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The Failures of the CNCS — Compliance Edition

People who dedicate their lives to service in the community are in a privileged position to make a difference in the lives of vulnerable men and women. The Corporation for National and Community Service (CNCS)’s mission is to help and serve communities in need, and CNCS is entrusted with millions of taxpayer dollars each year to meet this objective.

This is no small responsibility, and CNCS has an obligation to exercise its power properly and ethically to fulfill its purpose. In the case of members, directors, or grantees not in compliance with federal and state law, corrective measures should be taken to ensure the accountability and integrity of the agency.

Unfortunately, CNCS has failed to consistently hold bad actors in its organization accountable, which has resulted in widespread violations at multiple levels.

  • Lobbying. The Office of Inspector General (OIG) found that a grantee inappropriately assigned AmeriCorps members to participate in political campaigning during a local school board election. (2008[1]) (SAR 08-02)

  • Ineligible Members. The Corporation disallowed nearly $180,000 in federal share costs and education awards after an OIG audit found a grantee had violated grant provisions by enrolling ineligible members in the AmeriCorps program. The grantee enrolled current teachers as members even after the grant conditions specifically prohibited such a practice. (2010) (SAR 10-02, SAR 11-01, Audit Report 10-11)

  • Violation of VISTA Regulations. The OIG found a VISTA program supervisor enrolled 11 college students as VISTA members, while they continued to attend classes full time, in violation of VISTA regulations. To conceal this fraudulent activity, the program supervisor instructed the VISTA members to not disclose their status as college students to the Corporation. The supervisor pled guilty and the grantee reached a settlement in the amount of $160,000 (2010[2]) (SAR 10-01, SAR 12-01, SAR 13-02)

  • Intentional Misuse of AmeriCorps Members. The OIG found that a school was regularly and deliberately misusing an AmeriCorps member as a substitute teacher for approximately three months in violation of the law. Further, the school concealed this placement from the AmeriCorps supervisor during a site visit. (2013) (SAR 13-02)

  • Abortion. One grantee, who had received $30 million over the five prior years, allowed AmeriCorps members to provide doula care to women during abortion procedures in direct violation of the Serve America Act. Further investigation revealed a pattern of ineffective subgrantee management, lack of institutional control, and discouragement of transparency by administrators. (2013-2015) (SAR 16-02, 2016-003)

  • Anti-Deficiency Act Violations. The OIG found evidence Corporation employees violated the Anti-Deficiency Act by accepting voluntary services and then ratifying the purchase order after the services were rendered. The Corporation further violated federal regulations by failing to publicize a $15,000 modification to an existing purchase order. (2006) (SAR 06-02, SAR 07-01, OIG 06-039)

  • Illegally Charging Clients for Services of VISTA Members. From at least 2009 through early 2014, a VISTA project sponsor violated multiple regulations and laws when it improperly utilized VISTA members by having them perform staff functions and charged clients for the services of VISTA members. After the OIG’s investigation, the Corporation issued a debt letter for over $500,000 to the sponsor and debarred them for two years. (2009-2014) (Case 2014-015)

  • Improper Certification of Pro-rated Awards. The OIG highlighted the ongoing issues of the partial education awards being improperly certified for members who left the program early for compelling personal circumstances (CPC). Under AmeriCorps regulations, members may only receive a prorated education award if they leave the program for compelling personal reasons that are beyond the member’s control. The OIG found that 75 percent of the cases they examined were not in compliance with AmeriCorps CPC related regulations, leading the OIG to question more than $328,000 in federal costs. The Corporation disagreed with OIG recommendations to correct these issues. (2007-2009) (SAR 16-02, Audit Report 12-04)

  • Nepotism. The OIG found that a VISTA supervisor violated the Corporation’s nepotism policy and misled Corporation employees when she knowing allowed two relatives to serve in a VISTA program under her supervision. (2012[3]) (SAR 12-02)

  • Information Technology Security. Fundamental weaknesses and serious vulnerabilities remain in the Corporation’s Information Security Program. In 25 of the 57 IT security metrics tested, CNCS did not comply with applicable laws, regulations and authoritative guidance governing information security. (2016) (SAR 17-01, Audit Report 17-03)

[1] Estimated based on which Semi Annual Report it first appeared, as the OIG report does not disclose exact date.

[2] Estimated based on which Semi Annual Report it first appeared, as the OIG report does not disclose exact date.

[3] Estimated based on which Semi Annual Report it first appeared, as the OIG report does not disclose exact date.

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