Finding Text
2023—003—SPECIAL TESTS AND PROVISIONS Federal Agency: AmeriCorps Corporation for National and Community Service Federal Program Name: Foster Grandparents/Senior Companion Cluster/Senior Companion Program Assistance Listing Number: 94.016 Federal Award Identification Number and Year: Multiple Award Period: Project period: Multiple; Budget period: Multiple Questioned Costs: None Type of Finding (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instances of Noncompliance related to Federal Awards Statement of Condition During our audit, we noted the following issues related with the AmeriCorps Senior Companion Program: The Institute does not appear to have a conflict-of-interest statement or form for the staff/volunteers to sign/certify that they are not related to any of the Board members or staff, etc. or a process to notify Americorps in cases where these relationships exist. 14 out of 25 volunteers did not have a 100% name match in the background checking forms Context Out of 25 volunteers tested (43% of the entire population), 14 did not have complete names in the background check forms. Note: the background checks were redone during 2024. Criteria The grant requires that the National Service Criminal History Checks are completed in accordance with AmeriCorps regulations (i.e., completing the required checks and making an eligibility determination within the required timelines and documenting them correctly). The grantee needs to use AmeriCorps approved vendors for the background checks and provide evidence that the first and last names used on the name-based checks reflect the current name of the individual. All documents used to determine an individual first and last name must be consistent with the grant recipient policies and procedures. Also, persons selected for project staff positions shall not be related by blood or marriage to other project staff, sponsor staff or officers, or members of the sponsor Board of Directors, unless there is written concurrence from the Advisory Council or community group established by the sponsor under subpart B of this part, and with notification to AmeriCorps. Effect The organization does not appear to have sufficient internal controls in place and does not appear to be in compliance with grant requirements as set forth in 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J. Potential effect of noncompliance of the federal award or future funding decisions could result in disallowance of costs, suspension or termination of the award, or reduction of future allocations. Cause Internal controls over compliance do not appear to have been adequately implemented due to a lack of training and awareness of the program rules. Recommendation We recommend the organization gets familiar with the below CFR pertaining to the Americorps Senior Companion Program and implement internal controls to make sure that the program rules are carried out including but not limited to (42 USC 5011(a) and (d) and 5013(a) and (b); 45 CFR Part 2551, Subpart J and 45 CFR Part 2552, Subpart J, 45 CFR sections 2551.91 and 2552.91, Domestic Volunteer Service Act of 1973, Title II (42 USC 5000 et seq.) and their implementing regulations are found in 45 CFR parts 2551 and 2552. ). We also recommend training the staff about the rules of this program. View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, president and Authorized Representative.