GRANTS 

MANAGEMENT

Monitoring Efforts by 

Corporation for 

National and 

Community Service 

Could Be Improved

Report to Congressional Requesters

March 2017

GAO-17-90

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-90, a report to 

congressional requesters

March 2017

GRANTS MANAGEMENT

Monitoring Efforts by Corporation for National and 

Community Service Could Be Improved

What GAO Found

The Corporation for National and Community Service (CNCS) assesses its 

grants before the beginning of each fiscal year and prioritizes its grant monitoring 

based on the scoring of certain indicators, such as potential performance or 

financial problems and the length of time since the last compliance visit. For 

fiscal year 2015, CNCS identified about 2,200 grants for assessment and 

prioritized 16.4 percent for compliance visits and 5.4 percent for other types of 

visits and financial reviews. In addition, each year CNCS selects a sample of 

grant records to review for improper payments.

CNCS’s process for grant monitoring is not fully aligned with the internal controls 

for identifying, analyzing, and responding to risks (see fig.). Specifically, because 

CNCS’s assessment process does not include all grants, risks may go 

unidentified. Further, the assessment process uses a scoring model of 19 

indicators to analyze and prioritize grants for monitoring visits rather than to 

identify the highest-risk grants. For example, multiple financial risks are grouped 

together under one indicator, including for improper payments, and a grant found 

to have such risks would not be scored as high priority for monitoring based on 

this indicator alone. In addition, while nearly half of CNCS grant dollars are 

passed through to other organizations (referred to as subrecipients) and 

evidence indicates that subrecipient oversight is a key risk area, CNCS’s 

monitoring of grantees’ oversight of subrecipients is limited, leaving the agency’s 

response to risk vulnerable in this area. 

Areas for Improvement in CNCS’s Grant Monitoring Process

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 suggest. CNCS’s workforce management 

activities to address vacancies have been largely ad-hoc, including vacancies in 

a key office responsible for grant monitoring, at senior levels across the agency, 

and among program and grant officers. Some of these vacancies reduced the 

number of fiscal year 2015 monitoring activities conducted. Further, 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

they had not developed a strategic workforce planning process because of 

limited resources. Without such a process, CNCS’s efforts to address workforce 

challenges may continue to be ad hoc and reactive.

View GAO-17-90. For more information, 

contact Allison Bawden at (202) 512-7215 or 

bawdena@gao.gov

Why GAO Did This Study

Created in 1993, CNCS distributes 

about $750 million in grants annually to 

volunteer and national service 

programs for needs ranging from 

disaster recovery to improving 

education. A 2014 CNCS Office of 

Inspector General (OIG) report cited 

problems with grant management. 

GAO was asked to review CNCS's 

efforts to improve its grant monitoring.

This report examines (1) CNCS’s 

process for grant monitoring; (2) the 

extent that this process aligns with 

relevant internal controls for identifying, 

analyzing, and responding to risk; and 

(3) the extent that CNCS has the 

capacity necessary to monitor 

grantees’ compliance with grant 

requirements. GAO reviewed agency 

documents for fiscal years 2015 and 

2016; analyzed fiscal year 2015 

assessment and monitoring data (the 

most recent complete year of data 

available); interviewed agency officials 

and a nongeneralizable sample of 

program and grant officers who had 

experience with grants with negative 

outcomes, such as greater-thanexpected monitoring needs or audit 

findings; and held discussion groups 

with a small nongeneralizable number 

of grantees attending two 2016 training 

conferences.

What GAO Recommends

GAO is making six recommendations 

to CNCS, including to ensure that all 

grants are assessed for risk and that 

its scoring model prioritizes risk; to 

review its monitoring protocols; and to 

develop a strategic workforce planning 

process. CNCS and CNCS OIG 

provided technical comments, which 

were incorporated as appropriate.
Page i GAO-17-90 CNCS Grants Management

Letter 1

Background 4

CNCS Has a Process for Assessing Grants Annually to Prioritize 

Various Monitoring Activities 8

CNCS’s Process Is Not Fully Aligned with Internal Controls for 

Risk Assessment, Control Activities, and Monitoring 15

CNCS’s Monitoring Capacity Needs Are Unclear Because It Has 

Not Conducted Strategic Workforce Planning 27

Conclusions 34

Recommendations for Executive Action 35

Agency Comments 36

Appendix I State-by-State Data on Corporation for National and Community 

Service (CNCS) Grants 37

Appendix II GAO Contact and Staff Acknowledgments 39

Tables

Table 1: Select Data on Grant Programs Funded by CNCS, Fiscal 

Year 2015 5

Table 2: Number of CNCS Grants with Select Monitoring Activities 

Planned and Conducted in Fiscal Year 2015, by Program 12

Table 3: CNCS Monitoring Provisions for Subrecipient Oversight 24

Table 4: Variation in CNCS Program and Grant Officer Training 

Opportunities, by Office 32

Table 5: Number of CNCS Projects and Volunteers, and Funding 

by State, Fiscal Year 2016 37

Figures

Figure 1: Organizational Chart of CNCS Grant Assessment and 

Monitoring Staff 7

Figure 2: CNCS’s Grant Monitoring Process 8

Figure 3: Percentage of Fiscal Year 2015 Grants Assigned 

Various Priority Levels in CNCS’s Annual Assessment 

Process, by Program 10

Figure 4: Internal Control Principles Relevant to Identifying and 

Responding to Risk, and to Monitoring 15

Contents
Page ii GAO-17-90 CNCS Grants Management

Figure 5: Indicators of Potential Grant Vulnerabilities Assessed by 

CNCS and Their Relative Weight in Points 17

Abbreviations 

CNCS Corporation for National and Community Service

ERM Enterprise Risk Management

IPERA Improper Payments Elimination and Recovery Act of 2010

IT information technology

OCRO Office of the Chief Risk Officer

OIG Office of Inspector General 

OMB Office of Management and Budget

SIF Social Innovation Fund

VISTA Volunteers in Service to America

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Page 1 GAO-17-90 CNCS Grants Management

441 G St. N.W.

Washington, DC 20548

March 21, 2017

The Honorable Jason Chaffetz

Chairman

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable Mark Meadows

Chairman

The Honorable Gerald E. Connolly

Ranking Member

Subcommittee on Government Operations

Committee on Oversight and Government Reform

House of Representatives

Created in 1993, the Corporation for National and Community Service 

(CNCS) administers a variety of volunteer and national service programs 

for needs ranging from disaster recovery to improving education.1 In fiscal 

year 2015, CNCS administered grants totaling about $750 million to 

support national service, and CNCS reported that nearly 350,000 

Americans participated in its major programs. 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. However, recent reports 

from the CNCS Office of Inspector General (OIG) have cited problems 

with the agency’s grants management, noting that the agency does not 

have a comprehensive risk management strategy and that its grant 

monitoring system is inefficient and ineffective.2 You asked us to review 

CNCS’s efforts to improve its grant monitoring. In this report, we examine 

(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 

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

Stat. 785, 873.

2 See for example, Office of Inspector General for the Corporation for National and 

Community Service, Fiscal Year 2017 Management Challenges (Washington, D.C.: 

December 2016); and Fiscal Year 2014 Semi-Annual Report No. 1 (October 1, 2013 -

March 31, 2014).

Letter
Page 2 GAO-17-90 CNCS Grants Management

CNCS has the capacity necessary to monitor grantees’ compliance with 

grant program requirements.3

To describe CNCS’s process for grant monitoring and improvements 

under way, we reviewed agency documents, including policies, 

procedures on assessment and monitoring, and reports from the CNCS 

OIG for fiscal years 2015 and 2016. We also analyzed assessment and 

monitoring data from eGrants, CNCS’s system of record for grant 

monitoring activities, to identify the number of grants prioritized for 

monitoring and the number and types of monitoring activities conducted 

during fiscal year 2015 (the most recent complete fiscal year of data at 

the time of our analysis). We determined that CNCS’s processes have 

generally not changed since fiscal year 2015, and as a result, that the 

data were reliable for the purpose of illustrating aspects of CNCS’s 

current approach to grant monitoring.4 To further understand CNCS’s 

monitoring processes and any efforts under way to improve monitoring, 

we also interviewed agency officials in the Office of the Chief Risk Officer

(OCRO), Office of Grants Management, and Field Financial Management 

Center, as well as officials from CNCS’s four largest programs, and 

observed a compliance visit of a grantee in South Bend, Indiana, selected 

based on geographic location from a list of visits to be conducted in late 

summer 2016. Views of the program officials and observations from the 

compliance visit are not generalizable to all programs or grantees.

To evaluate the extent to which CNCS’s grant monitoring process and 

plans for improvement align with relevant internal controls for identifying, 

analyzing, and responding to risk, 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, 

 3 You also asked us to review CNCS’s information technology (IT) modernization, 

including its status and alignment with the agency’s needs for system functionality to 

support its grant monitoring process. We plan to present the results of our study on IT 

modernization in a forthcoming report.

4 To test eGrants data reliability, we reviewed related documentation and conducted 

electronic testing for missing data, outliers, and obvious errors. CNCS also provided data 

on the number of active grants for fiscal year 2015 and their funding amounts. However, 

CNCS could not provide funding data at the individual grant level for fiscal year 2015, and 

we were unable to resolve inconsistencies between data on fiscal year 2015 active grants 

and data from CNCS’s assessment and monitoring activities. As a result, we determined 

that eGrants data on the number of active grants and funding amounts for individual 

grants were not reliable for our purposes.
Page 3 GAO-17-90 CNCS Grants Management

control activities, and monitoring.5 We compared CNCS’s process—as 

documented in policies, procedures, and plans—against these principles. 

We also compared CNCS’s process with effective practices in federal 

grants management, identified in prior GAO work.6 To obtain examples of 

how CNCS’s monitoring activities can help identify and mitigate grantee 

risk, we examined a small judgmental, nongeneralizable sample of eight 

grants from those that eGrants data identified as having additional 

monitoring needs, that were terminated early, or that OIG had cited as 

having audit findings. We selected these eight grants to reflect a range of 

different programs, geographic locations, and CNCS priority designations. 

We then conducted semi-structured interviews with the seven program 

officers and four grant officers responsible for monitoring these eight 

grants. To gather grantee perspectives on CNCS’s assessment and 

monitoring process, we also conducted four discussion groups with 

grantees from two CNCS programs (AmeriCorps and Senior Corps) in 

attendance at two 2016 agency-sponsored training conferences: one in 

Reno, Nevada, and the other in Springfield, Massachusetts. We also 

interviewed two grantees representing AmeriCorps State and National 

(one state commission, and one grantee that operates in several states) 

as well as officials from two professional associations that include CNCS 

grantees: The National Council of Nonprofits and America’s Service 

Commissions.7 The perspectives gathered from these interviews with 

grantees and grantee organizations are not generalizable.

 5 GAO, Standards for Internal Control in the Federal Government, GAO-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.

6 The underlying source of these effective practices was also primarily based on an 

analysis of federal internal control standards (Standards for Internal Control in the Federal 

Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: Nov. 1999).These effective 

practices are described in GAO, Grant Monitoring: Department of Education Could 

Improve Its Processes with Greater Focus on Assessing Risks, Acquiring Financial Skills, 

and Sharing Information, GAO-10-57 (Washington, D.C.: Nov. 19, 2009); Recovery Act: 

States’ and Localities’ Current and Planned Uses of Funds While Facing Fiscal Stresses, 

GAO-09-829 (Washington, D.C.: Jul. 8, 2009); and Federal Grants: Improvements 

Needed in Oversight and Accountability Processes, GAO-11-773T (Washington, D.C.: 

June 23, 2011).

7 We selected a state commission involved in planning the training conferences, and one 

grantee that operates in several states and thus had experience with multiple state 

commissions. We selected the National Council of Nonprofits so that we could discuss 

how CNCS grants differ from other federal grant programs; and we selected America’s 

Service Commissions because of its work with state commissions, which receive 

AmeriCorps funds.
Page 4 GAO-17-90 CNCS Grants Management

To evaluate the extent to which CNCS has the necessary capacity 

(people and resources) to effectively monitor grantee compliance, we 

assessed CNCS’s workforce management efforts against key principles 

for effective strategic workforce planning identified in prior GAO work.8

We also reviewed CNCS’s training practices against the federal internal 

control standard relevant to workforce planning and competence9 and our 

guide for assessing strategic training and development efforts.10 We 

obtained CNCS documents regarding its workforce status and needs, and 

analyzed eGrants data on the number of monitoring activities completed 

in fiscal year 2015.

We conducted this performance audit from November 2015 to March

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

CNCS provides grants and technical assistance to organizations 

throughout the United States to strengthen communities and foster civic 

engagement.11 In fiscal year 2015, CNCS received appropriations totaling 

over $750 million to fund a variety of grant programs, as shown in table 

1.12 CNCS grants are typically for multiple years in duration.

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

GAO-04-39 (Washington, D.C.: Dec. 11, 2003). In this work, we identified key principles 

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

workforce planning organizations and federal agency workforce planning practices. 

9 GAO-14-704G, Principle 4: Management should demonstrate a commitment to recruit, 

develop and retain competent individuals.

10 GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: Mar. 1, 2004). We 

obtained the information in this guide through consultations with government officials and 

experts in the private sector, academia, and nonprofit organizations; examinations of laws 

and regulations related to training and development in the federal government; and by 

reviewing the sizeable body of literature on training and development issues, including 

previous GAO products on a range of human capital topics.

11 See appendix I for the amount of grant funds received by, and the number of volunteers 

serving in, each state in fiscal year 2016.

12 CNCS’s total appropriation for fiscal year 2015 was about $1.1 billion. 

Background
Page 5 GAO-17-90 CNCS Grants Management

Table 1: Select Data on Grant Programs Funded by CNCS, Fiscal Year 2015 

Program Grantees and purpose

Appropriation

(inimillions)

Number of 

grantsa Number of volunteersb

AmeriCorps State and 

National

Provides grants to nonprofit, public, and other 

organizations to address community needs. Many 

grants are made to state service commissions, 

which make subgrants to organizations to operate 

AmeriCorps programs. 

$335.4 383 69,000

Senior Corps

(Foster Grandparent, 

Retired and Senior 

Volunteer, and Senior 

Companion programs)

Provides grants to help fund a network of 

organizations sponsoring projects staffed by 

volunteers aged 55 and older to meet community 

needs.

$202.1 1,175 270,000

Volunteers in Service 

to America (VISTA)

Provides grants to community organizations to 

help create and expand antipoverty programs. 

VISTA grants include projects in which CNCS 

awards a certain number of positions to a 

sponsoring organization and provides benefits 

directly to VISTA volunteers. No financial 

resources are provided by CNCS; however, CNCS 

includes these projects in its grant monitoring 

efforts.

$92.4 783c 7,800

Social Innovation 

Fund

Provides grants to identify, validate, and grow 

promising approaches to challenges facing local 

communities.

$70.0 19 Not applicabled

Other grant programs Provide grants for other purposes. $53.4 49 13,000

Total $753.3 2,409 346,800

Source: GAO analysis of Corporation for National and Community Service (CNCS) documents. | GAO-17-90

a

The number of grants is based on CNCS counts of grants as of August 20, 2014, that were expected 

to be active in fiscal year 2015. Of the total number of grants, at least 191 were new for fiscal year 

2015; the rest of the grants had been awarded previously.

b

The number of volunteers is based on CNCS’s approximate counts of volunteers (also called 

“members” or “participants”) as reported in its Agency Financial Report for fiscal year 2015.

c

Data on the number of VISTA grants include all grants, including zero-dollar grants. According to 

CNCS officials, zero-dollar grants provide the authorization for a grantee to operate a VISTA 

program, but these programs do not receive operational funds from CNCS.

d

The Social Innovation Fund does not have volunteers in the same way as other grant programs. 

Instead, the fund works with and through existing grantmaking institutions, or “intermediaries,” to 

direct resources to nonprofit organizations and state and local government entities, or “subgrantees,”

focused on youth development, economic opportunity, and healthy futures.

In 1993, the National and Community Service Trust Act of 1993 was 

enacted,13 which created CNCS and established the AmeriCorps State 

and National grant programs. This law also gave the agency responsibility 

 13 Pub. L. No. 103-82, 107 Stat. 785.
Page 6 GAO-17-90 CNCS Grants Management

for administering VISTA and Senior Corps. In 2009, the Serve America 

Act was enacted,14 which gave CNCS responsibility to administer several 

newly-established programs including the Social Innovation Fund. This 

act also directed CNCS to focus more on evaluating its programs’

performance, and in 2012 we reported on the extent to which CNCS 

funded activities were covered by its performance measures and on 

performance measurement challenges.15 In addition, the Serve America 

Act generally requires that grantees conduct criminal history checks on 

volunteers and program employees in national service programs. Criminal 

history check regulations have been in effect since November 2007 and 

were expanded after the enactment of the Serve America Act to all 

national service programs. Beginning April 21, 2011, the law generally 

required that entities conduct three-part checks—including Federal 

Bureau of Investigation, statewide registry or repository, and sex offender 

registry checks—on individuals who will have recurring contact with 

vulnerable populations.

CNCS’s Chief Risk Officer, Chief of Program Operations, and Chief 

Financial Officer share responsibility for assessing and monitoring the 

agency’s grants. Program officers and grant officers implement grant 

monitoring activities and review grant applications. Program officers, 

located in program offices overseen by the Chief of Program Operations, 

focus on issues related to grantee performance and compliance with 

program objectives. Grant officers, overseen by the Chief Financial 

Officer, focus on grantees’ financial issues and performance. (See fig. 1.)

 14 Pub. L. No. 111-13, 123 Stat. 1460.

15 GAO, Measuring Performance: The Corporation for National and Community Service

Faces Challenges Demonstrating Outcomes, GAO-12-310 (Washington, D.C.: Feb. 17, 

2012).
Page 7 GAO-17-90 CNCS Grants Management

Figure 1: Organizational Chart of CNCS Grant Assessment and Monitoring Staff

Note: Every state and territory is represented by a CNCS State Office, which is a federal office staffed 

by federal employees. Among other things, these offices conduct public outreach and program 

support and are also responsible for overseeing all of the projects for two CNCS programs, Senior 

Corps and VISTA, within their states.

Federal law requires federal agencies administering programs identified 

as susceptible to improper payments to estimate the improper payments 

made by those programs and report annually on their efforts to reduce 

improper payments.16 An improper payment is defined by statute as any 

payment that should not have been made or that was made in an 

incorrect amount (including overpayments and underpayments) under 

statutory, contractual, administrative, or other legally applicable 

requirements. In addition, the Office of Management and Budget’s (OMB) 

guidance instructs agencies to report as improper payments any 

 16 Pub. L. No. 107-300, 116 Stat. 2350, as amended, codified as amended at 31 U.S.C. § 

3321 note. 
Page 8 GAO-17-90 CNCS Grants Management

payments for which insufficient or no documentation was found.17 Since 

fiscal year 2012, the OIG has reported annually that the agency faced 

challenges complying with improper payment laws.18 For example, the 

OIG found that CNCS did not complete valid fiscal year 2015 improper 

payment assessments for two of its programs: Senior Companion 

Program (a Senior Corps program) and Social Innovation Fund.19

CNCS program and grant officers are responsible for implementing the 

agency’s grant monitoring process, which includes activities from the time 

before the grant award is made to when the grant is closed out, as shown 

in figure 2.

Figure 2: CNCS’s Grant Monitoring Process

Note: CNCS has a separate process for estimating and monitoring for improper payments.

Pre-Award. According to CNCS policy, during the pre-award phase 

(before CNCS makes a grant award), grant officers are to assess the 

applicant’s financial management capabilities and other aspects, such as 

whether the grantee has any open audit findings on any current or prior 

grants. CNCS officials generally are to perform these reviews before 

 17 OMB, Memorandum No. M-15-02, Appendix C to Circular No. A-123, Requirements for 

Effective Estimation and Remediation of Improper Payments (Oct. 20, 2014), p.7.

18 For example, see Office of Inspector General for the Corporation for National and 

Community Service, Performance Audit of the Corporation for National and Community 

Service’s Compliance with the Improper Payments Elimination and Recovery Act of 2010 

(IPERA) for Fiscal Year 2015, OIG Report 16-04 (Washington, D.C.: May 13, 2016).

19 OIG Report 16-04, p. 5-6.

CNCS Has a Process 

for Assessing Grants 

Annually to Prioritize 

Various Monitoring 

Activities
Page 9 GAO-17-90 CNCS Grants Management

making an award to a new or current grantee to determine if the grant 

should be made.

Annual Assessment. To implement the annual assessment (performed 

between August and October) CNCS personnel are to take the following 

steps:

• Step 1: determine which grants will be assessed. The universe of 

grants to be assessed is to include all grants that are active at the 

time CNCS is ready to begin the assessment, typically in mid-August 

of each year, and that are expected to be active during the following 

fiscal year.

• Step 2: assess each grant in the universe identified in step 1 for 

potential vulnerabilities related to program compliance, financial 

weakness, or other issues.

• Step 3: rate each grant as a high-priority, medium-priority, or lowpriority for various monitoring activities, based on the assessment in 

step 2.

• Step 4: prepare an annual monitoring plan that identifies which grants 

will receive monitoring visits, desk reviews, or financial reviews during 

the coming year, based on the ratings in step 3. The plan is to be 

prepared by the end of October.

More specifically, during step 2 of the annual assessment phase, CNCS 

program and grant officers are to jointly assess each grant on 19 criteria 

that are intended to reflect potential vulnerabilities related to program 

compliance, financial weakness, or other issues. They are to enter their 

responses into eGrants, which applies certain weights to each criterion 

and calculates a score for each grant, up to a possible total of 760 points. 

During step 3, CNCS officials group grants into three categories based on 

the grant’s total score to determine the grant’s monitoring priority: highpriority (150 points or more), medium-priority (80 to 149 points), and lowpriority (0 to 79 points). According to CNCS policy, each grant recipient 

must generally receive a compliance visit by either the program or grant 

officer every 6 years, so the grant is to be rated high priority for 

monitoring if 5 years or more have elapsed since the last visit. Also, if a 

grant receives a high-priority rating, CNCS program officers must 

generally conduct a compliance visit, or an on-site training and technical 

assistance visit in the upcoming fiscal year. If a grant receives a mediumor low-priority rating, CNCS program officers can conduct a visit, with 

supervisory approval, if they determine that it could help address known 

issues or help prevent future problems.
Page 10 GAO-17-90 CNCS Grants Management

To illustrate CNCS’s process, we reviewed CNCS grant data for fiscal 

year 2015 (the most recent complete fiscal year of data available at the 

time of our review). We found that in August 2014, CNCS had identified a 

universe of 2,188 grants that were active at the time and expected to be 

active during fiscal year 2015, and had assessed these grants to plan its 

monitoring activities for fiscal year 2015. As shown in figure 3, CNCS 

rated about 14 percent of these grants overall as high-priority for 

monitoring, with some variation across the agency’s grant programs. For 

example, 17 percent of AmeriCorps State and National grants included in 

the assessment were rated high-priority, compared to 9 percent of VISTA 

grants.

Figure 3: Percentage of Fiscal Year 2015 Grants Assigned Various Priority Levels in CNCS’s Annual Assessment Process, by 

Program

Note: The priority levels were assigned during August 2014 to grants expected to be active during 

fiscal year 2015, in the programs shown. CNCS also rated eight fiscal year 2015 grants in other 

programs as high-priority.

Finally, during step 4 of the annual assessment phase, CNCS officials are 

to set the monitoring plan—which consists of compliance and other types 

of visits, desk reviews, and financial reviews (such as drawdown 

analyses)—for the fiscal year.20 A compliance site visit occurs on-site 

where the grantee does its work, and reviews a wide range of compliance 

 20 Other monitoring activities include reviews of grantee progress reports and financial 

reports, as well as routine communications (phone calls and emails) with grantees.
Page 11 GAO-17-90 CNCS Grants Management

issues following a structured protocol. Other types of visits which may be 

included in the monitoring plan include:

• follow-up visits, conducted to follow-up on a previous compliance site 

visit, desk review, or a targeted / issue-based site visit;

• targeted / issue-based site visits, conducted to address specific 

issues, such as observing CNCS providers delivering 

training/technical assistance services; and

• training and technical assistance visits, conducted when the grantee 

is a new grant recipient or there is a new program director, among 

other situations.21

Desk reviews also address compliance issues and can be targeted or 

comprehensive in scope. For example, a program officer may conduct a 

desk review of a grantee’s AmeriCorps position description to ensure the 

description complies with legal requirements and agency policy. 

Drawdown analyses are financial reviews that are conducted to determine 

whether certain grantees are drawing down their funds in a timely manner 

and whether the rate at which they draw down their funds is consistent 

with the length of time (period of performance) for their award.22 For 

example, if a grant has completed 50 percent of its period of 

performance, then one would expect to see about 50 percent of funds 

drawn down.

Monitoring. During the monitoring phase (performed between October 

and August), program and grant officers generally are to implement the 

monitoring activities described in the plan, but can either add or omit an 

activity with supervisory approval for a number of reasons. For example, 

program and grant officers may consider adding a monitoring activity for a 

grant after the initial monitoring plan is set based on issues such as that

 21 According to agency guidance, CNCS personnel may also conduct “opportunity” visits 

which are scheduled because of the economy and efficiency of making the trip, such as 

due to the recipient’s proximity to other scheduled monitoring or other CNCS activities.

22 According to agency guidance, CNCS uses drawdown analyses on full-time, fixedamount grants. The Serve America Act authorized CNCS to award fixed-amount grants 

which allow programs to apply for a fixed-amount per individual enrolled in the program. 

Under fixed-amount grants, grantees do not have an approved budget in their grant award 

and do not have specific restrictions on the use of the grant funds because the amount of 

the grants will be significantly less than the cost of conducting the program. Grantees can 

only draw all of the funds awarded if all members participate for the requisite number of 

hours. CNCS uses drawdown analyses to monitor these grants to help ensure that 

grantees do not draw more funds than allowed.
Page 12 GAO-17-90 CNCS Grants Management

the OIG has identified findings with the grantee suggesting that the 

grantee might be spending grant funds inappropriately. Also, CNCS 

officials told us there are instances when a compliance visit is canceled, 

which creates an opportunity to add a grant to the site visit schedule. To 

illustrate, our analysis of CNCS grant data for fiscal year 2015 indicates 

that the initial monitoring plan called for 358 grants to receive a 

compliance visit; by the end of the fiscal year, 385 had been conducted 

(see table 2). Most compliance visits were conducted with Senior Corps 

and VISTA grants (programs with the highest number of grants).

Table 2: Number of CNCS Grants with Select Monitoring Activities Planned and Conducted in Fiscal Year 2015, by Program

Number of grants

With a compliance visit

With a follow-up 

compliance visit or a 

training or technical 

assistance visit With a desk review

With a draw-down 

analysisb

Program

Included in 

the annual 

assessmenta Planned Conducted Planned Conducted Planned Conducted Planned Conducted

AmeriCorps 

State and 

National 377 32 26 13 9 6 7 78 74

Senior 

Corps 1051 210 233 15 18 0 0 0 0

Social 

Innovation 

Fund 18 14 15 2 1 0 1 0 0

VISTAc 712 95 103 4 5 0 0 0 0

Other 30 7 8 1 2 0 1 0 0

Total 2188 358 385 35 35 6 9 78 74

Source: GAO analysis of Corporation for National and Community Service (CNCS) data.| GAO-17-90

a

CNCS conducts an annual assessment of grants to determine their priority for various monitoring 

activities. In fiscal year 2015, CNCS conducted monitoring activities on some grants that were not 

included in the annual assessment, such as activities planned but not conducted in the prior year.

b

Drawdown analyses are financial reviews that are conducted to determine whether grantees are 

drawing down their funds in a timely manner and whether the rate at which they draw down their 

funds is consistent with the length of time (period of performance) for their award.

c

The number of VISTA grants includes projects that award a certain number of positions to a 

sponsoring organization, but no financial resources, and CNCS includes the projects carried out by 

VISTA volunteers in its monitoring efforts.

When conducting a compliance visit, CNCS personnel—typically the 

program officer—are to use a standard protocol to interview grantee staff 

regarding compliance with program regulations and policy, including 

financial accounting for grant funds. During these interviews, CNCS 
Page 13 GAO-17-90 CNCS Grants Management

personnel also are to review grantee documentation indicated by the 

protocol to verify compliance. For example, program officers may ask 

grantee staff how they are complying with the criminal history background 

checks required by the Serve America Act, and may ask for 

documentation such as reports received from law enforcement agencies.

Close-out. Finally, the close-out phase is to take place at the end of a 

grant’s performance period. During this phase, CNCS officials are to 

close out the grant by reviewing the recipient’s transactions and 

expenditures reports, and reconciling them with records on the amounts 

disbursed under the grant. Grantees may also submit a final 

programmatic report of activities under the grant.

Improper payments. CNCS has a separate process for estimating 

improper payments,23 although many of the items reviewed during 

traditional grant monitoring are also reviewed during improper payment 

reviews. To determine the extent of improper payments being made 

through its grant programs, CNCS’s process calls for selecting a random 

sample of Federal Financial Reports (the standard form approved by 

OMB that federal agencies use to collect financial information) from each 

program. The sampling is conducted such that records with a higher 

dollar value have a proportionally higher chance of being included. For 

each sampled Federal Financial Report, CNCS selects transactions and 

reviews and tests related documentation in place at the time of the 

payment. Because most of CNCS’s grant funds go to personnel-type 

costs, CNCS primarily evaluates payments by grantees to individuals 

working for or serving with that grantee, and verifies the eligibility of the 

individual to receive those payments according to law, based on the 

documentation produced at the time of the review. If all the required 

documentation is not provided, the payment is considered an improper 

payment in the estimation process. For example, in fiscal year 2015, 

based on documentation provided during the improper payment review, 

the Americorps State and National program was estimated to have $14.5 

million in improper payments, mostly due to lack of documentation 

confirming that criminal history checks were completed prior to making 15 

payments to individuals. However, subsequent to the review, CNCS 

confirmed that in several cases, individuals receiving payments were fully 

eligible at the time of payment even though the criminal history check was 

 23 As of fiscal year 2016, the Office of the Chief Risk Officer (OCRO) is responsible for 

conducting the improper payment review. Prior to this, the Office of Accountability and 

Oversight was responsible. 
Page 14 GAO-17-90 CNCS Grants Management

not yet complete, and that although some individuals received payment 

prior to their documentation being provided, no payments were made to 

ineligible individuals.

In a 2016 report,24 the OIG recommended that CNCS take action to 

improve its methodology and reporting on improper payments, as well as 

to implement procedures to hold grantees accountable for providing 

documentation. In response, CNCS said it would take several steps to 

improve its process for estimating improper payments, such as updating 

its statistical sampling plan and revisiting the improper payment testing 

and reporting approach, and developing more training. In addition, as of 

fiscal year 2016, responsibility for conducting reviews and other activities 

pursuant to improper payment laws was moved to the newly established 

Office of the Chief Risk Officer (OCRO). Created in fiscal year 2016, the 

OCRO is now responsible for overseeing and collaborating 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.25 The 

OCRO is also responsible for developing and for delivering select training 

and providing technical guidance and support to CNCS staff regarding the 

implementation of the annual assessment.

In addition, according to CNCS officials, further changes to the grant 

monitoring process are anticipated as the agency implements Enterprise 

Risk Management (ERM). In 2014, OMB recommended that agencies 

consider adopting ERM, which is an approach for addressing the full 

spectrum of risks and challenges related to achieving the agencies’

missions.26 In 2016, OMB issued the revised Circular No. A-123, which 

required that agencies begin to implement ERM in fiscal year 2017.27

 24 OIG Report 16-04, pp.2-3.

25 Prior to creation of the OCRO, the Office of Accountability and Oversight was 

responsible for grant monitoring and improper payment reviews. 

26 OMB, Preparation, Submission, and Execution of the Budget, OMB Circular No. A-11,

(2014), p. 270-13.

27 OMB, Management’s Responsibility for Enterprise Risk Management and Internal 

Control, OMB Circular No. A-123 (revised 2016).
Page 15 GAO-17-90 CNCS Grants Management

CNCS’s grant monitoring process includes efforts to identify and mitigate 

risks but does not fully align with relevant internal control principles for 

risk assessment, control activities, and monitoring (see fig. 4).28

Specifically, the agency’s annual assessment process may not result in 

the riskiest grants receiving a high-priority for monitoring because of 

limitations in its scoring model. Also, the annual assessment process 

does not ensure all grants are included. Further, the agency’s monitoring 

of grantees’ oversight of subrecipients is limited. Finally, CNCS has not 

systematically evaluated its monitoring efforts to identify opportunities to 

improve its assessment of and response to risks.

Figure 4: Internal Control Principles Relevant to Identifying and Responding to Risk, and to Monitoring

CNCS’s indicators used in its scoring model have limitations that may 

result in the riskiest grants not receiving a high priority designation for 

monitoring and that do not meaningfully cover all identifiable risks, such 

as fraud and improper payments. This is largely because the scoring 

model is designed to support CNCS’s monitoring policy by identifying 

grants due for a monitoring visit, rather than for specifically assessing risk 

and using this risk information to drive prioritization of monitoring 

 28 GAO-14-704G, Principles 6 through 9.

CNCS’s Process Is 

Not Fully Aligned with 

Internal Controls for 

Risk Assessment, 

Control Activities, and 

Monitoring

Limitations in CNCS’s 

Scoring Model Affect 

Identification and 

Monitoring of Risk
Page 16 GAO-17-90 CNCS Grants Management

activities. To this end, we found that CNCS’s process for assessing and 

monitoring its grant portfolio has a number of limitations that prevent it 

from being fully aligned with the internal control standard stating that 

management should identify, analyze, and respond to risks related to 

achieving the defined objectives.29

First, we found that 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—far less than the 150 points needed to 

be designated high priority for monitoring. As shown in figure 5, only one 

indicator is given sufficient weight on its own to result in a grant being 

assigned a high-priority for monitoring: “time since last on-site compliance 

visit” (150 points). According to CNCS guidance, this indicator supports 

the agency’s efforts to ensure compliance monitoring visits are conducted 

every 6 years, in accordance with agency policy. Agency guidance further 

states that this indicator is important because potential vulnerabilities may 

increase as time between visits lengthens. It is important to conduct 

monitoring visits periodically as required; however, as noted by one 

officer we spoke with, the amount of time elapsed since the last visit does 

not necessarily indicate risk. In contrast, the indicator for “prohibited 

activities” is given much less weight (30 points), even though prohibited 

activities constitute a significant risk because they are an unallowable use 

of federal funds. As a result, a check for this indicator may only result in a 

grant being assigned medium-priority for monitoring and, according to 

CNCS policy, a monitoring visit or desk review is not required for a grant 

that receives a medium-priority rating.30 Of the 25 grant awards with “yes”

on the prohibited activities indicator in fiscal year 2015, nearly two-thirds 

were designated as medium priority, and 17 of the 25 did not receive a 

compliance visit or other monitoring activity that year. Similarly, the 

indicator for “financial competency” is given even less weight (20 points). 

A grant would get a “yes” on this indicator if a bankruptcy filing had been 

made or an intent to file had been announced, or if another federal or 

state agency had notified CNCS regarding a weakening of an 

organization’s financial competency. However, a “yes” on this indicator 

only contributes 20 points to the 150 needed to be designated high 

priority for monitoring.

 29 GAO-14-704G, Principle 7.

30 According to CNCS policy, the agency may conduct monitoring visits or desk reviews 

for grants with medium or low priority levels, as it deems appropriate. 
Page 17 GAO-17-90 CNCS Grants Management

Figure 5: Indicators of Potential Grant Vulnerabilities Assessed by CNCS and Their Relative Weight in Points

a

An additional indicator (titled ‘One or more partners or subcontractors’) is applicable to grants to 

national training and technical assistance providers only.
Page 18 GAO-17-90 CNCS Grants Management

Second, we found that several potential risk factors were included in a 

single indicator: “other key concerns and challenges” (80 points). 

According to CNCS’s scoring model, a grant would receive a score for 

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

risks. For example, this indicator includes open compliance findings, 

improper payment findings, and the potential for financial management 

problems. This indicator also includes any findings from the pre-award 

review, which CNCS conducts under federal grants management 

guidance established by the Office of Management and Budget (OMB), 

referred to as the Uniform Guidance.31 A grant that receives a “yes” for 

this indicator in the scoring model would not receive a high-priority 

designation on its own, regardless of the severity of the risk or how many 

of these concerns are noted. Several CNCS grant and program officers 

we spoke with noted that it may be more useful if some of these potential 

risks stood alone rather than grouping them together in a single indicator. 

For example, to give improper payment findings greater weight, one 

officer suggested there should be an indicator solely based on these 

findings. Other officers suggested that compliance findings regarding 

criminal history checks should be elevated to its own indicator, to flag 

potential or past compliance problems in this area. Another officer 

suggested that compliance findings regarding concerns with supervision 

of volunteers should be highlighted through an indicator of its own, 

because this can indicate problems with prohibited activities.

Third, we found that 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 retention 

(“participant enrollment and retention”), but this indicator is only marked 

“yes” if the retention is below 50 percent for 1 year, or 75 percent for 2 

years. AmeriCorps State and National program office staff we interviewed 

told us that 50 percent retention is considered very low, and they would 

prefer to intervene before performance had dropped to this level.

 31 OMB developed government-wide policies to ensure that grants are managed properly 

and that grant funds are spent in accordance with applicable laws and regulations. In 

December 2013, OMB consolidated its grants management guidance documents into a 

single document, Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards (Uniform Guidance) to streamline its guidance, promote 

consistency among grantees, and reduce administrative burden on nonfederal entities, as 

well as to strengthen oversight of federal funds to reduce risk of waste, fraud, and abuse. 

Subsequently, CNCS issued regulations adopting OMB’s Uniform Guidance for its grant 

programs. See 2 C.F.R. § 2205.100.
Page 19 GAO-17-90 CNCS Grants Management

Lastly, we found that several indicators are too frequently applicable to be 

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

19 indicators were checked ”yes” for more than a quarter of the grants 

assessed, which could indicate that they have minimal impact in 

distinguishing among grants to determine their priority status for 

monitoring. One indicator—”multiple awards”—was checked for nearly 

half the grants assessed.

In addition to these limitations in the scoring model, CNCS has not clearly 

documented its assessment scoring process, although internal controls 

suggest that documentation could contribute to the effectiveness of this 

activity.32 The rationale is unclear for why CNCS has defined its indicators 

and assigned their weights the way it has, and outcomes from this 

process are not well-documented. CNCS has a monitoring workgroup that 

is charged with, among other duties, reviewing the indicators used for the 

annual assessment and determining whether the point value for each 

indicator needs to be changed. However, CNCS does not have 

documentation on the criteria used for selecting the 19 indicators or 

determining their weights. Decisions on changes to the scoring are also 

not well-documented, and it is unclear how the group decides which 

indicators are most important. CNCS officials said that the original 

documentation on indicator selection was not maintained because it was 

outside the records retention time frame, and in recent years, limited staff 

capacity contributed to the agency not documenting its decisions on 

changes to the indicators. Improving documentation on the rationale for 

CNCS’s decisions on indicators and scoring could help the agency revise 

its indicators in the future to improve their relevance and effectiveness.

CNCS has begun various efforts that could lead to improvements in the 

scoring model used to support the agency’s assessment process, but all 

of these efforts are in the early stages of development and their ultimate 

effect is not yet clear. For example, according to the agency’s first Chief 

Risk Officer, who came on board in April 2016, the OCRO is undertaking 

an effort to benchmark CNCS’s assessment criteria and process against 

other federal agencies and programs with similar grantee profiles (that is, 

 32 GAO-14-704G. Principle 10: Management should design control activities to achieve 

objectives and respond to risks. Also, one of the attributes contributing to the design, 

implementation, and operating effectiveness of this principle is 10.03: Management 

designs appropriate types of control activities for the entity’s internal control system, and 

clearly documents internal control and all transactions and other significant events in a 

manner that allows the documentation to be readily available for examination. 
Page 20 GAO-17-90 CNCS Grants Management

the agency or program funds grantees with varying levels of financial, 

administrative, and staff capacity). As of July 2016, the OCRO had 

gathered information from six federal programs and planned to contact 

several more. In addition, officials said that the Field Financial 

Management Center, one of CNCS’s two grant offices, had also begun 

development of a pilot to develop additional indicators of risk, based on a 

review of past performance of 10 Senior Corps grants and analysis of 

related data. They said they hope that the results of the pilot will inform 

future changes to the assessment process, but it is too early to tell at this 

point how relevant the results will be to other programs.33 Finally, officials 

also told us that, as part of the agency’s plan for implementing Enterprise 

Risk Management (ERM) under OMB’s revised Circular A-123, CNCS 

held listening sessions with senior management in spring 2016 to gather 

their perspectives on key agency risks and began conducting similar 

sessions with CNCS staff in fall 2016. Officials said that they plan to use 

this information to create an agency-wide risk profile. Also, in response to 

the focus on fraud in OMB’s revised circular, CNCS had included fraud as 

a topic in its listening sessions with senior management. However, it 

remains to be seen the extent to which identification of these top risks 

agency-wide, including the potential for fraud, will result in changes to the 

assessment indicators for grant monitoring. As of September 2016, 

CNCS had not included any indicators of fraud risk in its assessment 

process.

CNCS does not have a policy to ensure all grants, including those 

awarded after the annual assessment is complete, are assessed for 

potential risk in the current year. Delaying grants from being included in

this process limits CNCS’s ability to identify and analyze the significance 

of certain risks in its grant portfolio, which is inconsistent with internal 

controls for risk assessment and control activities.34 As described earlier, 

CNCS’s policy and procedures call for its assessment process to begin in 

August each year to guide its monitoring activities for the fiscal year that 

 33 Officials noted that this pilot includes mostly financial indicators rather than 

programmatic indicators. In addition, they noted that the pilot was a time-consuming effort 

due to the data sources used, and it would take significant time and effort to assess all of 

the office’s grants (approximately 1,500) against these indicators. 

34 GAO-14-704G. Principle 7 (under Risk Assessment): Management should identify, 

analyze, and respond to risks related to achieving the defined objectives; and Principle 12 

(under Control Activities): Management should implement control activities through 

policies.

CNCS Does Not Have a 

Policy to Assess All Grants 

Annually, and Some Are 

Not Assessed
Page 21 GAO-17-90 CNCS Grants Management

will start in October. CNCS determines the universe of grants to be 

assessed and uses its tool of 19 indicators to assign a priority rating 

category for monitoring the grants in this universe. CNCS officials said 

that 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 when the annual assessment may 

already have been completed. However, without including new grants in 

the annual assessment process, CNCS cannot identify and analyze the 

significance of these risks, and use this information to prioritize these 

grants for monitoring activities, such as a site visit. As noted by one 

program officer we spoke with, an initial visit to a first-time grantee can 

identify issues that would not have otherwise been raised, and can 

prevent future problems.

Officials acknowledged that the agency does not have a policy regarding 

how and when to assess grants made after the annual assessment 

process is conducted in August, and that in practice, these grants are not 

assessed using its tool of 19 indicators until the following fiscal year’s 

assessment process if the grant is expected to be active for a second 

year. This was the case with one grant included in our selected review of 

eight grants with negative outcomes. The grant, funded at over $200,000 

in each of 3 years, was awarded on September 30, 2012, but was not 

assessed until the summer of the following year. Once assessed, it was 

deemed high-priority, but was nevertheless subsequently relinquished by 

the grantee in light of non-compliance findings. Had the grant been 

assessed as high-priority in its first year, and had it been assigned 

monitoring activities accordingly from the beginning, the compliance 

problems may have been avoided.

Due to data limitations, we were unable to determine the extent to which 

new grants were not included in the annual assessment and received no 
Page 22 GAO-17-90 CNCS Grants Management

monitoring in fiscal year 2015.35 However, using data on monitoring 

activities, we identified 44 newly-awarded grants that were not assessed, 

but nevertheless had received monitoring. It is unclear how CNCS 

determined that these grants, but not others, warranted monitoring. 

Without establishing and implementing a policy to ensure that all grants 

are assessed for potential vulnerabilities in the current year, CNCS may 

not be using its monitoring resources most effectively, focusing on the 

highest-risk grants.

CNCS conducts limited monitoring of grantees’ oversight of their 

subrecipients, despite the large amount of grant dollars involved and 

evidence indicating that subrecipient oversight is a key risk area. 

According to CNCS, two of CNCS’s largest programs, AmeriCorps State 

and National and Social Innovation Fund (SIF), allow their grantees to 

have subrecipients,36 involving a significant amount of grant funds—

almost half of CNCS’s total grant budget in fiscal year 2015. Data 

included in the agency’s fiscal year 2015 financial report shows that 

CNCS awarded about $300 million in grants to state commissions that 

subgrant the funds to organizations in the states to run AmeriCorps 

programs. Similarly, the report states that CNCS awarded the entire 

portfolio of SIF grants, about $70 million, to intermediaries that are 

required to make subawards to other organizations. Subrecipient 

oversight also has been identified as a key risk area. For example, in prior 

work, GAO has concluded that effective practices for overseeing 

 35 To determine the number of grants that had not been assessed, we requested data 

from eGrants on all grants that were active in fiscal year 2015 to compare with the list of 

grants included in the annual assessment. In response, CNCS provided three lists: one 

with 2,477 grants, one with 2,544 grants, and one with 2,807. In our review of the data and 

discussions with CNCS officials, we identified several possible explanations for the 

discrepancies between these lists, including: duplicate entries, different definitions of 

“active,” and lapses in edit checks. As a result, however, we determined that the data 

were not reliable for determining how many fiscal year 2015 grants were not assessed 

and received no monitoring. CNCS officials noted that staff were working on the 

requirements for their new IT system, currently under development. We are reviewing

these efforts in a separate study on CNCS’s IT modernization and will present the results 

in a forthcoming report.

36 Some of the grantees funded by these two programs are entities such as state 

commissions that pass through their CNCS funds to other organizations (referred to as 

subrecipients). According to CNCS officials, its two other largest programs, Senior Corps 

and VISTA, do not allow grantees to make subgrants to subrecipients.

CNCS Conducts Limited 

Monitoring of Grantee 

Oversight of Subrecipients
Page 23 GAO-17-90 CNCS Grants Management

subrecipients are a critical element of ensuring grant funds are used for 

intended purposes.37

OMB’s Uniform Guidance established oversight requirements for passthrough entities, such as CNCS’s state commissions, that provide funds 

to other organizations.38 CNCS conducts monitoring activities to review 

grantees’ compliance with these and other requirements. However, an 

OIG investigation identified concerns about CNCS subrecipients, 

indicating that additional subrecipient oversight may be needed.39 Among 

the selected program and grant officers we interviewed (who were 

responsible for monitoring the eight grants in our nongeneralizable 

sample of grants with negative outcomes), four identified problems with 

grants resulting from issues with subrecipients. For example, one CNCS 

officer told us about a grantee that lost nearly half of its subrecipients over 

2 years (from 11 subrecipients to 6); another said the grantee could not 

implement its program because of problems with subrecipients.

To monitor their grantees’ oversight of subrecipients, CNCS programs 

with subrecipients have developed provisions for subrecipient oversight 

as part of their programs’ standard protocols. However, we found these 

provisions to be limited in certain areas, such as criminal history checks 

(see table 3), even though, in fiscal year 2015, CNCS reported that nearly 

all of its estimated reportable improper payments stemmed from problems 

 37 GAO, Federal Grants: Improvements Needed in Oversight and Accountability 

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

38 According to OMB’s guidance, pass-through entities must evaluate each subrecipient’s

risk of noncompliance and consider imposing specific subaward conditions, if appropriate, 

based on, for example, their prior experience with similar awards or results of previous 

audits. Pass-through entities must also (1) review financial and performance reports, (2) 

follow up to ensure subrecipients take timely and appropriate action on any deficiencies 

that are detected pertaining to the federal award, and (3) issue a management decision for 

any audit findings related to the federal award. See Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards, 78 Fed. Reg. 78,590 (Dec. 

26, 2013).

39 An April 2016 OIG investigation found that a subrecipient of a CNCS grant was 

performing prohibited activities; the OIG found that the grantee’s guidance to its 

subrecipients did not include all abortion-related prohibited activities listed in law, and the 

grantee’s oversight of subgrantees was inadequate. See Office of Inspector General for 

the Corporation for National and Community Service, Major AmeriCorps Grantee Allowed 

Members to Provide Abortion-Related Services Prohibited by Law; CNCS Management 

Undertakes Robust Actions in Response, Closed Investigations, accessed April 26, 2016. 

https://www.cncsoig.gov/news/closed-cases. 
Page 24 GAO-17-90 CNCS Grants Management

with conducting or documenting criminal history checks.40 For example, 

the AmeriCorps State and National program monitors a grantee’s 

oversight of subrecipient compliance with criminal history checks by 

reviewing a total of 25 volunteer and staff files, but there is no 

requirement to select the files based on the number of subrecipients, or 

size of grant. Officials told us that the largest AmeriCorps State grantee 

had five grants with a total of 55 subrecipients.41 Further, the SIF 

program’s protocol requires review of 3 employees from a minimum of 3

different subgrantees or subrecipients to gauge compliance; however, the 

SIF program has had one grantee with as many as 47 subgrantees, and 

four grantees with 20 or more subgrantees. As a result, the monitoring 

approach of these CNCS programs may cover only a small portion of 

their grantees’ subrecipients in some cases. In addition, both programs 

check that the grantee has a plan for overseeing its subrecipients, but the 

AmeriCorps State and National program protocol does not require a 

review of the results of these activities, such as subrecipient progress 

reports or monitoring findings.

Table 3: CNCS Monitoring Provisions for Subrecipient Oversight 

Grantee oversight of subrecipients Visits to subrecipient sites Criminal history check compliance

AmeriCorps State 

and National

Ensure grantee has implemented a plan 

for oversight and monitoring to ensure 

subrecipients are complying with relevant 

grant requirements

Suggested in certain 

circumstances

Review 25 volunteer and staff files for 

compliance at the grantee level, with 

no specification for reviews at the 

subrecipient level

Social Innovation 

Fund

Review grantee’s strategy for monitoring 

(should be risk-based), including a 

monitoring plan, and subrecipient 

monitoring documents

Occurs when subrecipient is 

located near the grantee

Select 3 employees from a minimum 

of 3 different subgrantees/

subrecipients to check for the various 

components of criminal history check 

requirement

Source: GAO analysis of Corporation for National and Community Service (CNCS) documents and interviews with agency officials. | GAO-17-90

CNCS officials acknowledged that ensuring grantees are overseeing 

subrecipients is an ongoing challenge. One officer we interviewed 

suggested that it could be helpful for CNCS to obtain more information 

from its grantees on how they are managing their subrecipients. 

Gathering additional information about subrecipients by improving 

monitoring protocols could help CNCS to ensure that its grantees are 

 40 See Corporation for National and Community Service, FY 2015 Agency Financial 

Report (Washington, D.C.), p.124.

41 Officials said that CNCS typically conducts one monitoring visit for a state grantee’s 

entire portfolio of grants.
Page 25 GAO-17-90 CNCS Grants Management

overseeing subrecipients appropriately. CNCS officials said they have 

some plans to update monitoring protocols to address certain risks, but 

did not provide timeframes for doing so, and it is unclear whether all 

areas of subrecipient oversight will be addressed.

CNCS has not systematically evaluated the results of its monitoring 

activities, as called for by internal controls.42 Officials said that the 

agency’s monitoring workgroup holds an annual discussion of the year’s 

monitoring activities, but CNCS does not compile monitoring findings, 

such as types of compliance problems or errors identified, systematically 

across all programs. Moreover, CNCS has not used data systems for 

summarizing monitoring findings to use in trend analyses or to evaluate 

opportunities for improving its monitoring efforts.

A senior official said they had not conducted agency-wide analyses of 

their monitoring efforts because eGrants does not provide reports that 

include both assessment information and monitoring results for each 

grant, and because the agency has had limited staff capacity to manually 

analyze this data given these limitations in reporting. In addition, officials 

said that CNCS does not have standardized reporting or longitudinal data 

to facilitate evaluation of the effectiveness of CNCS’s monitoring efforts, 

although they acknowledged that both would be helpful. With respect to 

assessment information, the “yes” or “no” data captured in eGrants from 

the annual assessment process for each of the 19 indicators cannot be 

easily analyzed for trends. For example, for the indicator on grantee 

volunteer retention, the eGrants system records a “yes” or “no” for each 

grant depending on whether the grantee’s retention is above or below the 

indicator’s threshold, rather than capturing the actual percentage of 

volunteers retained.

With respect to monitoring results, each program office has a monitoring 

tool to complete when conducting on-site monitoring, but these tools are 

not integrated so that the results can be analyzed within the eGrants 

system. As a result, some program officers we spoke with described 

 42 GAO-14-704G, Principle16: Management should establish and operate monitoring 

activities to monitor the internal control system and evaluate the results. Also, one of the 

attributes contributing to the design, implementation and operating effectiveness of this 

principle is 16.09: Management evaluates and documents the results of ongoing 

monitoring and separate evaluations to identify internal control issues. Management uses 

this evaluation to determine the effectiveness of the internal control system.

CNCS Has Not 

Systematically Evaluated 

Its Monitoring Efforts
Page 26 GAO-17-90 CNCS Grants Management

manual approaches they sometimes used to assess common findings 

from their monitoring activities within their programs. For example, they 

have used compliance visit letters—sent to grantees to summarize 

compliance visit findings—to determine the effectiveness of monitoring 

and track trends. CNCS officials told us that, as of November 2016, the 

agency was developing the requirements for the monitoring component of 

the agency’s new IT system.43 In developing these requirements, CNCS 

has the opportunity to provide additional functionality to support 

evaluation of its assessment and monitoring efforts. However, in the 

meantime, a more formal effort to summarize monitoring results across all 

programs could help identify trends and areas for improvement.

CNCS officials also said that they have not fully evaluated the 

effectiveness of the types of monitoring activities the agency conducts 

and whether a different mix of these activities could result in improved 

monitoring outcomes, although the monitoring workgroup has discussed 

the need to do so. In particular, officials said that because on-site 

compliance visits can take up to three days and can be very costly, it 

would be helpful to have a lower-cost alternative, such as a desk review. 

According to CNCS policy, monitoring may consist of a visit or a desk 

review. However, we found that in fiscal year 2015, of the 506 grants that 

received a monitoring activity, only 9 received desk reviews. Several 

grant and program officers we spoke with commented that greater use of 

desk reviews could be helpful for identifying and responding to potential 

risks.

 43 This refers to CNCS’s effort to develop a new IT system that will support its future grant 

monitoring process. We did not assess CNCS’s activities regarding development of the 

new IT system. We are conducting a separate study on CNCS’s IT modernization and will 

present the results in a forthcoming report.
Page 27 GAO-17-90 CNCS Grants Management

CNCS has not conducted the strategic workforce planning necessary to 

determine whether it has the capacity—including both people and 

resources—to effectively monitor grantees’ compliance with grant 

program requirements.44 CNCS included plans to conduct a strategic 

workforce planning process in the agency’s strategic plan for fiscal years 

2011 through 2015, but these plans were not implemented. Further, 

CNCS does not have a training planning process aligned with agency 

goals and competencies to help ensure program officers who have similar 

grant monitoring responsibilities receive the same needed training to 

perform their jobs effectively.

CNCS has not developed or documented a strategic workforce planning 

process as key principles for effective strategic workforce planning 

suggest.45 Without such a planning process, CNCS’s efforts to address 

gaps in staffing due to attrition have been ad hoc and reactive. In 

addition, CNCS has not established whether differences in workload 

among grant and program officers in different programs and locations are 

reasonable, or if these differences also result from ad hoc responses to 

attrition. Internal controls suggest that agencies demonstrate commitment 

to various workforce planning activities, such as succession planning, so 

that vacancies in key roles are filled with competent staff and that the 

entity can continue achieving its objectives.46

CNCS has experienced considerable attrition over the past few years in 

positions that affected the agency’s capacity to conduct key monitoring 

functions, including staff in the OCRO (previously the Office of 

Accountability and Oversight), program and grant officers, and other 

officials at high levels within the agency. Specifically:

 44 We have previously defined “agency capacity” to mean people and resources in GAO, 

High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015).

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

GAO-04-39 (Washington, D.C.: Dec. 11, 2003).

46 GAO-14-704G, Principle 4: Management should demonstrate a commitment to recruit, 

develop, and retain competent individuals. Also, one of the attributes contributing to the 

effectiveness of this principle is 4.06: Management defines succession and contingency 

plans for key roles to help the entity continue achieving its objectives. Succession plans 

address the entity’s need to replace competent personnel over the long term, whereas 

contingency plans address the entity’s need to respond to sudden personnel changes that 

could compromise the internal control system. 

CNCS’s Monitoring 

Capacity Needs Are 

Unclear Because It 

Has Not Conducted 

Strategic Workforce 

Planning

CNCS Does Not Have a 

Strategic Workforce 

Planning Process
Page 28 GAO-17-90 CNCS Grants Management

• OCRO: Nine of 13 staff in OCRO separated from CNCS in fiscal year 

2015.47 According to the CNCS OIG, as a result of this attrition, as 

well as the departure of key OCRO staff members at the beginning of 

fiscal year 2016, this office had few, if any, staff members with 

sufficient training or experience in grant monitoring and improper 

payment assessments, among other responsibilities.48 Further, in its 

fiscal year 2015 financial report, CNCS reported that insufficient staff 

in this office limited its ability to conduct improper payment reviews.49

More recently, CNCS officials noted that the only staff person in the 

OCRO with the knowledge to interpret reports on aggregated data 

from the grant assessment component of CNCS’s eGrants information 

system left the agency in August 2016. At this time, CNCS was also 

completing fiscal year 2016 monitoring and beginning the fiscal year 

2017 process, which officials said was challenging in the absence of 

OCRO staff with eGrants expertise. Officials also acknowledged that 

due to staffing and leadership changes, reviews of eGrants data had 

become infrequent.

• Program and grant officers: During fiscal year 2015, vacancies 

occurred in 15 program officer and 4 grant officer positions. Officials 

said that CNCS’s efforts to refill positions were handled on an ad-hoc 

basis, without a strategy for addressing turnover trends throughout the 

agency to maintain critical skills for monitoring and oversight. Our 

analysis of CNCS data indicate that these vacancies had an impact 

on the number of monitoring activities conducted in fiscal year 2015. 

Specifically, at least 58 desk reviews, drawdown analyses, and 

monitoring visits planned for fiscal year 2015 monitoring were not 

completed or were delayed because of staff shortages, in particular 

the loss of two grant officers.50 Several program and grant officers told 

us that turnover had also affected their workload, often requiring them 

to manage additional grants. For example, one grant officer said that 

 47 Of the 9 staff separating from CNCS, 6 were temporary employees and 3 were full-time 

employees.

48 Corporation for National and Community Service Office of Inspector General, SemiAnnual Report to Congress: October 1, 2015-March 31, 2016 (Washington, D.C.: 2016).

49 Corporation for National and Community Service, FY 2015 Agency Financial Report

(Washington, D.C.), p.123. 

50 CNCS’s data show that the preponderance of grant monitoring activities not completed 

due to turnover were drawdown analyses attributed to the separation of two grant officers.

In some cases, CNCS records note that the monitoring activity was completed, but the 

program officer or grant officer did not follow up with the grantee and scheduled 

monitoring for fiscal year 2016.
Page 29 GAO-17-90 CNCS Grants Management

in addition to his responsibilities for monitoring Senior Corps and 

VISTA grants, he took on monitoring responsibilities for 40 to 45 

additional grants when a grant officer left the agency.

• High-level officials: CNCS has also experienced considerable 

turnover of senior officials over the past few years. Between fiscal 

years 2012 and 2015, the Director of Accountability and Oversight, 

Chief Financial Officer, Chief Information Officer, Chief Human Capital 

Officer, and General Counsel departed the agency.51 In addition, the 

Director of the Office of Grants Management and the Director of the 

Field Financial Management Center also left during this time.

In a previous report, we examined best practices for workforce planning 

based on a review of studies by leading workforce planning organizations 

and federal agency workforce planning practices, and concluded that a 

strategic workforce plan is essential to addressing two critical needs: (1) 

aligning an organization’s human capital program with its current and 

emerging mission and programmatic goals; and (2) developing long-term 

strategies for acquiring, developing, and retaining staff to achieve 

programmatic goals.52 In that report, we identified five principles that 

agencies should follow for effective strategic workforce planning: 

leadership involvement; determining critical skills and competencies; 

developing strategies to address gaps; building capacity to support 

workforce planning; and monitoring and evaluating progress toward 

human capital goals and programmatic results.

We found that CNCS’s most recent strategic plan (for 2011-2015) had 

called for developing and implementing a strategic workforce plan that 

reflects a workforce assessment, identifies new competencies, and 

includes an ongoing assessment of CNCS’s key work requirements; 

however, as of fall 2016, the agency had not yet taken these actions, and 

the agency does not have a strategic plan in place for fiscal year 2016 or 

beyond. CNCS officials said that they recognize the importance of 

strategic workforce planning—which can help with key agency functions 

such as grant monitoring—and that efforts to refill vacancies had been ad 

hoc, but that they had not yet had an opportunity to begin such planning 

because of limited resources. In October 2016, officials said they would 

 51 The staff and responsibilities of the Office of Accountability and Oversight were 

assumed by the OCRO when it was established in fiscal year 2016.

52 GAO-04-39.
Page 30 GAO-17-90 CNCS Grants Management

begin strategic workforce planning soon, but could provide no time frames 

or documentation about its planned efforts.

In addition, we found that the planned monitoring workloads and 

responsibilities of program and grant officers varied across the agency, 

and that CNCS had not evaluated whether these differences reflect an 

appropriate deployment of resources to monitor grantees effectively. For 

example, data from eGrants showed that, across CNCS’s offices, 

program officers’ workloads ranged from 1 to 13 planned monitoring 

activities, while grant officers’ workloads ranged from 1 to 44 planned 

monitoring activities.53 Some grant officers and program officers we 

interviewed noted that not all grants require the same amount of time to 

monitor. For example, certain grantees require more day-to-day 

communication, depending on such things as their capacity, experience, 

and number of subrecipients. Program and grant officers also described 

recent changes to their workloads resulting in part from more 

comprehensive grant application reviews. A CNCS program management 

official told us that increasing responsibilities for grant application reviews, 

resulting from new initiatives and partnerships with other federal 

agencies, had reduced the amount of time available for grant 

monitoring.54

While the program or office where an officer works might explain some 

workload differences, CNCS officials told us that they have not evaluated 

whether staff have been deployed to the offices where they are most 

needed for grant monitoring. As a result, it is unclear if workload 

differences are reasonable or if they are affecting the agency’s capacity to 

monitor grantees effectively. Senior officials said that the grant monitoring 

workload distribution is based on the results of the annual assessment 

process, but they do not balance the number of high-value, high priority 

grants for monitoring across grant and program officers. Instead, their 

reviews of the effectiveness of the agency’s workload distribution to meet 

 53 Planned monitoring activities include compliance visits, training and technical 

assistance, and financial reviews, among others. We excluded six program officers and 

two grant officers from this analysis because we were unable to identify their workloads in 

CNCS’s data.

54 According to CNCS officials, during fiscal year 2015, CNCS grant officers and program 

officers reviewed applications for 20 grant application competitions, an increase from 12 

application competitions in 2014 and 10 in 2013. CNCS officials said that some of the 

grant application competitions do not require the review of both program officers and grant 

officers. Applications for some of the competitions are lengthy, some have as few as five 

applications to review, and others have limited applications or just a budget to review.
Page 31 GAO-17-90 CNCS Grants Management

its monitoring objectives have been ad hoc. In the absence of a strategic 

workforce planning process that fully incorporates and is consistent with 

key principles for effective strategic workforce planning, CNCS’s efforts to 

address gaps in staffing and to deploy program and grant officers where 

they are most needed may continue to be ad hoc and reactive.

CNCS does not ensure that all program officers with similar grant 

monitoring responsibilities are offered or receive the same needed 

training to perform their jobs effectively, as suggested by internal 

controls.55 Although program officers have been asked to conduct fiscal 

monitoring, not all CNCS offices have planning processes that ensure 

their program officers receive training on this topic. In addition, CNCS’s 

planning process for training is not aligned with agency goals and critical 

competencies, which was identified in GAO’s guide for assessing training 

as a way to focus strategically on improving performance.56

We reviewed CNCS’s training plans for new staff and lists of training 

offered to staff in each office and found that training offerings vary by 

office, including training on certain key areas of grant monitoring 

responsibility (see table 4). Program officers in the AmeriCorps State and 

National program office generally did not receive training on fiscal 

monitoring, even though they have been asked to conduct fiscal 

monitoring.

57 Similarly, in fiscal year 2015, grant officers did not receive 

ongoing training on CNCS’s grant monitoring practices, although officials 

said that grant officers received this training in fiscal year 2016. While 

officials said that program officers in the Office of Field Liaison received 

training on fiscal monitoring,58 four program officers that we interviewed 

 55 GAO-14-704G, Principle 4. Another attribute contributing to the effectiveness of this 

principle is 4.05: Management recruits, develops, and retains competent personnel to 

achieve the entity’s objectives. Management considers the following: [. . .] Train – Enable 

individuals to development competencies appropriate for key roles, reinforce standards of 

conduct, and tailor training based on the needs of the role.

56 GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: Mar. 1, 2004). 

57 Officials said that AmeriCorps State and National and Social Innovation Fund program 

officers may have chosen to participate in the fiscal monitoring training provided to 

program officers in the Office of Field Liaison, but that the training was designed for 

program officers in the Office of Field Liaison. 

58 Officials said that the Office of Field Liaison began providing this training in 2009 and 

completed training for all program officers in 2013. Since 2013, the office has provided 

fiscal monitoring training for new employees in the Office of Field Liaison.

CNCS Does Not Ensure 

Program Officers Are 

Offered or Receive 

Training in Key Areas
Page 32 GAO-17-90 CNCS Grants Management

said that they needed additional training on fiscal monitoring, in part to 

help them better understand fiscal terminology and review financial 

documents.59 One of the four program officers noted that because she is 

not as familiar with fiscal monitoring, she sometimes had to contact her 

grant officer with fiscal compliance questions while conducting a 

monitoring visit. In addition, a grant officer told us that training on CNCS’s 

grant monitoring tool, including specific examples of information that 

could be provided to respond to questions on the tool, would help grant 

and program officers meet their monitoring responsibilities more efficiently 

and effectively.

Table 4: Variation in CNCS Program and Grant Officer Training Opportunities, by Office 

Program Offices Grant Offices

AmeriCorps 

State and 

National

Office of 

Field 

Liaison

Social Innovation 

Fund Program 

Office

Field Financial 

Management 

Center

Office of Grants

Management

Program and grant officer training 

opportunities

New employee orientation training 

includes CNCS compliance 

monitoring practices

Yes Yes Yes No No

New employees receive one-on-one 

coaching on compliance monitoring

Yes Yes Yes Yes Yes

New employee 2-year training 

program provided by an outside 

vendor, with option to receive a 

nationally-recognized certification

No No No Yes Yes

Ongoing refresher trainings or 

optional developmental training on 

CNCS grant assessment and 

monitoring were offered in fiscal year 

2015

Yes No No No No

Fiscal monitoring training is provided 

to program officers

No Yes No Not applicablea Not applicablea

Source: GAO analysis of Corporation for National and Community Service (CNCS) documents and interviews with CNCS officials. | GAO-17-90

a Officers in the Field Financial Management Center and Office of Grants Management are grant 

officers. Grant officers take a class on Cost Principles for Federal Awards as part of their 2-year 

training program described above.

 59 These program officers said that they are primarily responsible for carrying out 

monitoring visits, which include fiscal compliance monitoring, because grant officers’

workloads are too high to attend these visits unless there is a serious fiscal need.
Page 33 GAO-17-90 CNCS Grants Management

Officials told us that variation in training opportunities occurred because 

each program and grant office is responsible for planning training for their 

staff at the individual level, and practices varied. At the office level, each 

CNCS office meets with the Office of Human Capital to discuss skills 

gaps, needs, and priorities of staff. For example, they consider such 

issues as training required by law and the number of staff in need of 

particular training. The Office of Human Capital administers a training 

needs survey to each office at the beginning of each fiscal year. At the 

individual level, officials told us that each year, employees work with their 

supervisors to develop a workplan that includes training requirements.60

However, CNCS’s training planning process is not aligned with agency 

goals and critical competencies, as GAO’s guide for assessing training 

identified as essential for effective performance.61 In GAO’s guide for 

assessing training, we state that it is essential that agencies ensure 

training and development efforts are undertaken as an integral part of, 

and are driven by, their strategic performance planning processes. By 

taking this approach, agencies can help ensure that their training and 

development efforts are not initiated in an uncoordinated manner, but 

rather are focused on improving performance toward their goals as laid 

out in their strategic plan. Well-designed training and development 

programs, linked to agency goals and to the organizational, occupational, 

and individual skills and competencies, are needed for the agency to 

perform effectively.62 In our review of the documents outlining CNCS’s 

planning process for training, we found no links to agency goals for grant 

monitoring and associated competencies for program and grant officers. 

CNCS officials said that they have not reviewed competencies or 

assessed gaps in critical skills and competencies agency-wide since 

2008, and that they have been continuing to operate under a 2011-2015 

strategic plan.63 In September 2016, CNCS officials said that they plan to 

build an employee development program, but it is unclear whether this 

effort will link training to agency goals and competencies for program and 

grant officers. In the absence of a training planning process linked to 

 60 The workplan that CNCS provided to us notes that employees should complete 

required training, such as monitoring training, in a timely manner.

61 GAO-04-546G.

62 GAO-04-546G, p.5.

63 CNCS reviews competencies for grant officers and program officers when individual 

position descriptions are updated with vacancy announcements, but the agency last 

determined critical competencies in 2008. 
Page 34 GAO-17-90 CNCS Grants Management

current agency goals and competencies, program and grant officers may 

continue to receive inconsistent training opportunities, and the 

opportunities provided may not fully address important aspects of their 

grant monitoring responsibilities.

CNCS programs support efforts across the country designed to 

strengthen communities and foster civic engagement through service and 

volunteering. To do this, CNCS awards grants totaling hundreds of 

millions of dollars annually and must ensure that those funds are used in 

accordance with program rules and federal requirements, such as OMB’s 

new Circular A-123. In particular, as CNCS implements these new 

requirements, further emphasis on assessing and responding to risks, as 

well as taking an agency-wide, strategic approach to its workforce 

planning, will be key to strengthening CNCS’s ability to effectively monitor 

its grants and to move toward a risk-based approach to these activities.

Although CNCS has an assessment process for prioritizing grants for 

monitoring activities, there are limitations in the scoring model that 

underpins this assessment process. These limitations result in a process 

that does not fully identify potential risks, such as the potential for fraud, 

or result in the riskiest grants receiving the highest priority for monitoring.

Further, some grants are not included in this assessment process, but are 

monitored regardless and without the benefit of information from the 

assessment. In addition, available documentation does not indicate how 

CNCS developed its indicators or their scoring, or how the agency has 

changed them over time. Taken together, these issues create 

vulnerabilities for CNCS in its ability to meet federal standards for internal 

control with respect to risk assessment, control activities, and monitoring 

principles. CNCS’s efforts to benchmark its assessment criteria and pilot 

new risk indicators are positive steps in enhancing its approach to 

assessing risk and determining monitoring priorities; however, these 

efforts are in their early stages. Going forward, it will be important for 

CNCS to complete its benchmarking efforts and ensure that information 

from these efforts is used to address the limitations we identified in the 

agency’s scoring model and in documenting its decisions about it.

Further, CNCS conducts limited reviews of how its grantees oversee their 

subrecipients, although subrecipient performance is critical to grant 

success. Reviewing monitoring protocols to ensure that they include 

collection of information on grantees’ oversight of subrecipients’ activities 

will help to identify and mitigate any risks posed by subrecipients. Also, 

CNCS has not evaluated its monitoring activities or gathered data 

Conclusions
Page 35 GAO-17-90 CNCS Grants Management

systematically to enable analysis of how well its current efforts assess 

risk. By reviewing the outcomes and findings from its monitoring activities, 

CNCS will be better positioned to improve these processes and 

determine the effectiveness of these activities.

CNCS has taken some steps in workforce planning to fill vacancies in 

monitoring staff and key senior management positions, but the agency 

has not developed a strategic workforce planning process, which would 

help to address its workforce challenges at a strategic, agency-wide level. 

In addition, departures of senior officials and staff with grant monitoring 

responsibilities have affected the agency’s capacity to conduct key 

monitoring functions; but these departures were handled on an ad-hoc 

basis, without efforts designed to maintain critical skills for monitoring and 

oversight. Meanwhile, staff workloads and responsibilities have changed 

due to staff turnover and other factors, but CNCS has not reviewed its 

workload distribution on an agency-wide level. In order to ensure the 

agency can effectively monitor its grantees, it will be important for CNCS 

to take a strategic approach to workforce planning in order to address 

current and future agency needs. Finally, CNCS does not ensure that all 

program officers have opportunities for or receive training on their grant 

monitoring responsibilities, particularly for fiscal monitoring. Its training 

planning process is not aligned with agency goals and competencies, and 

the agency has not reassessed these competencies in a number of years. 

Updating competencies for grant monitoring and planning training to 

address agency goals and critical competencies would help CNCS 

ensure that its workforce can meet current and future grant monitoring 

needs.

To improve CNCS’s efforts to move toward a risk-based process for 

monitoring grants and to improve its capacity for monitoring grantee 

compliance, we are making the following six recommendations to the 

Chief Executive Officer of the Corporation for National and Community 

Service:

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 fraud and improper payments; and (c) 

document decisions on how indicators are selected and weighted.

Recommendations for 

Executive Action
Page 36 GAO-17-90 CNCS Grants Management

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.

3. Review monitoring protocols, including the level of information 

collected for oversight of subrecipients’ activities such as criminal 

history checks, and enhance protocols, as appropriate.

4. Establish activities to systematically evaluate grant monitoring results.

5. Develop and document a strategic workforce planning process.

6. As part of CNCS’s efforts to develop an employee development 

program, update critical competencies for grant monitoring, and 

establish a training planning process linked with agency goals and 

these competencies.

We provided CNCS a draft of this report for review and comment. CNCS 

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

provide technical comments, which we incorporated as appropriate. We

also incorporated technical comments received from CNCS OIG, as 

appropriate.

We are sending copies of this report to the appropriate congressional 

committees and the Chief Executive Officer of the Corporation for 

National and Community Service. In addition, the report is available at no 

charge on the GAO website at http://www.gao.gov.

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

me at (202) 512-7215 or bawdena@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix II.

Allison Bawden

Acting Director, Education, Workforce, and

 Income Security

Agency Comments
Appendix I: State-by-State Data on Corporation 

for National and Community Service (CNCS) 

Grants

Page 37 GAO-17-90 CNCS Grants Management

Table 5: Number of CNCS Projects and Volunteers, and Funding by State, Fiscal 

Year 2016

State

Number of CNCS 

grants/projects

Number of 

volunteers

Total CNCS

fundinga

Alabama 82 9,635 $9,152,881 

Alaska 23 633 $2,941,445 

Arizona 60 3,702 $9,211,551 

Arkansas 59 4,591 $7,229,399 

California 364 25,508 $73,375,903 

Colorado 113 7,659 $22,637,068 

Connecticut 51 3,348 $8,237,050 

Delaware 18 1,305 $2,523,326 

District of Columbia 113 3,671 $24,144,397 

Florida 159 14,418 $29,471,153 

Georgia 96 3,992 $14,526,254 

Hawaii 35 3,166 $4,090,080 

Idaho 42 2,755 $4,261,729 

Illinois 144 14,140 $22,196,259 

Indiana 86 6,421 $10,558,532 

Iowa 76 6,847 $15,728,319 

Kansas 52 5,481 $6,045,291 

Kentucky 68 5,482 $12,953,497 

Louisiana 82 4,949 $12,973,407 

Maine 25 2,338 $5,027,898 

Maryland 82 8,156 $18,987,226 

Massachusetts 146 9,001 $31,675,544 

Michigan 151 10,166 $21,126,893

Minnesota 96 15,653 $35,121,147 

Mississippi 55 3,118 $13,159,659 

Missouri 88 6,136 $11,132,714 

Montana 41 4,849 $7,502,090 

Nebraska 43 3,070 $6,663,263 

Nevada 36 2,414 $4,370,247 

New Hampshire 27 2,941 $5,825,741 

New Jersey 78 6,081 $11,910,101 

New Mexico 88 4,566 $5,724,313 

New York 254 26,229 $67,198,074 

North Carolina 108 7,688 $15,836,148 

Appendix I: State-by-State Data on 

Corporation for National and Community 

Service (CNCS) Grants
Appendix I: State-by-State Data on Corporation 

for National and Community Service (CNCS) 

Grants

Page 38 GAO-17-90 CNCS Grants Management

State

Number of CNCS 

grants/projects

Number of 

volunteers

Total CNCS

fundinga

North Dakota 17 3,330 $2,349,296 

Ohio 108 10,119 $19,159,789 

Oklahoma 53 7,439 $9,457,780 

Oregon 78 5,850 $12,352,922 

Pennsylvania 129 15,765 $25,664,442 

Rhode Island 34 4,220 $4,938,865 

South Carolina 71 4,073 $10,083,018 

South Dakota 32 3,457 $3,692,401 

Tennessee 83 6,193 $11,144,660 

Texasb 232 33,667 $32,563,990 

Utah 63 5,187 $11,728,511 

Vermont 26 2,403 $4,476,522 

Virginia 95 5,724 $10,324,809 

Washington 102 8,745 $23,991,442 

West Virginia 47 3,798 $9,552,979 

Wisconsin 88 9,728 $14,618,993 

Wyoming 22 1,165 $2,479,091 

Source: GAO analysis of Corporation for National and Community Service (CNCS) State Profiles (data as of February 22, 2016). | 

GAO-17-90

a

Total funding amount does not include education awards. Funding amounts for territories are not 

included.

b

Data for Texas is as of April 13, 2016.
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 39 GAO-17-90 CNCS Grants Management

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

In addition to the contact named above, Margie K. Shields, Assistant 

Director; Dana Z. Hopings, Analyst-in-Charge; Jason S. Palmer; and 

Sarah M. Martin made key contributions to this report. Alexander G. 

Galuten, Monica P. Savoy, Ruben Montes de Oca, Kathleen van Gelder, 

Michael L. Kniss, Amy Sweet, Nicholas Weeks, and James E. Bennett 

also provided assistance.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100422)
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