Finding Text
2023-002 Approval of Living Allowance Payments
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
National
Year 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.
Views of Responsible Officials: See views of responsible officials on page 29.