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24–758 PDF 2017

EXAMINING THE CORPORATION FOR NATIONAL 

AND COMMUNITY SERVICE AND ITS FAILED 

OVERSIGHT OF TAXPAYER DOLLARS 

HEARING 

BEFORE THE

SUBCOMMITTEE ON HIGHER EDUCATION AND 

WORKFORCE DEVELOPMENT 

COMMITTEE ON EDUCATION 

AND THE WORKFORCE 

U.S. HOUSE OF REPRESENTATIVES

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

HEARING HELD IN WASHINGTON, DC, MARCH 28, 2017 

Serial No. 115–11 

Printed for the use of the Committee on Education and the Workforce 

( 

Available via the World Wide Web: 

www.gpo.gov/fdsys/browse/committee.action?chamber=house&committee=education 

or 

Committee address: http://edworkforce.house.gov 

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(II) 

COMMITTEE ON EDUCATION AND THE WORKFORCE 

VIRGINIA FOXX, North Carolina, Chairwoman 

Joe Wilson, South Carolina 

Duncan Hunter, California 

David P. Roe, Tennessee 

Glenn ‘‘GT’’ Thompson, Pennsylvania 

Tim Walberg, Michigan 

Brett Guthrie, Kentucky 

Todd Rokita, Indiana 

Lou Barletta, Pennsylvania 

Luke Messer, Indiana 

Bradley Byrne, Alabama 

David Brat, Virginia 

Glenn Grothman, Wisconsin 

Steve Russell, Oklahoma 

Elise Stefanik, New York 

Rick W. Allen, Georgia 

Jason Lewis, Minnesota 

Francis Rooney, Florida 

Paul Mitchell, Michigan 

Tom Garrett, Jr., Virginia 

Lloyd K. Smucker, Pennsylvania 

A. Drew Ferguson, IV, Georgia 

Robert C. ‘‘Bobby’’ Scott, Virginia 

Ranking Member 

Susan A. Davis, California 

Rau ́l M. Grijalva, Arizona 

Joe Courtney, Connecticut 

Marcia L. Fudge, Ohio 

Jared Polis, Colorado 

Gregorio Kilili Camacho Sablan, 

Northern Mariana Islands 

Frederica S. Wilson, Florida 

Suzanne Bonamici, Oregon 

Mark Takano, California 

Alma S. Adams, North Carolina 

Mark DeSaulnier, California 

Donald Norcross, New Jersey 

Lisa Blunt Rochester, Delaware 

Raja Krishnamoorthi, Illinois 

Carol Shea-Porter, New Hampshire 

Adriano Espaillat, New York 

Brandon Renz, Staff Director 

Denise Forte, Minority Staff Director 

SUBCOMMITTEE ON HIGHER EDUCATION AND WORKFORCE 

DEVELOPMENT 

BRETT GUTHRIE, Kentucky, Chairman 

Glenn ‘‘GT’’ Thompson, Pennsylvania 

Lou Barletta, Pennsylvania 

Luke Messer, Indiana 

Bradley Byrne, Alabama 

Glenn Grothman, Wisconsin 

Elise Stefanik, New York 

Rick W. Allen, Georgia 

Jason Lewis, Minnesota 

Paul Mitchell, Michigan 

Tom Garrett, Jr., Virginia 

Lloyd K. Smucker, Pennsylvania 

Susan A. Davis, California 

Ranking Member 

Joe Courtney, Connecticut 

Alma S. Adams, North Carolina 

Mark DeSaulnier, California 

Raja Krishnamoorthi, Illinois 

Jared Polis, Colorado 

Gregorio Kilili Camacho Sablan, 

Northern Mariana Islands 

Mark Takano, California 

Lisa Blunt Rochester, Delaware 

Adriano Espaillat, New York 

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(III) 

C O N T E N T S 

Page 

Hearing held on March 28, 2017 ............................................................................ 1 

Statement of Members: 

Davis, Hon. Susan A., Ranking Member, Subcommittee on Higher Education and Workforce Development ............................................................. 4 

Prepared statement of ............................................................................... 5 

Guthrie, Hon. Brett, Chairman, Subcommittee on Higher Education and 

Workforce Development ................................................................................ 1 

Prepared statement of ............................................................................... 3 

Statement of Witnesses: 

Bawden, Ms. Allison, Acting Director of Education, Workforce, and Income Security, Government Accountability Office ..................................... 7 

Prepared statement of ............................................................................... 9 

Darling, Ms. Elizabeth, CEO and President Onestar Foundation and 

National Service Commission ...................................................................... 28 

Prepared statement of ............................................................................... 30 

Giblin, Ms. Lori, Chief Risk Officer, Corporation for National and Community Service .............................................................................................. 20 

Prepared statement of ............................................................................... 22 

Jeffrey, Hon. Deborah, Inspector General, Corporation for National and 

Community Service ....................................................................................... 42 

Prepared statement of ............................................................................... 44 

Additional Submissions: 

Courtney, Hon. Joe, a Representative in Congress from the State of 

Connecticut: 

Article: TVCCA to open coffeehouse for veterans ................................... 80 

Article: Veterans coffeehouse celebrated ................................................. 86 

Article: Town supports Veterans Coffeehouse ........................................ 90 

Mrs. Davis: 

Letter dated March 7, 2017, from Voices for National Service ............. 91 

Questions submitted for the record by: 

Mrs. Davis .................................................................................................. 95 

Chairman Guthrie ..................................................................................... 97, 100 

Scott, Hon. Robert C. ‘‘Bobby’’, a Representative in Congress from 

the State of Virginia .............................................................................. 95 

Responses to questions submitted for the record: 

Ms. Darling ................................................................................................ 101 

Ms. Giblin .................................................................................................. 107 

Ms. Jeffrey ................................................................................................. 118 

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(1) 

EXAMINING THE CORPORATION FOR 

NATIONAL AND COMMUNITY SERVICE 

AND ITS FAILED OVERSIGHT OF 

TAXPAYER DOLLARS 

Tuesday, March 28, 2017 

U.S. House of Representatives 

Committee on Education and the Workforce 

Subcommittee on Higher Education and Workforce Development 

Washington, D.C. 

The subcommittee met, pursuant to call, at 10:07 a.m., in Room 

2175, Rayburn House Office Building, Hon. Brett Guthrie [chairman of the subcommittee] presiding. 

Present: Representatives Guthrie, Thompson, Messer, Grothman, 

Allen, Lewis, Mitchell, Smucker, Davis, Courtney, Adams, 

DeSaulnier, Krishnamoorthi, Polis, Sablan, Takano, Blunt Rochester, and Espaillat. 

Also Present: Representatives Foxx, Scott, and Rooney. 

Staff Present: Courtney Butcher, Director of Member Services 

and Coalitions; James Forester, Professional Staff Member; Tyler 

Hernandez, Deputy Communications Director; Amy Raaf Jones, Director of Education and Human Resources Policy; Nancy Locke, 

Chief Clerk; Dominique McKay, Deputy Press Secretary; James 

Mullen, Director of Information Technology; Brian Newell, Communications Director; Krisann Pearce, General Counsel; Alex Ricci, 

Legislative Assistant; Mandy Schaumburg, Education Deputy Director and Senior Counsel; Alissa Strawcutter, Deputy Clerk; 

Tylease Alli, Minority Clerk/Intern and Fellow Coordinator; Austin 

Barbera, Minority Press Assistant; Jacque Chevalier, Minority 

Deputy Education Policy Director; Denise Forte, Minority Staff Director; Mishawn Freeman, Minority Staff Assistant; Carolyn 

Hughes, Minority Senior Labor Policy Advisor; Alexander Payne, 

Minority Education Policy Advisor; and Veronique Pluviose, Minority Civil Rights Counsel. 

Chairman GUTHRIE. Good morning. A quorum being present the 

Subcommittee on Higher Education and Workplace Development 

will come to order. 

Good morning and welcome to today’s hearing on the Corporation 

for National and Community Service. One of the most important 

responsibilities given to Congress by the Constitution is oversight 

of the Federal bureaucracy. As members of this committee, we 

share in that responsibility by conducting oversight of the departCEWDOCROOM with DISTILLER

2 

ments, agencies, commissions, and government corporations at our 

jurisdiction. 

It is our duty to hold the executive branch accountable for both 

the way it administers the law and how it spends taxpayer dollars 

and that is why we are here today, to hold the Corporation for National and Community Service accountable. 

Commonly known as CNCS, the corporation is an independent 

Federal agency created in 1993 to oversee a range of community 

service programs and grants, including AmeriCorps and 

SeniorCorps programs. 

Today it receives more than $1 billion a year to support 11 different initiatives and issues $750 million in grants annually. In 

fact, at any given time, CNCS is responsible for overseeing more 

than 2,000 active grants ranging in size from $40,000 to $10 million. 

That is a significant amount of money, making the corporation’s 

oversight of those funds significantly important. CNCS has a responsibility to ensure taxpayer dollars are being spent in full compliance with the law. However, time and time again, the corporation has fallen short of the goal. 

Just last year, the subcommittee held a hearing after learning 

about a particularly egregious misuse of taxpayer dollars under the 

corporation’s watch. As the corporation’s inspector general reported, one AmeriCorps grantee allowed members to participate in 

illegal activity by providing support services during abortion procedures, all the while continuing to receive taxpayer funds. Incidents 

like this are simply unacceptable. 

CNCS has a history of failing to prevent the unlawful use of taxpayer dollars. According to the corporation’s own inspector general, 

AmeriCorps may have misspent at least $14.5 million in 2015. I 

say ‘‘at least’’ because the information used to determine the extent 

of that misspending was not statistically valid, complete, or accurate. The actual amount may have been even higher. 

Due to poor planning, CNCS could not even determine the 

amount misspent in 2016. Additionally, it is estimated that 

SeniorCorps programs misspent $47 million in 2016. Let me repeat 

that, 47 million. That’s 30 percent of SeniorCorps’ total spending. 

Of course, while misspending is a serious problem, the corporation’s oversight failures extend beyond funding. Under Federal law, 

CNCS grantees are required to perform criminal history checks on 

their participants and staff to ensure that safety of the individuals 

and communities they serve. However, the corporation’s chief risk 

officer found that an alarming number of grantees failed to properly do so last year. In fact, 40 percent of the participants or staff 

in the senior companion program and 41 percent in the retired and 

senior volunteer program did not undergo the required background 

checks. 

These are just two examples, but the percentages are shocking. 

We are talking about individuals who are working closely with our 

seniors and some of the most vulnerable members of our local communities, yet we know nothing or very little about their background or criminal histories. That is just not an issue of mismanaged or misspent money. It is an issue of safety and security. 

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3 

It is clear CNCS is not fulfilling its responsibilities to ensure taxpayer dollars are spent in accordance with the law. We the members of the committee have the responsibility to demand better. 

We are joined today by several individuals who are very familiar 

with the corporation’s shortcomings. I would like to thank you all 

for being here today and I look forward to discussing the changes 

that must be made at CNCS. We have quite a bit of ground to 

cover, so I will now recognize Ranking Member Davis for opening 

remarks. 

[The statement of Chairman Guthrie follows:] 

Prepared Statement of Hon. Brett Guthrie, Chairman, Subcommittee on 

Higher Education and Workforce Development 

One of the most important responsibilities given to Congress by the Constitution 

is oversight of the federal bureaucracy. As members of this committee, we share in 

that responsibility by conducting oversight of the departments, agencies, commissions, and government corporations in our jurisdiction. It is our duty to hold the executive branch accountable both for the way it administers the law and how it 

spends taxpayer dollars. And that’s why we are here today—to hold the Corporation 

for National and Community Service accountable. 

Commonly known as CNCS, the corporation is an independent federal agency, created in 1993 to oversee a range of federal community service programs and grants, 

including AmeriCorps and SeniorCorps programs. Today, it receives more than $1 

billion dollars a year to support 11 different initiatives and issues $750 million in 

grants annually. In fact, at any given time, CNCS is responsible for overseeing more 

than 2,000 active grants—ranging in size from $40,000 to $10 million. 

That’s a significant amount of money, making the corporation’s oversight of those 

funds significantly important. CNCS has a responsibility to ensure taxpayer dollars 

are being spent in full compliance with the law. However, time and time again, the 

corporation has fallen short of that goal. 

Just last year, this subcommittee held a hearing after learning about a particularly egregious misuse of taxpayer dollars under the corporation’s watch. As the corporation’s Inspector General reported, one AmeriCorps grantee allowed members to 

participate in illegal activity by providing support services during abortion procedures—all while continuing to receive taxpayer funds. Incidents like this one are 

simply unacceptable. 

CNCS has a history of failing to prevent the unlawful use of taxpayer dollars. According to the corporation’s own Inspector General, AmeriCorps misspent at least 

$14.5 million in 2015. I say ‘‘at least’’ because the information used to determine 

the extent of that misspending was not ‘‘statistically valid, complete, or accurate’’— 

meaning the actual amount may have been even higher. Due to poor planning, 

CNCS could not even determine the amount misspent in 2016. 

Additionally, it is estimated that Senior Corps programs misspent $47 million dollars in 2016. Let me repeat that: $47 million. That’s 30 percent of Senior Corps’ 

total spending. 

Of course, while misspending is a serious problem, the corporation’s oversight failures extend beyond funding. 

Under federal law, CNCS grantees are required to perform criminal history 

checks on their participants and staff to ensure the safety of the individuals and 

communities they serve. However, the corporation’s Chief Risk Officer found that an 

alarming number of grantees failed to properly do so last year. In fact, 40 percent 

of participants or staff in the Senior Companion Program and 41 percent in the Retired and Senior Volunteer Program didn’t undergo the required background checks. 

These are just two examples, but the percentages are shocking. We are talking 

about individuals who are working closely with our seniors and some of the most 

vulnerable members of our local communities. Yet, we know nothing or very little 

about their background or criminal histories. That’s not just an issue of mismanaged 

or misspent money. It’s an issue of safety and security. 

It is clear CNCS is not fulfilling its responsibilities to ensure taxpayer dollars are 

spent in accordance with the law. We, the members of this committee, have a responsibility to demand better. 

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4 

Mrs. DAVIS. Thank you very much. Good morning, thank you, 

Chairman Guthrie. I also want to very warmly thank our witnesses 

for being here and providing your experience and expertise. 

Last year, 325,000 Americans, serving through AmeriCorps and 

SeniorCorps invested 155 million hours of service to their communities at more than 50,000 locations across the Nation. The majority called this hearing today because of 10 total service hours performed by 6 AmeriCorps members. That is 10 hours out of 155 million hours of service performed last year. CNCS funding last year 

was $1.01 billion, which means taxpayers gave CNCS $6.51 per 

hour of service performed. So the majority is holding a hearing because they do believe that this $65.10 was mismanaged. It is also 

important to remember the President’s budget as the backdrop to 

the conversation that we are having today. President Trump’s 

Skinny Budget would completely do away with the funding for the 

Corporation for National and Community Service. 

Mr. Chairman, I ask unanimous consent to enter into the record 

this letter signed by 65 current and former Republican officials expressing strong support for funding CNCS in this year’s appropriations bill. And I want to point out that this list includes Republicans, like Mississippi Governor Haley Barbour, former Congressman Chris Gibson and Ron Kauffman, who served as President 

George H.W. Bush’s political director. 

Since its founding, CNCS has engaged millions of volunteers in 

national and community service. These volunteers have taught students, they have been mentors, helped local communities recover 

from national disasters, and helped our Nation’s veterans adjust to 

civilian life. Beyond that, CNCS has taught generations of Americans about the importance of national service. 

National service is the only way to ensure and inform empathic 

citizenry and a healthy Nation and that is exactly what these volunteers do. In fact, the local partnerships that CNCS supports are 

so successful that they leverage 15 private dollars for every 10 Federal dollars that we invest. 

Such success means that CNCS and its members are there during the times America needs them most. During the Flint water 

crisis, for example, CNCS deployed an AmeriCorps team to Flint, 

Michigan, to support State and local efforts to protect the public 

health of residents facing challenges from increased lead levels in 

the Flint water supply. 

When hurricane Katrina devastated the South, CNCS deployed 

an AmeriCorps team to the region. When tornadoes wreaked havoc 

in Oklahoma, AmeriCorps volunteers were there. In my own district, AmeriCorps VISTA members collaborate with veterans’ service providers to create the most comprehensive and seamless transition process for all military members and veterans. 

They connect veterans and military families to housing, financial 

literacy, and employment resources throughout our district. The 

Edward M. Kennedy Serve America Act signed into law by President Obama in 2009 reauthorized and expanded the national service programs administered by CNCS. Passed with strong bipartisan 

support, the Act showed how much America values national service 

by expanding service programs so over 4 million Americans could 

engage in results-driven service each year. 

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5 

With regard to last year’s AmeriCorps incident, CNCS discovered 

and resolved these issues with deliberate action. I’m sorry, but I 

can’t help but think that if what happened was related to anything 

other than women’s health services, CNCS would not be called in 

front of us here today for the second time and about the same incident. 

So as we proceed with this hearing, I hope that we remain focused on the vital importance of service to our Nation. I have had 

many conversations with my colleagues across the aisle who agreed 

that service is a crucial part of engaging Americans and their communities. 

CNCS gives us the vehicle to invest in our national service infrastructure and we have a great deal to learn about the way that 

they have done that. 

While we should value and uphold oversight and enforcement, we 

must also remember that CNCS engages over a million volunteers 

who assist local communities across America, communities represented on both sides of the aisle. 

I look forward to hearing more about how we can improve and 

strengthen national service programs that are so important to our 

Nation’s success. Thank you, Mr. Chairman. 

[The statement of Mrs. Davis follows:] 

Prepared Statement of Hon. Susan A. Davis, Ranking Member, 

Subcommittee on Higher Education and Workforce Development 

Good morning and thank you, Chairman Guthrie. I would also like to thank our 

witnesses for being here. 

Last year, 325,000 Americans serving through AmeriCorps and Senior Corps invested 155 million hours of service to their communities at more than 50,000 locations across the nation. The Majority called this hearing today because of ten total 

service hours performed by six AmeriCorps members. That’s 10 hours out of the 155 

million hours of service performed last year. CNCS funding last year was $1.01 billion, which means taxpayers gave CNCS $6.51 per hour of service performed. So, 

the Majority is holding a hearing because THEY believe $65.10 was mismanaged. 

It is also important to remember the President’s budget as the backdrop to the 

conversation we’re having today. President Trump’s ‘‘skinny’’ budget would completely do away with the funding for the Corporation for National and Community 

Service. 

Mr. Chairman, I ask unanimous consent to enter into the record this letter signed 

by 65 current and former Republican officials expressing strong support for funding 

CNCS in this year’s appropriations bill. I want to point out that this list includes 

Republicans like former Mississippi Governor Haley Barbour, former Congressman 

Chris Gibson, and Ron Kaufman, who served as President George H. W. Bush’s political director. 

Since its founding, CNCS has engaged millions of volunteers in national and community service. These volunteers have taught students, been mentors, helped local 

communities recover from natural disasters, and helped our nation’s veterans adjust 

to civilian life. 

Beyond that, CNCS has taught generations of Americans about the importance 

of national service. National service is the only way to ensure an informed, empathetic citizenry and healthy nation. And that is exactly what these volunteers do. 

In fact, the local partnerships that CNCS supports are so successful that they leverage 15 private dollars for every 10 federal dollars that we invest. 

Such success means CNCS and its members are there during the times Americans 

are most in need: 

* During the Flint Water Crisis, CNCS deployed an AmeriCorps team to Flint, 

Michigan, to support state and local efforts to protect the public health of residents 

facing challenges from increased lead levels in the Flint water supply. 

* When Hurricane Katrina devastated the South, CNCS deployed an AmeriCorps 

team to the region. 

* When tornadoes wreaked havoc in Oklahoma, AmeriCorps volunteerswere there. 

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6 

* In my own district, AmeriCorps VISTA members collaborate with veterans’ service providers to create the most comprehensive and seamless transition process for 

all military members and veterans. They connect veterans and military families to 

housing, financial literacy, and employment resources throughout our district. 

The Edward M. Kennedy Serve America Act, signed into law by President Obama 

in 2009, reauthorized and expanded the national service programs administered by 

CNCS. Passed with strong bipartisan support, the Act showed how much America 

values national service by expanding service programs so over four million Americans could engage in results-driven service each year. 

With regard to last year’s AmeriCorps incident, CNCS discovered and resolved 

these issues with deliberate action. I can’t help but think that if what happened was 

related to anything other than women’s health CNCS would not be called in front 

of us here today. For the second time. About the same incident. 

As we proceed with this hearing, I hope that we remain focused on the vital importance of service to our nation. I’ve had many conversations with my colleagues 

across the aisle who agree that service is a crucial part of engaging Americans in 

their communities. CNCS gives us the vehicle to invest in our national service infrastructure. While we should value and uphold oversight and enforcement, we must 

also remember that CNCS engages over a million volunteers who assist local communities across America, communities represented on both sides of the aisle. 

I look forward to hearing more about how we can improve and strengthen national service programs that are so important to our nation’s success. 

Thank you. 

Chairman GUTHRIE. Thank you and before moving on, I just 

want to clarify the hearing is about $750 million that has been— 

CNCS, the oversight of that, that is spent by CNCS or granted by 

CNCS. 

So pursuant to the Committee Rule 7(c), all members will be permitted to submit written statements to be included in the permanent hearing record, and without objection the hearing record will 

remain open for 14 days to allow such statements and other extraneous material referenced during the hearing to be submitted for 

the official hearing record. 

I will now turn to the introduction of our distinguished witnesses. Ms. Alison Bawden, is that correct? Ms. Bawden serves as 

the acting director of Education, Workforce, and Income Security 

Team for the General Accountability Office. Ms. Lori Giblin serves 

as the chief risk officer for the Corporation for National and Community Service. 

Ms. Elizabeth Darling is the president and CEO of the OneStar 

Foundation and previously served as the chief operating officer for 

the Corporation of National and Community Service. 

And the Honorable Deborah Jeffrey is the inspector general for 

the Corporation for National and Community Service. 

I will now ask the witnesses to raise your right hand. Do you solemnly swear or affirm that the testimony you are about to give will 

be the truth, the whole truth, and nothing but the truth? 

[Witnesses sworn.] 

Chairman GUTHRIE. Let the record reflect the witnesses answered in the affirmative. 

And before I recognize you to provide your testimony, let me 

briefly explain our lighting system. You each have 5 minutes to 

present your testimony. When you begin, the light in front of you 

will turn green. When 1 minute is left, the light will turn yellow. 

When your time has expired, the light will turn red. At that point, 

I will ask you to wrap up your remarks as best as you are able. 

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7 

Members will each have 5 minutes to ask questions following the 

testimony. 

So now, Ms. Bawden, I will recognize you for 5 minutes for your 

testimony. 

TESTIMONY OF ALLISON BAWDEN, ACTING DIRECTOR OF 

EDUCATION, WORKFORCE, AND INCOME SECURITY, GOVERNMENT ACCOUNTABILITY OFFICE 

Ms. BAWDEN. Chairman Guthrie, Ranking Member Davis, and 

members of the subcommittee, thank you for inviting me to discuss 

GAO’s recently completed work on grant monitoring by the Corporation for National Community Service. My remarks today highlight key findings and recommendations from that work with respect to, first, whether the corporation’s current process for monitoring grants aligns with standards for identifying, analyzing, and 

responding to risk; and second, whether the corporation has the capacity necessary to monitor its grantees’ compliance with program 

requirements. In fiscal year 2015, the corporation had over 2,000 

active grants totaling about $750 million. 

As such, the corporation is administering and monitoring a significant Federal investment. Bottom line, it is essential for the corporation to have a full understanding of the potential risks of the 

grants and awards and to align its monitoring efforts to mitigate 

the most significant risks. Currently, the corporation annually assesses grants that it expects to be active in the next fiscal year. Up 

to 19 indicators are assessed for each grant and scores for each indicator are weighted to result in a total. 

This total places each grant into a high, medium, or low priority 

category for grant monitoring activities. These activities mainly 

consist of visits and desk reviews, among other things, to assure 

compliance with fiscal and program requirements. 

First, we found that the corporation’s current process for grant 

monitoring is not fully aligned with the federal standards for internal control that describe how agencies should identify, analyze, and 

respond to risk. We recommended actions the corporation should 

take to better consider risk when prioritizing grants for monitoring, 

including these three. 

One, the corporation should establish and implement a policy to 

ensure that all grants expected to be active during the next fiscal 

year are, in fact, assessed for potential risk. We found that some 

grants, particularly new ones, may be omitted from the assessment 

process in the year they are first awarded because the reward was 

made after the process was complete. One program officer told us 

that monitoring new grants in their first year can help avoid future 

problems. 

Two, the corporation should improve its collection of information 

used to oversee subrecipients, especially with respect to their conduct of required criminal history checks. Sub-recipients receive 

pass-through funds from the corporation’s grantees and the corporation is required to monitor how its grantees oversee those subrecipients. We found that the corporation has limited standard 

monitoring requirements for subrecipient oversight and that the 

subrecipient information collected by grantees may cover only a 

small portion of criminal history check activities. 

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8 

And three, the corporation should revise its assessment indicators to meaningfully cover all identifiable risks and revise their 

scoring so that the riskiest grants get the highest scores. We found 

that the indicators may not address all potential risks such as 

fraud and that the highest scoring indicator may not measure 

grant risk. 

The corporation has taken some steps to improve how its assessment and monitoring processes consider risk. For example, it established the Office of the Chief Risk Officer, which has begun to 

benchmark assessment indicators against those of other Federal 

grant-making agencies and programs. However, improvement efforts are in their early stages and do not address the full scope of 

our findings. 

As a result, we made the recommendations I discussed to help 

guide the corporation’s efforts as it moves forward. The corporation 

did not comment on them. 

Second, with respect to strategic workforce planning, we found 

that the corporation has not determined whether it has the people 

and resources to effectively monitor grantees’ compliance with program requirements. 

The corporation’s efforts to address vacancies have been largely 

ad hoc, including for senior-level grant-monitoring positions, and 

we found that vacancies did affect the number of grant-monitoring 

activities conducted in fiscal year 2015. 

The corporation also has not evaluated whether staff have been 

deployed where they are most needed. 

Officials said they had not developed a strategic workforce planning process because of limited resources. We concluded that the 

corporation’s efforts to address workforce challenges may continue 

to be ad hoc without such planning and recommended that it be 

conducted. The corporation also did not comment on this finding or 

recommendation. 

In closing, thank you for your time today. I would be pleased to 

respond to any questions you may have. 

[The statement of Ms. Bawden follows:] 

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Insert offset folio 1 here 24758.001

For Release on Delivery 

Expected at 10:00 a.m. ET 

Tuesday, March 28, 2017 

GA0-17-528T 

United States Government Accountability Office 

Testimony 

Before the Subcommittee on Higher 

Education and Workforce Development, 

Committee on Education and the 

Workforce, House of Representatives 

GRANTS MANAGEMENT 

Corporation for National 

and Community Service's 

Grant Monitoring Process 

Could Be Improved 

Statement of Allison Bawden, Acting Director, Education, 

Workforce, and Income Security 
10 

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Insert offset folio 2 here 24758.002

Chairman Guthrie, Ranking Member Davis, and Members of the 

Subcommittee: 

Thank you for the opportunity to join you today as you examine issues 

related to grant monitoring by the Corporation for National and 

Community Service (CNCS). Created in 1993, CNCS administers a 

variety of volunteer and national service programs for needs ranging from 

disaster recovery to improving education.' CNCS administered grants 

totaling about $750 million in fiscal year 2015 to support national service 

and reported that nearly 350,000 Americans participated in its major grant 

programs that year (see app. I for additional data by state for fiscal year 

2016) 2 CNCS is the nation's largest federal grantmaker for service and 

volunteering, and the agency's mission is to improve lives, strengthen 

communities, and foster civic engagement through service and 

volunteering. 

My testimony today summarizes findings from our report entitled Grants 

Management: Monitoring Efforts by Corporation for National and 

Community Service Could Be Improved.' My testimony, like the report, 

addresses: (1) CNCS's process for grant monitoring; (2) the extent to 

which CNCS's process for grant monitoring aligns with relevant internal 

controls for identifying, analyzing and responding to risk; and (3) the 

extent to which CNCS has the capacity necessary to monitor grantees' 

compliance with grant program requirements. 

To conduct this work, we reviewed agency documents for fiscal years 

2015 and 2016 and analyzed fiscal year 2015 assessment and monitoring 

data (the most recent complete year of data available at the time of our 

review). We reviewed the internal control principles in the Standards for 

Internal Control in the Federal Government and selected those we 

determined to be most relevant to conducting assessment and monitoring 

activities: principles on risk assessment, control activities, and monitoring. 

We compared CNCS's current processes-as documented in policies, 

1 National and Community Service Trust Act of 1993, Pub. L No. 103-82, § 202(a), 107 

Stat. 785, 873. 

2 CNCS's major grant programs are AmeriCorps State and National, Senior Corps, 

Volunteers in Service to America {VISTA) and Social Innovation Fund. 

3 GA0-17-90 (Washington, D.C.: Mar. 21, 2017). 

Page 1 
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procedures, and plans-against these principles• We also interviewed 

agency officials and a nongeneralizable sample of 11 program and grant 

officers who had experience with grants with negative outcomes, such as 

greater-than-expected monitoring needs or audit findings. Lastly, we held 

discussion groups with a nongeneralizable sample of 27 grantees 

attending two 2016 training conferences. Additional information on our 

scope and methodology is included in our report. The work on which this 

statement is based was performed in accordance with generally accepted 

government auditing standards. 

First, we found that CNCS assesses its grants before the beginning of 

each fiscal year and prioritizes its grant monitoring based on the scoring 

of 19 indicators, such as potential performance or financial problems and 

the length of time since the last compliance visit. For fiscal year 2015, 

CNCS identified a universe of about 2,200 grants for assessment that 

were expected to be active during fiscal year 2015, and prioritized 16.4 

percent for compliance visits and 5.4 percent for other types of visits 

(such as for training and technical assistance) and for financial reviews. 

These visits and financial reviews are forms of grant monitoring. In 

addition, CNCS each year selects a random sample of grant records from 

each program to review for possible improper payments. 

Second, we found that CNCS's current process for grant monitoring is not 

fully aligned with federal internal controls for identifying, analyzing, and 

responding to risks (see fig. 1 ). 5 Specifically, risks may go unidentified 

because CNCS's assessment process is conducted only once a year, in 

August, to guide its monitoring activities for the following fiscal year, while 

grants may continue to be awarded after the annual assessment is 

complete. Thus new grants are particularly vulnerable to being omitted 

from the assessment process, as these grants tend to be finalized just 

before the beginning of the new fiscal year. One CNCS official noted that 

an initial visit to a first-time grantee can prevent future problems. In 

addition, while nearly half of CNCS grant dollars are passed through by 

grantees to other organizations (referred to as subrecipients) and 

evidence from prior GAO work indicates that subrecipient oversight is a 

4 GAO, Standards for Internal Control in the Federal Government, GA0-14-704G 

(Washington, D.C.: Sept 10, 2014). We compared CNCS's process against these current 

internal control standards, which became effective October 1, 2015. 

5 GA0-14-704G. 

Page 2 GA0·17-528T 
12 

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key risk area,6 CNCS's monitoring of grantees' oversight of subrecipients 

is limited, leaving the agency's response to risk vulnerable in this area. 

Moreover, CNCS has not systematically evaluated the results of its 

monitoring activities to use in trend analyses or to evaluate opportunities 

for improving its monitoring efforts. 

Figure 1: Areas for Improvement of Internal Controls in CNCS's Grant Monitoring 

Process 

Analyze risks 

to 

CNCS'ssconngmodel 

determine monitoring 

~ 

·~ 

ac\IVitiesdoesno!priori!ize 

Identify risks !he highest-risk grants Respond to risks 

CNCS's monitoring 

of some identified 

nsksislimited 

Sour~:e GAO analys<$. of Corporation for National and Community Serv•ca (CNCS) m<m<tor·ng proces~ and GAO Stand~rds 

for Internal Control in \he "'ederai Govemrrwn1. GAQ.14·704G, PnnCJp:e 7 os shown m GA0-17-90 ) GA0-17-f>28T 

Further, we found that limitations in CNCS' scoring model affect the 

identification and monitoring of risk in the following ways: 

Some indicators that are not based on risk are given 

considerable weight in the rating process, while others that are 

based on risk are given much less weight. The highest rated 

indicator is "time since last visit," which does not necessarily indicate 

risk, and this indicator alone can prioritize a grant for a compliance 

visit In contrast, indicators for financial risks, including a high potential 

for improper payments, would not alone result in a grant being 

prioritized for a monitoring visit. 

Several potential risk factors were included in a single indicator, 

"other key concerns and challenges." A grant would receive a 

score for this indicator only once, even if it demonstrated the potential 

for multiple risks falling within the indicator, including open compliance 

findings, improper payment findings, the potential for financial 

management problems, and any findings from the pre-award review. 

As a result, the indicators may not meaningfully cover all potential 

risks, such as fraud and improper payments, as the scoring model 

limits the weight assigned for such risk factors to less than what is 

required to be prioritized for a monitoring visit. 

Page3 

Federal Grants: Improvements Needed in Oversight and Accountability 

GA0-11-773T (Washington, D.C.: June 23, 2011) 

GA0-17-528T 
13 

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Some indicators may not be calibrated effectively to capture risk. 

For example, CNCS's scoring model includes an indicator that 

identifies whether a grantee has problems with volunteer retentionspecifically, if retention is below 50 percent for 1 year, or 75 percent 

for 2 years. But CNCS program office staff we interviewed told us that 

the retention level measured by the indicator is very low, and they 

would prefer to intervene before retention dropped to this level. 

Several indicators are too frequently applied to be useful in 

distinguishing relative risk among grants. For example, 4 of the 19 

indicators were applied to more than a quarter of the grants assessed 

in fiscal year 2015, which could indicate that they have minimal impact 

in distinguishing among grants to determine their priority status for 

monitoring. One indicator-"multiple awards"-applied to nearly half 

the grants assessed. 

CNCS has taken some steps to improve the extent to which its process 

for grant monitoring considers grant risk, but these efforts are in the early 

stages and their effect is not yet clear. For example, in April2016 CNCS 

hired a chief risk officer to oversee and collaborate with agency program 

and grant offices to develop and implement CNCS policies, procedures, 

and guidance related to the agency's risk framework, and to coordinate 

the development and implementation of documentation and reporting 

processes, including the improper payment review. In addition, the Office 

of the Chief Risk Officer is undertaking an effort to benchmark CNCS's 

assessment indicators and process against those of other federal 

agencies and programs with similar grantee profiles {i.e., agencies or 

programs that fund grantees with varying levels of financial, 

administrative, and staff capacity). CNCS has also begun a pilot effort to 

develop additional indicators of risk, based on a review of past 

performance of 10 grants and analysis of related data. Finally, officials 

also told us that, in addition to implementing the Enterprise Risk 

Management (ERM) process under Office of Management and Budget 

revised Circular A-123, the agency has held listening sessions with senior 

management and staff to gather their perspectives on key agency risks. 7 

Officials said that they plan to use this information to create an agencywide risk profile. 

Page4 

Management's Responsibility for Enterprise Risk Management and Internal 

OMB Circular No. A-123 (revised 2016). 

GA0-17·528T 
14 

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CNCS's efforts to improve its consideration of grant risk are in the early 

stages and do not fully address our findings. As a result, based on our 

work, we identified four ways CNCS can move toward a risk based 

approach for monitoring grants: 

1. Establish and implement a policy to ensure that all grants expected to 

be active in a fiscal year, including those awarded after the annual 

assessment, are assessed for potential risk. 

2. Improve the level of information collected for oversight of 

subrecipients' activities. 

3. Establish activities to systematically evaluate grant monitoring results. 

4. Ensure that CNCS completes its efforts to benchmark its assessment 

criteria and scoring process so that the riskiest grants get the highest 

scores and assessment indicators meaningfully cover all identifiable 

risks. 

Third, we found that CNCS has not conducted the strategic workforce 

planning necessary to determine whether it has the people and resources 

to effectively monitor grantees' compliance with grant program 

requirements, as key principles for effective strategic workforce planning 

in prior GAO work suggest• CNCS's workforce management activities to 

address vacancies have been largely ad-hoc, including addressing 

vacancies in a key office responsible for grant monitoring, at senior levels 

across the agency, and among program and grant officers. Our analysis 

showed that some of these vacancies reduced the number of fiscal year 

2015 monitoring activities conducted. Also, program and grant officers' 

workloads varied across the agency, and CNCS has not evaluated 

whether staff have been deployed where they are most needed. Officials 

said that they had not developed a strategic workforce planning process 

because of limited resources. Without such a process, however, CNCS's 

efforts to address workforce challenges may continue to be ad hoc and 

reactive. We also found that training opportunities vary by CNCS office, 

and coverage of grant monitoring responsibilities is inconsistent. For 

example, program officers have been tasked with monitoring grantees' 

fiscal management practices, but many have not received fiscal 

monitoring training. This is because CNCS has not established a training 

6 GAO, Human Capital: Key Principles for Effective Strategic Workforce Planning, 

GA0*04*39 (Washington, D.C.: Dec. 11, 2003). ln this work, we identified key principles 

for effective strategic workforce planning by conducting a rev1ew of studies by leading 

workforce planning organizations and federal agency workforce planning practices. 

Page 5 
15 

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GAO Contact 

Staff 

Acknowledgments 

planning process aligned with critical competencies for program and grant 

officers, such as fiscal monitoring. 

Based on our work, we identified two ways CNCS can improve its 

capacity for monitoring grantee compliance: 

1. Develop and document a strategic workforce planning process, and 

2. Establish a training planning process linked with critical competencies 

for grant monitoring. 

CNCS did not comment on the report's findings or recommendations, but 

did provide technical comments, which we incorporated as appropriate. 

Chairman Guthrie, Ranking Member Davis, and Members of the 

Subcommittee, this completes my prepared statement. I would be 

pleased to respond to any questions that you may have at this time. 

If you or your staff have any questions about this testimony, please 

contact Allison Bawden at (202) 512-7215 or at bawdena@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this statement. 

GAO staff who made key contributions to this testimony are: Margie K. 

Shields, Assistant Director; Dana Z. Hopings; Sarah M. Martin; and Jason 

S. Palmer. 

Page6 
16 

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Appendix I: State-by-State Data on 

Corporation for National and Community 

Service (CNCS) Grants 

Page7 GA0-17-528T 
17 

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{101942) 

Appendix 1: State-by-State Data on Corporation 

for National and Community Service (CNCS) 

Grants 

a Number of volunteers represents number of awarded positions for the program year. 

b Total funding amount does not include education awards. Funding amounts to grantees in territories 

are not included. 

c Data for Texas are as of April13, 2016. 

Page 8 GA0-17-528T 
18 

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20 

Chairman GUTHRIE. Thank you for your testimony. Ms. Giblin, 

you are now recognized for 5 minutes for your testimony. 

TESTIMONY OF LORI GIBLIN, CHIEF RISK OFFICER, 

CORPORATION FOR NATIONAL AND COMMUNITY SERVICE 

Ms. GIBLIN. Chairman Guthrie, Ranking Member Davis, and 

members of the subcommittee, thank you for inviting me to testify 

today. I share the committee’s view that our agency has a responsibility to ensure Federal funds are well managed and welcome this 

opportunity to discuss our commitment to strong risk management 

and prudent stewardship of taxpayer dollars. 

My written testimony details our comprehensive risk management frameworks and the multiple steps we have taken since the 

subcommittee hearing last year. I will summarize them now. To 

properly identify and manage risk, the first step has to be a commitment from the top. CNCS leadership has made an extraordinary commitment to risk management and has backed up that 

commitment with action. 

We are one of the first independent and small Federal agencies 

to hire a chief risk officer. We are one of the only agencies that has 

aligned all of our risk assessment functions into one integrated 

framework. We have been identified as a leader among our peers 

in implementing the principles of risk management laid out by 

OMB. 

Even in an extremely tight budget environment, we have redirected scarce resources to ensure this function is properly staffed 

and have hired 17 professionals with extensive experience in accounting, auditing, compliance, internal controls, and risk management. Over many years, CNCS has built a culture of accountability 

and a strong system for monitoring and oversight. 

Now, with the strong commitment for leadership, infusion of resources, and a top-notch team, we are building on that foundation 

to implement a risk-based program modeled on industry best practices. 

Our focus is to identify actual evidence-based risks, validate and 

prioritize them, and mitigate them on an ongoing basis. We follow 

leading industry practices in organizing risk into four basic categories: programmatic, financial, compliance, and fraud. 

In the area of programmatic risk, we provide training and technical assistance to our grantees to assist them in successfully implementing their programs. For financial risk, we continually assess our grantees’ financial liability and ability to manage Federal 

funds. If a grantee has challenges, we use a wide range of strategies and corrective actions, including increased monitoring, putting 

grantees on a reimbursement only status, requiring them to report 

monthly on expenditures, termination, suspension, and debarment. 

For compliance and fraud risk, we have taken multiple steps to 

ensure that grantees comply with the terms and conditions of their 

award and to ensure that we safeguard the agency against fraud, 

waste, and abuse. 

To ensure our work is effective, coordinated, and delivering results, we have consolidated five risk assessment programs under 

my office. 

CEWDOCROOM with DISTILLER

21 

First, we are taking comprehensive action to improve compliance 

with national service criminal history check requirements. We implemented a solution enabling our grantees to directly obtain FBI 

checks from a private vendor. We are now seeking another marketbased solution to conduct the State criminal history checks that 

many of our grantees are currently unable to perform. This solution will include a check of the National Sex Offender public 

website, which will ensure that a required check is complete. 

We are leaning in, going beyond what is required, to do what is 

smart by providing resources to our grantees so they can better detect and prevent misconduct before it happens. My office is implementing a testing process for improper payments that will help us 

identify root causes of noncompliance and more accurately report 

the effectiveness of our program to eliminate such payments. 

The agency is taking multiple steps to strengthen internal controls, including testing enterprise-wide controls, convening a fraud 

risk assessment committee, and aligning our internal controls annual testing approach with industry best practices. 

CNCS is also implementing an enterprise risk management program and developing a risk profile that will inform how management invests limited resources and risk mitigation strategies. 

And last, we are refining the criteria used in the annual grant 

risk assessment that informs the types of monitoring and technical 

assistance grantees require. All these actions and many others 

demonstrate the priority we place on risk management and the 

commitment we have to accountability and the responsible use of 

taxpayer dollars. 

Our systems for monitoring oversight are working. Misconduct is 

very rare and when it happens, we take swift action. We are always looking for ways to improve and strengthen our systems and 

we appreciate the guidance from our IG and from GAO and this 

committee. Enhancing these systems will help us better support 

the 325,000 dedicated Americans serving through AmeriCorps and 

SeniorCorps at 50,000 locations across our Nation. 

They are tutoring and mentoring at-risk youth, responding to 

disasters, supporting veterans and their families, and much more, 

all while recruiting millions of additional volunteers to serve alongside them and multiply their impact. 

I hope my testimony today assures the committee of our commitment to accountability and our interest in doing more and I welcome your questions. 

[The statement of Ms. Giblin follows:] 

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Written Testimony of Lori Giblin 

Chief Risk Officer, Corporation for National and Community Service 

Before the Committee on Education and the Workforce 

Subcommittee ou Higher Education and Workforce Development 

March 28, 2017 

Chairman Guthrie, Ranking Member Davis, and Members of the Subcommittee, 

Thank you for the invitation to testify today. I appreciate the opportunity to discuss the 

Corporation for National and Community Service's (CNCS) commitment to strong risk 

management and prudent stewardship of taxpayer dollars. 

My name is Lori Giblin, and I've served as Chief Risk Officer for CNCS since April of2016. I 

joined CNCS ten months ago with nearly 25 years of experience working for the great states of 

Virginia and Arizona and the federal government in the areas of community development, 

compliance, monitoring, internal controls, and risk management. Today, I will provide you with 

an update on the activities of the Office of the Chief Risk Officer since our former CEO Wendy 

Spencer appeared before this Subcommittee in May 2016. 

I would like to start by recognizing CNCS's senior leadership, as well as CNCS stafffor their 

support as my team and I have developed a strategy and work plan that refines and builds on 

CNCS 's current risk management framework. Without this team of dedicated professionals, I 

would not be able to share our accomplishments to date and be confident that we can address the 

opportunities and challenges that lie ahead. I also want to acknowledge the ongoing collaborative 

partnership and support that I have received from the Inspector General who has been helpful in 

identifying areas where attention is needed. 

My presence here today represents CNCS's extraordinary commitment to risk management. We 

view an effective risk management program as an essential strategy for ensuring we meet our 

grantee management and oversight responsibilities. It bears noting that CNCS is one of the first 

small, independent federal agencies to hire a Chief Risk Officer. We are also one of the only 

agencies that has aligned all of our risk assessment functions within one integrated framework. 

And, through our participation as steering committee members of the Association of Federal 

Enterprise Risk Management's Small Agency Community of Practice, we have been identified 

as a leader among our peers in implementing the principles of risk management described in the 

Office of Management and Budget (OMB) guidance released in FY 2016. 

Even in an extremely tight budget environment, agency management prioritized the 

implementation of risk management, redirecting scarce resources to ensure that this function is 

properly staffed and supported. This has enabled us to develop and begin to implement a robust 
23 

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work plan. Thanks to management support we have built a team of seventeen risk management 

professionals with extensive public and private sector experience in accounting, auditing, 

compliance, internal controls, and risk management. 

My top priority as Chief Risk Officer is to build on our strengths and accomplishments and 

address challenges by further developing a risk-based program modeled on industry best 

practices. This program will identify where the agency faces challenges and risks in terms of 

fully delivering on our mission. Once these challenges and risks are clearly identified, tested, and 

verified, my job is to design and implement strategies to mitigate those risks. Mitigating risks 

means to eliminate, prevent, or reduce the negative impact upon our programs, which are vitally 

important to communities across the country and the American public. 

In this testimony I will describe risk management at CNCS as it relates to four standard 

categories of risk: programmatic, financial, compliance, and fraud. I will also provide an update 

on progress and accomplishments in the five programs that the Office of the Chief Risk Officer 

directs. I will end with a summary of our path forward. 

Corporation for National and Community Service Overview 

To appreciate the risk management systems that CNCS has put in place to ensure accountability, 

it is important to understand the structure of national service and our programs. 

CNCS supports service opportunities and building evidence for social interventions through 

AmeriCorps members, Senior Corps volunteers, and Social Innovation Fund grantees. The 

support we provide includes service opportunities and grants that focus on disaster services, 

economic opportunity, education, environmental stewardship, healthy futures, and veterans and 

military families. Last year, 325,000 Americans served in CNCS supported programs at more 

than 50,000 locations across the nation, including more than 244,000 Senior Corps members and 

nearly 80,000 AmeriCorps members. Our Social Innovation Fund supports more than 426 

organizations in 44 states building the evidence base to support interventions in communities 

around the country. Since 2011, CNCS responded to 200 state and federally declared disasters, 

deploying more than 16,000 national service participants, including AmeriCorps NCCC and 

FEMA Corps teams. The structure ofCNCS includes a wide variety of grantee activity at many 

locations and thousands of members each year, creating a complex environment for risk 

management. 

Risk Management Framework at CNCS 

CNCS follows leading industry practice in organizing risk into four basic categories: 

programmatic, financial, compliance, and fraud. The Office of the Chief Risk Officer ensures 

2 
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that the agency actively identifies and mitigates risk in each of these categories in order to 

successfully deliver effective national service and social innovation activities and benefits. 

Our current direction in risk management is to identify actual, evidence-based risks; validate and 

prioritize them, and mitigate them on an ongoing basis. CNCS takes any misuse of federal funds 

extremely seriously and our framework will ensure that our risk management efforts are 

prioritized for impact rather than focusing on isolated incidents that are not representative of the 

entire grant portfolio. 

Programmatic Risk 

In the area of programmatic risk, CNCS manages a large, diverse, and active grant portfolio. A 

majority of our funding is invested in grantmaking. We assess, award, monitor, and provide 

training and technical assistance to our grantees to assist them in successfully implementing their 

programs and that any programmatic, financial, compliance or fraud risk on the part of the 

grantee is mitigated. 

Financial Risk 

In defining financial risk to the agency, we assess challenges that affect our grantees' financial 

viability and their ability to manage federal funds. In some circumstances we may make a 

strategic choice to tolerate a higher level of financial risk in order to support grantees that are 

delivering high-quality services that address needs in low-income and hard-to-serve communities 

or facing pressing or emerging risks. 

CNCS employs a wide range of strategies to deal with grantees that have financial challenges, 

including termination if the grantee cannot comply with the terms and conditions of the award, 

not considering a grantee for further funding, suspension, and debarment. Other corrective 

actions include putting grantees on reimbursement only or requiring them to report monthly on 

their programmatic progress and expenditures. In addition, the agency has taken strong measures 

over the last two years to ensure that disallowed costs that are identified through audits, 

investigations and monitoring are recovered. 

Compliance and Fraud Risk 

Another priority as the Chief Risk Officer is to ensure that grantees comply with the terms and 

conditions of their award and to ensure that we safeguard the agency against fraud, waste and 

abuse. Let me share with you what our agency has done to enhance our risk mitigation posture 

and ensure that we have effective controls in the areas of compliance and fraud risk. 

3 
25 

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First, the CNCS senior leadership team has provided significant support for the framework of our 

risk program-its leadership, governance, and organizational structure. Since I arrived at CNCS, 

senior leadership, based upon my recommendations and their commitment to our success, has 

increased staffing of the risk management team. 

To ensure that this team meets its goal of building, implementing, and reporting the results of a 

robust risk program, we have established a governance structure that will hold CNCS to the 

highest standards. Our senior level governance body has met seven times since l arrived and they 

have made important decisions on staffing, internal controls, and the criminal history check 

program. I am confident that this governance structure, combined with strong CEO and Board 

oversight and support, as well as monthly meetings with the IG and OIG staff, will ensure 

successful implementation of our risk strategies. 

Programs of Office of the Chief Risk Officer 

CNCS established the Office of the Chief Risk Officer to oversee all of the agency's financial 

and programmatic internal risk assessment programs under one executive, including National 

Service Criminal History Checks, Improper Payments, Internal Controls, Grants Assessment, and 

Enterprise Risk Management programs. 

National Service Criminal History Checks 

The National Service Criminal History Checks program is the newest addition to the portfolio of 

the Office of the Chief Risk Officer. It was added as a follow-up action after the agency last 

testified before this Committee. Since we added the program to the Office of the Chief Risk 

Officer, senior leadership has approved a seven-point strategy that we are implementing to 

address the root causes of grantee noncompliance. These critical controls are designed to 

enhance the controls currently in place to protect our most vulnerable populations from those 

who wish to do harm. 

As our former CEO shared during her testimony last year, CNCS developed and implemented a 

strategy to improve compliance with the National Service Criminal History Check requirements. 

This strategy includes using the agency's legal authority to enable our grantees to directly obtain 

fingerprint based checks from a private vendor. Since engaging in this solution, the vendor has 

provided 17,476 checks to 531 grant recipient organizations in 44 states and the District of 

Columbia and Puerto Rico. The vendor has helped CNCS and our grantees identify potential 

ineligible applicants thus fortifying our risk efforts and protecting those we serve. Building on 

that success, my office will seek a market-based solution to conduct the state criminal history 

checks that our grantees are currently unable to perform due to lack of access or capability. 

4 
26 

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In addition, the market-based solution will include the National Sex Offender Public Website 

checks, ensuring a complete three-part check. This solution will enable us to continue to protect 

our most vulnerable citizens, serve our grantees, and standardize a complex procedure. In 

addition to this public-private partnership, CNCS will augment and strengthen our outreach and 

training plans by educating our grantees in detection and encouraging active participation in 

proven prevention strategies. 

Improper Payments 

Every federal agency is required to assess payments that were made to the wrong person, at the 

wrong time, or in the wrong amount. Our agency has faced challenges in implementing a testing 

process that allows us to report, with confidence, our estimated rate of improper payments. 

We have met with OMB and other federal agencies to gather their input on our testing design 

and approach to ensure that we are adopting proven strategies so we can more accurately report 

on the effectiveness of our program to eliminate improper payments. Next month we will submit 

a testing methodology to OMB that will help us report accurately and test in a way that identifies 

root causes to our major sources of noncompliance. 

Internal Controls 

I have been working closely with senior leadership to enhance and refine our internal control 

framework to comply with all Government Accountability Office (GAO) standards, including 

those detailed in GAO's Framework for Managing Fraud Risks in Federal Programs. We have 

recently conducted the agency's first ever entity-level assessment that tested the agency's 

enterprise-wide controls. We are pleased to report that no material gaps were identified. 

We have also convened a Fraud Risk Assessment Committee and have scheduled meetings of the 

group for the remainder of the fiscal year. This committee will guide the agency in identifying 

potential fraud risks. It will rate, rank, and calibrate identified risks for further action and 

implement risk mitigation strategies. In addition to the fraud risk assessment, we have hired a 

contractor to reconfigure our overall internal controls annual testing approach to make sure it is 

aligned with industry best practices. This year we have selected the procurement and grant 

lifecycle functions for testing and will continue to develop the assessment tools needed to test the 

agency's other key business processes. 

Enterprise Risk Mllnagement 

My team is actively participating in the government-wide effort to implement an enterprise risk 

management program as one component of our risk management framework. We are in the 

5 
27 

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process of drafting an agency risk register that will be validated and prioritized by senior 

leadership. We anticipate completing this assessment in the coming months. This risk register 

will also be used to further assess agency risks and vulnerabilities and provide us the opportunity 

to refine our mitigation strategies on an ongoing basis. 

Monitoring Risk Assessment 

My team is charged with developing and facilitating the annual risk assessment of all grants. The 

agency has an assessment tool that assists us in identifying whether grantees require additional 

monitoring and training and technical assistance. Nearly a decade ago, CNCS was at the leading 

edge of federal agencies that developed assessment criteria used to determine which grantees we 

monitor and how we conduct grantee monitoring. Though we have refined this criteria over the 

years, we will be working to further refine and mature it moving forward. In addition to 

strengthening our risk assessment process, CNCS continues to enhance our grantee oversight and 

monitoring throughout the grant lifecyclc to ensure grantee success and accountability. 

Conclusion 

Thank you for the opportunity to provide testimony today. I want to assure the Committee that 

CNCS and I are deeply committed to developing and enhancing our approach to risk 

management. We take our responsibilities very seriously and are confident in our ability to 

effectively manage federal funds and provide national service opportunities to the American 

public. I welcome your advice and counsel. 

6 
28 

Chairman GUTHRIE. Thank you for your testimony. I know recognize Ms. Darling for 5 minutes for her testimony. 

TESTIMONY OF ELIZABETH DARLING, CEO AND PRESIDENT, 

ONESTAR FOUNDATION AND NATIONAL SERVICE COMMISSION 

Ms. DARLING. Mr. Chairman and members of the committee, 

thank you for inviting me to testify today. I appreciate the opportunity to discuss the Corporation for National and Community 

Service and their unique structure and systems of accountability 

and oversight. 

I am also pleased to share with you a snapshot of how the State 

of Texas benefits from the corporation grant funding administered 

by OneStar National Service Commission. OneStar is 1 of 52 State 

service commissions charged with strengthening local communities 

through service and volunteering. The corporation’s decentralized 

structure provides States the flexibility to meet local needs in 

alignment with our governor’s priorities. Three-quarters of the corporations of AmeriCorps funding flows through governor-appointed 

State service commissions. 

In Texas, OneStar administers approximately $14 million in corporation grant funding through a highly competitive process engaging nonprofits, State agencies, universities, and local governments. 

These funds leverage an additional $31 million in private cash and 

in-kind support for 2,400 AmeriCorps VISTA members who collectively will earn over $9 million in education awards that may be 

used to repay student loans or for continuing education. 

Many private Texas funders look to OneStar’s portfolio of programs to inform their own grant decisions. They know our grant 

making is rigorous from our intensive pre-award vetting to risk assessment to subsequent monitoring of performance throughout the 

life cycle of the grant. Commissions truly are the first line of defense in ensuring accountability and good stewardship of taxpayer 

dollars. 

In Texas, we don’t hesitate to disallow costs for even the smallest 

compliance issue. Our subgrantees know that we don’t tolerate 

noncompliance and if mistakes are made, there are real financial 

consequences. 

Compliance is critical and community impact is the ultimate 

goal. National service, whether AmeriCorps or its companion program, SeniorCorps, allows nonprofits to serve thousands more people than they could otherwise serve. In 2016, AmeriCorps Texas 

programs served almost 153,000 at-risk youth. Thirty thousand 

SeniorCorps members in Texas kept frail, elderly Texans in their 

homes, mentored youth in detention facilities, and responded in 

times of disaster. 

Like many State service commissions, OneStar works closely 

with our Division of Emergency Management. We are named in our 

State disaster response plan as the point of contact for national 

service and the coordination of unaffiliated volunteers. 

Last year, 1,600 AmeriCorps members recruited, trained, and 

managed almost 11,000 volunteers who responded to a series of 

disasters and still assist today in ongoing recovery projects, including Southeast Texas flooding, Wimberley flooding, Memorial Day 

CEWDOCROOM with DISTILLER

29 

flooding, the Hidden Pines wildfire, Halloween flooding, North 

Texas tornadoes, the 2015 Van tornadoes, and the 2013 West Fertilizer explosion. 

These are not just names of unfortunate events. These are now 

threads in the fabric of Texas history. Texas will soon also be home 

base to the first RV DisasterCorps, deploying SeniorCorps volunteers and their recreational vehicles in response to disasters within 

our 254 county region. Over the past 5 years, the corporation has 

mobilized thousands of SeniorCorps volunteers and AmeriCorps 

members throughout the country in response to over 200 declared 

disasters, some in your home States and districts. 

Along the southernmost tip of Texas is a border region known as 

the Rio Grande Valley, an area of high need and few resources to 

lift people out of poverty. The University of Texas Rio Grande Valley AmeriCorps program supports 160 university students as mentors, providing college access services to over 5,000 low-income, 

first-generation high school seniors and last year, over 3,300 of 

those school students successfully enrolled in postsecondary education. The Literacy First AmeriCorps program in Austin supports 

106 AmeriCorps members at 32 high-poverty schools, providing 

daily intensive, individualized reading interventions to over 2,000 

kindergarten, first grade, and second grade students. Approximately two-thirds of those tutored students reach grade level by 

the end of the school year. 

OneStar, like the commission in your State, is able to support 

these high-performing programs because of CNCS. The corporation 

provides consistent guidance, resources, and tools to assist us in 

our work. Our staff attend comprehensive trainings, adopt CNCS 

developed monitoring tools and templates, and receive regular and 

frequent support from dedicated program and grants officers. 

My written testimony provides greater detail on the corporation’s 

support and monitoring of OneStar National Service Commission 

as well as our policies and procedures related to the oversight of 

subgrantees. I am grateful to the committee and to each of you as 

public servants charged with ensuring that taxpayer dollars are 

used effectively and that all actors are good stewards of the resources with which we are entrusted. Thank you. 

[The statement of Ms. Darling follows:] 

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Written Testimony of Elizabeth Darling 

CEO/President Texas One Star Foundation and OneStar National Service Commission 

Before the Committee on Education and the Workforce 

Subcommittee on Higher Education and Workforce Training 

March 28, 2017 

Chairman Guthrie, Ranking Member Davis, and Members of the Subcommittee: 

Thank you for the invitation to testify today. I appreciate the opportunity to provide the 

Committee insight into the accountability structures within the OneStar National Service 

Commission, a grantee of the Corporation for National and Community Service (CNCS). This 

testimony also outlines for the Committee, the many ways CNCS works with state service 

commissions to ensure compliance with federal regulations and good stewardship of taxpayer 

dollars. 

INTRODUCTION 

OneStar is one of 52 state service commissions, each of which is as different as our state flags 

and our geography, yet we are bound by many commonalities. Many commissions reside 

within a state agency as determined by their governor. Some even reside within the Office of 

the Governor or Lt. Governor. Other co~missions may be stand-alone agencies or separate 

nonprofit organizations with a link to the Office of the Governor like OneStar Foundation. 

Each commission is governed by a board of gubernatorial appointees who represent various 

constituencies as directed by federal statute. All Commissions are charged with identifying 

local needs, setting polices and program priorities, and overseeing the AmeriCorps 

competitive grant process for their state. 

Commissions administer three quarters of CNCS' AmeriCorps grant funding which is matched 

dollar for dollar or greater. Commissions award grants supporting human capital (AmeriCorps 

members) to local nonprofits, universities, state agencies and Tribal governments; provide 

training and technical assistance; monitor grantees to ensure program quality and compliance 

with federal and state law; and promote service and volunteering. Many governors also look to 

their state service commission to support special initiatives funded by state or philanthropic 

dollars such as annual nonprofit conferences, volunteer awards programs, special mentoring 

programs, disaster corps and other purposes as determined by their state. 

In Texas, OneStar administers approximately $14 million in Corporation grant funding 

through a highly competitive process engaging nonprofits, state agencies, universities and 

local governments. These funds leverage an additional $31 million in private cash and in-kind 
31 

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support for 2400 AmeriCorps members who collectively will earn over $9 million in education 

awards that may be used to repay student loans or for continuing education. 

like many state service commissions, OneStar works closely with our Division of Emergency 

Management. We are named in our state disaster response plan as the point of contact for 

national service and the coordination of spontaneous volunteers. Last year 1,600 AmeriCorps 

members recruited, trained and managed almost 11,000 volunteers who responded to a 

series of disasters and are assisting still in ongoing recovery projects including Southeast 

Texas Flooding, Wimberley Flooding, Memorial Day Flooding, the Hidden Pines Wildfire, 

Halloween Flooding, North Texas Tornados, the 201S Van Tornados and the 2013 West 

Fertilizer explosion. These are not just names of unfortunate events, these are now threads 

in the fabric ofTexas' history. 

Texas will soon be home-base to the first RV Senior Corps program deploying Senior Corp 

volunteers in their motor homes in response to disasters within our 254 county region. Over 

the past 5 years, the Corporation has mobilized thousands of Senior Corps volunteers and 

AmeriCorps members throughout the country in response to more than 200 declared 

disasters, some in your home states and districts. 

National service, whether AmeriCorps or its companion program Senior Corps, allows local 

non profits to serve tens of thousands more people than they could otherwise serve. In 2016 

AmeriCorps Texas programs served almost 153,000 youth at risk. 30,000 Senior Corps 

volunteers kept frail elderly Texans in their homes, mentored youth in detention facilities and 

managed thousands of volunteers after disaster. 

Along the southern-most tip of Texas is a border region known as the Rio Grande Valley, an 

area of high need and few resources to lift people out of poverty. The University of Texas Rio 

Grande Valley AmeriCorps program supports 160 university students as mentors providing 

college access services to over 5,000 low-income, first-generation high school seniors. Last 

year over 3,300 of these high school students successfully enrolled in accredited 

postsecondary institutions. 

The Literacy First AmeriCorps program in Austin supports 106 AmeriCorps members at 32 

high-poverty schools providing daily, intensive, individualized reading interventions to over 

2,000 kindergarten, first and second grade students. Literacy First's robust evidence-based 

model works! Approximately two-thirds of tutored students reach grade-level in reading by 

the end of the school year. 

We have a great national service story to tell in Texas and the same is true in each of your states. 

In order to accomplish our work, we must have well managed programs that are in compliance 

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with state and federal regulations and accountable for the funds awarded through the 

AmeriCorps program. 

For the purposes of my testimony today I will focus on OneStar's role as Texas' state service 

commission and the management of our AmeriCorps portfolio. I would like to note that some 

CNCS AmeriCorps grantees (National Direct programs) apply directly to the Corporation for their 

funding without going through state service commissions. Their risk assessment, monitoring and 

oversight activities will have many parallels and similarities to commissions due to our common 

funder, CNCS. 

I have served as CEO/President of OneStar Foundation and OneStar National Service 

Commission since my appointment by Governor Rick Perry in 2009. I currently serve under 

Governor Greg Abbott. Over the past 8 years the sophistication and integrity of One Star's 

grant-making and oversight has matured along with that of CNCS. Many private Texas 

funders look to OneStar's portfolio of programs to inform their own grant decisions. They 

know our grant-making is rigorous from our intensive pre-award vetting and risk assessment 

to the subsequent monitoring of performance throughout the lifecycle of our grants. With 

CNCS' guidance and resources we are engaged in continuous improvement, never satisfied 

with the status quo. State service commissions truly are the first line of defense in ensuring 

accountability and good stewardship of these taxpayer dollars. 

CNCS OVERSIGHT 

One Star has found CNCS's oversight to be robust and the resources and trainings provided to be 

improving over the last few years. It is clear that CNCS takes training and prevention activities 

seriously, and puts a great deal of effort into ensuring the national service field has access to 

resources needed to run compliant programs. OneStar frequently uses resources developed by 

CNCS to provide oversight to our sub-grantees. OneStar feels confident in our ability to provide 

oversight to our grantees based on the oversight we receive as a grantee of CNCS. 

Within the last three years OneS tar has received a monitoring visit from our CNCS Program 

Officer and CNCS Grants (fiscal) Officer. Both visits spanned several days and covered in detail 

primary AmeriCorps regulations. The tools and feedback used by our CNCS Program and Grants 

Officers were beneficial to OneStar as a state service commission, to refine how we monitor our 

sub-grantees and to ensure we are documenting written policies and procedures. The 

monitoring visit from our Program Officer also included a review of full member files, member 

National Service Criminal History Check (NSCHC) files, and staff NSCHC files of selected subgrantees. Additionally, the visit included member observations of one of our sub-grantees. The 

visits were constructive and thorough. 

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Under the Improper Payments Elimination and Recovery Act (IPERA) CNCS is responsible for 

determining if its programs are susceptible to significant levels of improper payments. CNCS uses 

random sampling methodology to select transactions, and then grantees must submit supporting 

documentation. OneStar and our sub-grantees have been selected for IPERA testing for several 

years and found the process to be thorough. 

CNCS PROVIDED RESOURCES, TRAINING AND SUPPORT 

State service commissions are fortunate to have the benefit of countless resources from CNCS to 

help us provide critical oversight to sub-grantees. Below is a summary of some of the resources 

OneStar has found particularly helpful: 

AmeriCorps State and National SyrJ1jJ_~ium: Each year, CNCS delivers a multi-day Symposium for 

leaders of state service commissions, and AmeriCorps National grantees. The AmeriCorps State 

and National Symposium offers an opportunity to learn about grant requirements and best 

practices, build relationships with CNCS staff at all levels, and network with colleagues from a 

variety of programs. The event is designed to build the AmeriCorps network and strengthen 

programming and service experiences across the country. OneStar typically sends 2-4 staff to the 

Symposium, and brings back resources to share with the full team. Information learned at the 

Symposium is used to shape OneStar trainings and technical assistance to our sub-grantees 

throughout the upcoming year. 

National Service Region~!I@inings: These regional trainings are hosted in collaboration with 

state service commissions, CNCS, and America's Service Commissions (ASC) the association for 

state commissions. Staff representing all streams of national service are encouraged and 

welcome to attend the training events including but not limited to AmeriCorps State (state 

service commissions), AmeriCorps National Direct, Senior Corps, Social Innovation Fund grantees, 

AmeriCorps VISTA, Volunteer Generation Fund grantees, Tribal Grantees, and AmeriCorps 

National Civilian Community Corps (NCCC). These trainings provide critical "how-to" training for 

both OneStar staff and our sub-grantee staff. The fact that these trainings are developed locally 

within regions allows the trainings to be tailored to regional needs, while also providing the 

expertise from CNCS presenters on AmeriCorps regulations and best practices. The CNCS Office 

of Inspector General is a frequent presenter and attendee at these regional events. 

"f!gular Webinars and _Tr_aif1ings: CNCS is frequently hosting webinars and distributing resources 

to their grantees to provide training on AmeriCorps regulations, training on new information, and 

general support for running high quality, compliant national service programs. 

Communication with CNCS Program and Grants Officer: The CNCS model of one assigned 

Program Officer and Grants Officer is effective in ensuring grantees receive the support they 

need from CNCS. OneStar has scheduled monthly calls with our assigned Program Officer, and is 

in constant communication outside of those call times as well, typically on a weekly basis. 

OneStar's assigned Grants Officer is available to help when questions arise. It is extremely 

beneficial to have a primary contact at CNCS that we can trust to provide us guidance in a timely 

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manner. This is essential for us to in turn provide the guidance necessary to our sub-grantees. 

When we have difficult or ambiguous questions we know we can reach out to our Program or 

Grants Officer. 

CNCS Website: The CNCS website contains countless resources for state commissions and subgrantees. OneStar staff reference resources on the website on an almost daily basis. Some of the 

most helpful resources are the Knowledge Networks that provide in depth information on a wide 

variety of topics, such as Evaluation, Recruitment, Disability Inclusion, and National Service 

Criminal History Checks. 

Ni'Jt:iO_t}91 Servig:_Clim_irlal Histor'{C:he~ (NSCHC}J3~sources: CNCS has been increasing the level of 

support and guidance for NSCHC checks every year. There is now a robust eCourse that is 

required for all grantees and sub-grantees to take annually. CNCS has also released guidance for 

disallowing costs for non-compliant NSCHCs that uses a risk-based approach. They have also 

recently added a state-by-state guide for running compliant "state of residence checks", which 

can often be one of the most time-intensive check components to complete. 

ONESTAR OVERSIGHT 

gisk Assessm_entand Monitoring Procedures 

One Star conducts an annual Portfolio Risk Assessment, which includes 23 different categories 

across inherent, program, and fiscal risk. The Risk Assessment includes: Inherent items of risk, 

any items as a result of pre-award reviews, follow-up items as a result of any site and/or deskbased monitoring, issues identified in monthly compliance meetings, external information as 

applicable (i.e. publicly available information, complaints, news headlines, etc.). The risk scores 

determine the intensity of monitoring each sub-grantee receives, but does not determine when 

monitoring is received. 

Each sub-grantee receives a monitoring visit once during their three-year project period. In 2016, 

One Star conducted monitoring visits of 9 sub-grantees, or 32% of the portfolio. Additionally, 

three sub-grantees received post-award visits in the first year of their grant, one sub-grantee 

received a pre-award visit prior to the start of their grant, and two planning sub-grantees 

received visits to provide in person training. In total, 54% of sub-grantees received some type of 

visit from OneS tar staff (15 of 28 grantees) in 2016. 

During monitoring visits OneStar Grants and Program Officers conduct group interviews with 5 

AmeriCorps members, conduct member observations, and site supervisor interviews. The 

number of interviews and observations conducted are dependent on portfolio risk assessment. 

Additionally there are Program and Fiscal staff interviews that take place during monitoring visits, 

where One Star staff can monitor for sub-grantees' adherence to required regulations and to their 

own written policies, which are reviewed in conjunction with the visit. 

100% of operating AmeriCorps sub-grantees receive an annual desk-based monitoring of both 

their program and fiscal files. For program monitoring portfolio risk assessment is used to 

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determine how many full member files, member NSCHC files, and staff NSCHC files are pulled for 

review for each grantee. For fiscal monitoring, all programs receive an end of year reconciliation 

of reimbursement requests, and the portfolio risk assessment is used to determine the number of 

transactions pulled for testing throughout the year for cost-reimbursement grants. 

911g<:>irlgB~ourc~s and SURJJ_Q_rtfQI_Oyer:sight 

In addition to Monitoring Visits, OneStar provides several avenues to prevent, detect, and 

enforce potential compliance issues. OneStar is committed to providing high quality training and 

resources to sub-grantees to ensure quality, compliant programming. Below is a summary of 

these types of activities: 

)I.JL(Jrantee Meeting (AGMJ: OneStar hosts the All-Grantee Meeting (AGM) annually for our subgrantees as a required training, typically 2 days. Participants are brought together from across 

Texas to build relationships and networks, share best practices, address challenges, reflect on the 

year to date, and receive important updates and trainings from the field on programmatic and 

fiscal topics. Previous sessions include: National Service Criminal History Check Bootcamp, 

Procurement Procedures, and Preparing for an OIG Audit and Securing Federal Funds. 

N_e\'{_jl.meriCorps Staff Orientation (NASOl: OneStar holds a speciall.S-day orientation and basic 

training for new sub-grantees and/or new staff working with sub-grantees approximately 2-3 

times per year, typically in July, November, and March. This orientation is mandatory for any 

Primary Program and Fiscal Staff listed on the AmeriCorps Authorized Representative Form (ARF) 

within the first year of being assigned as a Primary contact. 

l',ll_q_l}!hly Calls: OneStar hosts 2 sets of Grantee Training and Technical Assistance (TTA) calls for 

sub-grantees. Every other month is an "Updates from the Field Call" where OneStar staff share 

our updates and reminders with the whole portfolio, and on the alternate months, OneStar 

Program and Grants Officers have one-on-one calls with each sub-grantee. 

M~mh_eLEXpE?rience Survey: Every year, OneStar requires programs to send the Member 

Experience Survey out to AmeriCorps members. While this survey is optional, OneStar strongly 

recommends that programs encourage their members to complete it. Typical response rate is 

about 50% of AmeriCorps members within the OneS tar portfolio (approximately 1200). This 

survey includes topics asking members what they have received training on, if they have ever 

been asked to participate in prohibited activities, as well as reflection on how meaningful they 

find their service. Responses are broken down by sub-grantee and OneS tar Program Officers 

follow-up with sub-grantees on any issues raised in the responses. 

Pre-Award Review: Each summer, as part of OneStar's annual Pre-Award Review process, each 

OneStar Program and Grants Officers complete an in-depth review of all relevant program and 

fiscal start up documents. The Notice of Funding Availability (NOGA) will not be issued until 

Program and Grants Officers have approved all required start up documents. 

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Pre-Award Visits: For newly selected AmeriCorps sub-grantees, OneStar Program and Grants 

Officers conduct a full day Pre-Award Start Up Visit prior to issuing the NOGA. During this on-site 

visit, OneStar Program and Grants Officers provide initial, face-to-face training and technical 

assistance related to the program launch. 

§~<!D.Likview: During annual grant review (New, Recompete, and Continuation), OneStar-trained 

grant reviewers specifically review all grant application narratives and proposed member activity 

descriptions for any concerning language or other red flags. If any red flags are detected, the 

applicant must go through additional clarification; if for any reason resolution of the concerns or 

questions was not reached, the grant application would not be considered for funding. 

AmeriCorps Progress Report (APR) Review: During the mid-year and end of year APR review, 

OneStar Program Officers complete a careful review of sub-grantees' submitted APR. This review 

occurs twice per year for the mid-year and end of year report. The Program Officers review 

performance measures, demographic information, and member data reported for validity, 

completeness, consistency, accuracy and verifiability. If the Program Officers detect any potential 

errors or items that need clarification, they will be addressed in the APR Review document sent 

to the program with action items. 

Data Dive: On a yearly basis, OneStar Program Officers complete a data dive for every subgrantee. This review occurs after the mid-year AmeriCorps Progress Report is submitted. In this 

review, they conduct a basic test of the accuracy and verifiability of one data point reported in 

the Mid-Year AmeriCorps Progress Report. All data submitted as part of progress reports are 

potentially subject to testing and review. 

Federal Financial Re]:lQr!__[Ef=ffi: During mid-year and end of year FFR Review, OneS tar Grants 

Officers complete a careful review of sub-grantee' submitted FFRs. OneStar's FFRs and 

Unexpended Reports for its prime grants reflect the following 4 key elements: federal 

expenditures ("CNCS Share"), grantee expenditures ("Grantee Share"), program income, and 

other federal sources used to support the program ("Federal Funds Used as Match"). 

Ongoing Technical Assistance/Trainil}g~ OneStar Program and Grants Officers are always available 

by phone and email to grantees, and are in constant communication with grantee staff to 

promptly address any issues or concerns. As funding allows, OneStar hosts additional trainings 

for grantees, such as Disability Inclusion Training or AmeriCorps Evaluation Institute. 

NATIONAL SERVICE CRIMINAL HISTORY CHECK_~ 

OneStar takes the prevention, detection, and enforcement of National Service Criminal History 

Checks (NSCHC) very seriously. We have heard clearly from the CNCS that the expectation is "on 

time, every time" and we pass this message on to our sub-grantees regularly. Below is a 

summary of OneStar procedures to ensure compliance of NSCHC regulations. 

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NSCHC- OneStar Procedures for Prevention 

In order to prevent the likelihood of programs conducting non-compliant criminal history checks, 

OneStar conducts the following prevention-focused activities: 

Pre_-A\\fard Visits: During this visit, OneStar Program Officers specifically train sub-grantee 

staff on how to conduct a compliant National Service Criminal History Check (NSCHC). 

Pre-Award Review: Each summer, as part of OneStar's annual Pre-Award Review process, 

Program Officers complete an in-depth review of all relevant program start up 

documents. Sub-grantees submit the following documents: 

NSCHC Consent and Verification Form- template used by sub-grantee to 

document member and staff person consent to run checks, and verification that 

checks were run and documented. OneS tar Program Officers will require the subgrantee to edit the document if it does not include all requirements for 

documentation, including requirements specific to OneStar's Alternative Search 

Protocol (ASP). 

Staff NSCHC Certification- document where the sub-grantee self-certifies that all 

required components of the National Service Criminal History Check are complete 

for all covered staff positions. 

Staff NSCHC Review- OneStar Program Officer reviews NSCHCs for all staff on a 

planning grants. NOGAs are not released until the OneStar Program Officers have 

verified that compliant NSCHCs have been conducted. 

NSCHC Policies and Procedures- Program Officer will review sub-grantee's NSCHC 

Policies and Procedures, using the NSCHC Policy and Procedure Checklist. Program 

Officer will require sub-grantee to edit policy and procedure if it does not include 

all requirements. 

CNCS NSCHC eCourse- sub-grantees are required to submit eCourse certificate for 

at least one individual on staff. The eCourse must be completed annually. 

lll_~w Ameri~OB:J?Ji!?ff O_lj__entatio_ll_(NASO): During NASO, a two hour session on Criminal 

History Checks is covered, including step-by-step instructions on how to complete a 

compliant NSCHC. 

Ongoing Training & Technical Assistance (TTA): OneStar sub-grantees also receive 

frequent, regular training and technical assistance coaching from OneStar staff related to 

NSCHCs. The topic of NSCHC Requirements and Alternative Search Protocols (ASPs) is a 

standing topic on the individual one-on-one calls every other month so sub-grantee staff 

are frequently being reminded of this important requirement. Additionally, One Star holds 

an annual All-Grantee Meeting (typically in spring) that includes annual trainings related 

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to the National Service Criminal History Check requirements; this meeting is required 

attendance for all Primary Program and Fiscal Contacts. 

NSCHC- OneStar Procedures for Detection 

In order to ensure swift detection of any compliance issues related to National Service Criminal 

History Checks, OneStar conducts the following detection-focused activities: 

Desk Based File Review: Per OneStar's Monitoring Policy and Plan, OneStar Program 

Officers, conduct a file review of complete member files, member criminal history checks, 

and staff criminal history checks for the current and/or most recently completed year. If 

any compliance concerns arise as a result of the desk based review, these will be 

addressed in writing along with any clarification questions in the monitoring report. 

rv!O_rlit_OEii1R.Yisits: During formal monitoring visits, OneStar Program Officers conduct a 

Program Staff Interview with sub-grantee. This interview asks sub-grantee staff to walk 

through the sub-grantee's specific policy and procedures for criminal history checks. 

On-Going Detection: OneStar Program Officers are ready to process any self-reported 

NSCHC issues by the sub-grantee. 

If there are any components of the National Service Criminal History Check that are not 

compliant, or any results of the criminal history check that would render an individual ineligible 

to serve or work in a covered position, OneStar uses the CNCS Guidance for Risk Based 

Disallowance. 

PROHIBITED ACTIVITIES 

OneStar understands the importance of training sub-grantees on Prohibited Activities, and having 

robust systems in place to detect any issues of non-compliance. 

Prohibited Activities- Procedures for Prevention 

In order to prevent the likelihood of AmeriCorps members from participating in prohibited 

activities, OneStar conducts the following prevention-focused activities: 

§ra_nt Review and Clarification: During annual grant review (New, Recompete, and 

Continuation), OneStar-trained grant reviewers specifically review all grant application 

narratives and proposed member activity descriptions for any concerning language or 

other red flags that may suggest the potential for prohibited activities. Secondly, grant 

reviewers specifically look for language in the grant application that mentions how the 

program will train AmeriCorps members and staff on the prohibited activities. If any red 

flags are detected, the applicant must go through additional clarification; if for any reason 

resolution of the concerns or questions was not reached, the grant application would not 

be considered for funding. 

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Pre-Award Visits: During this visit, the OneStar Program Officer discusses allowable 

member service activities and timekeeping to ensure prohibited activities are not 

conducted by members. 

Pre-Award Review: The Sub-grantees submit their Member Service Agreements (MSAs} 

during this review, and are required to include the prohibited activities language. lfthe 

language in the MSA does not align exactly with the requirements, the Program Officer 

will require the sub-grantee to edit the document and resubmit it for approval. Secondly, 

the Program Officer also reviews each sub-grantee's proposed Member Position 

Descriptions to ensure they do not include any prohibited activities. 

New AmeriCorps~_t!ffOrientation (NASO): During NASO, the topic of prohibited activities 

is specifically discussed and explained to attendees for additional reinforcement. 

Ongoing Training & Technical Assistance (TTJ!)_: OneStar sub-grantees also receive 

frequent, regular training and technical assistance coaching from OneS tar staff, including 

required monthly conference calls. The topic of prohibited activities periodically comes 

up as a question from sub-grantee staff, and OneStar Program Officers are prepared to 

answer sub-grantee questions. Additionally, OneStar holds an annual All-Grantee 

Meeting (typically in spring) that includes annual reminders of and activities/discussions 

related to the prohibited activities requirements. 

Prohibited Activities- Procedures for Detection 

In order to ensure swift detection of any compliance issues related to Prohibited Activities, 

OneStar conducts the following detection-focused activities: 

Monitoring Visits: During formal monitoring visits, OneStar Program and Grants Officers 

conduct a 2 hour member interview with OneStar-selected focus group of 5-10 currently 

serving members. During this group interview, the Program and Grants Officers pass out a 

list of the prohibited activities and ask members the following question: 

"Take a minute to review the list of activities. Have you participated or been asked 

to participate in activities such as those on the list?" (Probe: Give a few examples 

of the types of activities that would be prohibited and ask if they've been involved 

in these.) 

In addition to the member interview, OneStar staff conducts a 30-minute interview with 

at least 2 site supervisors. During the interviews, the Program and Grants Officers pass out 

a list of the prohibited activities and ask supervisors the following question: 

"How familiar are you with the kind of activities that are prohibited and what you 

therefore may not ask your members to do?" 

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In addition to the formal interviews, OneStar Program and Grants Officers carefully 

observe members and staff in action during the visit to determine potential implications 

with regards to prohibited activities requirements. 

If any concerns arise as a result of the monitoring site visits and interviews, this will be 

addressed in writing along with any clarification questions in the monitoring report. 

In addition to the member and site supervisor interview and observations, the Program 

Officer also conducts a Program Staff Interview with sub-grantee staff. This interview asks 

sub-grantee staff to walk through the sub-grantee's specific policies and procedures, 

including the sub-grantees policies and procedures for prohibited activities. 

Annual Member:.~.\!!_\'~: The following questions are asked related to prohibited activities 

requirements: 

Have you participated in or been asked to participate in any activities on the list 

while earning service or training hours? 

Yes No Unsure 

If you answered yes or unsure, please describe: 

Have you ever been asked to participate in any service activities that made you 

uncomfortable or seemed inappropriate for your position? 

Yes No Unsure 

If you answered yes or unsure, please describe: 

If any members answer "yes" to the questions above, OneStar Program Officers will 

contact the member directly if she/he provided contact information to find out more 

information. If the member response indicates the program was not following the 

prohibited activities requirements, it will be discussed with the program to determine if 

corrective action needs to occur. Secondly, the responses to the above questions are 

included in the individualized reports sent out to programs. OneStar Program Officers 

discuss the results with any programs who have responses above which indicate that 

members could have participated, or been asked to participate in prohibited activities. 

Qll:GoLQ@l_~!iQn: On an on-going basis, the OneStar team carefully listens and 

observes during monthly calls, community events, trainings, and impact visits to detect if 

any prohibited activities occurring in the field. 

Prohibited Activities Procedures for Enforcement 

In order to handle and resolve any compliance issues related to prohibited activities, OneStar 

conducts rigorous enforcement activities in an escalated manner in accordance with OneStar 

Foundation Terms and Conditions ("Enforcement") and OneStar's Enforcement Policy & Matrix. 

11 
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This additional documentation is available upon request but has not been included for the 

purposes of testimony before this Committee. For more information on OneStar's policies and 

procedures please contact Liz@onestarf()(JD.<J_atLo~n_.org. 

CONCLUSION 

Chairman Guthrie, Ranking Member Davis, and Members of the Subcommittee, thank you for 

inviting me to speak to you today. It is an honor to be included in the discussion of strengthening 

national service accountability through various mechanisms including risk assessments, 

monitoring, protocols for criminal history checks and other critical points of compliance. OneStar 

is grateful for the support and guidance offered by CNCS as it allows us to more effectively serve 

our programs in Texas. AmeriCorps and Senior Corps programs are making considerable impact in 

communities across this country. They truly are a powerful force for good. 

12 
42 

Chairman GUTHRIE. Thank you for your testimony, Ms. Jeffrey, 

you are recognized 5 minutes to testify. 

TESTIMONY OF THE HONORABLE DEBORAH JEFFREY, INSPECTOR GENERAL, CORPORATION FOR NATIONAL AND 

COMMUNITY SERVICE 

Ms. JEFFREY. Chairman Guthrie, Ranking Member Davis, Chairwoman Foxx, Ranking Member Scott, and members of the subcommittee, thank you for the opportunity to testify today about the 

Office of Inspector General’s recommendations to strengthen grant 

oversight at CNCS. 

The OIG is an independent and nonpartisan unit charged with 

preventing and detecting waste, fraud, and abuse, and improving 

the efficiency and effectiveness of CNCS and its programs. 

My written statement describes the progress that CNCS has 

made since I last appeared before you 10 months ago. Today, I 

would like to describe significant challenges that remain. For the 

first time in my 5 years as inspector general, CNCS has the skilled 

leadership and experienced staff needed to make progress in the 

areas that have historically proven challenging. 

Criminal history checking, identifying and reducing improper 

payments, and developing robust, risk-based grant management, 

rapid improvements in these areas are needed to compensate for 

years of inaction and ineffective action. The first longstanding challenge that CNCS must tackle is strengthening grant risk management. Currently, the corporation continues to operate under legacy 

grant oversight protocols that my office has consistently found to 

be flawed. It relies heavily on a risk model that has never been 

validated. OIG’s preliminary analysis of grants with catastrophic 

outcomes found that half of them were rated as low or medium 

risk. 

Our audits and investigations often uncover serious problems not 

anticipated by CNCS’s risk assessment and we find that red flags 

were overlooked. CNCS has not done enough to learn from those 

bad outcomes. 

The current risk model omits fraud risk, although OIG has uncovered significant frauds. A few months ago, for example, investigators reported that the CEO of a for-profit business used a shell 

nonprofit organization to obtain grant funds from CNCS, which 

were funneled back into the business through a management services agreement. 

Ultimately, one-quarter of the RSVP program funds spent by the 

grantee were paid to the CEO’s for-profit business. Not a single one 

of the promised 176 volunteers was ever brought on board and no 

services were provided to the community. Proper risk management 

could have anticipated this. Related party transactions and common control between a prospective grantee and a for-profit business 

are the kind of red flags that should trigger close scrutiny. CNCS 

has not implemented OIG recommendations on this subject and 

even after the events of last year, including the hearing before this 

subcommittee, CNCS has not properly addressed the risk of prohibited activities or implemented the majority of OIG’s recommendations on that subject. As OIG has repeatedly recommended, CNCS 

must better understand and acknowledge its grant risks to achieve 

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43 

a more granular assessment of risk broken into components. The 

agency also needs a cafeteria approach to monitoring, developing a 

menu of oversight activities that are tailored to particular risks 

where financial risks predominate. Grant officers and not program 

officers should perform the relevant monitoring. 

Keeping our communities safe from harm is another urgent challenge. Congress wisely mandated specific criminal history checks to 

prevent convicted murderers and sex offenders from using CNCS 

programs to gain access to at-risk individuals. Far too many grantees do not conduct these background checks timely and thoroughly. 

Last year, depending on the program, 22 to 41 percent of individuals paid through CNCS grants served without complete and timely criminal history checks. The risk is real and immediate. Last 

week, OIG learned that a three-time convicted sex offender served 

for more than a year in the 

senior companion program where he visited elderly individuals in 

their homes. 

Several years ago, an audit discovered a murderer and a sex offender working on a social innovation fund grant. CNCS has not 

enforced these requirements effectively. The nominal fines for compliance are too low to create proper incentives and may actually 

backfire. 

Over a 6-month period, we determined that fines average less 

than 1 percent of the funds awarded by CNCS. That’s a small cost 

of doing business, not an effective sanction for recklessness. 

Mr. Chairman, this concludes my statement and I would be 

pleased to answer the subcommittee’s questions. 

[The statement of Ms. Jeffrey follows:] 

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Statement of Deborah J. Jeffrey, Inspector General 

Corporation for National and Community Service 

before the United States House of Representatives 

Committee on Education and the Workforce 

Subcommittee on Higher Education and Workforce Development 

March 28, 2017 

Chairman Guthrie, Ranking Member Davis, and Members of the Subcommittee: 

Thank you for the opportunity to testify today about the work of the Office of Inspector 

General (CNCS-OIG) to strengthen grant oversight and accountability at the Corporation for 

National and Community Service (CNCS or the Corporation). As you know, the OIG is an 

independent and nonpartisan unit charged with detecting and preventing waste, fraud and 

abuse and improving the efficiency and effectiveness of CNCS and its programs. I have had 

the privilege of serving as the Inspector General for nearly five years. 

Grant-making is CNCS's core activity, and grants account for three-quarters of the 

Corporation's annual budget of $1 billion. At any given time, CNCS must oversee more than 

2,100 active grants, ranging in size from $40,000 to $10 million, in seven programs that 

operate throughout the United States, its Territories and Indian Tribes. Grantees include 

well established national nonprofits, such as the Red Cross, major research universities, 

State and local governments and small community-based organizations that depend on 

CNCS for the majority of their funding. Not surprisingly, these grantees vary greatly in their 

capabilities, experience and infrastructure. All of this presents challenges for grant 

oversight. 

Today, I would like to update the Subcommittee on developments in CNCS's grant oversight 

since my last appearance. In addition, my testimony will describe the significant challenges 

that remain and explain how CNCS can meet them. 

Positive Developments 

of the Chief Risk Officer. Over the past four years, CNCS-OIG warned repeatedly that CNCS lacked the 

skilled leadership and experienced staff needed to 

Standing up the Office strengthen internal controls and risk management, and that these 

critical areas were severely under-resourced. The past year has seen dramatic 

improvements in this area. In April 2016, CNCS created the Office of the Chief Risk Officer 

(OCRO) at the executive level and hired my co-panelist, Lori Giblin, an experienced risk 

management professional, as its leader. OCRO is now responsible for areas that have 

historically proven challenging for CNCS: criminal history checking, identifying and reducing 

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improper payments, improving grant risk management, introducing Enterprise Risk 

Management to CNCS, and the testing and improvement of internal controls. 

Based on her needs assessment, the Office of the Chief Risk Officer now employs 17 staff 

members, with additional funds available to engage contractors, to support the rapid 

improvements that CNCS's leadership now recognize to be necessary. The oversight of this 

Subcommittee, statements accompanying appropriations bills in the House and Senate and 

the support of the Office of Management and Budget (OMB) were essential in persuading 

CNCS to devote this level of support to OCRO. 

Strengthening the Office of Grants Management. The Office of Grants Management 

(OGM) provides critical financial oversight of grants and is responsible for recovering 

misspent funds. CNCS-OIG has seen both cultural changes and increased capacity in this 

area. 

Bringing in leaders with substantial grant management expertise from other Federal 

agencies has created a more business-like and rigorous approach to financial accountability. 

OIG has observed greater willingness to hold grantees to grant terms and conditions, 

disallow improperly incurred costs and recover the funds promptly. 

CNCS has expanded the capacity of OGM by 43 percent, restoring staffing to the level 

needed for effective oversight. To cite one example, CNCS-OIG reported in 2016 that, 

although the Social Innovation Fund (SIF) had made grants then totaling some $241 

million, its entire grant portfolio was overseen by a single senior grant officer, who also 

had other supervisory responsibilities. CNCS now devotes three grant officers to 

oversight of the 51 F. 

OGM's increased capacity has produced immediate results. OGM has eliminated its 

backlog of management decisions and corrective actions on OIG audits and investigations. 

Increasing the timeliness of corrective actions and collection of disallowed costs improves 

accountability and reduces the vulnerability of particular grants. The expectations and 

messaging communicated by OGM to grantees support strong accountability. 

More sophisticated approach to internal controls. Under OCRO's leadership, CNCS has 

assessed risk across 19 business processes and are beginning meaningful compliance 

testing in the areas determined to be high-risk. These include procurement, purchase and 

travel cards and accounts receivable. This represents significant progress in an area 

repeatedly found to be weak in the Corporation's prior annual financial statement audits. 

Stronger cybersecurity. For years, our audits found significant deficiencies in the security 

of CNCS's information technology sysems. Over the last 18 months, the Corporation 

invested heavily in this area, and our 2016 cybersecurity audit reported substantial 

improvements. We no longer consider CNCS's IT security to be significantly deficient, and 

CNCS was not required to report a material weakness in cybersecurity in its annual report. 

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Though further work is needed to achieve full effectiveness, the progress in cybersecurity 

shows that CNCS can leap forward when it focuses its efforts. 

Continuing Management Challenges 

Strengthening grant risk management. To manage its extensive grant portfolio effectively 

and efficiently, CNCS must develop and implement risk-based grant management. This is 

the most critical challenge confronting the Corporation and is the single most important 

recommendation of CNCS-OJG that CNCS has not yet implemented. 

Instead, CNCS continues to operate today under most of the same monitoring protocols 

that my Office has found to be poorly designed and implemented. For example, routine 

grant monitoring failed to detect: 

• Fraud - Leaders of the national service program in American Samoa used national 

service funds to entertain themselves with lavish personal travel. They also bilked the 

taxpayers by charging inflated rents for broken down shacks owned by family 

members and falsely claiming that national service programs were operating from 

those locations. CNCS personnel conducted site visits annually while these frauds 

were occurring, but never discovered them. 

A community college claimed that its students were performing $4 million worth of 

community service when those students were merely completing the classroom study 

and clinical work required for their degrees. The $4 million expenditure provided no 

net benefit to the community. 

Perhaps it is not surprising that CNCS's grant monitoring does not discover such 

frauds, because the monitoring protocols contain few, if any, fraud prevention and 

detection measures. Until recently, leaders did not acknowledge that the 

Corporation's programs are subject to fraud risk and therefore did not identify, assess 

and mitigate those risks. 

• Widespread inadequacies grantees' performance of statutorily required criminal 

history checks intended to exclude murderers and sex offenders from national 

service- According to the Office of the Chief Risk Officer, between 22 and 41 percent 

of grantees do not conduct thorough and timely criminal history checks, potentially 

jeopardizing the safety of the communities served by CNCS programs. 

This risk is more than theoretical. Last week, my Office learned that a volunteer who 

had been convicted of three sex offenses served for more than one year in the Senior 

Companion Program, which works with the elderly in their homes. In 2013, we found 

a murderer and a sex offender working on a subgrant funded through the Social 

Innovation Fund. Instead of removing them when it learned of their criminal histories, 

the subgrantee allowed them to continue to work on the grant-funded program but 

paid their compensation with other funds. CNCS-OIG discovered this in an audit. On 

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the other hand, careful compliance by an AmeriCorps grantee last year enabled the 

organization to exclude a convicted sex offender shortly after he began serving. 

At one Senior Corps grantee, investigators discovered that more than 120 individuals 

were serving without proper criminal history checks. 

CNCS is doing more to find noncompliance and enforce the rules, but, as I discuss later 

in this statement, the problem is far from solved. 

• Prohibited activities - CNCS rarely learns of prohibited activities1 through its routine 

grant monitoring. Instead, the information typically comes from self-reporting by a 

grantee, a whistleblower call to the OIG hotline, or discovery in the course of 

investigating other allegations. As l testified ten months ago, CNCS does not currently 

identify grantees that are at risk of specific prohibited activities, nor does it have 

appropriate techniques to monitor those grantees' compliance. 2 

Last year's hearing arose from an investigation that found a major grantee to have 

allowed a subgrantee to violate the prohibition on using AmeriCorps resources for 

"abortion services or referrals for the receipt of such services." 42 U.S.C. § 

12584a(a)(9). CNCS-OIG recommended that CNCS explain clearly, definitively and 

transparently how it will interpret and apply this prohibition. Without such an 

explanation, program officers may provide incorrect and inconsistent direction to 

grantees, who remain unnecessarily at risk of violating the law, with severe 

consequences. 

In December 2016, CNCS's Office of General Counsel (OGC) prepared a written analysis 

of the abortion prohibitions. This is the first time that CNCS has reduced to writing an 

explanation of the restrictions and how they are to be applied. 

In other respects, however, CNCS has not implemented CNCS-OIG's 

recommendations.' OGC's advice was not transparent and has not been released to 

the general public. The AmeriCorps program has not translated the legal analysis into 

practical guidance for grantees, members and program officers. CNCS has not 

determined whether non-healthcare grantees may also present a heightened risk of 

abortion-related prohibited activities. Both logic and experience indicate that 

1 The national service laws forbid the use of national service resources for eleven categories of activity, including 

legislative advocacy; partisan and political activity; religious study, worship and proselytizing; strikes, boycotts 

and protests; pro- or anti-union organizing; abortion services and referrals; and supporting a for-profit business 

or organization. 42 U.S.C. § 12584a. 

2 For more detail, see Special Review: Prohibited Activities: Missed Opportunities, Red Flags Ignored and Next 

Steps to Improve Grants Management at CNCS (Dec. 21, 2016) at 

CNCS also needs to determine which of its grantees present a heightened risk of other prohibited activities. 

Faith-based groups, for example, face a higher risk of religious worship, study or proselytizing than do secular 

groups. 42 U.S.C. § 12584a(a)(7). Grantees associated with for-profit entities are more likely to run afoul of the 

prohibition on providing a direct benefit to such an organization. 42 U.S.C. § 12584a(a)(8)(A). CNCS has not 

implemented our recommendation to conduct such a risk analysis. 

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grantees serving children and youth and those serving immigrant populations are also 

points of contact for girls and women facing crisis pregnancies. 

CNCS also needs to develop better methods of detecting prohibited activities when 

they occur. Currently, CNCS monitors for prohibited activities by interviewing 

members during site visits. But those site visits may occur only once every six years, 

and they include only a fraction of subgrantees and service sites. CNCS has not 

implemented CNCS-OIG's recommendation to develop surveys that will enable more 

frequent contact with members. 

The shortcomings in CNCS's approach to prohibited activities illustrate the need for a 

disciplined, risk-based approach to all aspects of grant making, management and monitoring. 

There is a significant opportunity to improve stewardship, cost-effectiveness and results by 

strengthening the way that CNCS assesses grant risk and the way that it monitors and 

manages those risks. 

Currently, CNCS decides annually which grants it will monitor closely by assessing each grant 

according to a uniform set of 19 criteria, which it treats as risk indicators. It uses the same 

criteria across the entire agency, despite critical differences among CNCS programs and grant 

vehicles that bear directly on risk. The model omits significant risks identified in CNCS-OIG 

audits and investigations, and it includes no fraud indicators. (No one currently at CNCS can 

explain how the criteria were selected or why they are weighted as they now are.) CNCS uses 

this model to calculate a single risk score; a grantee that scores in the "high" range typically 

receives a site visit from a program officer, who goes through standardized steps prescribed 

by a "monitoring tool." 

As I told the Subcommittee 10 months ago, CNCS relies heavily on this model, but has never 

validated it against outcomes. The entire grant monitoring program still rests on assumptions 

that are untested. CNCS-OIG audits and investigations often uncover major problems at 

grantees that the Corporation rated as low or medium risk and therefore did not scrutinize 

closely. To take one example, a grantee rated as low-to-medium risk ceased operations and 

went bankrupt during the grant, owing CNCS over $1 million. A preliminary analysis by CNCSOIG of grants with catastrophic outcomes-filing for bankruptcy during a grant, ceasing 

operations mid-grant, or CNCS terminating the grant for cause-showed that half were rated 

as low or medium risk. A risk model that fails to warn of an impending catastrophe SO 

percent of the time isn't much good. CNCS has operated under this risk model for about ten 

years, with only modest tweaks along the way. 

Now that CNCS has an experienced Chief Risk Officer, supported by a robust staff and budget, 

it has the capacity to develop a more granular approach to risk. Doing so will enable CNCS to 

direct its limited resources (grant funds and staff attention) where they will have the greatest 

impact. Achieving risk-based grant management will require the following steps: 

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1. Identifying the risks associated with various kinds of grants and grantees, including 

fraud risk. Key question: what events or factors could impact performance, 

compliance and financial management of a grant?; 

2. Developing indicators that align to those risks. Key question: how could CNCS know 

whether those events and factors are likely to exist?; 

3. Assessing the individual risks presented by each grantee. Key question: what is the 

likelihood and potential impact of each of these risks? 

4. Mitigating risks. Key question: what could CNCS or the grantee do to reduce the 

likelihood that a risk will materialize or its impact?; and 

5. Developing oversight activities suited to particular risks. Key question: what is the 

most cost-effective way to monitor for the risk in question? 

The resulting risk model should inform every aspect of grant management throughout the 

grant lifecycle, including the information elicited in grant applications, whether to impose 

special conditions on a particular grant and selecting the appropriate monitoring activities. 

Risk does not exist in the abstract; when we say that a grantee is high-risk, it is at high risk of 

something, a particular failure, problem or bad outcome. By breaking grant risk into its 

component parts-financial, programmatic, compliance, etc.-CNCS can target its monitoring 

on the specific component or activity within a grantee that is high-risk. A grantee that 

presents a significant financial risk needs to be monitored for that risk, even it is low-risk in 

other respects. This would represent a significant improvement over the current single risk 

score and site visit approach, which is both underinclusive and overly broad: ( 1) 

underinclusive in that a grantee may present a high financial risk but escape monitoring if its 

overall risk score falls into the low or medium range; and (2) overly broad because a grant 

that scores in the high range will undergo the full range of site visit monitoring activities, even 

those that address risks that are de minimis for the particular grantee. Breaking grant risk 

into its component parts will make CNCS's monitoring more precise and effective and less 

wasteful. 

Risk-based grant management may also require changes to the CNCS's workforce and 

organizational structure. The type of risk presented should dictate who performs the 

monitoring. Where financial risks predominate, grant officers, who have extensive financial 

training, should conduct the necessary monitoring. Similarly, better risk assessments and 

risk-based monitoring may make it unnecessary for CNCS to maintain an office in every state 

to oversee Senior Corps grantees. Converting the smallest CNCS grants4 to a fixed-amount 

basis would simplify financial administration for the grantees and reduce the amount of 

oversight needed. 

4 RSVP grants average $75,000. Though the Senior Companion Program and the Foster Grandparent Program 

grants average more, $200,000 and $300,000, respectively, both programs award a number of small grants. 

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CNCS should also monitor by grantee, rather than by grant, as it now does. An increasing 

number of grantees participate in multiple CNCS programs, and those programs should be 

pooling information about grant risks. In 2013, VISTA made an award to a grantee one day 

after AmeriCorps terminated its relationship with the same grantee, because it refused to 

cooperate with corrective actions arising from a monitoring visit. The grants management 

database is not readily searchable by grantee, only by grant, so VISTA had no practical way to 

know that AmeriCorps found this grantee uncooperative. 

Strong risk management also requires a culture of continuous improvement. CNCS should 

institutionalize a structured process to determine the root causes of bad outcomes, including 

how they could have been prevented or detected sooner. Doing so would help to identify 

systemic gaps, develop new risk mitigation options and address human error appropriately. A 

good after-action analysis creates an opportunity to learn from mistakes and to use that 

knowledge to refine risk assessment and monitoring, to prevent errors from recurring. 

Criminal history checking. Ensuring the safety of the communities served by CNCS programs 

should be among the highest priorities of agency leaders. This requires that CNCS and its 

grantees prevent dangerous persons from exploiting grant-funded programs to gain access to 

at-risk individuals. Predators can do incalculable harm, and we know that many of them seek 

out opportunities to interact with vulnerable persons and may conceal their identities in 

order to do so. Vigilance in screening national service participants and staff is a moral, as well 

as a legal, imperative. 

Mindful of these risks, Congress mandated in the Edward M. Kennedy Serve America Act of 

2009 (the Serve America Act) that grantees exclude murderers and sex offenders from 

national service, prescribing specific sources that must be checked.5 For members or grantfunded staff that work with vulnerable populations-children and youth, the elderly or 

persons with disabilities-the grantee must check the National Sex Offender Public Website 

(NSOPW), the criminal history repository of the state in which the individual resides and the 

state in which s/he will serve, and secure a fingerprint-based from the Federal Bureau of 

Investigation (FBI). CNCS requires that the NSOPW check be completed before the member 

or staff begins service; the other checks must be initiated at that time, and the individual may 

not be alone with a member of a vulnerable population until the grantee receives results 

establishing that the individual has no disqualifying criminal history. 

Many grantees have difficulty performing the required criminal history checks (CHCs). Audits 

and investigations conducted by CNCS-OIG have consistently found high rates of 

noncompliance. Until recently, CNCS treated them as outliers and did not recognize the 

pervasiveness of failure to timely screen members and staff. As I mentioned earlier in my 

testimony, CNCS's monitoring did not uncover the severity of this problem. Since 2014, CNCS 

5 An individual may not serve in a national service position if s/he was convicted of murder; is a registered or 

registerable sex offender; refuses to undergo a criminal history check; or makes a false statement in connection 

with a criminal history check. 

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has taken a number of steps to increase compliance with this important safety measure, with 

limited success. In 2016, the Chief Risk Officer found that noncompliance in CNCS-funded 

grants ranged from 22 percent (AmeriCorps State and National) to 41 percent (RSVP). These 

numbers are consistent with CNCS's FY 2016 statistical analysis of improper payments. 

In the past year or so CNCS has begun to enforce these requirements consistently, but its 

enforcement approach remains flawed. Enforcement has onsisted principally of small fines, 

as low as $250 for a partial or grossly untimely check and $750 enrolling a member without 

any background check. These amounts befit a minor regulatory infraction-parking on 

private property carries a $250 ticket in the District of Columbia-and trivialize the grave 

harm that would result if a predator were to gain access to an at-risk individual in a CNCS 

program. Our review of penalties for a six-month period in 2016 found that the median 

sanction was only $1,500, on average less than one percent of the funding that the grantee 

received from CNCS. These nominal amounts undermine CNCS's messaging that criminal 

history checking must be a priority. 6 CNCS has just announced its intention to double these 

fines beginning next month, but they will remain so low that a grantee might reasonably 

dismiss them as a small cost of doing business. 

CNCS needs a better solution than expecting 2100 grantees, who experience frequent staff 

turnover, to check the criminal histories of tens of thousands of people each year. Given the 

widespread difficulties, and the resources that CNCS must now devote to CHC compliance and 

the related testing and recovery of improper payments, CNCS-OIG has urged CNCS to explore 

outsourcing criminal history checking to a vendor or vendors capable of performing the 

required CHCs. Doing so could radically improve compliance, relieve grantees of task that 

they do not perform well and enable CNCS to monitor compliance by direct contact with the 

vendor(s), far less burdensome than overseeing individual grantees. CNCS has agreed and 

charged OCRO with this responsibility. At our suggestion, the Chief Risk Officer has contacted 

the National Center for Missing and Exploited Children, which provided similar services to 

nonprofits for a number of years. The necessary contract action will take time, but it offers 

the best prospect we have seen to resolve this issue once and for all. 

Information Technology Modernization. Following a study confirming that its legacy 

information technology (IT) does not support robust oversight or operating needs, CNCS has 

undertaken a multi-year effort to upgrade the capabilities of its grants management database 

and systems. Successful completion of this modernization can greatly improve the 

effectiveness and efficiency of grant oversight. The effort is expected to cost approximately 

$43 million and is by far the largest IT investment since the creation of CNCS. To date, the 

project has cost $19 million, and CNCS may spend an additional $6- $7 million by the end of 

the current fiscal year. 

6 The risk of incurring any fine is small because most noncompliance goes undetected; CNCS visits only a fraction 

of its grantees in any given year and does not directly monitor subgrants. The sanctions are also 

disproportionately small relative to the cost disallowances by which CNCS routinely enforces non-safety-related 

regulatory requirements, such as timekeeping, expense recording and fundraising for match. 

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The modernization effort began in FY 2014 and consists of three phases: 

• Grants Management (Phase 1): Standing up a highly configurable platform to integrate 

the entire grant lifecycle (grants planning through the Notice of Funding Availability, 

review of grant applications, grant funding packet routing, grantee reporting, 

recording monitoring results and grant closeout) into a single data system. This 

should facilitate seamless use of grant risk information throughout the entire lifetime 

of a grant. 

• Member Management (Phase 2): This component includes member recruitment and 

acceptance, on boarding and off-boarding, training and orientation, member travel and 

member payroll management, as well as management of education awards from the 

National Service Trust. 

• Performance Measures and Analytics (Phase 3): Key projects include performance 

measures, data analytics, new mobile applications and services, as well as customer 

contact relationship management. 

Phase 1 is scheduled for release in October 2017, to be preceded by training for staff. No 

release dates or target completion dates have been established for Phases 2 and 3. Until 

completion of Phase 3, CNCS will remain unable to automate routine monitoring tasks, 

benchmark and perform other comparisons necessary for robust grant risk oversight. 

CNCS's original intent was to design the new grant management database and system in 

tandem with developing a new risk model, a task that CNCS put aside in FY 2015 for lack of inhouse capability. Consequently, these closely related efforts are not on parallel tracks, and 

the Office of Information Technology (OIT) does not have the new risk model to inform its 

development of the grant management system. OCRO and OIT have only recently begun to 

collaborate. Although the new system is intended to be flexible, CNCS may incur future 

delays and expenses in order to tailor the database to new risk management requirements. 

IT acquisition/development is inherently a high-risk area, with a high rate of failure. 7 The 

General Accountability Office (GAO) is currently conducting a study of CNCS's IT 

modernization project. We do not know when it will be completed. 

let me end by saying how much I and my staff appreciate the Committee's interest in 

improving CNCS's grant oversight and your support of our work. Mr. Chairman, that 

concludes my prepared testimony. I would be pleased to answer any questions. 

7 According to GAO, "federal IT investments too frequently fail or incur cost overruns and schedule slippages 

while contributing little to mission-related outcomes." Such projects often "lack[] disciplined and effective 

management, such as project planning, requirements definition, and program oversight and governance" and 

because the agency "ha[sl not consistently applied best practices that are critical to successfully acquiring IT 

investments. l:illJJ://www.gao.gov/highrisk(improving management it acquisitions operations/why did study 

9 
53 

Chairman GUTHRIE. Thank you for your testimony. The testimony is concluded. We will move into members’ questions. And 

first, I will recognize the chairwoman of the full committee, Chairwoman Dr. Foxx, for 5 minutes for questions. 

Mrs. FOXX. Thank you, Mr. Chairman, and I want to thank our 

witnesses for being here today and providing their testimony. This 

is an area that I have a great deal of interest in. 

Ms. Bawden, in summary, your report seems to indicate the corporation does not monitor the most at-risk grantees and does not 

have a staff properly deployed or educated to ensure that it is conducting oversight monitoring to find and deter fraud and misuse of 

public funds. Did I get that right or would you characterize it another way? 

Ms. BAWDEN. Thank you. Generally, that is correct. What GAO 

found is that the process the corporation uses to assess grants and 

prioritize them for monitoring does not necessarily result in the 

highest risk grants receiving the highest priority for monitoring. 

Mrs. FOXX. Why is it concerning the corporation does not even 

know what grantees truly pose a risk? 

Ms. BAWDEN. The corporation has limited resources to conduct 

monitoring and it’s essential that it focus those resources on the 

grants of highest risk. 

Mrs. FOXX. Thank you. One more question. In your report, you 

found the corporation’s grant-monitoring process is not fully 

aligned with the internal controls for identifying, analyzing, and responding to risk. Given this finding, can you be fully confident that 

the corporation administers the 750 million in grants in full compliance with the law? 

Ms. BAWDEN. No, I can’t be fully confident of that and the recommendations that we made are addressed to the corporation in 

the hopes that they will move in that direction. 

Mrs. FOXX. Thank you. Ms. Giblin, in its fiscal year 2017 Management Challenges report, the OIG listed reducing improper payments as a management challenge. In this context, challenge seems 

to mean a significant problem of the corporation. The OIG reports 

that according to your own sampling, the improper payment rates 

for the three SeniorCorps programs are extraordinarily high. In 

fact, your sampling found the rate of improper payments to be 34 

percent in the foster grandparent program, 23 percent in the retired seniors volunteer program, and 33 percent in the senior companion program, fiscal year 2016. Together this represents improper payments of $47 million or 30 percent of the SeniorCorps 

spending. Even worse, this is only the three SeniorCorps programs. 

You could not even estimate the rate of improper payments for the 

AmeriCorps State and national program, a much larger program. 

This is not a management challenge, but a management failure. 

Why should Congress and the taxpayers continue to provide 

funds for grants when a third or more of those funds are improperly disbursed? 

Ms. GIBLIN. Thank you for that question and I share your concerns. I have been working closely with the Office of Management 

and Budget as well as other Federal agencies to identify a testing 

mechanism, a methodology that will ensure that we can report 

CEWDOCROOM with DISTILLER

54 

with confidence to this body and to senior management on the rate 

of improper payment for our programs. 

I have been working with Federal agencies to identify best practices and driving down noncompliance. And my office is charged 

with all five aspects of risk management, including both the Improper Payments Program and the CHC Program, so that we can 

work in an integrated fashion to ensure that we are addressing the 

roots of noncompliance and working with our grantees to ensure 

that they have the tools necessary to effectively administer their 

programs. 

Mrs. FOXX. Thank you. Mr. Chairman and our ranking member, 

I will tell you, every time I come here and I am asked to spend 

money, I tell people I think about the hardworking taxpayers in my 

district who work very, very hard, play by the rules and give up 

their money to the Federal Government to provide for programs 

where they think we are going to make life better. 

This kind of fraud and abuse is not a good use of hardworking 

taxpayer dollars. And you know, I think the first thing we have to 

do is get rid of the word ‘‘volunteer.’’ You know, people making 

$29,000 a year are not volunteers. They are being paid, and so I 

think the very first thing we need to do is acknowledge the fact 

that these are not volunteers. And I have great respect for the 

ranking member, but I will tell you we should not waste a dime 

of hardworking taxpayer dollars and to excuse this kind of abuse 

and fraud is unconscionable. It is just unconscionable. Thank you, 

Mr. Chairman. 

Chairman GUTHRIE. I thank you for yielding back and the chair 

recognizes the ranking member, Mr. Scott, for 5 minutes for questions. 

Mr. SCOTT. Thank you, Mr. Chairman, Ranking Member Davis, 

and I would like to thank the witnesses for being with us today to 

testify about the benefits to our Nation from the Corporation of National and Community Services. Last year, 325,000 Americans 

serving through AmeriCorps and SeniorCorps invested 155 million 

hours of service to their communities in more than 50,000 locations 

across the Nation. 

In my district alone, over a million dollars in funding from CNCS 

and matching contributions supported 253 AmeriCorps and 

SeniorCorps members, supporting programs like the Virginia Peninsula Boys and Girls Club, which inspires and enables youth to 

realize their full potential. Four of these clubs are strategically located in public housing developments. The larger benefits of the 

AmeriCorps experience greatly exceeds its cost. In our corps member surveys, 79 percent of corps alumni say that their service was 

a defining professional experience. Fifty-nine percent of hiring 

managers believe that AmeriCorps alumni have the soft skills difficult to find in traditional job applicants for job openings, and 

more than 450 companies, including Disney, CSX, and Comcast, 

are prioritizing national service alumni in their hiring. 

An empirical study published by the Journal of Policy Analysis 

and Management found that AmeriCorps participants increased its 

members’ civic engagement, connection to communities other than 

their own, and knowledge about the problem facing the community. 

Older participants who are not at the beginning of their careers, 

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the report cites gains in health, self-esteem, life satisfaction, financial help, and civic capital resources. All these benefits I mentioned 

are reasons why there is a positive cost-benefit ratio of AmeriCorps 

to public benefit for every dollar invested. 

We have talked about one example of 10 hours that has been 

found to have been misspent and you have to put that in the context of 155 million hours at 1 percent of 1 percent of 155 million. 

One percent of 1 percent is over 15,000, so that’s not enough to call 

a hearing over. 

I would like to ask Ms. Darling, first of all, how sequestration 

has affected your ability to provide grants to eligible responsible 

applicants? 

Ms. DARLING. Thank you for that question, Congressman. When 

we see reduced funding, we may not be able to fund the same number of AmeriCorps positions that we had previously or we may also 

take—we may have limitations in some of the program dynamics 

and scope. We try to make sure that we hold the members in the 

programs harmless as much as we can when there is indeed a cut. 

Mr. SCOTT. And have you done an evaluation of the value on 

services for every dollar invested in the program? Because you are 

dealing with the volunteers and matching funds for every dollar invested in the program, do you know how much of a service is accomplished? 

Ms. DARLING. For each of our programs, there is a requirement 

for evaluation and that is commensurate with the level of funding 

that they receive. We are in—we just started an evaluation institute in Texas to teach our grantees how to evaluate the impact of 

their programs and calculate that return on investment for us, for 

a $14 million investment in our portfolio, over 31 million in matching and in-kind funds, and that is separate from the number of 

hours that they serve. 

Mr. SCOTT. Thank you. Ms. Jeffrey, you mentioned a fraudulent 

scheme where money ended up in a private account. What has happened to the individuals involved? 

Ms. JEFFREY. The individual and the organizations have been 

debarred and CNCS has made a demand for return of the funds. 

Mr. SCOTT. Were any criminal charges filed? 

Ms. JEFFREY. They were not. I believe it was because the amount 

did not accord with the prosecution thresholds in the particular jurisdiction. 

Mr. SCOTT. How much money was fraudulently diverted? 

Ms. JEFFREY. It was about $20,000. The total grant was 

$131,000. 

Mr. SCOTT. The way you described it, it appeared to be intentionally stealing the money and no criminal charges were filed? 

Ms. JEFFREY. That is often the case, that prosecutors elect not 

to file criminal charges, even when they have strong evidence of 

fraud, because they are too busy, they have other priorities. 

Mr. SCOTT. Mr. Chairman. 

Chairman GUTHRIE. Thank you for yielding back and I recognize 

myself for 5 minutes to ask questions. 

First, to follow up what Mr. Scott said for Ms. Bawden, we are 

talking about whether money is important. So your report raises 

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er the corporation has the right people and resources in the right 

place to effectively monitor grantees’ compliance with the law. 

Some people may argue the corporation needs more money, more 

staff to improve their monitoring, but your report seems to indicate 

that this is not about funding. Is that your opinion? 

Ms. BAWDEN. From GAO’s perspective, the question about funding is a little bit premature. It’s essential that the corporation first 

take steps to understand exactly what staff resources they would 

need to effectively oversee and monitor grants as well as sort of 

how the workload should be broken down across their programs. 

That question needs to be answered first before we can think about 

funding. 

Chairman GUTHRIE. Okay, thank you. And Ms. Giblin, the GAO 

report concludes the corporation’s protocols do not lead to appropriate oversight of subgrantees. In fact, this subcommittee has held 

a few hearings over the last few years on problems with subgrantees and I believe those hearings always highlighted the challenges the corporation has in effectively monitoring for compliance 

with the law. 

Your report released just last week demonstrates monitoring of 

subgrantees’ compliance with the law continues to be a weakness 

for the corporation. Taxpayers continue to see their money spent 

inappropriately. Can you give us a timeline when you would expect 

you could come back before this committee and tell us if all these 

challenges are truly behind you? 

Ms. GIBLIN. Thank you for that question. First, I’d like to say 

that CNCS, like other Federal grant programs, complies with the 

laws and the regulations governing oversight and monitoring in 

that we provide monitoring over the direct grant funds that we provide to grantees. 

In addition, we work closely with those grantees, especially if 

they are forwarding those funds to sub-recipients, to ensure that 

their monitoring tools are effective and efficient. We are working 

over the coming year to incorporate many of the GAO recommendations to ensure that we have a more robust risk analysis that incorporates all four aspects of basic risk category and we’ll ensure that 

we complete this work within the next 12 months. 

Chairman GUTHRIE. Thank you. So within the next 12 months. 

Ms. Jeffrey, the corporation oversees $750 million in taxpayer 

funds to support multiyear grants in several different programs 

that provide funding to more than 346,000 participants. 

The GAO report notes the process the corporation takes to assist 

their grantees creates ‘‘vulnerabilities for the corporation in its 

ability to meet Federal standards for internal control with respect 

to risk assessment, control activities, and monitoring principles.’’ 

In thinking about this and your previous work looking at the corporation, can you tell us whether you believe that taxpayers’ money 

is appropriately safeguarded and used within the requirements of 

the law? 

Ms. JEFFREY. As Acting Director Bawden stated a moment ago, 

I think there are serious vulnerabilities. The corporation does not 

have in place good systems and good mechanisms to ensure that 

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guarded, but the entire notion of a risk-based grant-monitoring program is intended to improve that. 

Right now, the corporation is too reliant on the honor system and 

that’s just not an effective internal control. 

Chairman GUTHRIE. Thank you. And I have completed the questions I had prepared, so I will yield back and I will recognize Ms. 

Davis 5 minutes for questions. Ranking Member. 

Mrs. DAVIS. Thank you, Mr. Chairman and Inspector General 

Jeffrey. If I could follow up with that because I think we obviously 

are seeing the chief risk officer, who has spoken here, as well as 

other changes based on the recommendation. So I wonder if you 

could—I heard what you just said, but I am wondering, are they 

on a path that you believe is going to address these concerns and 

what other specific recommendations would you give? 

Ms. JEFFREY. For the first time that I’ve seen, I think the corporation has built for itself the capacity to tackle these challenges, 

the capacity to review the way in which it monitors, to understand 

its risks, to create monitoring that will truly target those risks in 

an efficient fashion. 

That may require a different workforce. It may require a different structure to some of the programs and the matter in which 

they are overseen. I think they are at the very beginning of the 

right path. 

Mrs. DAVIS. If you look at the funding and the possibility that 

funding could be cut fairly dramatically, if not all together, I am 

wondering when you talk about the people who are overseeing this, 

is it the level of education, the skillset? Is it the idea? And I am 

looking at our panel and I am delighted to see that so many women 

are involved in this, but I also know sometimes that there is a 

sense that there are volunteers in some people’s eyes, perhaps, the 

level of—their work product is not something that we would see 

necessarily at a corporate level and yet it sounds like it should be. 

So where is that issue? And is it, in some ways, it is then a matter 

of funding and the ability to hire the very best in order to make 

this work and to acknowledge the role that the great, great percentage of people are contributing to their communities? 

Ms. JEFFREY. In a resource constrained environment, an agency 

needs to work smarter. There is a limit to how much harder you 

can expect people to work, but they can work smarter. 

CNCS, as it currently monitors risks, doesn’t concentrate its resources where the strongest risks are. I think it needs to understand that and make decisions about what risks it wants to focus 

on and how best to monitor them to make the greatest possible use 

of its existing staff. Some of that may require reconfiguring the 

workforce or building different skillsets, but I don’t think it’s the 

size of the staff that is the barrier here. 

Mrs. DAVIS. Not size, but perhaps the ability to work in that environment. And, Ms. Giblin, could you speak to that as well in 

terms of resources and, again, what we are looking for in terms of 

the individuals who are heading up those kinds of organizations? 

Ms. GIBLIN. Well, first, let me share with you that with regard 

to resources, the CNCS management team has made a concerted 

commitment to risk management at the organization ensuring that 

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I have the resources that I need to effectively manage the risk and 

the five components that we oversee. 

In addition to the staff that we’ve been able to hire, we are expediting our reviews in the most critical areas, by augmenting with 

industry leaders in the areas of internal controls and grant risk assessment. But I agree that internal controls in any organization 

need to be both effective and efficient, and efficiency is what should 

drive the work in an organization that has limited resources. And 

I look to partner and employ the recommendations provided by 

GAO to ensure that we were able to do that. 

Mrs. DAVIS. Maybe, Ms. Darling, could you just respond to that 

as well because obviously you are in a position that really sees a 

great deal and knows how things are working? 

Ms. DARLING. I think managing these large programs is a challenge and I think it’s not a matter of who is exactly at the helm, 

but the skillset that each leader has. Organizational effectiveness 

is all about, I think, structuring the right people in the right positions in order to leverage a workforce that has limited resources. 

At OneStar Foundation, we have made a choice to limit the number of grantees that we have. We may grow our programs, but we 

only have 26 programs, but more boots on the ground so that our 

grants and program officers will have a set number of monitors and 

monitoring and risk assessments to make. So that’s one way that 

we make sure we are using our limited resources effectively. 

Mrs. DAVIS. Thank you. And I think I was hearing from everyone 

that you believe that it is very important to manage those risks, 

but that there is great benefit as well? 

Ms. DARLING. Oh, absolutely. 

Mrs. DAVIS. Thank you. 

Ms. DARLING. Thank you. 

Chairman GUTHRIE. Thank you. The gentlelady yields back. 

There is a competing meeting going on with some Republican members, so if it’s okay with you, we can go out of order and to recognize Mr. Courtney since we have kind of an imbalance on this. So 

Mr. Courtney, you are recognized for 5 minutes. 

Mr. COURTNEY. Thank you, Mr. Chairman, and I appreciate 

again your courtesy. And I would like to just say that I know the 

chairman; we have served together for a number of years. And, you 

know, the focus of the hearing today, which is about trying to make 

this program operate better. I think you would have total, 1000 

percent support on both sides of the aisle that we need to come up 

with, whether it is legislative initiatives or again, the oversight 

function as a way of trying to make sure that these dollars are 

spent appropriately. But, obviously, we are in a different setting 

here today, which is we have a budget which we submitted today, 

the Skinny Budget, so called, for 2018, which proposes to just completely obliterate AmeriCorps. And so I have wanted to spend my 

5 minutes just to focus a little bit in terms of just another perspective, which, again, is a picture that I put up, which is of a 

SeniorCorps program, again, organized through AmeriCorps up in 

Eastern Connecticut, which is a veterans coffeehouse program. 

Again, the SeniorCorps program has organized three different locations. It is the most sort of sparsely populated part of ConCEWDOCROOM with DISTILLER

59 

necticut. And as the picture shows, we have got a great contingent 

up in Norwich, Connecticut, which, again, meets on a regular basis. 

Again, it is an opportunity, first of all, to socialize because there 

is a lot of social isolation issues which, again, I think AmeriCorps 

and SeniorCorps identified in the region, which is important to try 

and break through, but also, frankly, it is a great opportunity for 

folks to connect with the VA system because it is an opportunity 

to get speakers. The guy in the far right in the picture there is my 

veterans’ caseworker. He is a 30-year submarine force veteran, 

Manuel Menesis, who, again, has connected veterans through the 

coffeehouse program with hearing aids, with medical appointments, 

with disability claims, medal recovery. 

Again, there is a value here that I think is also important for all 

of us as members of Congress to recognize that the AmeriCorps 

program which, again, basically has a force multiplier that costs 

the taxpayer virtually nothing with volunteers to organize these 

types of events. 

So Mr. Chairman, I have five actually recent articles talking 

about the great success that SeniorCorps has accomplished and it 

is a program which, frankly, is now being emulated in other parts 

of the country. My Republican predecessor, Rob Simmons, who is 

a colonel in the Army and served in Vietnam, is quoted in one of 

the stories, talking again about the great work that these coffeehouses are being done. 

And again, we are in a place right now where a budget proposal 

could just completely and totally eviscerate this type of, I think, 

positive, very efficient use of taxpayer dollars. So, Ms. Darling, in 

your testimony, you again sort of cited some of the great success 

that SeniorCorps in particular is doing in Texas, so I was just wondering if you could sort of talk about that in terms of, again, the 

larger picture here about what we are talking about. 

Ms. DARLING. I think we all know that effective use of taxpayer 

money is important. And in Texas, we certainly know that government can’t do it all and government partners with nonprofits to get 

their work done, but we have seen AmeriCorps and SeniorCorps 

volunteers work alongside those nonprofit organizations and actually expand their reach and to be able to do things that they could 

not otherwise do. 

Of course, disaster response is one of the largest areas. The State 

of Texas is the most disaster-prone State in the country, according 

to FEMA. If it weren’t for SeniorCorps volunteers, the recovery 

after the fertilizer explosion in West would have been seriously 

hampered. There was nothing left, but SeniorCorps volunteers living in the community knew how to mobilize and how to set up volunteer reception centers and then manage more volunteers in order 

to help the residents begin to rebuild. 

We’ve seen the same across the State with mentoring and tutoring programs. Communities in Schools, College Forward, Teach For 

America are all AmeriCorps members. If it weren’t for them, these 

organizations that many of us support but may not recognize as 

AmeriCorps programs are able to serve far fewer young people and 

they do provide a consistent presence in the lives of the children 

they tutor and mentor and make a tremendous difference in our 

state. 

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Mr. COURTNEY. Thank you. And again, Mr. Chairman, as I said, 

I think we are all prepared to help you in the effort to try to make 

this program work as effectively as possible. But, again, we do not 

want to throw the baby out with the bathwater, so I would just 

again ask for permission to submit the articles regarding the veterans coffeehouse. 

Chairman GUTHRIE. Without objection, so ordered. 

Mr. COURTNEY. And I yield back. 

Chairman GUTHRIE. Thank you. Thank you for yielding. I now 

recognize Mr. Thompson for 5 minutes for questions. 

Mr. THOMPSON. Chairman, thank you and thank you for this 

hearing. This is an important topic and I think that we are exercising our oversight responsibilities in doing that because nothing 

sanitizes better than sunlight, so having a hearing and being able 

to talk about these issues. And let me just say, I have watched 

great results of the programs that we are talking about. 

Am I impacting the folks in my congressional district? I have a 

friend, Melissa McHugh, that is an AmeriCorps employee. She actually works with the intermediate unit. She is responsible for all 

over Pennsylvania, spreading the good news on Raise.me. If you do 

not know what that is, look it up. It is an incredible program and 

Melissa is doing a great job of really reaching out to kids to help 

them plan for their higher education. 

That said, though, I heard my colleague say though it is not that 

much money and everything is hunky dory. Well, they did not use 

those words, but kind of we do have a responsibility. We have a 

fiduciary responsibility. I have a responsibility to the 2,824 participants in my congressional district in this program, make sure we 

are getting it right and to all the more than 730,000 taxpayers that 

we are getting it right. 

And someone said we are not spending that much money, I have 

to tell you that program is in the 5th District based on one report 

here, they total, if you add in potential educational awards to 

AmeriCorps members, it is almost $3 million in just my congressional district. That is a chunk of change and I think we have a 

fiduciary responsibility to make sure that we are getting it right 

for everybody, for all involved. 

So my first question, Ms. Giblin—first of all, thank you for your 

leadership and dedication to improving the operations of the corporation. What would you say your main challenge is when it 

comes to assessing or reporting improper payments? And in your 

opinion, why has it taken the corporation so much time, so long to 

work towards a system of accurate reporting? 

Ms. GIBLIN. Thank you for that. I think one of the main challenges we did experience in past years was staffing resources dedicated to our improper payment testing and, quite frankly, identifying an alternative sampling methodology with which we can instill confidence in OMB that our reporting would be robust. And I 

am happy to say that I am ahead of schedule in developing an alternative sampling methodology with the Office of Management 

and Budget and hoping to submit my request for such a methodology within the coming days, 30 days ahead of schedule from when 

I am required to submit that. I was able to bring on additional staff 

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cording to improper payments regulations on to my team, and I am 

looking forward to rolling this testing methodology out this year 

and reporting with confidence the results of the end-of-year of assessment in our annual financial report. 

Mr. THOMPSON. Well, thank you for your leadership and thank 

you for bringing what I would describe as that discipline to our accountability process because we do need to get right. 

Ms. Jeffrey, in your testimony you described instances where individuals with dangerous criminal records were participating in 

and being compensated for their service and various programs, volunteer programs specifically. You stated that this program this 

problem was far from resolved, which is rather frightening. In your 

experiences as inspector general, is this a widespread problem 

across similarly structured organizations or is this issue unique in 

nature, and what is the main reason for this to occur? Is it a lack 

of awareness, lack of resources, lack of accountability, or something 

different? 

Ms. GIBLIN. To me this is an issue of priority. In all too many 

of our grantees, they leave the criminal history checking, which requires some detail orientation and some care, to low-level administrative staff. They treat it like it’s a routine administrative regulatory requirement and not a critical safety measure, and it doesn’t 

get supervised by the senior leadership in some of our grantees. I 

think we need to elevate its importance and it needs to be treated 

as a make or break activity. 

Mr. THOMPSON. Thank you very much. Chairman, my time is 

waning so I’ll yield back. 

Chairman GUTHRIE. I thank the gentleman for yielding and I 

recognize Ms. Adams for 5 minutes for questions. 

Ms. ADAMS. Thank you, Mr. Chairman and Ranking Member 

Davis, for the opportunity to discuss the immense value that the 

Corporation for National and Community Service plays in communities across the country, and I want to thank all the witnesses for 

your testimony and your experiences with working with CNCS. 

In the 12th District of North Carolina that I represent, CNCS 

and the volunteers they empower make a significant mark. Volunteers help serve food and supports to 500 homeless individuals 

daily. AmeriCorps VISTA volunteers have developed, implemented, 

and expanded programs to help provide homeless individuals with 

skills and training. AmeriCorps members serve in a variety of capacities in public schools across Charlotte, providing important 

support to students and teachers. 

And further, CNCS provides over 140 teachers single education 

awards and loan deferment as they work in classrooms, impacting 

thousands of students in low-income schools. I know that the 12th 

District of North Carolina feels the benefits of CNCS on a daily 

basis, yet the President’s budget proposes eliminating funding for 

CNCS, stripping communities of these critical services. Cutting 

educational funding, research, and service is not putting America 

first. It’s putting America last. 

My first question, Ms. Darling, for every $10 CNCS provides 

States, States are able to leverage $15 from private funders. As 

former COO of CNCS, without the Federal investment in national 

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service, do you think that Americans will have the opportunity to 

engage in meaningful service at this scale? 

Ms. DARLING. Thank you for that question. I do not believe they 

would be able to participate in meaningful service at the scale that 

the corporation allows because there is a structure that allows for 

the recruitment and training and management of thousands of volunteers beyond just each AmeriCorps member’s year of service. 

Ms. ADAMS. Is that private-public partnership helpful for States 

and would States be able to leverage that much funding without 

the CNCS grants? 

Ms. DARLING. It is my opinion that States would not be able to 

leverage that additional funding for where would it come from if 

it were not from private philanthropic dollars? And the beauty of 

the AmeriCorps program is that when these Federal dollars go to 

grantees, our subgrantees, for example, Communities in Schools is 

a popular one, they are then able to use the AmeriCorps presence 

to get additional philanthropic dollars because it’s a recognized investment and absolutely makes a difference to their bottom line. 

Ms. ADAMS. Thank you. What are some of the benefits that you 

have experienced with this model both during your time as COO 

and on the State Service Board of Texas? 

Ms. DARLING. Well, I can speak particularly to my service at 

OneStar National Service Commission. We could not even begin to 

make a dent in the issues related to children at risk and those that 

are performing below grade level in just the city of Austin in Travis 

County without AmeriCorps members in at least 32 schools working with children. It’s an early childhood intervention that teachers 

do not have time to do by themselves that allows a resource that, 

frankly, for not—if not for our funding of those programs, we would 

have outcomes for our children that are far less than what we 

would like. 

Ms. ADAMS. So in your opinion, budget cuts would drastically impact the ability to be responsive? 

Ms. DARLING. Absolutely. 

Ms. ADAMS. Thank you very much. Mr. Chair, I yield back. 

Chairman GUTHRIE. I thank the lady for yielding and I now recognize Mr. Grothman from Wisconsin for 5 minutes for questions. 

Mr. GROTHMAN. Ms. Giblin, first of all, how many people work 

for your organization overseeing these programs? 

Ms. GIBLIN. The staff within the Office of the Chief Risk Officer 

comprises 17 individuals. 

Mr. GROTHMAN. Pardon? 

Ms. GIBLIN. Seventeen staff are in OCRO. 

Mr. GROTHMAN. Okay. A lot of times, all these things, you know, 

you are giving out these grants. When I was involved with organizations in the past that give out grants or that live on grants, they 

spend an awful lot of time applying for the grants, I mean, just 

kind of a scary amount of time, not really getting their mission 

done. Did you ever look into see how much time is spent in your 

organization that you are giving grants to or their subgrantees? Is 

that a concern? 

Ms. GIBLIN. Is the question have we researched the amount of 

time it takes our grantees to complete a grant application? 

Mr. GROTHMAN. Right, that sort of thing. 

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Ms. GIBLIN. My office does not analyze that. 

Mr. GROTHMAN. Okay, with regard to AmeriCorps, how much are 

people making to work for AmeriCorps? 

Ms. GIBLIN. I don’t have the specific dollar amounts, but it is a 

nominal living allowance. 

Mr. GROTHMAN. What is a nominal living allowance? 

Ms. GIBLIN. In the range of—depending on if it’s full-time, part- time service, no more than $500 a month. 

Mr. GROTHMAN. Okay, and do you have anybody managing the 

program full time? 

Ms. GIBLIN. The AmeriCorps program within the CNCS headquarters is managed with a robust staff that is full-time. These 

grantees are managed by individuals that are dedicated to the 

oversight of the CNCS AmeriCorps grant on the ground within the 

grantee itself. 

Mr. GROTHMAN. How much are those people making? 

Ms. GIBLIN. I don’t have that figure in front of me. I can provide 

that at a later time. 

Mr. GROTHMAN. Are they making six figures? 

Ms. GIBLIN. I couldn’t estimate. 

Mr. GROTHMAN. Okay. Ms. Bawden, your report says the corporation conducts limited monitoring of grantee oversight of your subgrantees. What concerns do you have with the limited nature of the 

current subgrantee oversight protocol and do you believe the corporation’s current system leaves taxpayer dollars at risk? 

Ms. BAWDEN. With respect to the subgrantees, what we found is 

that the corporation collects limited information across programs, 

on how its grantees are overseeing subrecipients, particularly with 

respect to criminal history checks, and we recommended that the 

corporation collect more information to assure itself that those 

criminal history checks were being consistently conducted. 

Mr. GROTHMAN. Okay, percentage-wise, how many of the dollars 

do you think are really spent by the grantees and how many by the 

subgrantees? Do you know that? 

Ms. BAWDEN. In fiscal year 2015 about half of the grant awards 

were passed through the subrecipients. 

Mr. GROTHMAN. Okay, Ms. Giblin, we will ask you again. As part 

of the review, the General Accounting Office requested a list of 

2015 grantees from the corporation and you guys wound up providing 3 grants ranging from 2,477 to 2,807 organizations. That is 

kind of a big difference in numbers. In light of the difference, GAO 

found your information unreliable. The taxpayers trust you to administer $715 million in grants. How can you effectively monitor 

grants if you cannot even produce a reliable number, a reliable list 

of the active grants that the corporation is administering, and have 

you changed the procedure since that time? 

Ms. BAWDEN. The procedures that resulted in the numbers that 

you provided really are based on the IT system, the antiquated IT 

system that we had been relying on for that information. 

I am happy to report that the agency is undergoing a complete 

IT modernization effort that will provide us with a platform that 

is known in the private and the public sector for its robust data 

analytics, and we’ll be able to provide more reliable data going forward. 

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Mr. GROTHMAN. I guess I would think even if we did not have 

computers, you would know how many grants were going out, but 

do you know how many grants are going out now since this request 

was made? 

Ms. BAWDEN. On average we manage a grant portfolio of about 

3,000 grants. 

Mr. GROTHMAN. Okay, so more than any of the numbers that you 

gave us in the past? 

Ms. BAWDEN. The information that GAO provided comprised 

those grants that were received as an assessment. We do our assessment in the summer of each year. Grants are fully awarded by 

September 30th, so the number will fluctuate. 

Mr. GROTHMAN. Okay, and what are the dollar amounts from the 

grants? What are the lowest grants? 

Ms. BAWDEN. Grants range from 40,000 to the millions. 

Mr. GROTHMAN. Okay, $40,000. I always kind of wondered about, 

that’s the type of small grant I have wondered about given the time 

it takes to process it, the time it takes for you to monitor, do you 

think it is worthwhile for you to get involved in a $40,000 grant? 

Ms. BAWDEN. Again, as I shared with the committee earlier that 

a proper internal control framework for any organization, whether 

it’s the Federal entity or a grantee with whom we invest, should 

be both effective and efficient, and efficiency should drive— 

Mr. GROTHMAN. I have one more quick question. One more quick 

question? 

Chairman GUTHRIE. Really quick. 

Mr. GROTHMAN. Okay. As you know, we are very broke in this 

Federal Government and sometimes people focus on what is the 

Federal Government’s purpose and is it under our Constitution 

something that the Federal Government should do? It seems to me 

that this is such a wide open program, covering so many different 

things, it is like we just gave you a bunch of money and said find 

something to do with it. 

How do you justify the Federal Government, at a time when we 

are so broke, just giving out grants kind of to anybody under the 

sun? Does that ever bother you? Don’t you think it should be perhaps something handled more appropriately at the local level? 

Chairman GUTHRIE. Real quick, a 5-second answer. 

Ms. BAWDEN. We invest heavily in the communities that Congress has mandated that we work in. Many of them are distressed, 

serving some of the hardest and most difficult to serve populations, 

and so an investment in this organization is actually an investment 

in the communities in which all of us serve. 

Chairman GUTHRIE. Thank you. I am going to have to switch 

from here, so I thank the gentleman for yielding back. And I’ll now 

recognize Mr. Sablan, 5 minutes for questions. 

Mr. SABLAN. Thank you very much, Mr. Chairman. And, Ms. 

Giblin, I liked your last statement that you work in distressed locations. And I must confess that any program whose mission is to improve lives, strengthen communities, and foster civic engagement 

through service and volunteering is a program I like. And the Corporation for National and Community Service is active in my district, in the Northern Mariana Islands, providing valuable community service for many years now. Our public school system has been 

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a regular beneficiary of AmeriCorps grants that fund that help dozens of high school students, provide tutoring and mentoring services to at-risk elementary and middle school students every year. 

The student volunteers also support teachers and other students 

in implementing quality service learning projects to meet unmet 

needs in the community. 

The program members reap many benefits, I must agree, including professional on-the-job experience and a little bit of money, 

funds, to help pay for college. We are very poor people and the 

knowledge of knowing that they are making a positive impact in 

the lives of others. 

In August of 2015, the Northern Marianas were struck by a devastating typhoon, causing widespread damage the likes that most 

of us have never seen. It destroyed the homes of thousands of residents, leaving the main island of Saipan without electricity and 

running water for months afterwards. 

We continue to rebuild to this day and services provided through 

AmeriCorps has proven to be an indispensable part of the recovery 

effort. 

The AmeriCorps VISTA project, through carried out social services, supports post disaster recovery and resiliency efforts. Together 

with the local commonwealth advocates for recovery efforts, CARE, 

AmeriCorps’ VISTA members are addressing the long-term recovery needs of many residents and have helped provide safe and secure housing for over 350 families. 

These AmeriCorps VISTA members have served over 3,000 volunteer hours, leveraged more than 110,000 of in-kind resources, 

and raised $300,000 in financial resources. They have also worked 

to assess the Island’s available food programs to design and implement a sustainable food bank. 

AmeriCorps and AmeriCorps VISTA members have proven to be 

an integral part of our island community, in our schools and in our 

homes. It has been shown that for every $10 in Federal funds appropriated, CNCS grants have raised$15 from private sources, the 

very essence of a successful private-public partnership that our 

friends in the majority like to commend. And I know that there are 

problems, but we are not shooting for perfect here. We are trying 

to find the good, I must say, as it has been said this past week or 

so about another program. So instead of eliminating the CNCS as 

the President proposed, this Congress should provide robust funding for these valuable services. 

Ms. Darling, I think the Committee Ranking Member Bobby 

Scott alluded to in one of his questions the President’s recently released budget and how it eliminates entirely the Corporation for 

National and Community Service. I sincerely hope that does not 

happen, but even reductions, and he says sequestration, in funding 

can have serious effects. How will budget cuts affect the ability of 

CNCS to be responsive to needs on the ground? 

Ms. DARLING. We look to CNCS to participate in their robust 

trainings and avail ourselves of resources that they have online 

and with our program and grants officers. We have a very close relationship with them because they are our funder and we are their 

grantee. We, in turn, use those tools with our subgrantees in order 

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to manage risk assessment and monitoring programs so that we 

can have programs that have impact and outcomes. 

Mr. SABLAN. Okay, thank you. I am going to go and risk—my 

staff hates me for doing this at times, but I am going to risk and 

I am going to ask a question of Dr. Jeffrey, inspector general. Do 

you find enough reasons or causes or findings in your opinion because what you have, you issue opinions, do you find enough reason in your opinion to close the program entirely? Yes or no? 

Ms. JEFFREY. It’s not appropriate for an IG to weigh in or— 

Mr. SABLAN. I am asking you, you are here as a witness, I am 

asking you yes or no. 

Ms. JEFFREY. That is simply not a question that’s appropriate for 

me to address. 

Mr. SABLAN. But you do issue opinions? 

Ms. JEFFREY. We issue reports. 

Mr. SABLAN. You issue reports that are based on your opinions. 

Ms. JEFFREY. We issue reports— 

Mr. SABLAN. Even licensed accountants acknowledge that they 

issue opinions. 

Ms. JEFFREY. We issue reports that are based on investigations 

and audits. They are not based on opinions. 

Mr. SABLAN. Thank you. 

Chairman GUTHRIE. I let that run over a little bit to try to get 

balance back, so let us try to stick to the 5 minutes just to be fair 

since we went over a little bit on one. Okay, now Mr. Mitchell, you 

are recognized for 5 minutes for questions. We’ll try to stick to the 

5. 

Mr. MITCHELL. Thank you, Mr. Chair. Ms. Jeffrey, the chairman 

highlighted some of the background check issues that you have 

identified that, in fact, despite the requirements and training, selfassessments and all kinds of activities you have taken, the failure 

to complete background checks adequately is extraordinary. Twenty-two percent of AmeriCorps and State programs, the national 

program failed background checks; they didn’t have them; 36 percent in the foster grandparent program; 40 percent in the senior 

companion program; and 41 percent in retired seniors volunteer 

program. 

I have to say, you know, I spent 10 years coaching youth hockey 

and USA hockey had a pretty simple requirement. You had to do 

a criminal background check before you set your foot in the ice or 

the locker room. Lacking that, you did not coach. It did not seem 

to be tricky and had about 100 percent compliance because the insurance would say they could not cover them. 

So could you tell me why it is so hard and what we do about it? 

Because that is a pretty fundamental issue. You have got people 

that are with children that 36 percent of them did not clear criminal background checks. What are we doing about that? 

Ms. JEFFREY. Let me be clear, it’s not that 36 percent didn’t clear 

a background check. It’s that complete background checks were not 

performed. 

Mr. MITCHELL. Thank you. 

Ms. JEFFREY. Or not performed timely on 36 percent. So the public is exposed to a great risk. 

Mr. MITCHELL. Sure. 

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Ms. JEFFREY. By interacting with people whose background 

checks are unknown. To me, the biggest concern is that CNCS’s enforcement mechanism does not seem well designed to tell grantees 

you must make this a priority. The system of fines that are imposed are simply too small to make a difference. If you had a teenager who was driving recklessly, you would not take away 1 percent of his allowance. 

Mr. MITCHELL. I would take away the car, thank you very much. 

I guess that leads me to the next question. It is not a 1-year phenomenon; this has been a multiyear phenomenon with some of 

these agencies, yet they continue in their existence despite their 

failures. 

Ms. JEFFREY. This is ongoing. I think for a very long time, the 

corporation did not realize or did not acknowledge that they had 

a comprehensive problem. It was only when they were required to 

undertake improper payments testing that, that testing as a byproduct revealed the extent of this criminal history checking problem. And since then, the corporation has been sort of doing the 

same thing and hoping for a better response. We will provide better 

education, we will do more training, we will give you a chance to 

come into compliance, and an amnesty, and then hope that you’ll 

do better going forward. The problem is that those interventions 

don’t seem to have worked or they haven’t worked enough. 

Mr. MITCHELL. I guess I have a concern that we are going to give 

you a chance to come into compliance when you are talking about 

the foster grandparents program, for example. How many chances 

are you going to give them? How many chances are we going to 

take with children when you have failures to complete? Ms. Giblin, 

why don’t you weigh in here because I am concerned with how 

many chances are we going to give them? 

I have a 6-year-old. If they were involved, how many chances are 

we going to give them? 

Ms. GIBLIN. I appreciate your concern and I, too, am a parent 

who has these concerns. In the 6 months that this program has 

been under my purview, we have already doubled the disallowed 

costs to better align it with the priority that we give this program. 

Mr. MITCHELL. Let me stop you. What is the disallowed cost? 

Ms. GIBLIN. The amount that we would be charge for— 

Mr. MITCHELL. How much is that? 

Ms. GIBLIN. It ranges anywhere from $250 to $1,500. 

Mr. MITCHELL. To how much? 

Ms. GIBLIN. Two hundred and fifty to fifteen hundred dollars. 

Mr. MITCHELL. Now, if I did a quick poll in the audience here 

of anybody in this group and said, now, we are going to penalize 

this out for $250 to $1,500 if this person does not have the criminal 

background check completed, does that concern you if they are 

interacting with your children, what do you think the response 

would be in this audience? What would your response be? Are you 

happy with that? 

Ms. GIBLIN. Thank you for that. My response, more notably, 

would be that, again, in the 6 months that I’ve had this program, 

I’ve already worked with management on developing a— 

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Mr. MITCHELL. All due respect, Ms. Giblin, that does not answer 

my question. My question is, are you satisfied with that as a parent? 

Ms. GIBLIN. I am committed to ensuring that this these disallowed costs align with the agency’s priorities for this program. 

Mr. MITCHELL. Why would we allow that to continue multiple 

years? I mean, this is a pretty fundamental thing if these people 

are involved, vulnerable populations. Why do we allow that to happen year over year and not simply say we need someone that is 

going to do the job properly? Why would we do that? 

Ms. GIBLIN. Most notably, I think what we are doing right now 

is identifying the root causes for the noncompliance to ensure that 

our grantees have the tools necessary. 

Mr. MITCHELL. How about the root causes? If they are not running very professionally, we should find someone that is. 

Ms. GIBLIN. For a number of our grantees, they can’t even access 

the State repository checks that are required to complete a final 

check. 

Mr. MITCHELL. All due respect, my oldest son is a police officer 

and it is not that hard to complete a criminal background check, 

and I had to do one every year, so that is an excuse. You know the 

difference between an excuse and a problem? A problem comes 

with possible solutions; an excuse is a justification for the status 

quo. It is not acceptable. It puts children and vulnerable people at 

risk and that ought to be a fundamental requirement of the program. 

I yield back. Thank you, sir. 

Chairman GUTHRIE. Thank you. Thank you for yielding. I now 

recognize Mr. Takano for 5 minutes for questions. 

Mr. TAKANO. Yes, I do want my friends on the other side of the 

aisle to understand that this member does take the committee’s 

oversight rule very seriously, so I think when there is an agency 

that is not performing as well as we like and the inspector general 

has raised, I think, some serious issues, and Ms. Giblin is trying 

to respond to those—you came on to the job just 6 months ago, is 

that correct? 

Ms. GIBLIN. The CHC program was given to me as part of my 

management responsibility about 6 months ago. 

Mr. TAKANO. So the risk management, managing the risk. So my colleague from Pennsylvania gets $3 million worth of services 

through this agency and I think about a million to my agency, 

about 88 AmeriCorps programs. I did not quite hear, and I do not 

want to be unfair to him, I did not hear him conclude that he, 

therefore, wants to see the entire program zeroed out because of 

the concerns raised. I mean, $3 million is an awful lot. I mean, it 

is three times as much as my district. And I certainly hope that 

none of my programs are suffering from some of these issues and 

I do hope, Ms. Giblin, that we are going to get the service programs 

on track and it sounds like—but it has been a 20-year program, but 

I wonder if there might be some fundamental issue with the design. 

The design of the program was to allow for maximum flexibility 

and I know that Republicans—and this is not a bad thing—I am 

not trying to cast dispersions, but they did insist that very minimal 

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contact with the Federal agency and individual volunteers. There 

is a whole series of intermediaries, whether it is a State grantee, 

a State organization that is appointed by the governor. So there is 

a Federal system involved here and they wanted it was designed 

for maximum flexibility at the local level. Is that not correct, Ms. 

Jeffrey? 

Ms. JEFFREY. I’m glad you asked that question because I think 

it points at one of the challenges. So much of the oversight, particularly in the AmeriCorps program, is performed by the State service 

commissions, the 52 that exist throughout the United States. Some 

of them do a great job of oversight of their grantees, others do not. 

And the difficulty is that CNCS doesn’t always have good visibility 

into who is doing a great job and who really needs to do better. The 

problem is that we can’t be sure that tiered oversight is actually 

working effectively. 

Mr. TAKANO. So the federalized nature of how this bill was designed, oversight might not have been thought through very carefully and the Federal agency might not have been very clear about 

what a task it is to oversee all these State agencies. 

Ms. JEFFREY. I’m not sure that’s correct. 

Mr. TAKANO. Okay. 

Ms. JEFFREY. I think the agency has been fairly clear that it— 

what it expects the commissions to do. It doesn’t always do a good 

job of knowing whether they’re doing what they’re expected to do. 

Mr. TAKANO. Is there— 

Ms. JEFFREY. And beyond that— 

Mr. TAKANO. Is there an authority problem? Is there a leverage 

problem with being able to get these State agencies to kind of take 

these concerns seriously? 

Ms. JEFFREY. I don’t know whether I’d call it a leverage problem. 

I think there is an accountability problem with the willingness to 

hold the States accountable. I think some of these risks are such 

that they ought to be monitored directly. While the statute contemplates a system of tiered oversight, there is nothing in the statute that would prevent CNCS from monitoring directly which 

grantees and which subgrantees are complying with proper criminal history checking. 

Mr. TAKANO. Well, my general sense, after listening, and I am 

listening to all sides here, my own opinion is that I would hate to 

see this, as one member said, throw the baby out with the 

bathwater. I, too, could read testimonials from people in my district 

about the great things that have happened here. The gentleman 

from Pennsylvania, also, in fairness, recounted great things that 

were happening in his district. He told a story about that. 

So my sense is that I would hate to see us zero this program 

completely out. I would like to get the accountability right and if 

we could take a deeper dive into that rather than have this be a 

kind of all of us telling the great stories and then—and I don’t hear 

members on the Republican side uniformly saying that we—that 

they agree with zeroing this out. So my hope is that we can get 

the accountability correct. And I thank the inspector general for 

her hard work. 

Chairman GUTHRIE. Thank you. I thank the gentleman for yielding back and now recognize Mr. Lewis for 5 minutes for questions. 

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Mr. LEWIS. I would like to thank the chair. Ms. Giblin, I want 

to start with you. You said a moment ago that you thought the 

grants amounted to around $500 a month. You were guessing, you 

didn’t have the figures in front of you on some of these. 

Ms. GIBLIN. Exactly. 

Mr. LEWIS. 1993, as I understand it, AmeriCorps combined 

VISTA and NCCC, correct? And that was one of the provisions of 

the 1993 law? 

Ms. GIBLIN. I’m sorry, I don’t understand. 

Mr. LEWIS. In 1993, AmeriCorps brought together VISTA and 

NCCC, correct? 

Ms. GIBLIN. That’s correct. 

Mr. LEWIS. All right. And if you take a look at the grant specifically with some of these programs, especially AmeriCorps, you 

thought they were around $500 a month. I have got data here that 

shows the grant set about $11,800 per year plus a $5,300 stipend 

for education. 

Ms. GIBLIN. The amount I was estimating was just the monthly 

stipend. You are right that they also receive an additional education award. 

Mr. LEWIS. But you are at $500 a month and I have got them 

higher. Can we look into that and get an actual number? 

Ms. GIBLIN. We can. 

Mr. LEWIS. Because if you add up the educational stipend and $11,800, you are looking at $17,000 a year for community service. 

You are not going to get rich off that, but it is not $500 a month. 

I want to go into an area here that I do not think we have 

touched on and, and frankly, I do not know that there is really 

good information, so I genuinely ask this question. And that is 

there have been—oh, by the way, one more thing on the funds. The 

Office of the Inspector General did find out that the National Civilian Community Corps cost taxpayers 4 to 8 times more money and 

that the NCCC members’ 10 months of service cost $29,674. 

Ms. GIBLIN. The cost associated with the NCCC program is vastly different than that of AmeriCorps or SeniorCorps. 

Mr. LEWIS. But those figures, that number is not obviously 

monthly stipends. That is the cost to administer the program and 

everything. 

Ms. GIBLIN. Yes. 

Mr. LEWIS. All right. 

Ms. GIBLIN. It is a residential program, to be clear. 

Mr. LEWIS. All right. And that is what has been alluded in some 

areas of the media and I am not certain they are true. I am genuinely asking the question of you and the Honorable Ms. Jeffrey as 

well, and that is the political activism associated with some of 

these groups, specifically AmeriCorps and their association with 

groups like ACORN. And, again, I am not trying to make political 

points. I am trying to get to the bottom of this. 

We can all quote the famous Jefferson quote about tyranny is 

being forced to fund the propagation of other people’s ideas. And 

there is a Supreme Court Finley case, and the Solomon case, it said 

that the Federal Government may rein in speech in certain cases 

if they are funding it, but regardless of the legal aspects, just as 

a matter of policy, why would we allow that? I mean, why would 

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we take money from liberals or conservatives to fund political activism, if indeed that is happening? 

Ms. GIBLIN. The agency takes a strong position with regard to 

prohibited activities, which is, I believe, what you are addressing. 

We have a multifaceted approach to ensuring that our grantees 

and our members individually understand their rules and responsibilities and the rules governing prohibited activities. In fact, we 

are providing a training today and our southern regional conference to ensure that everyone understands clearly their roles and 

responsibilities. 

Mr. LEWIS. And those roles and responsibilities are what? 

Ms. GIBLIN. To not engage in prohibited activities. 

Mr. LEWIS. To not engage in what? 

Ms. GIBLIN. Prohibited activities. 

Mr. LEWIS. Prohibited activities, including political activism? 

Ms. GIBLIN. It’s one of the prohibited activities. 

Mr. LEWIS. Ms. Jeffrey? 

Ms. JEFFREY. The law expressly forbids engagement in political 

activism, partisan or nonpartisan, and any form of legislative advocacy. 

I know that there were, at some times, concerns about that happening. Certainly during my tenure, we have not seen that. 

Mr. LEWIS. And what are the penalties for that if someone or 

some group or someone receiving a grant is engaged in that? 

Ms. JEFFREY. That’s up to the management when they act on a 

particular investigation. 

Mr. LEWIS. And you say you have not seen it recently? Does anyone have any evidence to say it has never gone on? 

Ms. JEFFREY. We’ve received no reports of it occurring. Or actually we did receive one report. It turned out to be unfounded. 

Mr. LEWIS. All right. I yield back my time, thank you. 

Chairman GUTHRIE. Thank you for yielding. I now recognize Mr. 

Espaillat for 5 minutes for questions. 

Mr. ESPAILLAT. Thank you, Mr. Chairman. My question will be 

directed to Elizabeth Darling. There are thousands of AmeriCorps 

members serving in New York City, a number of whom serve in my 

congressional district. They are essential, a locally based part of 

addressing important community needs for the most part. 

Next week, April 4th is the Mayor’s Day of Recognition for national service and nearly 4,000 bipartisan mayors from around the 

country have registered to participate. This is an overwhelming 

display of local support for this particular program. I appreciate 

the critical need for effective oversight, but let us not lose the sight 

of the critical work and bipartisan support for national service programs in all our States and districts and the leveraging of private 

resources that national service funding enables. For example, in 

my district, the operation of AmeriCorps, which partners with the 

New York City Department of Education and the Henry Street Settlement, matches senior companions with homebound seniors, desperately rely on their services, so this is critical to the district. 

Ms. Darling, coming from the State of Texas, very different from 

New York City, of course, can you talk about how local AmeriCorps 

programs in Texas use national service to engage the community, 

leverage additional private funds, and support key local services? 

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What will be the loss in our communities and with our locally 

based organizations if we lose AmeriCorps or CNCS? 

Ms. DARLING. In Texas, we have 2,400 AmeriCorps members in 

26 current programs. Some serve full time, some part time in 

schools, in mentoring programs, in tutoring programs. They are 

working in the Rio Grande Valley, pairing college students with 

seniors in high school, helping them apply to college, and 3,300 of 

5,000 were recently accepted. We have several programs that also 

mentor those young people in college through college completion. 

It’s not just enough to be accepted, but we want them to be graduates as well. 

And the same is true at the other end of the spectrum. Many 

programs that are dealing with kindergarten, first grade, and second grade, bringing them up to reading level and with very effective evidence-based programs. Our Texas Conservation Core is absolutely an invaluable resource in the State of Texas, working 

closely with our Division of Emergency Management and ready to 

deploy within hours of any number of disasters. If we did not have 

that resource for the State of Texas to help mobilize and train and 

manage volunteers, set up volunteer centers and long-term recovery centers, which long-term recovery, as you know, Congressman, 

goes on for years, we would drastically have a different environment within the State of Texas. 

And your mention of Mayor and County Day of Service on the 

4th, in Texas last year we had 522 commissioners, mayors, and 

elected officials, judges on both sides of the aisle that recognized 

the service in our State on that day. 

Mr. ESPAILLAT. So these are critical services in education, higher 

education, emergency preparedness that strengthened the safety 

net for thousands, if not millions, of families in the State of Texas. 

We are happy to hear that and I am glad to see that the program 

is yielding some good fruit. And although we may face some issues 

with it, overall it is a good program for communities across the 

United States. And I yield back the remaining part of my time, 

thank you so much. 

Chairman GUTHRIE. The gentleman yields back. Now please recognize the gentleman from Florida, Mr. Rooney, for 5 minutes of 

questioning. 

Mr. ROONEY. Thank you, Mr. Chairman. We taxpayers trust this 

Corporation for National and Community Service to administer 

$750 million in some kind of effective and accountable manner. In 

2015, the GAO requested a list from you all of grants that you have 

done and it ranged from some 2,400 to over 2,800 by my math and 

it is not really all that good being from Oklahoma and Florida. But 

that is a 14 percent difference, which equates to $100 million out 

of that $750 million. 

Now, that is a lot of money and I am curios, Ms. Giblin, if you 

can show us with all that how you can effectively monitor grants 

if you do not even know how many grants you have done and 

where the $100 million might have gone. 

Ms. GIBLIN. Thank you for that question. As I shared with the 

committee earlier, the difference in numbers that were provided to 

the GAO were with regard to the time that the census of grants 

was taken. Our antiquated IT system that we had at the time to 

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help us get that data analytics and get that information to GAO 

is being replaced by a much more robust and more fulsome IT modernization effort that is providing us with the best-in-class data 

analytics platform from which we’ll be able to provide the types 

of—the numbers that are necessary to better assess our grant portfolio. 

Mr. ROONEY. So given this $100 million discrepancy, Mrs. 

Bawden and Mrs. Jeffrey, perhaps, do you think that the CNCS 

leaves us at risk? And can you assure us that this money was not 

wasted and that more money had not been wasted? 

Ms. JEFFREY. What you’ve pointed to is a serious problem with 

data validation inside the corporation. In 2014, a study was performed by the Mitre Corporation, and one of the things they found 

was these serious discrepancies between what should be identical 

information in multiple systems. It was not, in fact, identical and 

it led to some of the problems that you’ve identified. 

We’ve encountered the same problem in our work. What has happened over the past year is a very serious scrubbing of the data so 

that as the new system comes online, the data it will have will be 

valid. I don’t think that we really have money that’s missing. I 

think we are looking at records that are just not internally consistent. 

Mr. ROONEY. Thank you, ma’am. 

Ms. BAWDEN. As Ms. Giblin noted, the data that we looked at 

was with respect to how many grants the corporation assessed to 

determine their priority for monitoring and we received some inconsistent information with that and that data request. We did 

make a recommendation to ensure that the corporation assesses all 

of the grants it expects to be active in the coming fiscal year to 

make sure that it understands their risk and effectively monitors 

them. 

Mr. ROONEY. Thank you. So the inspector general recently made 

it clear that they think the CNCS lacks ‘‘sufficient expertise and 

has not devoted the level of resources necessary to detect millions 

of dollars of improper payments. These improper payments are reporting high-dollar overpayments that failed to complete a costbenefit analysis for the receipt of payments.’’ So, Ms. Giblin, how 

can you assure us that this money is being spent well? 

Ms. GIBLIN. Again, as I shared earlier that I am working closely 

with the Office of Management and Budget to ensure that I have 

a more robust testing methodology that will be implemented this 

year to ensure that we have the information we need to more accurately and report with confidence the improper payment rate for 

the agency. I am also happy to share that I have also met with a 

number of Federal agencies to garner best practices in not only the 

reporting and testing methodologies, but in the strategies to address noncompliance. 

Mr. ROONEY. Thank you. Have you levied any penalties or fines 

or anything on any of these grantees that have failed to do the 

background checks or have used the untested assumptions or have 

not made sure that the payments that they dispersed were proper? 

Have you penalized those folks any? 

Ms. GIBLIN. With regard to the annual improper payment testing, we do recall any improper payment that we identify and disCEWDOCROOM with DISTILLER

74 

allowed those costs and we are in the process of recovering those 

costs right now. With regard to the CHC program, we do have a 

disallowance policy. 

Mr. ROONEY. So do you ban them from future grant applications 

and things like that? 

Ms. GIBLIN. We work with them closely on a corrective action 

plan and to retrieve disallowed costs. If grantees are compliant 

with a corrective action plan and do repay those costs, we are amenable to continue working with the grantee. 

Mr. ROONEY. That will never happen in the private sector. Thank 

you, ma’am. I yield my time. Thank you. 

Chairman GUTHRIE. Gentleman yields back. Now please recognize the gentleman from Colorado, Mr. Polis, for 5 minutes. 

Mr. POLIS. We want to thank our witnesses, thank you, Mr. 

Chair. This is the second hearing we have had on the Corporation 

for National and Community Service in the same year and I had 

the opportunity last hearing to share some of the good work CNCS 

is doing to my district. 

Again, I want to highlight some of the work of the agency that 

is near and dear to the heart of my constituents. And as many of 

you know, my State, Colorado, had a state of emergency in 2013 

after experiencing the most damaging floods in our State’s history. 

Several people in my district lost their life, hundreds lost their 

homes and everything they had, and many more suffered significant damage. 

Thanks to the CNCS, though, volunteers were deployed to Colorado to help in the aftermath of the flood. I got to meet and work 

with and volunteer with many of those volunteers. In total, over 

700 national service members came to our State and their work involved volunteering donations management, staffing call centers, 

coordination of medical mobility rides, community relations, meal 

services, debris removal. I got to see them doing all sorts of things. 

My first question for Ms. Darling is can you share more about 

CNCS’s work with natural disaster recovery efforts, like the floods 

in Colorado? Because that is an area that a lot of people do not 

know that CNCS is involved with. 

Ms. DARLING. Yes, thank you for the opportunity to talk about 

disaster response and AmeriCorps in Texas, and I will include 

SeniorCorps in that as well. 

We have 2,400 members in our portfolio for our commission. We 

expect the majority of them to be trained at some level in disaster 

response and they know—the programs know that we may call 

upon them in times of disaster. We have a dedicated disaster core, 

the Texas Conservation Core, that is trained and ready to deploy 

at any moment. They also have a fee-for-service model and were 

deployed after Hurricane Sandy, after numbers of disasters across 

the country. 

Mr. POLIS. Can you name a few of the other disasters that they 

were deployed to help with? 

Ms. GIBLIN. Well, in the State of Texas, the Memorial Day flooding, Halloween flooding on Halloween, two separate Halloweens 

two years apart, the Bastrop fires in 2011; 2013 fires, wildfire in— 

May I borrow my notes for a moment ? There are so many in 

Texas. 

CEWDOCROOM with DISTILLER

75 

Mr. POLIS. I want to thank you for that answer. I also want to 

highlight a story from an AmeriCorps member in Fort Collins, Colorado, in my district, Alex Grimm. Alex said ‘‘During the school 

day, I work one-on-one with students in grades kindergarten 

through third grade, who are reading below grade level. I then 

work with teachers to administer reading interventions that help 

students to attain their grade level reading.’’ And Mr. Chairman, 

I would like to submit Alex Grimm’s full remarks for the record, 

if I may. 

Chairman GUTHRIE. Without objection. 

Mr. POLIS. And to me, this kind of investment really helps 

AmeriCorps make an impact on its volunteers, whether they are at 

schools or whether they are doing disaster recovery work, which we 

are just so grateful for when I met the AmeriCorps reinforcements 

during what was really our biggest tragedy and natural disaster in 

my life. 

My next question for Ms. Bawden is in your testimony you highlighted GAO’s recommendations to improve CNCS and I think everybody wants to improve the work. Now, as several of my colleagues have mentioned, President Trump’s budget actually eliminates CNCS. If CNCS were to face significant budget cuts, how 

would that impact your own ability to implement the recommendations that are provided in the GAO report? 

Ms. BAWDEN. Thanks for your question. Several of the recommendations that we made seem to be underway and are not necessarily resource-intensive, but we did not evaluate the cost of implementing the recommendations. 

Mr. POLIS. Yeah, and so I think if the goal is to actually implement some of those GAO recommendations, we have to be cautious 

about some of the obvious. If the agency is eliminated, they will not 

be able to be implemented, but even under severe cuts they will not 

be able to. 

I also wanted to go to Ms. Darling to highlight, for the final 

minute, work about AmeriCorps’ education and programming work 

in schools that you have seen and kind of the impact that you have 

seen that they have on kids. 

Ms. DARLING. Thank you for that question. In my oral testimony, 

I talked about a program in the Rio Grande Valley of Texas, which 

is a vastly underresourced area of poverty, Colonias along the border. The University of Texas Rio Grande Valley has AmeriCorps 

members that are working with seniors in high school and helping 

them reach college access. Out of 5,000, 3,300 were accepted to institutions of higher education. Those kinds of programs are happening throughout the State, in Houston and in Austin, and not 

just acceptance to college, but college completion. 

We know that they are never going to get that far in the beginning unless we also help with them, kindergarten, first grade, second grade, to help them stay on reading level. And our presence 

in the schools, with Communities in Schools or others of our grantees, absolutely augment the resources that public education are 

able to give to these children. 

Mr. POLIS. Thank you and I yield back. 

CEWDOCROOM with DISTILLER

76 

Chairman GUTHRIE. The gentleman yields back. Now please recognize this gentleman from Georgia, Mr. Allen, for 5 minutes for 

questions. 

Mr. ALLEN. Thank you, Mr. Chairman and the Honorable Ms. 

Jeffrey. In your fiscal year of 2017 Management Challenges report 

you highlight the need for the corporation to commit to cultivating 

a culture of accountability and the progress that Office of Grants 

Management has made towards this goal. However, you cite the resistance from staff and grantees still entrenched in the prior permissive culture. Can you elaborate on what you mean by permissive culture and what reforms you believe they need to bring about 

a culture of accountability to the entire corporation? 

Ms. JEFFREY. I think empowering the Office of Grants Management has been very important. I will say that over the past 6 

months, we have seen an increased willingness to disallow costs 

that were improperly incurred. Often, when there is a proposal to 

do that, the program objects and wants to find some way to allow 

those costs. I think empowering the Office of Grants Management 

to be able to say no and to make a final decision has been very important. 

Right now, of course, the program heads are political appointees 

and so one major way to change the view of the programs towards 

this is based on who is appointed to lead those programs going forward. 

Mr. ALLEN. So you say this has happened in the last 6 months 

that we have been under this empowerment process? 

Ms. JEFFREY. I think it has gone on probably over the last year 

or so, but I think we’ve really seen the result increasing over the 

past 6 months. 

Mr. ALLEN. What preempted this process? I mean, what caused 

this to happen? 

Ms. JEFFREY. I think the committee’s oversight had a lot to do 

with it. 

Mr. ALLEN. Okay, all right. So it was questions like this. Do you 

believe that we need to change the way that grants are awarded 

to ensure guarantees better understanding of the requirements of 

active partners in overseeing the use of taxpayers funding? 

Ms. JEFFREY. I don’t think lack of understanding is the problem. 

I think it’s lack of emphasis and priority. 

Mr. ALLEN. All right. Ms. Giblin, in their report, GAO stated that 

the corporation does not ensure program officers are offered or received professional development in key areas. Specifically, GAO 

sites that program officers in the AmeriCorps stayed in a national 

program office generally did not receive professional development 

or fiscal monitoring even though it is a core responsibility of their 

grant monitoring responsibility. 

How can program officers effectively monitor grants if they do 

not have the essential knowledge to do so? What is the corporation 

doing to ensure all employees involved in grant monitoring have 

the knowledge and skills to effectively monitor grants? 

Ms. GIBLIN. Well, CNCS has, in the year that we have been undergoing the GAO audit, has reassessed its training program and 

has dedicated considerable funds to ensure that program officers 

and grants officers alike have received necessary training. SpecifiCEWDOCROOM with DISTILLER

77 

cally, with regard to fiscal oversight, our grants officer staff have 

benefitted greatly from enhanced training dollars to ensure that 

they are certified in the field which they serve. 

Mr. ALLEN. What kind of results have we seen from this effort 

so far? 

Ms. GIBLIN. I think that some of the successes that the IG has 

cited with a continued and robust commitment to ensuring that the 

oversight is provided, that costs are disallowed and recovered, and 

that we are working in a more effective and efficient manner. 

Mr. ALLEN. Is everyone fully on board with this requirement of 

education and how long will it take to get folks up to speed on 

where they need to be? 

Ms. GIBLIN. I know the agency is fully on board with ensuring 

that we are dedicating limited resources to the training protocols 

for the agency and, to date, I have seen evidence of that. 

Mr. ALLEN. Okay, well, thank you for your testimony here today 

and thank you for what you do for us. I yield back. 

Chairman GUTHRIE. Gentleman yields back. I am pleased to recognize the gentleman from California, Mr. DeSaulnier, for 5 minutes of questioning. 

Mr. DESAULNIER. Thank you, Mr. Chairman. And I do want to 

thank the chairman and the ranking member for having this hearing. 

Last weekend, the Oversight and Government Reform Committee, we had a very good bipartisan hearing on recommendations 

by the business community that regularly oversees the Department 

of Defense budget and they identified $125 billion of waste in that 

budget. I would remind members that in the Skinny Budget, one 

of the reasons why we would be—why the administration wants to 

eliminate the budget for this program, which I think is incredibly 

valuable, is to move that money to the Department of Defense. So 

we have to consider both our committee assignments and the expertise we develop, but also the larger budget as it applies to all 

citizens. 

And I would just say it is striking for me to have been in that 

last hearing and hear such a bipartisan approach to finding out 

where we can enforce the McKinsey report that was part of the recommendations to the Department of Defense to make sure that 

they do not waste money. 

But in this instance, it seems like, Mr. Chairman, that this is 

more of a partisan issue, which I really think it should not be. If 

you believe in a program, which I do in this program, and I can 

cite local instances of it working at least anecdotally, we want the 

best oversight. 

So, Ms. Jeffrey, you mentioned about the tiered approach and 

maybe that does not work, less of a tiered approach with the Department of Defense since there is more direct spending and it is 

Federal spending. But I know coming from local government, we 

have had issues when I was in local government and State government with Head Start programs, with community block grant programs, with workforce investment boards being administrated 

properly, either in terms of the oversight in the Federal region, 

having the proper oversight, or at the State level or at the local 

level or at the grantee level. 

CEWDOCROOM with DISTILLER

78 

All of that dynamic, we are hoping to come together to make a 

program work. CCDBG, in particular, when that works, it works 

really well and I have seen it not work well and I have seen some 

political influence where the auditors at the local level and the 

State level basically cover themselves to the Federal audit. 

So what I want to do is make sure that we are both—having 

come from the restaurant business, we used to say that there were 

really good gross operators and good net operators, and you want 

to be both. 

So you mentioned that State commissions; some do better than 

others. It certainly sounds like a subjective analysis or judgement. 

How do we get the high-performing States to bring the low-performing States up? Or was it your implication that this tiered system does not work in this instance? 

Ms. JEFFREY. I don’t recommend throwing out the tiered system, 

but I think your inclination that the application of good business 

risk management principles is absolutely the way to go. 

CNCS is always going to have limited resources, cannot provide 

the same level of oversight to every grant. But at the same time, 

you don’t need to oversee a $40,000 grant the way you oversee a 

$10 million grant. So risk management helps you decide where best 

to deploy those resources. 

I think there has been a number of efforts to bring peer-to-peer 

knowledge to bear with grantees with State commissions like Ms. 

Darling’s to help educate others. The difficulty is that different 

States commit different levels of resources to their commissions. 

We have one State commission that has a single employee. No matter what, that person is not going to be able to bring the same level 

of oversight as a well-resourced commission. 

Mr. DESAULNIER. I am sure California is right there at the top 

with Texas. 

Ms. JEFFREY. California actually is. 

Mr. DESAULNIER. Of course. I would not ask that question or 

make that observation if I did not know the answer. 

So, Ms. Giblin, it strikes me, and just a quote from GAO report, 

their second observation, we have found that CNCS’s current process for grant monitoring is not fully aligned with Federal internal 

controls for identifying, analyzing, responding to the risk. So what 

is your timeline to come into compliance and what is your corrective? How do you interact with both the committee, but also the 

GAO and the inspector general, so that you are reviewing this so 

we know that you are both acting in good faith to correct it and 

that you have a timeline to complete that? 

Ms. GIBLIN. Thank you for that question. I recently brought on 

staff who are well-versed in risk management and risk assessment 

and I am augmenting that staff with additional consultants, thirdparty objective consultants, who can bring industry knowledge to 

the organization as we work to implement the recommendations 

from the GAO. I do enjoy a collaborative work relationship with the 

IG and will be seeking her input, as I have in the 11 months that 

I’ve served at the corporation, and would be happy to report back 

progress to this committee in any fashion that you would see fit. 

CEWDOCROOM with DISTILLER

79 

Mr. DESAULNIER. Well, I think considering the budget recommendation, a timeline with a sense of urgency would be very important for the commission. 

Ms. GIBLIN. Understood, and we are presently working on a 12- 

month timeline. Thank you. Thank you, Mr. Chair. 

Chairman GUTHRIE. The gentleman yields back. I would like to 

again thank our witnesses for taking the time to testify before the 

subcommittee today. And now I am pleased to recognize Ms. 

Adams for any closing remarks that she may have. 

Ms. ADAMS. Thank you, Mr. Chair, and thank you all for sharing 

your testimony today. CNCS plays an invaluable role in communities across the country. I think we have heard that today and, 

as a matter of fact, heard it several months ago as well. It helps 

harness the talent and the skills of the American volunteer, helps 

to connect Americans with volunteer opportunities to fit local 

needs, and builds off of public-private partnerships to make a difference. And, indeed, it has made a difference as CNCS continues 

to strengthen its oversight program. 

I know that CNCS will improve its monitoring and better serve 

our Nation, and so I am pleased to continue to support the program 

and would encourage Congress to robustly fund service programs 

and not eliminate them. Thank you so very much for being here. 

Chairman GUTHRIE. Thanks to the gentlelady. As I had made in 

my remarks, I mean we should always be pushing ourselves to do 

better. Congress, this body has not just an authorizing responsibility, but an oversight responsibility, and so I really do appreciate 

the chairman and the ranking member providing this opportunity. 

I appreciate all of you being here to share your perspectives. 

My colleagues, Democratic colleagues, said that this hearing was 

about a previous single incident of wrongdoing. In fact, this hearing 

is about the corporation’s record over a number of years as an inability to protect the taxpayer dollars and monitor those dollars in 

a risk-based fashion and collect improper disbursements, and that 

hurts the participants when we do that. It detracts from the mission and our purpose with this program. As the chairman and others noted, there was $47 million in improper payment in just 1 

year at SeniorCorps. 

Now, having sat through this hearing and listened to my colleagues, I think we have a bipartisan agreement that one of the 

most important functions that this committee has is oversight. And 

I think, I am hoping, just as I appreciate the great work that has 

been done over the past 6 months and hoping this oversight hearing will serve continuous down that path of increased accountability and program effectiveness and the investment of the taxpayer dollars and the—because I know there are great programs 

out there and we need to do that. We will continue to hold the 

agency accountable for how it spends taxpayer dollars. It is nothing 

personal. It is just what our responsibility is. 

And so I do want to thank all the members and the witnesses 

and as well as the staff on both sides of the aisle because—with 

the hard work of the staff that help us to be able to do these types 

of hearings. 

Without objection, there being no further business, the subcommittee stands adjourned. 

CEWDOCROOM with DISTILLER

80 

[Additional submissions by Mr. Courtney follow:] 

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6, 10:00 PM Updated Mar 6, 2015 at 10:00 

DANIELSON The Thames 

a space org;anizers 

camaraderie among former service members. 

the council's Retired and Senior 

is 

volunteer \vill he open twice 

14 in the cafeteria and kitchen at the Broad 

Danit~LS<)n, RSVP Coordinator Kline said. 

coffeehouse \vill be a where vets can 

COJ!1n,ect with one another and build cmmara~jeJ~ie, 

common issues and " he said. "And even those this is 

all ages, this is also of the 

Kline said a recent U.S census found 3,700 veterans in 

northeastern 25 of them are 6o or older. 
81 

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Kline, a Woodstock resident and U.S. Army veteran, said his group is 

enlisting the support of oflocal veterans' groups including American 

Legion, Am Vets and VFW members, as well as municipal, state and 

federal leaders. Kline said the coffeehouse will provide conversation 

and serve as an information clearinghouse, providing veteran-related 

resource information to visitors and their families. 

At a glance 

The Thames Valley Council for Community Action's Veterans Coffeehouse will 

be open from 9 a.m. to noon on the second and fourth Tuesday of each month 

beginning April14 at the Killingly Community Center, 186 Broad St. in 

Danielson. 

A special presentation on the Flying Tigers pilot group is scheduled for 10 a.m 

March 24 in the center's theater. For more information, contact Greg Kline at 

(860) 774-9286 or at gkline@tvcca.org. 

"There's a lot of information out there, including benefits, education 

opportunities and health information, that local veterans don't know 

about," he said. "And while we're not going to be a service agency, we 

can be a starting point, providing a list of subjects with phone 

numbers and websites for the veterans to use." 

Garry Brown, Pomfret's appointed veteran advocate, said getting a 

group of veterans in one room is the best way to delivery relevant 

information. 

"Without a venue, you're just grabbing people off the street," he said. 

"There doesn't sound to be anything like this in the area. And if the 

guys just want to have a cup of coffee and read for a few hours, that's 

good, too." 

To help promote the coffeehouse, the RSVP group on March 24 will 

host a presentation on the Flying Tigers hosted by U.S. Army veteran 

Tom Pandolfi. The Tigers were made up of the pilots and crews of the 

American Volunteer Group of the Chinese Air Force during 1941-1942. 
82 

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Veterans coffeehouse to open 

DANIELSON -Military veterans of all ages are invited to the new Veterans 

Coffeehouse scheduled to open April 14 at the Killingly Community Center. The 

coffeehouse is sponsored by the RSVP program of Thames Valley Council for 

Community Action. 

Initially, the coffeehouse will be open twice monthly, on the second and fourth Tuesdays 

of each month, from 9 a.m. to noon. The coffeehouse will use the cafeteria and kitchen 

at KCC, 185 Broad St. 

"The Veterans Coffeehouse will be a place where vets can enjoy a 'cup of joe,' connect 

with one another and build camaraderie, while discussing common issues and needs," 

said Greg Kline, RSVP coordinator. "Developing a project that serves the needs of 

military veterans is a priority of our (RSVP's) Work Plan," he said. 

The coffeehouse project will be run by a small cadre of RSVP volunteers. Another goal 

of the project is to serve as a clearinghouse for information on resources available to 

veterans, their families and their caregivers. By providing this service, RSVP hopes to 

help meet TVCCA's objective of facilitating measures that help seniors age in place. 

RSVP is enlisting the support of veterans representatives (AmVets; American Legion; 

VFW; and Soldiers, Sailors and Marines Fund), municipal leaders, state and federal 

officials, and others to spread the word among local veterans. News of the coffeehouse 

concept has been warmly welcomed throughout northeast Connecticut, Kline said. 

To help promote the coffeehouse, RSVP is hosting a special presentation on the Flying 

Tigers- the pilots and crews of the American Volunteer Group of the Chinese Air Force 

during 1941-1942, before the U.S. entered WWII. The program, prepared and delivered 

by RSVP volunteer and former Army Green Beret Tom Pandolfi of Woodstock, is 

expected to draw a large audience to the KCC theatre at 10 a.m. March 24. It is free 

and open to the public. 

Source: Putnam Town Crier, p. 7, March 12, 2015 
83 

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3130/2017 Ki!hngly veterans coffeehouse celebrates its success 

m:oe ~uUetin 22::: .'>~'ITIII,g l,a,/t"nt ( "onnntt(lil Sm<: <' I ilJJ J 

Killingly veterans coffeehouse celebrates its 

success 

Tuesday 

Posted Apr 12, 2016 at 1:07 PM 

Updated Apr 12,2016 at 2:50PM 

By 

jpenney@norwichbulletin.com, (860) 857-6965 

KILLINGLY Dozens of local veterans, along with state and town officials and 

volunteers gathered in a second-floor room inside the Killingly Community Center 

on Tuesday to celebrate the RSVP Veterans Coffeehouse's inaugural anniversary. 

The center, which regularly attracts dozens of former service members at its weekly 

meetings, became a success thanks to the work and dedication of its volunteer staff1 

administrator Greg Kline said. 

"What a year it's been/' he said. "And thank you to our vohmteers, who make this 

place tick, and to the town of Killingly for supporting us." 

http:J/www.norwichbulletin.comfnewsl20160412/killingJy-veterans-coffeehouse-celebrates-its-success 1/3 
84 

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3130/2017 Killingly veterans coffeehouse celebrates its success 

Killingly Community Center 

The coffeehouse opened in April 2015 with the goal of providing local veterans with a 

place to relax and converse. After attendance continued to grow, the group was 

moved from smaller downstairs quarters to its current space, courtesy of the town of 

Killingly. Guest speakers were brought in and evening group meetings quickly 

followed. 

Town Manager Sean Hendricks, a U.S. Army veteran, said the meetings provide a 

valuable service to veterans. 

"In the end, it makes us look back on the good things about our service and reminds 

of us of why we joined," he said to a crowd of more than 50 on Tuesday. 'Tm the man 

I am because of the military and I went in because I was inspired by people like you." 

Kline said the coffeehouse "template" has attracted interest from towns across the 

country. 

"!went to a conference in Washington, D.C., and they were talking about local 

veterans' programs that have the potential of going national," he said. "And when I 

started talking about the coffeehouse1 heads turned." 

Town Council Chairman David Griffiths, a U.S. Air Force veteran, said he grew up in 

a family that felt an "obligation to serve." 

http:!lwww.norw!chbul!etin.com/newsf2:0160412/k!lhng!y-veterans-coffeehouse-cetebrates-its-success 213 
85 

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3130/2017 K1llingly veterans coffeehouse celebrates its success 

"But we never had an opportunity to sit down and talk about that service it's a 

chapter in our lives we didn't discuss/' he said. "I wish I had that opportunity, the one 

you have, to release the black hole in our hearts, to openly discuss what we went 

through." 

During Tuesday's meeting, state Sen. Mae Flexer, D-Killingly, presented several 

coffeehouse volunteers with citations from the General Assembly. 

Korean War veteran Norman Babbitt, a Thompson resident, said he was heartened to 

see so many veterans bonding on a regular basis. 

"! will keep coming, he said. 

http://www.norwichbulletin.com/newsf20160412/killingly·veterans-coffeehouse-celebrates-its-success 313 
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Veterans Coffeehouse celebrated 

A year ago on April 14, Killingly celebrated the kickoff of a new program that quickly became new of the 

town's most respected offerings and has since become a shining example that communities across eastern Connecticut 
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have looked to in an effort to follow suit. 

That program is the Veteran's Coffeehouse, which on April12 celebrated it's one-year anniversary in style with special 

guest speakers and the presentation of medals to some of the program's most active volunteers in an earty morning 

ceremony that packed the coffeehouse to near capacity. Since it's inception in 2015, the coffeehouse has made 

headlines across the state, and today towns like Bristol, New London, Norwich, Torrington and others are looking to the 

organizers of the coffeehouse for guidance to start their own programs in hopes to repeating the success seen in 

Kittingty. 

The coffeehouse has hosted forums, get·togethers and even the presentation of medals to veterans throughout the 

region and has quickly become a staple of northeastern Connecticut. 

Five veterans and one volunteer were honored with volunteer service pins from the National Veteran Corps white those 

who helped start the coffeehouse and those who have slnce come on board to make it a massive success were 

recognized for their commitment to the program. 

One of those was Army veteran Sean Hendricks, Killingly's town manager, who reflected 

on the first year of the program and what it has been like for him to see the coffeehouse thrive and grow into not only 

a great success story, but also an example for other towns to follow as they too try to bring their veterans together. 

"A lot of people did it, but I was part of putting this together and helped find a space. I'm a younger veteran, and so I 

don't identify with my military service the way the older guys do, but I think the surprise is that there are so many 

veterans. The cool thing is we found a spot and we didn't know what interest there was going to be," said Hendricks. 

'Week in and week out we had 30 to 35 people here not just coming to hang out but we provided services for them and 

things not done anywhere else. It's served as a model for other places and in the end it's not only what's best for these 

guys, but it's coot for little old KiUingty to be on the forefront of this kind of program." 

Tom Pandolfi, an Army veteran who has become a major contributor and volunteer to the coffeehouse in its first year, 

said he is proud to have been a part of making the program such a huge success. 

"We initially started it because there was really nothing up here in eastern Connecticut for veterans. The coffeehouse 

became a great gathering place to form a bond and camaraderie for veterans," he said. "As it expanded we brought in 

guest speakers, lawyers, anything and everything these veterans want. The vets decide who they want us to reach out 

too. It takes a grassroots effort to start up something like this." 

The special anniversary ceremony recognized veterans Charles Milewski, of Dayville, Jack Tucker, of Canterbury, 

George Brown, of Woodstock, Meredith Kerttula,of Pomfret, and Richard Dvorin, of Pomfret, as well as volunteer Linda 

Lee, of Danielson, for their commitment to the coffeehouse, adding their names to the long Ust of volunteers also 

recognized in October. Greg Klein, Retired and Senior Volunteer Program (RSVP) Coordinator for the Thames VaHey 

Council For Community Action, the organization responsible for the coffeehouse, said that it's because of these 

volunteers the coffeehouse have proven to be a lasting and cherished addition to the Quiet Corner community. 

"This has been such a great place for us," Klein said. "This would not have been anything close to what it has become 

without the collective effort [of the volunteers] ... 

Several veterans took the time to thank their town leaders, as welt as Klein and the volunteers, for their undying effort 

to make the coffeehouse a success. Sen. Mae Flexer, who sits on the Veteran Affairs Committee in Hartford, praised 

her town and its leaders for bringing such a great program to life and helping support it over the past year. 

"I want to say how proud I am that this is in Killingly. It's a testament to the great leaders that we have in this town," 

Flexer said. "You couldn't ask for better leaders that understand the needs of veterans and the sacrifices they made. 

This coffeehouse has been a tremendous resource for me and I'm so grateful for that. To come here every couple of 

weeks, to talk to the veterans and hear their concerns and get their feedback on what we're debating in Hartford and 

ideas for new things that we could be doing, I'm so grateful to be able to have those conversations." 
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Flexer presented citations signed by herself and State Reps. Danny Rovero and Christine Randall to the volunteers 

honored during the anniversary ceremony. Also speaking during the event was Town Council Chairman David Griffiths as 

well as a representative of the Norwich Veterans Center who congratulated the coffeehouse and its volunteers on a 

great first year and joined others in expressing confidence in a bright future for the now iconic program in Killingly. 

Jason Bleau may be reached at 508-909-4129, or by e-mail at jason@stonebridgepress.com. 

Thanks for visiting Stonebridge Press and Villager Newspapers 
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thewesterlysun com 

Town supports Veterans Coffeehouse 

August 22.2016 10:13AM 

By Brooke Constance White Sun staff writer 

STONINGTON- For many years, coffee has been a catalyst for conversation among veterans 

and that tradition continues vvith the twice-a-month Veterans Coffeehouse at the human services 

department, 166 South Broad St. 

The events are hosted by the Thames Valley Council for Community Action Inc.'s Retired and 

Senior Volunteer Program. They take place on the second and fourth Thnrsdays of the month 

from 8:30 to I 0:30a.m. During the two hours, attendees are given the chance to listen to 

speakers and connect with local, state and federal agencies that provide services to veterans. 

Gina King. program coordinator tor the volunteer program, RSVP, said that cotTec has been a 

nnifying torce among veterans both on the battlefield and off dating as far hack as the Civil War. 

"More than 150 years later and a few more historical wars notched into America's military belt, 

and veterans are still finding a common ground in meeting over a cup ofjoe here on the shoreline 

through the new RSVP Veterans Coffeehouse in Stonington:· she said. ''Through the veterans 

coffeehouse we hope to help bring together the veteran community, provide volunteer 

opportunities lor those who want to help others and ultimately create a positive lasting impact in 

the community that makes a difference in the lives of all veterans and their families." 

The regional RSVP veterans coiTeehouse project started a year ago and has become a welcoming 

place for veterans and their families to meet and talk. 

First Selectman Rob Simmons, a retired Army colonel, said he often gets calls trom local 

veterans looking for referrals and assistance. 

"l think it's important to have this service for veterans." he said. ''It's about vets speaking to 

other vets, sharing a common experience and ideas, and how to help a service buddy. Once you 

get in the service you have your own experiences, learn to be a team member, watch your 

buddies' hack and that doesn't go away." 

Within the first year of holding the cofkehouse events in various Connecticut towns, more than 

250 veterans and family members have attended, King said. The gatherings have drawn support 

tl'om U.S. Rep. Joe Courtney and Sen. Richard Blnmenthal, who have presented medals to many 

of the veterans. 

The next coffeehouse is on Aug. 25. 

bwhite@thewesterlysun.com 
91 

[Additional submission by Mrs. Davis follows:] 

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March 7, 2017 

The President 

The White House 

I 

!600 Pennsylvania Avenue, N.W. 

Washington, DC 20500 

Dear Mr. President) 

s 

Recent media reports indicate that the White House has drafted a spending blueprint that 

eliminates a slate of domestic programs, support for national service programs that are 

working daily to make America great by making our communities-~our infrastructure, our veterans, and our 

inner cities--great. 

As Republicans, we support the critical 

a lot worthy of cutting. But as corrservatives 

the C01·por·aticm 

el!rnrnatn1g g<wernrnerrt \\<aste: it's a massive budget and there's 

the nntilvine. patriotic values of national service, tve 

Comnt1urlity Servi<:e(CNCS), the federal agency that 

Through the Corporation, AmeriCorps has facilitated in excess of 1.4 billion hours of national and community 

service. relief. CNCS, which sector 

Bymatch1ingor '''weeding federal support with private sector dollars, AmeriCorps lessens the strain on the 

government's welfare net through its more than !,!00 religious 

ancl ccmunUJrlity non-profits, including Boy Scouts Charities USA, Teach For America, 

anu no:ow.nfor Humanity. 

Consider: for every Sl 0 in federal money appropriated, another $15 is sepa:rately 

fund AmeriCorps partnerships across the country. The ovc'fwhelmirlg rnajority c>f tl1ose d·ollatrs 

directly by the states. 

These programs arc saving the Studies show that national service programs 

generate a two-to-one return for tht' taxmtver· artd a nearly four-to-one return for society. 

federal gt>VCJrnnnentt's untenable budget bloat is a transcendent threat to America's security. But we 

""'"n"ct' >uu>ctt every federal dollar spent is not a dollar wasted. 

are going todisastt'f p•rqJart,dncss and rt'5p•:msc on our nation's coasts and 

plains, to care for our service and a reentry point for 

America's veterans. Since its inception, more 17,000 veterans have continued serving the country through 

AmeriCorps' programs. ln that same period, those same programs have supported more than 50,000 veterans. 

Voices for National Servi-ce j 1875 Connecticut Ave,, NW Suite 400 Washington, D.C. 200091202.742.7374] www.voicesforservice.org 
92 

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National service, like military service, breeds strong citizens and a strong homeland. We urge you to enable 

national service, just as past presidents have, both Republican and Democratic, by continuing to support 

AmeriCorps and Senior Corps. 

Sincerely, 

John Baker, Executive Chairman, FRP Holdings, Inc. 

The Honorable Haley Barbour, Former Governor of Mississippi 

Ross Barrett, General Partner, SeVen Holdings and Managing General Partner ofBVM Capital 

Mayor Richard J. Berry, Albuquerque, New Mexico 

Tere Blanca, Founder, Chairman, CEO, & President, Blanca Commercial Real Estate, Inc. 

Marvin Borgmeyer, Retiree, ExxonMobil 

Beau J. Box, President, Beau Box Commercial Real Estate 

Chris Brady Wolfe, Board Member, City Year Columbia 

John Bridgeland, Former Assistant to President George W. Bush, Former Director, USA Freedom Corps, 

Founder & CEO, Civic Enterprises 

Bonnie Brown, Former Chairwoman, Willacy County Republican Party (2000-2016), TX 

Neil Bush, Chairman, Points of Light 

William Calvert, Senior Vice President, Merrill Lynch 

Patricia Castellanos Cornish, Board Chair, City Year Miami 

Wolf Chapa, Chairman, Willacy County Republican Party, TX 

Gary Chartrand, Executive Chairman, Acosta Sales and Marketing 

Dr. Jack Christie, Houston City Council Member, At-Large Position 5 

Rick Christman, Former Corporation for National and Community Service Board Member 

Mayor David Condon, Spokane, Washington 

William Copeland Jr., Vice Chairman, National Industry Leader Life Sciences & Health Care, Deloitte LLP 

Karla Crawford, Commissioner, California Volunteers 

julie F. Cummings, Former Corporation for National and Community Service Board Member & ViceChair, Fisher Foundation 

Alice Curtin-Thaxton, Director of Educational Partnerships and Policy, United Way of the Midlands 

Elizabeth Darling, President/CEO, OneStar Foundation 

Diana Davis Spencer, Washington, DC 

Paul Edgerley, Managing Director, VantEdge Partners 

Sandy Edgerley, Trustee, Edgerley Family Foundation 

Stephen R. Fitzer, Esq., Retired Attorney 

The Honorable Chris Gibson, Former Congressman of New York 

Stephen Goldsmith, Former Mayor of Indianapolis and Former Chair, Corporation for National and 

Community Service Board 

Dr. Maria Hernandez Ferrier, President Emerita of Texas A&M University- San Antonio, Former 

Corporation for National and Community Service Board Member and Former Education Assistant Deputy 

Secretary under President George W. Bush 

Carolyn Hodges, Past President, Texas Federation of Republican Women 

Alan James, Senior Account Executive, South Carolina Business News 

Monte F, James, Partner at Jackson Walker L.LP. in Austin, Texas 
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Dorothy A. Johnson, Vice Chair and Board Member of the Board of Directors of the Corporation for 

National and Community Service 

Ron Kaufman, Assistant to the President and White House Political Director for President George H.W. 

Bush and Member of the Republican National Committee 

Barry Kern, President & CEO, Kern Studios and Mardi Gras World 

Kathy Klein, Columbia, South Carolina Community Volunteer 

Mary Grace Landrum, Principal, Landrum and Associates 

David Lincoln, General Partner, Element Partners 

Oscar Lovelace, MD, Founder of South Carolina American Party 

Sophia A. Mafrige, Attorney-Mediator & Past President, Magic Circle Republican Women 

Margaret Chai Maloney, Former PR Executive & Novelist, California 

Sean Maloney, Former Chairman, Intel China, California 

Ken Martinet, Commissioner, California Volunteers & President/CEO, Catholic Big Brothers Big Sisters 

Chris Meyer, CEO, New Schools for Baton Rouge 

Phil Oates, Chairman, Buzz Oates 

Wesley J. Palmisano, President/CEO, Palmisano 

Stacy Paragary, Co-Owner, Paragary Restaurant Group, Sacramento 

John Petersen, Shareholder, Polsinelli 

Gregg Petersmeyer, Former Assistant to the President (George H.W. Bush) and Director, White House 

Office of National Service 

Laura C. Poche, Attorney, Rabalais Estate Planning, LLC 

'The Honorable Richard Riordan, Former Mayor of Los Angeles 

Mark Rohr, Chairman and CEO, Celanese 

Cal Schmidt, Board Member, City Year Milwaukee 

John Sprouls, Executive Vice President and Chief Administrative Officer, Universal Parks & Resorts 

Chris Stadler, Managing Partner of CVC Capital Partners and Board Chair, jumpstart 

Amy Stephens, Former House Republican Majority Leader, State of Colorado 

Peter B. Stewart, Co-Founder, Chairman & CEO TraceSecurity 

Eric Tanenblatt, Former Vice Chair and Board Member, Corporation for National and Community 

Service Board 

Julie Tee!, Sacramento, CA 

Thomas Teepell, Chief Marketing Officer, Lamar Advertising Company 

Karen Thompson Owens, Executive Director, Chapin Chamber of Commerce 

Jimmy Valentine, Colonial Life Insurance Company 

Michael Ward, Chairman &CEO, CSX 

Jason Wolfe, Founder, Wolfe Solutions Sports Marketing 
94 

[Questions submitted for the record and their responses follow:] 

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VIRGINIA FOXX, NC 

Chairwoman 

MAJORITY- (202) 225-4527 

FAX (202) 225-9571 

May 12,2017 

Ms. Elizabeth Darling 

President and CEO 

OneS tar foundation 

COMMITTEE ON EDUCATION 

AND THE WORKFORCE U.S. HOUSE OF REPRESENTATIVES 

2176 RAYBURN HOUSE OFFICE BUILDING 

WASHINGTON, DC 20515-6100 

9011 Mountain Ridge Drive, Suite 100 

Austin, Texas 78759 

Dear Ms. Darling: 

ROBERT C. "BOBBY" SCOTT, VA 

Ranking Member 

MINORITY- (202) 225-3725 

FAX- (202) 226-5398 

Thank you, again, for testifying before the Subcommittee on Higher Education and Workforce 

Development at the hearing entitled "Examining the Corporation for National and Community 

Service and Its Failed Oversight of Taxpayer Dollars" on Tuesday, March 28,2017. 

As a follow-up to your testimony, please find enclosed additional questions for you submitted by 

Committee members after the hearing. Please provide your written responses to Education 

Legislative Assistant Caitlin Burke no later than June 2, 2017, for inclusion in the final hearing 

record. Her number is (202) 225-6558 should you have any questions about this request. 

We appreciate your time and insight, and we remain grateful for your contribution to the 

Committee's work. 

Sincerely, 

Brett Gutlu·ic 

Chairman 

Subcommittee on Higher Education and 

Workforce Development 
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Ranl<ing Membe1· Robc1·t C. "Bobby" Scott (D-VA) 

Would you provide clarification on how AmeriCorps members are paid and bow much money 

they receive? 

Some Members were rhetorically asking why they should call AmeriCorps and Senior Corps 

members "volunteers" when they are being paid. It is very clear to me why they are volunteers, 

but would you explain the reasoning why they are volunteers. 

Ranldng Member Susan A. Davis (D-CA) 

The Majority made it seem like the lag time in completing a background check or accomplishing 

the multiple components of a background check was gross negligence. Would you please 

describe how state regulations and restrictions complicate the process for grantees? What arc 

some examples that cause grantees to have to wait many months to complete a background check 

and what do they do with employees who have background checks pending? 
96 

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VIRGINIA FOXX, NC 

Chairwoman 

MAJORITY (202) 22G·4527 

FAX -(2021 225-9011 

May 12,2017 

Ms. Lori Giblin 

Chief Risk OJ11eer 

COMMITTEE ON EDUCATION 

AND THE WORKFORCE U.S. HOUSE OF REPRESENTATIVES 

21 !6 RAYBURN HOUSE OFFICE BUILDING 

WASHINGTON, DC 20515-6100 

Corporation for National and Community Service 

250 ESt. SW 

Washington, DC 20024 

Dear Ms. Giblin: 

ROBERT C. "BOBBY" SCOTT, VA 

Ranking Member 

MINORITY- (202) 225-3725 

FAX- (202) 226-5398 

Thank you, again, for testifying before the Subcommittee on Higher Education and Workforce 

Development at the hearing entitled "Examining the Corporation for National and Community 

Service and Its Failed Oversight of Taxpayer Dollars" on Tuesday, March 28,2017. 

As a follow-up to your testimony, please find enclosed additional questions from me for 

inclusion in the final hearing records. Please provide your written responses to Education 

Legislative Assistant Caitlin Burke no lntc1· thnn Jnne 2, 2017. Her number is (202) 225-6558 

should you have any questions about this request. 

We appreciate your time and insight, and we remain grateful for your contribution to the 

Committee's work. 

Sincerely, 

Brett Guthrie 

Chairman 

Subcommittee on Higher Education and 

Workforce Development 
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Chairman Brett Guthrie (R-KY) 

l. Failures in the Corporation's grant monitoring have been highlighted repeatedly by the 

Inspector General, the Government Accountability Office, and this Subcommittee. 

However, the Corporation has not systematically evaluated the results of its monitoring 

activities across all programs as called for by GAO in its Standards of Internal Controls 

report. Why hasn't the Corporation done such an evaluation to ensure it is utilizing 

taxpayer resources effectively and efficiently? When will the Corporation conduct this 

evaluation as recommended by GAO? 

2. The GAO report makes six recommendations to the Corpor<ttion in order to improve 

grant monitoring. Please provide a detailed plan and timelinc for the Corporation to 

complete these recommendations. 

3. The Corporation continues to struggle to ensure grantees conduct criminal history checks 

in compliance with the clear mandates in the law. In spite of mandatory professional 

development, selt~assessment, and an amnesty the prior year to encourage full 

compliance, you found significant failure rates on these checks. As noted in the hearing, 

grantees put vulnerable populations at risk when they fail to complete these criminal 

history checks in compliance with the law. 

a. Why docs the Corporation not disallow all costs associated with service 

conducted when a grantee is not in full compliance on this requirement? 

b. How will the Cotporation ensure a reduction in these failure rates and adequately 

assess penalties for noncompliance with the law? 

c. How will the Corporation assess the programs most at risk for not conducting 

criminal history checks? 

d. Please provide the full cost disallowance policy you referenced in the hearing, 

including how these financial penalties are determined. 

e. Please identify the minimum, maximum, and average financial penalty levied on 

grantees for noncompliance. 

4. ln their work, GAO found the Corporation is not strategic in how it utilizes its program 

and grant olliccrs. As a result, the workload of grant and program oflkers varies greatly 

among offices, but the Corporation has not evaluated how these differences affect the 

Corporation's ability to monitor grants effectively. Further, the Corporation has not 

evaluated how grant and program officers are distributed among offices. This ad hoc and 

reactive approach may prevent the Corporation from utilizing grant and program officers 

in the offices where they are most needed to provide effective grant monitoring. 

Considering the importance of grant and program officers in your grant monitoring 

efforts, what is the Corporation doing to evaluate and improve its utilization of the grant 

and program oftlcers? 

5. GAO's report on grant monitoring at the Corporation found the Corporation does not 

ensure all grants arc included in the annual assessment for potential risk. Particularly, 

those grants awarded after the annual assessment commences are often not included in 
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the assessment, which means they arc not assessed until the following year. Yet, one of 

your risk indicators is "new CNCS recipient." GAO recommended you correct this 

inconsistency and weakness by establishing and implementing a policy to ensure that all 

grants expected to be active in a fiscal year are assessed for potential risk. How is the 

Corporation working on establishing such a policy and will it be implemented by the next 

evaluation cycle that begins this summer? 

6. The Corporation currently uses 19 indicators, variably weighted, to assess the potential 

risk of grantees. Both GAO and the OIG have raised concerns with these indicators. They 

noted the current indicators do not effectively predict which grantees will produce 

problematic outcomes nor meaningfully cover all identifiable risks, including l!·aud and 

improper payments. Further, the indicators and scoring system do not ensure the riskiest 

grants get the highest scores and decisions on how indicators are selected and weighted 

have not been documented. The Corporation has contended repeatedly that its grant 

monitoring is risk-based, but there arc clearly weaknesses in the system. To correct this, 

Gi\0 recommends the Corporation complete its work to benchmark assessment criteria 

and scoring process to develop a truly risk-based approach to grant monitoring. What 

progress has the Corporation made in this work, and when can Congress expect it to be 

completed? 

7. Full-time AmeriCorps members receive a living stipend. Please provide the following 

information about these stipends: 

a. What is the minimum stipend provided to full-time AmcriCorps members? 

b. What is the maximum stipend provided to full-time AmeriCorps members? 

c. What are the exceptions to the minimums and maximum referenced above? 

d. What is the average stipend provided to full-time AmeriCorps members? 

e. What is the typical federal share of the living stipend provided to AmeriCorps 

members? 
99 

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VIRGINIA FOXX, NC 

Chairwoman 

MAJORITY -1202) 225-4527 

FAX -(202) 22S-9571 

May 12,2017 

COMMITTEE ON EDUCATION 

AND THE WORKFORCE U.S. HOUSE OF REPRESENTATIVES 

2176 RAYBURN HOUSE OFFICE BUILDING 

WASHINGTON, DC 20515--6100 

The Honorable Deborah Jeffrey 

Inspector General 

Corporation for National and Community Service 

250 ESt. SW, Suite 4100 

Washington, DC 20024 

Dear Inspector General Jeffrey: 

ROBERT C. "BOBBY" SCOTT, VA 

Ranking Member 

MINORITY -(202) 225-·3725 

FAX -(202) 226-5398 

Thank you, again, for testifying before the Subcommittee on Higher Education and Workforce 

Development at the hearing entitled "Examining the Corporation for National and Community 

Service and Its Failed Oversight of Taxpayer Dollars" on Tuesday, March 28, 2017. 

As a follow-up to your testimony, please find enclosed additional questions from me for 

inclusion in the final hearing record. Please provide your written responses to Education 

Legislative Assistant Caitlin Burke no later than .June 2, 2017. Her number is (202) 225-6558 

should you have any questions about this request. 

We appreciate your time and insight, and we remain grateful for your contribution to the 

Committee's work. 

Sincerely, 

Brett Guthrie 

Chairman 

Subcommittee on Higher Education and 

Workforce Development 
100 

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Chaimum Brett Guthrie (R-KY) 

1. The Corporation continues to struggle to ensure grantees conduct criminal history checks 

in compliance with the clear mandates in the law. ln spite of mandatory professional 

development, self-assessment, and an amnesty the prior year to encourage full 

compliance, the chief risk officer recently found signiJicant failure rates on criminal 

history checks. What has the Corporation done to levy penalties against these grantees or 

sanction a grantee's future involvement in the program? Are these penalties are effective? 

What would you recommend the Corporation do to prevent further inaction and 

strengthen compliance with the law? 

2. The fiscal Year 2017 Management Challenges Report indicates the Corporation has 

operated in the same inefficient manner since its inception. You advocate for a "radical 

restructuring" of the Corporation- going as far to say, "No expert, if given a free hand to 

achieve CNCS's mission on an operating budget of$1 billion per year, would choose the 

constraints, redundancies, and Byzantine structure that characterizes CNCS and its 

programs." Would you elaborate on the reforms needed at the Corporation to ensure the 

effective and eftlcient utilization of taxpayer funds? 

3. The OIG closed an investigation in November of20l6 into the Georgia Center for 

Nonprotlts (GCN), which found GCN violated the law by improperly utilizing its VISTA 

members when it directed members to perform staff functions and charged clients for 

their services. As a result, the grantee was debarred for two years and ordered to repay 

over half a million dollars in disallowed costs. This illegal activity took place over a six 

year period tl·om 2009 to 2014, which is an unusually long length of time to avoid 

detection ifCNCS did indeed employ a functioning risk-based monitoring system. To 

what would you attribute the failure of the Corporation to detect this illegal activity for 

such a long time? What corrective action should the Corporation take to more quickly 

detect and appropriately respond to such illegal activity in the future? 

4. Does the OfG track recommendations made to the Corporation and the status of these 

recommendations? If so, please provide a summary of open recommendations with the 

Corporation. 
101 

[Ms. Darling’s responses to questions submitted for the record 

follow:] 

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receives an allowance of$1, 139 per month; whereas a full-time member serving in a 9-month program 

will receive $1,392. The living allowance is taxable. Upon the successful completion of a term of 

service, an AmeriCorps member receives an Education Award (also taxable) that may be used toward 

qualified student loans or go directly to an educational institution for future educational expenses. The 

value of the Education Award is based on the value of the Pel! Grant. The current value of a full-time 

education award is $5,775 before taxes. Members may earn up to the value of two full-time education 

awards. 

Serving as an AmeriCorps member is not intended to be a career. For high school and college graduates 

AmeriCorps service can be a career launcher where members gain valuable experience for the 

workforce. Serving is also an opportunity for retirees, veterans, and others to give back to their 

community through a structured program. 

2. Some members were rhetorically asking why they should call AmeriCorps and Senior Corps 

members "volunteers" wheu they are paid. It is very clear to me why they are volunteers, but 

would you explain the reasoning why they are volunteers. 

AmeriCorps members are unique in that they arc not "volunteers" and they are not, by statute, 

"employees.'' We refer to individuals serving in AmeriCorps as AmeriCorps members, not AmeriCorps 

volunteers. They are individuals who have voluntarily signed-on to serve for up to a year in dedicated 

service to address local community needs. 

While AmeriCorps members are volunteering for a year of service, usc of the word volunteer may 

misrepresent or dilute the true commitment or level of engagement that is required of these individuals. 

A typical community volunteer may be episodic or on-going, but generally even on-going volunteers arc 

giving a few hours a week of their time. AmeriCorps members are committing to both a total number of 

service hours (full-time is 1700 hours), and a duration of a term of service (full-time is typically 10- 11 

months). This level of commitment is not something asked of a typical individual looking to volunteer 

in their community. 

AmeriCorps members do receive a living allowance; however, it is a modest stipend intended to cover 

basic living costs. Generally, community volunteers have full time jobs, or are retirees or students, and 

their volunteer activities are additional ways for them to be engaged in their community. Full-time 

AmeriCorps members are serving anywhere from 8 to 12 hour days in the community. Without the 

living allowance this opportunity would only be available to those with enough family resources to 

support those individuals for the year. 

Although we use different terminology "member" versus "volunteer" to describe an AmeriCorps 

member's service, it is without question that these individuals are dedicating themselves to serving 
103 

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communities and individuals in need over an extended period of time. Selfless service of this nature is 

typically equated with volunteers, and AmeriCorps members are certainly volunteering themselves for 

this service; however, because of the level of commitment needed, we consider AmeriCorps members as 

more than volunteers. 

3. The Majority made it seem like the lag time in completing a background check or 

accomplishing the multiple components of a background check was gross negligence. Would you 

please describe how state regulations and restrictions complicate the process for grantees? What 

are some examples that cause grantees to have to wait many months to complete a background 

check and what do they do with employees who have background checks pending? 

CNCS requires grantees working with vulnerable populations to obtain four criminal history checks for 

every covered service member and staff. The fingerprint-based FBI check and the National Sex 

Offender Public Website (NSOPW) check provide the information needed to determine whether an 

applicant has any disqualifying offenses on their criminal record, but grantees are additionally required 

to perform State of Service and State of Residence criminal history checks. The State of Residence 

check is otlen the most time-consuming and costly for grantees to obtain. It also provides no new 

information that would automatically disqualify an applicant from serving, because all such information 

is currently available under the fingerprint-based FBI check and the NSOPW check. 

No single, comprehensive criminal background check database is publicly available in the United States. 

Instead, each state is the "gatekeeper" for background checks, and they have great latitude to determine 

who can access background check information, tor what purpose, and how the records will be provided. 

Variation in criminal codes and criminal history procedures across states leads to inconsistency from 

state to state on eligibility, process, cost, turnaround time and thoroughness of results provided. 

Given the time and resources required to obtain multiple background checks for every participant and 

staff, some larger AmeriCorps grantees have elected to employ a full-time staff member to run 

background checks. One grantee reports that processing and managing criminal history checks for 

approximately 3,000 AmeriCorps members takes approximately 2,250 staff hours each year. 

If the Committee is interested, the Association for State Service Commissions (ASC) and Voices for 

National Service have been working on a set of recommendations for improving the background check 

process. Below is additional detail on each check and the challenges and delays that a grantee may 

encounter. 
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National Sex Offender Public Website INSOPWl Check 

A NSOPW check must be completed prior to a member or staff member starting work or service. Although 

this check is free and quick to run, it must include the results from all states. Problems can arise if a single 

state registry is "down" and not reporting at the time the check is run which happens not infrequently. In such 

cases the NSOPW check is not compliant and will result in disallowed costs. 

State of Residence and State of Service Criminal History Checks 

The most complicated component of the National Service Criminal History Check (NSCHC) is the State 

of Residence criminal history check. AmeriCorps programs arc required to run a State of Residence 

check on all prospective members. A member who will serve in a state other than where they reside, 

requires two criminal history checks, State of Residence and State of Service. 

The state of residence is the state an AmeriCorps applicant or AmeriCorps program staff applicant is 

living in when they apply to serve or work in the program. Each state criminal history repository is 

different, requiring different forms, different processes for acquiring checks, and costs vary widely. 

Some states require that applicants be fingerprinted in that state as part of their state criminal history 

check and other states do not. Some states require that applicants get specific forms notarized as part of 

the criminal history check process. In some states applicants must request that criminal history results 

be sent directly to the program, rather than allowing programs to make the request directly. 

To perform a compliant check for programs that recruit members nationally, conducting State of 

Residence checks requires a significant investment of time. National programs must be well-versed in 

the procedures required in all 50 U.S. states and the territories, not just the state where the program is 

headquartered. 

Each state repository not only has a different process to request criminal history checks, but also has 

different timelines for receiving responses. These timclines can vary from immediate responses to 

several weeks to months. ln recognition of the difficulties presented by the timely coordination of these 

differing procedures with applicants dispersed across the country, CNCS released a Resource Guide in 

2016 with a list of approved, designated state criminal history repositories (some states have more than 

one repository) which must be used to conduct a compliant State of Residence check. 

FBI Fingerprint Checks 

Initially, selling up accounts through a state criminal history repository for the State of Service and FBI 

fingerprint checks can be quite involved, but when successfully set up, running checks can become 

fairly routine. In Texas, we are fortunate that our state repository, Texas Department of Public Safety 

also runs FBI fingerprint checks. This is not the case in every state. 

In the recent past, complications occurred when programs were prohibited by state law from performing 

FBI fingerprint checks through their state criminal history repository. In these cases, some programs 
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were able to conduct background checks directly through their state service commission. While this was 

an option for some programs, it sometimes caused significant lag times as commissions do·not have the 

resources necessary to review all results in a timely manner. CNCS worked diligently to address this 

issue and as a result set up "FieldPrint" as an FBI Channeler so that all programs now have access to the 

required fingerprint checks. 

In Texas, our state laws prohibit us and our sub-grantees from maintaining the results of FBI fingerprint 

checks. This is in conflict with the AmeriCorps and Senior Corps regulations to retain all fingerprint 

check results. Due to this anomaly, we were required to apply to CNCS for an Alternative Search 

Protocol so we could develop a process to track compliance of the initiation and completion of 

fingerprint checks, without sharing the actual results with a monitoring official. Several states have 

similar laws. 

An additional complication that can cause delays is the start time for programs. Many programs hire the 

majority of their members for August or September start dates, which means AmeriCorps programs arc 

competing for limited fingerprinting appointments with other AmeriCorps programs, school districts, 

and community volunteer programs working with vulnerable populations. Beyond the issue of start 

dates, many AmeriCorps programs recruit their members from out of state, and are thus unable to send 

their members to be fingerprinted until their start date or only a few days prior. This delay can cause 

results to be a few days or several weeks late in getting back to the program. 

In the event that a program does not receive the necessary criminal history check results prior to the start 

of service or work for a member or staff person, AmeriCorps and Senior Corps programs are required to 

provide accompaniment to any member or staff person who has access to vulnerable populations. 

Accompaniment is required until either the State of Service and State of Residence criminal history 

check (or the FBI fingerprint check) have been completed along with the National Sex Offender Public 

Website check. Not only must programs provide accompaniment, but in order to stay in compliance and 

avoid disallowed costs, accompaniment must be documented contemporaneously. 

Senior Corps programs face similar challenges with the National Service Crimina! History Check 

process. Both Foster Grandparent and Senior Companion Programs have orientations the first week of 

service. The members do not have contact with vulnerable populations during the initial part of their 

orientation. State criminal history repository and FBI fingerprint checks must be conducted on or before 

the first day of service. Often even if the National Sex Offender Public Website (NSOPW) check is 

completed in advance of the first day of service, but the initiation of the state criminal history repository 

checks and FBI fingerprint checks is conducted on the second or third day of orientation, disallowed 

costs are assessed even though these late checks do not result in any contact or risk to vulnerable 

populations. The situation is similar for Senior Corps staff members that are hired, but for whom the 

state criminal history repository and FBI fingerprint checks are initiated a day or two late. 
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"On time every time'' can be challenging to coordinate especially for programs with hundreds of 

members coming from different states, with different state protocols and variable time lines. CNCS has 

recognized the complexity of the requirements for NSCHCs, and in addition to the resources already 

mentioned above, they have also created a NSCHC eCourse that is required for all grantees and subgrantees to complete annually. This in-depth course walks through all the requirements including how 

to ensure checks are performed and documented correctly. CNCS is deliberate in including NSCHC 

sessions at training events, such as the AmeriCorps State/National Symposium and National Service 

Regional Conference Trainings. Generally, compliance issues with NSCHCs are not due to a lack of 

clear policies and procedures nor to negligence. Compliance issues are usually due to human mistakes 

that can occur when trying to implement an administratively complex process with very specific 

requirements and no room for error. 
107 

[Ms. Giblin’s responses to questions submitted for the record follow:] 

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June 12,2017 

Questions for the Record 

l. Failures in the Corporation's grant monitoring have been highlighted repeatedly by the Inspector 

General, the Government Accountability Office, and this Subcommittee. However, the Corporation 

has not systematically evaluated the results of its monitoring activities across all programs as called 

for by GAO in its Standards oflnternal Controls report. Why hasn't the Corporation done such an 

evaluation to ensure it is utilizing taxpayer resources effectively and efficiently? When will the 

Corporation conduct this evaluation as recommended by GAO? 

CNCS response: On an annual basis the agency has convened its monitoring work group to evaluate 

the previous year's risk assessment process and used the results to improve the effectiveness and 

efficiency of the risk assessment efforts. In 2017, the Office of the Chief Risk Officer (OCRO) will 

perform a holistic evaluation of the risk assessment program. To do this, OCRO recently hired two 

staff with public and private sector risk assessment experience and recently awarded a contract to a 

third party vendor that will facilitate a complete review of the risk assessment process including 

changes to the assessment criteria, work flow, and internal controls, and the development of an 

evaluation process for continuous improvement. OCRO is also working on ways to automate the 

workflow of the annual risk assessment. It is expected that the contract will be awarded in June 2017 

and the new portfolio risk assessment criteria will be developed by the end of the calendar year. The 

agency will adjust the new criteria and test it for effectiveness and accuracy in calendar year 2018. 

2. The GAO report makes six recommendations to the Corporation in order to improve grant 

monitoring. Please provide a detailed plan and timeline for the Corporation to complete these 

recommendations. 

CNCS response: CNCS provided its plan to address GAO's recommendations in a memo 

transmitted on May II, 2017. A copy of that plan is attached for the Committee (see Attachment I 

20 170511_ CNCS Plan to GAO 17-90). 

3. The Corporation continues to struggle to ensure grantees conduct criminal history checks in 

compliance with the clear mandates in the law. In spite of mandatory professional development, selfassessment, and an amnesty the prior year to encourage full compliance, you found significant 

failure rates on these checks. As noted in the hearing, grantees put vulnerable populations at risk 

when they fail to complete these criminal history checks in compliance with the law. 

a. Why does the Corporation not disallow all costs associated with service conducted when a 

grantee is not in full compliance on this requirement? 

CNCS response: CNCS disallows all costs associated with ineligible individuals, including stipends, 

salaries, fringe benefits and, education awards. In cases where an individual is eligible to serve, but 

the grantee's files are not fully compliant, disallowance amounts are based on the level of 

noncompliance. CNCS's current disallowance guidance is a result of numerous years of working to 

educate grantees regarding the complexity of the National Service Criminal History Check 

(NSCHC) requirements and encourage compliance with the NSCHC regulations. Agency leadership 

is reviewing the disallowance amounts and may update the guidance in the coming months. 

NSCHC compliance includes documenting a multi-step process. To name just a few of these steps, 

the process includes: 

Determining who requires a background check 

Determining the type of check required 
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June !2, 2017 

Questions for the Record 

Determining the date the check must be initiated 

Documenting volunteer understanding of the requirement itself 

Documenting consent and the identity of the volunteer 

Identifying the proper sources from which to obtain the check 

Documenting the date the check was returned and adjudicated 

Validating that accompaniment was performed, if required. 

Under the current policy, noncompliance occurs if any of these steps are not performed or if one is 

performed incorrectly, untimely, and/or not fully documented. Additionally, CNCS award amounts 

range in dollar amount (from $0 to multi-million) and award type (full operating grants, education 

only awards, and awards to grantees comprised of just training dollars). Disallowing all costs 

associated with service without taking into account the award amount or type of grant, could result 

in zero to millions of dollars in disallowances regardless of the severity of noncompliance, and 

inconsistent treatment of noncompliance that depends on the type of grant rather than the level of 

noncompliance. 

Agency leadership will take all of these factors into consideration as we refine and strengthen the 

disallowance policies to more fully align with our commitment to holding all grantees accountable 

for noncompliance. 

b. How will the Corporation ensure a reduction in these failure rates and adequately assess penalties 

for noncompliance with the law? 

CNCS response: To address noncompliance, CNCS continues to provide multiple training 

opportunities for grantees and staff regarding criminal history noncompliance. In addition, the 

agency is currently in the process of identifying a vendor to perform state criminal history checks 

and nationwide sex offender checks. This will provide grantees with a single solution to mitigate 

most of the noncompliance associated with the multistep process. This new solution draws on 

CNCS's experience in providing a similar solution to its grantees in 2016 when the agency obtained 

the services of a vendor to provide FBI checks for grantees. The vendor has worked with over 500 

CNCS customers, performing over 23,000 checks that are known to be fully compliant with regard 

to data source and applicable clearances. CNCS believes that providing a simpler and more 

streamlined approach for completing criminal history checks accurately and more timely will result 

in a notable decrease in noncompliance. 

c. How will the Corporation assess the programs most at risk for not conducting criminal history 

checks? 

CNCS response: The agency will continue to assess programs (AmeriCorps, Senior Corps, Social 

Innovation Fund) risk through its annual Improper Payments Elimination and Recovery 

Improvement Act (!PERlA) testing process. In addition, CNCS continues to assess and evaluate 

grantee criminal history check compliance through our ongoing monitoring visits with grantees, as 

well as through our continuous training and technical assistance activities, such as the regional 

training conferences, webinars, and other resources. 

d. Please provide the full cost disallowance policy you referenced in the hearing, including how 

these financial penalties are detemtined. 
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June 12, 2017 

Questions for the Record 

f,:;NCS response: Please see attached enforcement and disallowance for NSCHC ineligibility and 

disallowance (Attachment 2). 

e. Please identify the minimum, maximum, and average financial penalty levied on grantees for 

noncompliance. 

CNCS response: According to the National Service Criminal History Check Enforcement Guide, the 

minimum disallowance amount per noncompliant file is $250. The maximum disallowance amount 

per noncompliant file is $1,500. These varying disallowance levels account for the types of grants 

and degrees of non-compliance mentioned in response to question 3.a., above. The average financial 

penalty levied on grantees for noncompliance in FY 2016 was $7,000.ln addition to the minimum 

and maximum disallowances associated with noncompliance, CNCS disallows all costs associated 

with staff salaries and other benefits and national service participants' stipends and education awards 

for any individuals who are deemed ineligible. As noted above, the agency is reviewing the 

disallowance amounts to better align them with the agency's requirement for NSCHC compliance. 

The agency will provide the Committee with an updates as the policy is updated or further refined. 

4. In their work, GAO found the Corporation is not strategic in how it utilizes its program and grant 

officers. As a result, the workload of grant and program officers varies greatly among offices, but the 

Corporation has not evaluated how these differences affect the Corporation's ability to monitor 

grants effectively. Further, the Corporation has not evaluated how grant and program officers are 

distributed among offices. This ad hoc and reactive approach may prevent the Corporation from 

utilizing grant and program officers in the offices where they are most needed to provide effective 

grant monitoring. Considering the importance of grant and program officers in your grant monitoring 

efforts, what is the Corporation doing to evaluate and improve is utilization of the grant and program 

officers? 

CNCS response: As mentioned in its response to the GAO audit, CNCS has taken significant steps 

in the last two years to address workforce needs. CNCS has established a senior executive level 

committee that reviews all staffing level requests and ensures appropriate staffing justifications are 

provided. This group also ensures that all functions within the agency are being resourced 

appropriately. As a result of this systematic approach, the Office of Grants Management (OGM), the 

Field Financial Management Center, and Office of Program Operations were able to add additional 

stair in order to meet current work demands, especially grants monitoring. CNCS is also reviewing 

its full corps of grant and program officers to ensure that they are appropriately allocated across the 

agency's programs and offices. 

5. GAO's report on grant monitoring at the Corporation found the Corporation does not ensure all 

grants are included in the annual assessment for potential risk. Particularly, those grants awarded 

after the annual assessment commences are often not included in the assessment, which means they 

are not assessed until the lollowing year. Yet, one of your risk indicators is "new CNCS recipient." 

GAO recommended you correct this inconsistency and weakness by establishing and implementing a 

policy to ensure that all grants expected to be active in a fiscal year are assessed for potential risk. 

How is the Corporation working on establishing such a policy and will it be implemented by the next 

evaluation cycle that begins this summer? 

CNCS response: CNCS agrees that all active grants should be assessed annually for potential risk. 

CNCS has revised its current guidance to ensure that all grants are included in the assessment 
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June 12,2017 

Questions tOr the Record 

process and will apply GAO's recommendation. The policy will be implemented with this year's 

assessment cycle and include all awards made in FY2017. 

6. The Corporation currently uses 19 indicators, variably weighted, to assess the potential risk of 

grantees. Both GAO and the OIG have raised concerns with these indicators. They noted the current 

indicators do not effectively predict which grantees will produce problematic outcomes nor 

meaningfully cover all identifiable risks, including fraud and improper payments. Further, the 

indicators and scoring system do not ensure the riskiest grants get the highest scores and decisions 

on how indicators are selected and weighted have not been documented. The Corporation has 

contended repeatedly that is grant monitoring is risk-based, but there arc clearly weaknesses in the 

system. To correct this, GAO recommends the Corporation complete its work to benchmark 

assessment criteria and scoring process to develop a truly risk-based approach to grant monitoring. 

What progress has the Corporation made in this work, and when can Congress expect it to be 

completed? 

CNCS response: The Chief Risk Officer (CRO) continues to validate and assess the agency's current 

risk indicators against industry best practices to ensure that CNCS is deploying the most appropriate 

risk model. The CRO will use this information and all other data, to develop criteria by the end of 

calendar year 2017. The new criteria will be calibrated and tested for effectiveness and accuracy in 

calendar year 2018. 

7. Full-time AmeriCorps members receive a living stipend. Please provide the following information 

about these stipends: 

a. What is the minimum stipend provided to full-time AmeriCorps members? 

CNCS response: The minimum living allowance for AmeriCorps State and National members 

for Fiscal Year 2017 is $12,630. 

b. What is the maximum stipend provided to full-time AmeriCorps members? 

CNCS response: The maximum living allowance for AmeriCorps State and National full time 

members for Fiscal Year 2017 is $24,930. 

c. What are the exceptions to the minimums and maximum reference above? 

CNCS response: The exceptions to the minimums and maximums referenced above are: 

Programs existing prior to September 21, 1993 are not required to offer a living 

allowance. If an applicant chooses to offer a living allowance, it is exempt from the 

minimum requirement, but not the maximum requirement. EAP Grantees are not required 

to provide a living allowance, but if a living allowance is provided, it must comply with 

the maximum requirements. Professional Corps Grantees must provide members a living 

allowance or salary, which must meet the minimum, but may exceed the maximum living 

allowance. Professional Corps member salaries are paid entirely by the organizations 

with which the members serve, and are not included in the budget. 
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June 12,2017 

Questions for the Record 

• Although AmeriCorps programs are allowed to provide supplemental benefits, almost all 

AmeriCorps State and National programs' living allowance plus supplemental benefits do 

not exceed the maximum living allowance amount. 

d. What is the average stipend provided to full-time AmeriCorps members? 

CNCS response: The average living allowance provided to a full time AmeriCorps State and 

National members in 2014 was $11,525, in 2015 was $13,254, and in 2016 was $13,166. 

e. What is the typical federal share of the living stipend provided to AmeriCorps members? 

CNCS response: The average federal share of living allowances provided to AmeriCorps State 

and National members in 2014 was 63 percent, in 2015 was 62 percent, and in 2016 was 63 

percent. 
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Moy 11,2017 

Dear GAO colleagues, 

On the behalf of CNCS, I want to thank you for your thoughtful and thorough work on this engagement. We 

are pleased GAO acknowledged our established assessment-based monitoring process and grateful for 

feedback on how to refine and improve the process going forward. GAO's recommendation thatCNCS move 

from compliance- to risk-based monitoring represents a maturational process that is occurring throughout the 

Federal Government. In fact, it is called out specifically in updates to OMB Circular A 123 focused on 

Enterprise Risk Management. Aided by the establishment and staffing of the Office of the Chief Risk Officer 

(OCRO), CNCS is moving forward toward this goal. We continue to review, revise, and refine the agency's 

approach to risk management and grants monitoring to ensure that we, as well as our grantees, are 

accountable for federal funds. 

CNCS values GAO's input and will continue to implement your recommendations as resources allow. 

Specifically, we will continue: 

• Improving risk monitoring, tracking, and scoring 

• Enhancing the alignment of monitoring actions with assessment results to include ensuring that all 

grants undergo an assessment 

• Conducting routine evaluations of our monitoring and oversight process to ensure continual 

improvement 

• Implementing strategic workforce planning and aligning employee development with agency goals 

and critical competencies. 

We appreciate the opportunity to collaborate with GAO to improve our programs and practices. Please find 

our responses tO your recommendations below: 

1. , Ensure that CNCS completes its efforts to benchmark its assessment criteria and scoring process to 

further develop a risk-based approach to grant monitoring and that information from this effort is used 

to (a) score the indicators so that the riskiest grants get the highest scores (b) revise the assessment 

indicators to meaningfully cover all identifiable risks, including improper payments, and (c) document 

decisions on how indicators are selected and weighted. 

We will continue to periodically benchmark our assessment criteria in order to ensure that we are assessing 

appropriate risks. CNCS recognizes the need to move from compliance~ to risk~based monitoring. We view 

this effort as maturing an existing approach, as opposed to starting a new one from scratch. The OCRO will 

help to refine this approach as part of reviewing and revising risk criteria and scoring. The agency's 

enhanced risk-based approach will begin with Fiscal Year (FY) 2018 grant awards. 

250 E Street, SW 

Washington, D.C. 20525 

202·606-5000 1800·942-26771 TTY 800-833-3722 

NATIONAL& 

COMMUNITY 

SERVICED'.I:C 
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2. Establish and implement a policy to ensure that all grants expected to be active in a fiscal year, 

including those awarded after the annual assessment, are assessed for potential risk. 

CNCS agrees that all active grants should be assessed annually for potential risk. In regards to the FY 2015 

assessment, 208 awards across our grant programs were made after the assessment data was pulled on 

August 26, 2015. Of the 208 awards made between August 26 and September 30, only 15 were for new 

CNCS grantees. The remaining grant awards went to existing grantees, predominately State Commissions, 

National Directs, and longstanding Senior Corps grantees, as well as ongoing VISTA projects. 

CNCS will revise our current assessment policy to ensure that all grants are included in the assessment 

process and immediately implement GAO's recommendation. 

3. Review monitoring protocols, including the level of information collected for oversight of subrecipient's activities such as criminal history checks, and enhance protocols as appropriate. 

CNCS, like most federal agencies, monitors at the prime grantee level. We recognize that more needs to be 

done to address risk at the sub-recipient level, particularly regarding CHC compliance. Per regulation, 

grantees are primarily responsible for monitoring their sub-recipients. However, CNCS has taken steps to 

resolve CHC compliance with grantees and sub-recipients. We have implemented the use of an FBI 

channeler and are exploring a contract solution for national and state checks. This will also address IPEI'tArelated concerns relating to CHC. In addition, CNCS is strictly enforcing CHC compliance and disallowing 

costs when grantees have failed to comply with CHC requirements. 

4. Establish activities to systematically evaluate grant monitoring results. 

As noted in our response to recommendation 1, G'\!CS has not only established the OCRO, but resourced it 

so that we can continue to bui1d on our current risk assessment framework and capture the information 

and data necessary to continue to enhance our approach to risk·based monitoring. 

5. Develop and document a strategic workforce planning process. 

CNCS has taken significant steps in the last two years to address workforce needs. CNCS has established a 

senior executive level committee that reviews all staffing level requests and ensures appropriate staffing 

justifications are provided. This group also ensures that all functions within the agency are being resourced 

appropriately. As a result of this systematic approach, OCRO has received an appropriate level of staffing 

needed to accomplish their mission. In addition, the Office of Grants Management (OGM), the Field 

Financial Management Center, and Office of Program Operations were able to add additional staff in order 

to meet current work demands. 

In accordance with direction received from OMB following the release of the "Memorandum for Heads of 

Executive Departments and Agencies", M-17-22, CNCS is launching an enterprise-wide re-examination of 

the agencies' mission, strategy and structure in order to develop a plan to ensure employee performance is 

maximized ,md the agency is operating effectively. 

NationaiService.gov 

NATIONAL& 

COMMUNITY 

SERVICEE.D.'C 
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6. As part of CNCS's efforts to develop an employee development program, update critical competencies 

for grant monitoring, and establish a training process linked with agency goals and these competencies. 

CNCS implemented a robust training initiative late in FY 2015 and carried this over into FY 2016 in which 

OGM staff received significant training in areas specifically associated with grants monitoring. A majority 

of Grant Management Specialists have now been able to obtain grant management certificates as part of 

this initiative. In addition to the staff training initiatives undertaken since FY 2015, CNCS is in the process 

of developing a broader agency-wide employee development program that will link competencies to 

development needs in a variety of mission-critical roles. 

Again, I want to thank you for your thoughtful and constructive work during this engagement and for the 

recommendations you have provided to CNCS. 

Since,ely:. / ~ ;; /i/ . 

Jeffr ij e 

Chi f erating Officer 

NationaiService.gov 

NATIONAL& 

COMMUNITY 

SERVICEI'.DJ: 
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Enforcement and Disallowance for 

NSCHC Ineligibility and NSCHC Noncompliance 

NSCHC- Ineligible Individual 

An ineligible individual (42 USC 12645g(c)) is anyone who (I) is registered or required to be 

registered on a sex offender registry; (2) has been convicted of murder; (3) refuses to consent to 

the NSCHCs; or (4) makes a false statement in connection with his or her NSCHC. Ineligible 

individuals are barred from working or serving on a grant-funded program. Recipients are 

strongly encouraged to promote the safety of those involved in their national service program 

through various means. The NSCHC establishes a baseline screening procedure. Recipients may 

establish a screening procedure with components and criteria that go beyond the NSCHC baseline 

requirements and that are tailored to the needs of their program, organization, and beneficiary 

population. Recipients should also be aware that regardless of documented accompaniment, all 

associated costs with an ineligible individual will be disallowed. 

If you determine that an ineligible individual served or worked on a CNCS grant (including 

matching funds), you must: 

Immediately remove any currently serving ineligible individuals from the CNCS grant, 

and retain documentation of their service history and NSCHC documentation. 

• Disallow all costs associated with the individual. Costs include any stipend, salary, 

fringe benefits, or education award. Calculate these costs from the individual's start 

date in a covered position. 

• Establish proper documentation and report the confirmed ineligibility to CNCS 

NSCHC- Eligible Individual- Noncompliant File 

Noncompliance refers to a situation in which an individual in a covered position is eligible to 

serve, but a recipient did not fully comply with all of these items: 

• Properly conduct all required NSCHC components for the individual. 

• Conduct the required NSCHC components on time. 

• Ensure that an individual with access to vulnerable populations was in the physical 

presence of a qualified individual while checks were pending (also known as 

"accompaniment"). 

• Retain proper documentation. 

If noncompliance is discovered: 

A recipient must take corrective action to correctly determine eligibility. 

• CNCS will disallow costs associated with NSCHC noncompliance. 

Use the Matrix on the next page to determine the level of mitigation in each noncompliant 

file and associated disallowance per individual. 

Page 1 of 2 
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High 

Mitigation 

Program a sex 

before the individual began \vork or started 

service on the grant AND at !east one of the 

fol!mving is present, even if late: 

Initiated a vendor check that included a 

!. Performed accompaniment (if required); AND 

2. Adjudicated a sex offender check before the 

individual began work or started service on the grant; 

AND 

nationwide search of state criminal history 3. Initiated one of the following on time: 

inf(wmation; OR A vendor check that included a nationwide search 

Initiated the State of Service or State of of state crimina! history information; OR 

Residence check through CNCS A State of Service or State of Residence check 

information: OR 

Initiated the State of Service or State of 

Residence check through CNCS 

sources; OR 

Initiated a fingerprint-based FBI check. 

initiated one of the following on time: 

A vendor check that included a nationwide search 

of state criminal history information; OR 

A State of Service or State of Residence check 

through CNCS designated sources; OR 

A fingerprint-based FBI check. 

2. Adjudicated a sex offender check before the 

individual began work or started service on the grant 

AND at least one of the following is present, even if 

late; 

A vendor check that included a nationwide search 

of state criminal history information; OR 

A State of Service or State of Residence check 

through CNCS designated sources; OR 

A FBI check. 

of factors that does not meet the requirements for Moderate Mitigation or High 

Page 2 of2 
118 

[Inspector Jeffrey’s responses to questions submitted for the 

record follow:] 

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Responses of Deborah J. Jeffrey, Inspector General of the Corporation for National and 

Community Service, to Questions for the Record following the hearing, Examining the 

Corporation for National and Community Service and Its Failed Oversight of Taxpayer Dollars, 

before the House Committee on Education and the Workforce, Subcommittee on Higher 

Education and Workforce Development, on March 28, 2017 

1. The Corporation continues to struggle to ensure grantees conduct criminal history 

checks in compliance with clear mandates in the law. In spite of mandatory professional 

development, self-assessment, and amnesty the prior year to encourage full 

compliance, the chief risk officer recently found significant failure rates on criminal 

history checks. What has the Corporation done to levy penalties against these grantees 

or sanction a grantee's future involvement in the program? Are these penalties 

effective? What would you recommend the Corporation do to prevent further inaction 

and strengthen compliance with the law? 

Response 

Congress mandated specific criminal history checks to prevent convicted murderers and 

sex offenders from using CNCS programs to gain access to at-risk individuals. Far too 

many grantees do not conduct these background checks timely and thoroughly. Last year, 

depending on the program, the Chief Risk Officer found that 22-41 percent of individuals 

supported through CNCS grants served without complete and timely criminal history 

checks. This level of noncompliance demonstrates that CNCS has not effectively enforced 

these critical safety requirements. CNCS-OIG is unaware of a single instance in which the 

Corporation terminated a grant or denied a new award because of noncompliance with 

criminal history checking requirements. 

Depending on its leadership over the years, CNCS has vacillated on enforcement. From 

October 2011 to October 2014, its stated policy under one former General Counsel was 

to disallow all costs associated with a national service participant or grant-funded staff 

member during a period of noncompliance. Enforcement of this strict policy, however, 

was spotty. Program officers generally helped grantees remedy noncompliance, but 

often did not disallow the associated costs. CNCS's Chief Grants Officer during this period 

retroactively approved noncompliant practices that she acknowledged were insufficient, 

to avoid penalizing a grantee.l 

After improper payments testing revealed the extent of noncompliance, in late 2014 the 

Corporation undertook the mandatory training and self-assessment referenced in your 

1 Semiannual Report to Congress, Audits and Reviews: Corporation Reaffirms Decisions to Allow Costs Related to 

Untimely and Improperly Performed Background Checks, at p. 14 (April 30, 2015) available at 

https://www.cncsoig.gov/sites/default/files/sar 15-01 O.pdf. 

2 
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question, and granted amnesty. CNCS-OIG recommended that the criminal history 

checking requirements thereafter be strictly enforced. 2 Under a successor General 

Counsel, however, CNCS rejected this approach. In August 2015, over the objections of 

CNCS-OIG, the Corporation adopted token fines that were purposefully designed to 

minimize the financial consequences for noncompliant grantees. The fines ranged $250 

to $1,500, subject to a 50 percent discount if the grantee self-reported. 

Such nominal amounts are too low to create proper incentives. In the first case under the 

new penalty structure, the fine totaled $8,500, only three-tenths of one percent (.003) of 

the grant amount. (The grantee had returned nearly $500,000 of the award as unspent, 

so this small fine was unlikely to make much of an impression.) Overt he six-month period 

analyzed by CNCS-OIG, the penalties averaged less than one percent of the funds awarded 

by CNCS. That's a small cost of doing business, not an effective sanction for recklessness. 

Shortly before the March 28, 2017 hearing, the Chief Risk Officer advised my Office that 

CNCS would be doubling the fines, effective in April. A 2 percent fine is still too low, given 

the low probability of detection3 and the gravity of the potential harm of allowing known 

predators access to at-risk communities. Now, in the wake of the Subcommittee's 

oversight hearing, CNCS reports that it is once again revisiting its enforcement strategy, 

promising to do better this time. 

Enforcement of critical safety requirements should not vary widely with changes in CNCS 

leadership, nor should it demand constant Congressional oversight. Given CNCS's lack of 

success and the absence of meaningful accountability over the past six years, it is 

appropriate for Congress to mandate robust enforcement, which can be achieved through 

modest changes to 42 USC § 12645g, Criminal history checking: 

1. Amending 42 USC§ 1264Sg(b) and (d) to require for all national service positions (1) 

a nationwide name-based search of the National Sex Offender Public Registry and (2) 

a criminal history search of the FBI fingerprint database, both to be completed prior 

to the start of an individual's service as a national service participant or as a grantfunded staff member; 

2 Semiannual Report to Congress, Audits and Reviews: Corporation Develops Promising New Criminal History Check 

Policy; Further Refinements Needed to Ensure Strong Accountability, at pp. 12-14 (April30, 2015) available at 

https:/lwww.cncsoig.gov/sites/default/files/sar 15-01 O.pdf. 3 Enforcement is also problematic because CNCS's monitoring fails to detect most noncompliance. Monitoring site 

visits to grantees may occur only once every six years. CNCS does not visit most subgrantees and relies on the 

prime grantee (often a State Commission for AmeriCorps) to monitor compliance. Improper payments testing, the 

second way CNCS identifies noncompliance, looks at only a tiny sample of grantees and their criminal history 

checks. 

3 
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2. Adding to 42 USC§ 12645g(c) that an individual is ineligible to serve during any period 

of noncompliance with subsections (b) and (d). 

3. Requiring that, in the case of fixed amount grants, CNCS disallow either a pro rata 

share of the amount awarded per person for each individual whose criminal history 

check is incomplete or untimely, or 25 percent of the value of the education award, 

whichever is greater. 

Taken together, these changes would require CNCS to disallow all costs for an individual 

during a period of noncompliance and generally preclude it from excusing partial 

compliance. These changes should not be burdensome for grantees; the National Sex 

Offender Public Website takes only minutes to search, and CNCS has a contractor that can 

perform the FBI search within days. 

For its part, CNCS should review grantees' criminal history checks more frequently and 

exercise direct oversight of subgrantees' compliance. Not only should CNCS require 

grantees to come into compliance and disallow costs during any period of noncompliance, 

it should perform a follow-up review the next year to ensure that there is no recurrence; 

no such reviews are currently performed, so a grantee may fail to comply year after year 

and still escape detection. Any grantee with repeated noncompliance should be 

disqualified from receiving additional grant funds. These measures must send a 

consistent message that criminal history checking is a high-priority item and that 

violations will not be tolerated, minimized or excused. 

CNCS reports that it is exploring the possibility of engaging one or more vendors to 

perform state criminal history checks, which would relieve grantees of a task that many 

cannot perform successfully. Implementation of such a solution, however, would require 

CNCS to overcome a number of obstacles and constraints and ultimately may not be 

feasible. Deferring action pending such a solution is inadvisable. 

2. The Fiscal Year 2017 Management Challenges Report indicates the Corporation has 

operated in the same inefficient manner since its inception. You advocate for a "radical 

restructuring" of the Corporation- going as far to say "No expert, if given a free hand 

to achieve CNCS's mission on an operating budget of $1 billion per year, would choose 

the constraints, redundancies, and Byzantine structure that characterizes CNCS and its 

programs." Would you elaborate on the reforms needed at the Corporation to ensure 

the effective and efficient utilization of taxpayer funds? 

Response 

CNCS's stovepipe structure impedes agency-wide management, resource allocation and 

flexibility. Agency leaders have limited ability to direct resources strategically as needed 

to meet the overall mission and do not have a portfolio-wide view of their grant risks. 

4 
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Insert offset folio 81 here 24758.081

Differences among programs' oversight and monitoring approaches appear to be 

historical artifacts, rather than reflecting a considered decision about the most costeffective way to meet current and future challenges. Restructuring CNCS should be 

dictated by its mission, strategy, priorities, legal responsibilities, the drivers of success, 

the risks that it will confront and the workforce skills necessary to perform in these areas. 

Even without a comprehensive analysis of these factors, certain structural reforms 

suggest themselves: 

1. Shrink or eliminate the $30 million National Civilian Community Corps and redirect 

a portion of the savings to grantees that perform comparable services, including 

disaster response and recovery, at a fraction of the cost. 4 

2. Consolidate financial oversight of grantees into a single office, rather than 

maintaining two separate grants management operations: the Federal Financial 

Management Center in Philadelphia, PA, which oversees Senior Corps and VISTA; 

and the Office of Grants Management at CNCS's Washington, DC headquarters, 

which oversees AmeriCorps State and National. 

3. Develop a rigorous, risk-based approach to all aspects of grants management, 

from application to closeout, including a cafeteria approach to monitoring, with a 

menu of oversight activities that align to specific risks. 

4. Accelerate the deployment of data analytics to support efficient, risk-based 

monitoring and reduce labor costs. 

S. Centralize programmatic oversight of Senior Corps, thereby eliminating 52 Field 

Liaison offices throughout the United States. Given the small size of the average 

Senior Corps grant, it is unlikely that a risk-based allocation of monitoring 

resources would require program officers in every state. 

6. Alternatively, distribute Senior Corps grants (which are effectively formula-based) 

either as block grants to the states or through the existing AmeriCorps State 

Commissions, and authorize CNCS to award large grants on a competitive basis. 

These changes would require legislation. 

7. Use fixed-amount grants for any awards below a predetermined dollar amount, 

to limit risks and reduce monitoring demands on staff. 

4 For an in-depth discussion of this issue, see Report No. 17-05, Evaluation of the AmeriCorps National Civilian 

Community Corps Program, available at https://www.cncsoig.gov/sites/default/files/17-05 nccc evaluation.pdf. 

5 
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8. Align VISTA (which is part of the AmeriCorps family) with AmeriCorps State and 

National, rather than with Senior Corps, for monitoring purposes. 

9. Monitor (and maintain grant management data) by grantee, as well as by grant 

and program. We understand that the new grants management database will 

enable this. 

10. Standardize the grant application and award processes across programs, so that a 

grantee can simultaneously apply for grants in more than one program. 

11. To the maximum extent practicable, standardize the regulatory requirements and 

monitoring across programs, e.g., eliminate unnecessary differences between 

AmeriCorps grants and VISTA grants. 

12. Directly monitor key risks, such as criminal history checking and prohibited 

activities, rather than relying on prime grantees for subgrantee monitoring. 

13. Outsource administrative support functions, such as procurement, via shared 

services agreements. 

14. Have senior leaders provide stronger oversight (including after-action 

assessments and accountability) of professional services, consulting and research 

study proposals above a predetermined dollar threshold. 5 

3. The OIG closed an investigation in November of 2016 into the Georgia Center for 

Nonprofits (GCN), which found GCN violated the law by improperly utilizing its VISTA 

members when it directed members to perform staff functions and charged clients for 

their services. As a result, the grantee was debarred for two years and ordered to repay 

over half a million dollars in disallowed costs. This illegal activity took place over a sixyear period from 2009 to 2014, which is an unusually long length of time to avoid 

detection if CNCS did indeed employ a functioning risk-based monitoring system. To 

what would you attribute the failure of the Corporation to detect this illegal activity for 

such a long time? What corrective action should the Corporation take to more quickly 

detect and appropriately respond to such illegal activity in the future? 

5 For more information on the elements of effective oversight of such spending, see Report No. 14-09, Audit of 

Blanket Purchase Agreements for Professional Consulting Services, available at 

https:/lwww .cncsoig.gov I sites( default/files/14-09. pdf. 

6 
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Response 

Here, the problem was not detection but rather a staff member's failure to respond to 

repeated allegations and complaints, and CNCS's failure to properly supervise an 

employee described by colleagues as a marginal performer, who had been denied a 

requested transfer to another State Office. Disruption in the employee's personal life, 

the transfer request and its denial should have been treated as performance risk 

indicators and triggered increased supervision. That did not occur. 

The former CNCS Georgia State Program Specialist, who was responsible for primary 

oversight of this VISTA activity, failed to act on numerous complaints from VISTA 

members, purposely omitted significant findings from her monitoring visit reports and 

chose not to alert her supervisors or CNCS-OIG to many of these serious problems. In 

addition to the complaints, documentation furnished by GCN to the Georgia State Office 

showed on its face that VISTA members were expected to perform administrative tasks 

not appropriate for VISTA service. On at least two occasions, the State Program Specialist 

failed to follow instructions from the State Director, and the State Director never followed 

up to see whether her instructions were carried out.6 

Willful misrepresentation or concealment by an employee poses challenges for any 

organization. Here, however, the State Director should have recognized that the Program 

Specialist had "checked out" and supervised her more closely. Spot checks of her work, 

including review of her monitoring visit notes, could have revealed many of the 

complaints on which she failed to act. 

On a more prosaic note, CNCS-OIG has also recommended that VISTA develop a 

standardized complaint form, to be used for every complaint, and require supervisory 

review of responsive actions. CNCS responded that it would consider this. Maintaining a 

trail and accountability for responding to complaints could have enabled earlier discovery 

of the problems at GCN. 

4. Does the OIG track recommendations made to the Corporation and the status of 

these recommendations? If so, please provide a summary of open recommendations 

with the Corporation. 

Response 

CNCS-OIG tracks recommendations made to the Corporation, the status of the 

Corporation's response and the extent to which it has implemented those 

recommendations. With the enactment of the Inspector General Empowerment Act of 

6 The State Director herself had a checkered history at CNCS, having been promoted after she was disciplined for 

misusing travel funds. In fact, while her supervisee was disregarding serious misconduct at GCN, the State Director 

was stealing Federal funds and charging personal expenses to government travel card. She resigned in lieu of 

termination in early 2014. 

7 
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2016, each Semiannual Report now includes a running list of unimplemented 

recommendations. A copy of the most recent list is attached. 

8 

Insert offset folio 85 here 24758.085CEWDOCROOM with DISTILLER

Awards Resulting from 

Compel!lng Personal 

Circumstances 

Amount Grants Program 

grantees to include searches of an individual's maiden, married or former married 

conducting National Service Crimina! History Checks, and revise guidance 

vulnerabilities in fixed amount grant programs by identifying the risk drivers {to indude 

enrollment and retention# drawdowns and non-CNCS resources) and developing 

by which to assess the associated risks. 

with Congressional intent define/establish criteria for the class of small and less 

organizations for whom modest fixed amount grants would be appropriate, 

I Determine the information that should be sought in the application and selection process to 

prudent fixed amount grant award decislons, Including requiring submission of a 

$8Ll,435 

Note 1 

Note 1: Savlngs cann

estimated with preci

potentially significan

lost more than $1 m

single maladminister

amount grant becaus

inadequate monitori

procedures and cont

Insert offset folio 86 here 24758.086CEWDOCROOM with DISTILLER

Commission 

I Benchmark the expected rate of member attrition so that monitoring can focus on grants with 

criteria for elevating seriously troubled grants for attention by senior management, to 

that corrective action plans are successful and accountability is maintained. 

on total program expenditures and/or development 

risk assessments using appropriately weighted criteria that are relevant to the rtsks 

fixed amount grants, including the grantee's ability to contribute funding from non~ the grant costs associated with successive service terms of AmeriCorps members who 

not eligible to serve a second term because they did not receive an evaluation of their first $4,602 

Insert offset folio 87 here 24758.087CEWDOCROOM with DISTILLER

Audit of Blanket Purchase 

Consulting Services 

a standardized entlty-wide decision process for the use of ccnsultlng/prof.essional 

to include and document consideration of (a) the need for the project; {b) speciflclty 

of design; (c} the intended users; (d) any alternative means of accomplishing the 

the project's progress will be monitored and by whom; (f) how quallty, value 

the project will be measured/evaluated, relative to its cost; (g) whether the 

is the best use of CNCS resources, in view of competing needs and priorities 

overall strategy, objectives and priorities; and (h) how the project !inks to CNCS's 

plan and the strategic objectives of the requesting office. Mere availability of funds 

a particular office's budget should not, without more. justify the expenditure. 

committee to review and approve any consulting projects that exceed prethresholds. lndude an Of>S representative on the committee or in an advisory 

review of contractor and subcontractor tost proposals, and maintain 

{appropriate documentation of the review and its conclusions in the contract file. Develop 

a post~performance review of each consulting project to assess lessons learned; 

whether project objectives were met; .and evaluate the impact of the dellverables 

the project, including a cost-benefit ana!ysls. Use the results to maintain 

laocou,nt'lbilitv improve the procurement process. 

$973,594 

Note 2 

Note 2: Savings canno

estimated with precis

likely represent severa

dollars, because a sma

included waste of $89

u-nauthorized commit

$81,331 during a thre

period. 

Insert offset folio 88 here 24758.088CEWDOCROOM with DISTILLER

Service Cooperative 

Agreements Awarded to 

AfYA Incorporated and 

Education Northwest 

share key information about grantee performance/nonperformance across programs and 

risks specific to training and technical assistance cooperative agreements and develop 

to assess them. Consider special terms and conditions. of the cooperative agreement, 

of a grantee's Negotiated Indirect Cost Rate Agreement, fraud risks and deficiencies 

in prior oversight or monitoring of the grantee. 

a rigorous and tested risk~based process for monitoring grants that takes into account 

characteristics of grant types and the risks associated with them. Discontinue the one~size~ that uses criteria applicable to tradltional cost reimbursement grants to assess 

fixed-amount grants and grants for techn!cal training and assistance, Align monitoring 

risk indicators and risk models against outcomes and use outcomes to identify other 

factors that could sharpen the risk analysis. 

Note3 

Note 3: Savings are di

estimate with precisio

represent milllons of d

better grant-making, e

detection of problems 

efficient and effective 

Insert offset folio 89 here 24758.089CEWDOCROOM with DISTILLER

Community Servicers 

Compliance with the 

Improper Payments 

Ellrr!'1nation and Recovery 

Act of 2010 for Fiscal Year 

2015 

!Strengthen internal controls over the Agency Financial Report (AFR) to ensure that the I 

section {Section IV, Other Information) contains each of the elements required by 

Circular No. A-136 and that the reported information is complete and accurate. 

and appropriate statistical methodologies to identify those programs susceptible 

Note4 

improper payments ov

five years. Quantifying 

payments, establishing 

and addressing the roo

are necessary steps to 

those improper payme

Insert offset folio 90 here 24758.090CEWDOCROOM with DISTILLER

Audit of Corporation for 

National & Community 

Service Grants Awarded to 

Hoopa Valley Tribe and 

multiple other reports 

related to Crimina! History 

Checks 

Criminal Hlstory Checks 

(multiple reports) 

Audit for the Corporation 

National and Community 

Service's Fiscal Year 2016 

Financial Statements 

three consecutive fisca! years, indud1ng: submitting a plan to OMB and Congres-s that 

ile milestones for achieving compliance; designating a senior agency offl-clat 

lac,countahle for achieving compliance; and, assessing whether additional funding, program lre;wtl1ori1ation or statutory changes would help bring CNCS into compliance with IPERA. 

penalties for crimina! history check (CHC) violations above the nominal level, so that 

command appropriate attention from grantee leaders, tncentivlze strong risk management I $61.400,000 

deter noncompliance. Discontinue the noMharm-no-fou! approach to CHC noncompliance NoteS 

for CHC noncompliance should reflect: (1) that complete and timely criminal history 

a critical safety measure to protect indiViduals in communities from harm at 

of convicted murderers or sex offenders, not a garden-variety regulatory requ1rement;l 

individuals, grantees and CNCS would face catastrophic consequences if 

allowed a predator to harm an indlvldual in a CNCS-funded program. 

Note 5: Aggregate po

savings based on CNC

projections of improper payments r

FY 2015 Annual Finan

(AFR) for AmeriCorps 

National and FY 2016 

Senior Corps program

both a critical safety p

and a means to reduc

improper payments d

!PERA assessments. 

Insert offset folio 91 here 24758.091CEWDOCROOM with DISTILLER

£valuation of the National 

Civilian Community Corps 

(NCCC) Program 

Modernizing Information 

Technology 

managers in continuing 

enterprlse-wide risk assessment and monitoring process. 

report to further develop responses to the risks identified. Test the 

effectiveness of key internal control to identify and respond to risks, and monltor these 

basis. 

Risk Officer (OCRO) should develop integrated internal control testing with 

!management's responsibilities related to financial management (with an emphasis on grants management}. Federal Information Security Modernization Act /information technology, 

Elimination and Recovery Act compliance, and during audit resolutions of 

audits. 

engage senior management 1n dose oversight of the Grants and Member Management 

I Modernization program, because (1) CNCS lacks a track record for managing projects of this 

magnitude; (2) CNCS programs urgently need better IT support for their 

!operations and oversight; (3) the amounts at risk--more than $40 million--are substantial; (4) the modernization effort has already experienced significant delays; {5) there are no release dates 

and 3 of the plan; and (6) IT development and acquisition projects are recognized 

lthrowthout the Federal government as carrying high risk. 

duplicative oversight structures and reorganize for risk-/portfolio-based grant 

Note7 

Notes 

Note 6: Based on red

40 percent of NCCC's f

Note 7: Savings diffic

quantify with precisio

likely substantial for r

stated. 

Note 8: Potentially su

savings to be realized 

consolidation of mon

Insert offset folio 92 here 24758.092CEWDOCROOM with DISTILLER

and communicate publicly a clear explanation of what constitutes "abortion services" 

within the meaning of the statutory prohibition, then formalize this guidance 

rulemaklng. 

the abort! on prohibitions broadly to bar services or activities directed at abortion, 

whether any of the other "prohibited activities" require e)(p!anation, clarification or 

,_, JGuidance should include instructions as to what grantHfunded personnel may and may not do 

asked for prohibited assistance or to perform a prohibited activity. 

shoufd make clear that avoidance of prohibited activities must be treated as a top 

and that a grantee proceeds at its peril if it undertakes any activities that potentially 

on prohibited activities without first obtaining written guidance from CNCS, 

the new guidance about the abortion prohibitions to grantees/subgrantees whose 

loroe:rammatlt activities place them at elevated risk of encountering issues related to the 

restrictions, including those whose service activities involve providing healthcare to 

girls of childbearing age, as well as those with service activities directed at educationl 

of girls and young women middle school-aged and above, 

onllne training for grantees at elevated risk regarding the abortion 

Insert offset folio 93 here 24758.093CEWDOCROOM with DISTILLER

in accessible language, perhaps using the MyAmeriCorps PortaL 

during the grant application process whether an applicant is at particular risk for one 

specific prohibited activities. If so, require the grantee to develop customized ways to 

compliance with that prohibition, including detection controls. Incorporate the 

lin formation into the monitoring plan and target CNCS monitoring activities accordingly and 

the effectiveness of the measures taken by the grantee. 

Note 9 

Note 9: Savings difficu

quantify with precision 

likely substantial given 

CNCS's grant portfolio. 
[Whereupon, at 12:06 p.m., the subcommittee was adjourned.] 

Æ 


Insert offset folio 94 here 24758.094CEWDOCROOM with DISTILLER

Modernization Act Eva!uatlon 

and Community Service 

fY 14-I'ISfVIA-~IfRl) Weaknesses with the Corporation's Security Planning and Assessment Process {FV 14-FJSMA·NFR 10) 

Inadequate Control Over Remote Access {FY 14~F!SMA~NFR Inadequate Disaster Recovery P!an Documentation and Planning {FY 14-FISMA~NFR 14) 

Access Controls Over the Corporation's Network and Momentum Fmandal User A<:cou;nts Ne1ed 

Inaccurate lnv<,ntc>ry c1f Pl1ysical llnform<!tio>n Te"hrrolof:l 1>sse:t(fY 15-f'ISfVIA-'ifR ·4) 

Needlmprovemer1t (FY16-

i• Insufficient Mon1torlng and Remediation of Server Backup Failures {FY 16-l'l5lv1A-~JFR2) Note 

Note 10: Given the co

of :a security breach, t

savings associated wi

strengthening 1T secu

:substantial.