Finding Text
Finding 2024-003 Corporation for National and Community Service Federal Assistance Listing No. 94.006 AmeriCorps State and National Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Condition: For 3 of 25 members selected for testing, the subsistence allowance to be paid was not specified in the signed agreements. In addition, for 6 of 25 members, the service period outlined in the agreement covered only two months of the audit year, and BCI was unable to provide updated agreements to support the remaining months within fiscal year 2025. Criteria: In accordance with 2 CFR 200.514: (c) Internal controls, (1) The compliance supplement provides guidance on internal controls over federal programs based upon the guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States and the Internal Control - Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). COSO requires entities to establish and maintain effective internal controls to achieve operational, reporting and compliance objectives. Per 45 CFR §§ 2540.200–2540.207, recipients of AmeriCorps federal awards must conduct, review, and document National Service Criminal History Checks (NSCHC) for all covered individuals. All components must be completed, adjudicated, and an eligibility determination made no later than the day before an individual begins work or service on an NSCHC-required grant. Individuals registered, or required to be registered, as sex offenders, or who have been convicted of murder, are ineligible to work or serve on an AmeriCorps grant. Additionally, AmeriCorps requires that a signed member agreement, a compensation letter confirming the approved rate, and supporting payroll documentation be maintained for each member. Compensation must not exceed 200% of the members’ total average annual subsistence allowance provided to vista volunteers. Cause: BCI’s internal controls over member file documentation of the signed agreements were not consistently followed and did not ensure that all required AmeriCorps documentation was obtained and retained in the member files. Effect: Failure to maintain required member documentation increases the risk of noncompliance with AmeriCorps program requirements and may result in questioned costs, monitoring findings, or potential disallowance by the granting agency. Questioned Costs: Unknown. Recommendation: We recommend that BCI strengthen its onboarding and document retention procedures to ensure all member files include the required AmeriCorps documentation, including the signed member agreement. Auditee Response and Corrective Action Plan: Refer to management’s corrective action plans. Auditor’s Conclusion: Finding remains as stated.