely. The audit readiness procedures should include...

Continue working with Administrative Resource Center to review and correct AmeriCorps’ balances in detail to ensure they are properly supported and that balances migrated to the ARC platform are complete, accurate, and reliable. (Modified Repeat)

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

Strengthen its policies and procedures over the processing of JEs going forward now that AmeriCorps has transitioned to the shared service environment. The policies and procedures should cover the following:

A policy as to when it is appropriate to use a JE and approval procedures for JEs recorded to ensure segregation of duties

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

A requirement to provide a fact-specific description of the purpose of the JE, along with adequate supporting documentation.

Validate and ensure JEs are properly supported, documented, and are readily available for examination. (Modified Repeat)

Design and implement an effective accountability system that includes clear expectations of goals, performance measures, estimated target dates, and monitoring to hold OIT leadership accountable for improving AmeriCorps’ information security program to...

Develop, document, and communicate an overall SCRM strategy, implementation plan, and related policies and procedures to guide and govern supply chain risk management activities. If AmeriCorps intends to limit its IT purchases to GSA vendors, it should...

Develop and implement a plan to modify external emails to include information to assist the recipient of the level of risk posed by external email. For example, the Subject line of an email should be modified to identify the source of the email as...

Implement a plan to increase the frequency of behaviortraining directed at the identification of unwanted spam emails with an emphasis on continual reminders of recognition techniques, appropriate actions, and confidence that self‐reporting poor...

Implement a process to improve the detection rate to reduce the occurrence of email spam that reaches the users’ inboxes.

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.

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)

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.

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.

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 executable...

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.

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:

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

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.

Determine the root cause behind the differences noted in the UDO balance derived from the procurement documents and the expenditures and the recorded GL amount and take the appropriate steps in resolving the reason behind the variances that are occurring.

Strengthen controls to ensure proper authorization signatures on all contracts and amendments that require bi-lateral signatures for the proper execution of the award.

Develop and implement its Accounts Payable (AP) accrual methodology and perform tests of design and effectiveness over its UDO and AP accrual process.

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.

Establish a requirement for the Office of Grant Administration (OGA) or an appropriate AmeriCorps official to prepare a summary report, as part of the closeout process, verifying all required grantee information has been received and accepted, and the...

Develop and implement financial reporting internal controls to analyze and address the root causes of the reconciliation errors.

Revamp the grant accrual processes to include internal controls such as reconciliations, calculation documentation, quality control reviews, and basis for the accrual methodologies to mitigate the risk of error. (Modified Repeat)

Provide training to all personnel involved in the grant processing to ensure proper classification of funds in the Oracle system and ensure timely resolution of the variances between identified between the Momentum, Oracle, and PMS systems.

Develop standard operating procedures to ensure all balances recorded in the Reimbursable Analysis are supported by underlying source documentation (e.g., invoices).

Assess the training necessary to ensure advance liquidations are properly maintained, documented, and are readily available for examination.

Develop an oversight mechanism to retain receipts and monthly reconciliations to ensure record retention. (Finding 1)

Develop an oversight mechanism to hold cardholders and Approving Officials accountable for timely completion and approval of monthly statement reconciliation and consider disciplinary actions for repeat offenders. (Finding 1)

Revise purchase request and approval controls to implement a mechanism to hold cardholders accountable to obtain Approving Official’s approval prior to making purchases. (Finding 2)

Verify purchase transactions were for allowable expenses and consider remediation action of any unallowable or unauthorized charges. (Findings 2 and 3)

Develop and document a mechanism to hold the Agency Program Coordinator accountable for proper oversight of the overall purchase card program including periodic review of the supporting documentations, certificates of training, monthly reconciliation,...

Provide training for Approving Officials to ensure proper retention of required supporting documentations such as the evidence of cardholder’s reconciliation of statements, Approving Official’s approval of the statement, signed purchase request forms,...

Implement a mechanism to hold travelers accountable to obtain travel approval prior to travel dates. (Finding 5)

Verify travel card transactions were for allowable expenses and consider remediation action of any unallowable or unauthorized charges. (Findings 5 and 7)

Develop an oversight mechanism to enforce its controls record retention of travel receipts and timely submission of travel authorizations and vouchers in accordance with Federal Travel Regulation and AmeriCorps policies and procedures. (Finding 5 and 6)

Research and verify that the travels were for official business purposes and maintain proper documentations to support the travel related charges. (Finding 7)

Develop and document a monitoring control to ensure Centrally Billed Accounts (CBA) Citibank statements are properly reconciled prior to payment submission. (Finding 8)

Implement a mechanism to hold Office of Human Capital accountable for timely notification of employee termination to the Agency Program Coordinator upon completion of exit form. (Finding 9)

Coordinate with Treasury Administrative Resource Center to timely disable the terminated employee’s account and identify root cause for accounts that are not closed timely. (Finding 9)

Follow up on the 36 separated cardholder accounts to verify no charges were made after employee separation date. (Finding 9)

Perform a root cause analysis of the untimely account closeout and develop remediation plan as appropriate. (Finding 9)

AmeriCorps enhance its process of performing enterprise risk management assessments to determine the respective risk posture of its systems to include the entity-wide performance metrics for measuring the effectiveness of its:
• Data exfiltration and...

Include additional terms and conditions within future AmeriCorps General Grant and Cooperative Agreement Terms and Conditions policy documents to address the root causes of improper payments. Repeat recommendation for FY 2022.

Implement financial consequences or additional reporting requirements for grantees that have confirmed improper payments. Repeat recommendation for FY 2022.

Reconcile the differences between grantees’ internal accounting records and Federal Financial Reports (FFRs)to determine the propriety of the component payments or require grantees to perform this reconciliation; or treat unmatched reporting errors as...

Include NST as a program susceptible to improper payments for future risk assessments. (New)

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

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

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...

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...

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

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’...

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...

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.

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

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.

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

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

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.

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

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.

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...

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.

Design and implement control activities to address 8 of the 17 Government Accountability Office Green Book framework principles that were not sufficiently designed during its FY 2023 Entity Level Control Assessment. (New)

Identify resource capabilities and needs, then recruit, train, develop, and retain financial leaders and personnel with relevant Federal financial management capabilities to achieve operations, reporting, and compliance objectives, complete and document...

Ensure its fraud risk management process includes external risk factors such as grantee and subgrantee recipients in its standard operating procedures for the agency risk profile. This process should include: (New)

A scheduled risk assessment, mitigation plan, and monitoring and reporting (e.g., relating to grantee and subgrantee recipients);

An integration of the fraud risk components for known, suspected, and alleged fraud risks;

Documentation on how the fraud risk components integrate;

How the risk scoring is conducted and applied;

The use of the results of monitoring, evaluation, audits, and investigations to improve fraud prevention, detection, and response; and

Guidance for adequate documentation on the risk determination reviews to match risk ratings or detect errors within the risk assessment.

Provide internal training that addresses:

Management’s overall responsibility for establishing internal controls to manage the risk of fraud, and the related impact on the financial statements; and

The connection between potential and known fraud by the grantee and subgrantee recipients and the impact that fraud may have on the underlying financial data being provided by the recipients and ultimately used for the preparation of information reported...

Establish policies and procedures on financial reporting in compliance with standards and guidance (i.e., U.S. generally accepted accounting principles, Office of Management and Budget Circular No. A-136, and the U.S. Standard General Ledger), which...

Establish policies and procedures that define its roles and responsibilities and those of its service provider to ensure that required internal policies and procedures regarding the SF 132, Apportionment and Reapportionment Schedule and SF 133, Report on...

Develop and implement standard operating procedures for a comprehensive reconciliation that includes reviews and approval and proper documentation to support the SF 132 and SF 133 reconciliation. (New)

Develop and implement standard operating procedures to ensure the applicable line items in the combined Statement of Budgetary Resources are properly reconciled in a timely manner to the SF 132, Apportionment and Reapportionment Schedule and differences...

Complete a comprehensive fluctuation analysis for its consolidated financial statements that is supported and detailed enough to allow management to detect accounting errors or evaluate the reasonableness of balances. (Modified Repeat)

Develop and implement standard operating procedures for a comprehensive fluctuation analysis to ensure the fluctuation analysis is properly reviewed, approved, and validated in a timely manner by appropriate AmeriCorps resources and account balances are...

Establish, implement, and document policies and procedures that define the roles and responsibilities of AmeriCorps and its service provider, such as an end-to-end business processes narrative with flowcharts related to journal entries activity. (New)

Identify the root cause for the differences between the trial balance and the subsidiary ledger details for its undelivered orders. (New)

Establish, document, and implement the required accounting policies and standard operating procedures, as well as establish an efficient control framework for reconciling undelivered order balances in the trial balance and the subsidiary ledgers on a...

Assess the training necessary to ensure established policies and procedures are followed, undelivered orders are recorded in the financial system, and amounts are properly supported. (New)

Establish, document, and implement policies and procedures to monitor outstanding balances resulting from financial system configuration issues and fix the issues for future transactions to be interfaced into shared service provider’s financial...

Identify the root cause of why documentation for all financial transactions were not properly documented, maintained, and readily available for examination as required by Federal laws and regulations. (New)

Develop, implement, and document the necessary standard operating procedures to establish an effective internal control environment, along with the end-to-end business processes and quality assurance process to ensure all balances recorded are supported...

Conduct the training necessary to ensure established policies and procedures for records management are communicated in effectively implemented. (New)

Establish policies and procedures related to prior year recoveries that define the roles and responsibilities of AmeriCorps and its service provider to provide supporting documentation in a timely manner, such as an end-to-end business process and...

Establish policies and procedures related to grant accruals that define the roles and responsibilities of AmeriCorps and its service provider to provide supporting documentation in a timely manner, such as an end-to-end business process and flowcharts. (...

Assess resource capabilities and needs, followed by the recruitment, training, development, and retention of personnel possessing pertinent grant management expertise, in order to attain operational, reporting, and compliance objectives. (New)

Establish, implement, and document policies and procedures that define the roles and responsibilities of AmeriCorps and its service provider relating to Advances from Others, including an end-to-end business processes narrative with flowcharts. (New)

Monitor outstanding balances resulting from financial system configuration issues and fix the issues for future transactions to be interfaced into the shared service provider’s financial management system. (Modified Repeat)

Establish, implement, and document policies and procedures that define the roles and responsibilities of AmeriCorps and its service provider relating to Other Liabilities, including an end-to-end business processes narrative with flowcharts. (New)

Establish and implement periodic training requirements to enhance knowledge of Federal capitalization standards and AmeriCorps capitalization policy for internal use software. (Modified Repeat)

Develop and implement a project management tool to track and monitor all project costs associated with the software in development including direct and indirect cost (e.g., labor). (New)

Design and implement control activities to address 8 of the 17 Government Accountability Office Green Book framework principles that were not sufficiently designed during its FY 2023 Entity Level Control assessment. (New)

Identify resource capabilities and needs, then recruit, train, develop, and retain financial leaders and personnel with relevant Federal financial management capabilities to achieve operations, reporting, and compliance objectives, complete and document...

Ensure its fraud risk management process includes external risk factors such as grantee and subgrantee recipients in its standard operating procedures for the agency risk profile. This process should include: (New)

A scheduled risk assessment, mitigation plan, and monitoring and reporting (e.g., relating to grantee and subgrantee recipients);

An integration of the fraud risk components for known, suspected, and alleged fraud risks;

Documentation on how the fraud risk components integrate;

How the risk scoring is conducted and applied;

The use of the results of monitoring, evaluation, audits, and investigations to improve fraud prevention, detection, and response; and

Guidance for adequate documentation on the risk determination reviews to match risk ratings or detect errors within the risk assessment.

Provide internal training that addresses:

Management’s overall responsibility for establishing internal controls to manage the risk of fraud, and the related impact on the financial statements; and

The connection between potential and known fraud by the grantee and subgrantee recipients and the impact that fraud may have on the underlying financial data being provided by the recipients and ultimately used for the preparation of information reported...

Establish policies and procedures on financial reporting in compliance with standards and guidance (i.e., U.S. generally accepted accounting principles, Office of Management and Budget Circular No. A-136, and the U.S. Standard General Ledger), which...

Develop and implement standard operating procedures to ensure the applicable line items in the trust statement of bugetary resources are properly reconciled to the SF 132, Apportionment and Reapportionment Schedule, and differences are properly...

Complete a comprehensive fluctuation analysis for its trust financial statements that is supported and detailed enough to allow management to detect accounting errors or evaluate the reasonableness of balances. (Modified Repeat)

Develop and implement standard operating procedures for a comprehensive fluctuation analysis to ensure the fluctuation analysis is properly reviewed, approved, and validated in a timely manner by appropriate AmeriCorps resources and account balances are...

Establish, implement, and document policies and procedures that outline the roles and responsibilities of AmeriCorps and its service provider, such as an end-to-end business processes narrative with flowcharts related to journal entries activity. (New)

Monitor outstanding balances resulting from financial system configuration issues and fix the issues for future transactions to be interfaced into the shared service provider’s financial management system, Oracle. (Modified Repeat)

Require Serve DC to implement, or verify that Serve DC implemented, internal controls ensuring timecards are signed by employees and supervisors and retained to support the payroll costs charged and claimed on the AmeriCorps grants.

Recover the total payroll questioned costs of $433,625 in Federal costs and disallow $308,090 in match costs related to missing timecards, missing supervisory signatures, and missing employee signatures related to CAH grants (16CAHDC001 and 19CAHDC001),...

Require, or verify that Serve DC has since implemented, policies and procedures that appropriately cite or reference CFR Cost Principles to claim allowable, reasonable, and allocable costs.

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

Require Serve DC to develop and implement policies and procedures to appropriately track in its accounting system and obtain supporting documentation for all in-kind match costs associated with AmeriCorps grants and from within the DC government and...

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...

Require that Serve DC implement policies and procedures that require documentation identifying the source and use of funds by batch and for each transaction.

Recover $297,407 in Federal costs and disallow $131,302 in match costs due to unsupported other direct costs.

Require Serve DC to implement controls to verify that subgrantees are performing the National Sex Offender Public Website Program (NSOPW) searches, including FBI Fingerprint, and documenting their verification of the government-issued photo IDs for all...

Recover the total questioned Federal costs of $66,605 and disallow match costs of $3,284 for payroll and administrative costs for grant (18AFHDC001) due to no National Sex Offender Public Website Program Search.

Recover the total questioned Federal costs of $6,159 and disallow match costs of $650 for payroll and administrative costs for grant (18AFHDC001) due to no DC Criminal Background Check.

Recover the total questioned Federal costs of $35,496 for payroll and administrative costs for grant (18AFHDC001) due to No FBI Fingerprint Check.

Require Serve DC to implement controls to prepare reports that support and reconcile to the amounts reported to AmeriCorps eGrants. Serve DC should also establish controls to reconcile and document costs recorded in the accounting record to the costs...

Recover $82,345 in questioned Federal costs and disallow $83,796 in claimed match costs not supported by the accounting records.

Require that Serve DC develop and implement a mandatory training program including a tracking system to ensure that all subgrantees’ staff have training, capability, and assistance to enter their budgets and costs into its reporting system to meet...

Instruct Serve DC to develop and implement procedures and controls to prevent future drawdowns in excess of incurred costs.

Recover the questioned Federal costs of $8,418 for member living allowance and support for grant (18AFHDC001).

Verify that Serve DC implements controls to ensure that subgrantees are applying costs for member living allowance in accordance with the approved budget in their accounting records and in PERs.

Instruct its Office of Regional Operations to implement an oversight mechanism to ensure that the Commission:

Performs and documents the results of subgrantee risk assessments.

Performs and documents annual subgrantee monitoring activities.

Communicates subgrantee performance measures.

Evaluates subgrantee performance against communicated performance measures.

Require the Commission to update its AmeriCorps State Policy and Procedure Manual to state that the Commission must base its subgrantee monitoring plans on each subrecipient’s risk of noncompliance, including risks regarding potential fraud and conflicts...

Recover the $52,919 in questioned Federal costs from the Commission and disallow the $259,225 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 19CAHPR001, and 19AFHPR001.

Require the establishment of clear guidance regarding how to evaluate and document the allowability of costs, including in-kind contributed costs, reported on AmeriCorps grants, and provide the Commission and its subrecipients with training on the...

Personnel and fringe benefit costs, including that they are consistent with organizational policies, the employee’s salary appointment, and the amount of effort the employee dedicated to the grant.

The benefit and value of in-kind contributions claimed as match costs, including other operating cost contributions such as office space, utilities, parking costs, and donated supplies.

That charged consultant costs are consistent with professional service agreements.

The benefit and value received of training activities.

The business purpose of trips taken.

Disallow the $100,409 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001

Require the Commission to update its PER review process to include verifying grantees only claim match costs for costs directly assignable to AmeriCorps grants.

Require the Commission to provide subrecipients with further guidance on the nature of F&A costs and conduct training to ensure subrecipients claim and report F&A costs consistent with AmeriCorps’ Terms and Conditions.

Recover the $69,756 in questioned Federal costs from the Commission and disallow the $23,869 in questioned match costs on AmeriCorps Grant Numbers 16CAHPR001, 16AFHPR001, 16TAHPR001, and 19AFHPR001.

Require the Commission to implement a process for reconciling its accounting system records to the costs reported on its FFRs on a quarterly basis and work with AmeriCorps to identify and resolve any discrepancies as necessary.

Require the Commission to ensure MI provides detailed accounting records from its general ledger to support the costs reported in its PERs before the Commission reimburses MI for the costs. This requirement should remain in place until MI updates its...

Recover the $38,148 in questioned Federal costs from the Commission and disallow the $1,500 in questioned match costs on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Disallow and recover the $23,499 in questioned education awards on AmeriCorps Grant Numbers 16AFHPR001 and 19AFHPR001.

Require the Commission and its subgrantees to obtain and document the required components of the NSCHCs using agency-approved vendors, consistent with 45 C.F.R. §2540.204(b).

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.

Require that the Commission update its subgrantee monitoring policies to include procedures to verify that subgrantees appropriately enroll and exit all ASN members.

Require that the Commission create templates and member training resources designed to ensure that subgrantees appropriately enroll and exit ASN members. Subgrantee resources should include:

Detailed procedures regarding how to document that a member meets the education requirements.

Contract, enrollment form, exit form, and end-of-term evaluation templates that subgrantees can use to ensure appropriate enrollment, evaluation, and exiting of ASN members.

Training on how to appropriately complete member enrollment and exit procedures, including how to verify that the subgrantee has appropriately completed the templates.

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...

The Commission and its subgrantees calculate all payroll expenses charged to AmeriCorps grants using a rate commensurate with the employee’s established salary and the level of effort the employee dedicated to the AmeriCorps program.

Employees understand how to document trip costs to demonstrate that costs did not increase due to combining personal and business travel.

Require the Commission to train its subgrantees on best practices to avoid claiming unallowable costs. The training should include how to ensure the subgrantees appropriately disburse member living allowances and do not report duplicate payments for...

Require the Commission to determine whether AmeriCorps members who served at MI in 2016 and 2019 should receive $20,794 in additional living allowance payments.

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...

Require the Commission to provide a training session for all current and future AmeriCorps members and site supervisors that discusses timekeeping procedures to ensure members and supervisors appropriately report hours to AmeriCorps. Specifically,...

Verify that the data reported to eGrants is accurate prior to submission.

Calculate the member’s daily service hours based on the times the member signs in and out each day.

Track and monitor member service hours to ensure that members do not spend more than 20 percent of their service hours performing training activities.

Require the Commission to implement controls regarding the submission of drawdown requests. Specifically, the Commission should perform timely reconciliations of its financial records and ensure that it only draws down funds once the reconciliation is...

Require the Commission to verify that MI begin tracking its Federal awards and expenditures within its general ledger accounting system. Specifically, MI’s accounting system should enable MI to identify all Federal costs and match costs reported in the...

Require that the Commission strengthen its administrative and management controls and processes for the timeliness of financial reporting. Processes should include:

Implementing updated procedures to ensure it submits FFRs to AmeriCorps on a timely basis.

Requiring reporting extensions from AmeriCorps if the Commission does not believe that it will be able to meet established FFR due dates.

Require that the Commission strengthen its administrative and management controls and processes over the timeliness of subgrantee financial reporting. Processes should include:

Contacting subgrantees that are consistently non-compliant with AmeriCorps grant reporting requirements and discussing the reporting requirements outlined in their grants.

Issuing waivers for or enforcing actions on, subgrantees that do not provide accurate financial reports on a timely basis.

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

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.