Finding Text
Title and Assistance Listing Number of the Federal Program: ALN 94.006 AmeriCorps State and National and ALN 94.006 COVID 19 - AmeriCorps State and NationalYear Finding Originated: 2023
Compliance Requirement: 2 CFR 200.303 Internal Controls, 2 CFR 200.404, 45 CFR 2522.230
Name of Federal Agency: Corporation for National and Community Service
Pass-through Agency: State of Louisiana/Volunteer Louisiana
Questioned Costs: None meeting the reporting threshold of $25,000.
Condition: For two out of the thirteen living allowance periods tested, approval of the payroll disbursements was not able to be provided. For one of the thirteen living allowance payroll disbursement periods tested, approval was granted, however, the payment did not appear reasonable, as required by 2 CFR 200.404. In this instance, an individual completed approximately 68% of their hourly commitment in the program but was paid approximately 95% of their annual contracted amount. Our sample was not statistically valid.
Criteria: As noted in 2 CFR 200.303 “The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
As noted in 2 CFR 200.404 “A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.”
As noted in 45 CFR 2522.230 “An AmeriCorps program may release a participant from completing a term of service for compelling personal circumstances, as determined by the program, or for cause.”
Cause: Internal controls over approval of living allowances are not operating effectively.
Effect: Disbursements under the program may not have been for allowable purposes.
Recommendation: LDSC should ensure internal controls over approval of living allowances are implemented as designed.