Annual Management Report

Fiscal Year 2021

November 15, 2021

250 E Street SW

Washington, D.C. 20525

202-606-5000/ 800-942-2677

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ABOUT THIS REPORT

The Annual Management Report (AMR) provides an overview of the Corporation for National and 

Community Service’s (AmeriCorps1) financial and performance results for the fiscal year (FY) 

spanning October 1, 2020 through September 30, 2021. The information, data, and analyses in this 

report provide an assessment of the agency’s yearly activities and accomplishments towards its 

mission. The FY 2021 AMR includes AmeriCorps’ FY 2021 Financial Statements Audit Report, including 

AmeriCorps’ Statement of No Assurance regarding its financial reporting, internal controls, and

operations. This report is published on the AmeriCorps website.

AmeriCorps will produce its FY 2023 Congressional Budget Justification with the integrated Annual 

Performance Report (APR) to provide an overall assessment of agency performance. AmeriCorps will 

transmit this report to Congress in early 2022. The Congressional Budget Justification will also be

published on the AmeriCorps’ website.

2

These reports meet the requirements of the Government Performance and Results Modernization Act, 

the Federal Financial Management Improvement Act, the Federal Managers’ Financial Integrity Act, 

the Government Corporation Control Act, and the Federal Information Security Modernization Act,

among others. These reports also follow applicable guidance from the Office of Management and

Budget (OMB).

This report is in the public domain. Authorization to reproduce it in whole or in part is granted with the 

citation: AmeriCorps FY 2021 Annual Management Report, Washington, D.C., 20525.

To request a printed copy of this report, obtain it in a format that is accessible to individuals with

disabilities, or provide any related feedback, please contact the Office of the Chief Financial Officer

at 202-606-6852 or at this mailing address: AmeriCorps, 250 E Street SW, Washington, D.C. 20525.

YOUR GUIDE TO USING THIS REPORT

This report is organized into four major sections, plus a glossary and URL index. 

Management’s Discussion and Analysis Section 

This section provides an overview of AmeriCorps’ organization, mission, and strategic framework. A 

summary of the agency’s FY 2021 programs and financial performance are provided along with 

management’s assessment of AmeriCorps’ challenges and its Statement of No Assurance on 

AmeriCorps internal controls. 

Financial Section 

A message from AmeriCorps Chief Financial Officer (CFO) opens this section, followed by the 

agency’s unaudited financial statements, accompanying notes, required supplementary 

information, and the independent auditors’ report. 

Other Information Section 

This section provides the top management challenges facing AmeriCorps, as identified by the 

Inspector General (IG), a summary table of financial statement audit and Statement of No 

Assurance, information on the agency’s efforts to eliminate improper payments, other administrative 

updates, and reporting requirements under AmeriCorps legislation.

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Glossary of Acronyms and Abbreviations 

The glossary lists and defines the acronyms used throughout this report. 

URL Index 

For those using a paper version of AmeriCorps FY 2021 AMR, you can find the underlined text items in 

the URL Index on page 238. It provides full web addresses for all hyperlinks included in this AMR 

narrative.

1 As of Sept. 29, 2020, AmeriCorps is the operating name of the Corporation for National and Community Service.

2 The Administration only requested funding for an orderly AmeriCorps shutdown in FY 2019, FY 2020, and FY 2021. Therefore,

the agency did not include performance information within these budgets. Prior year performance information is included

in AmeriCorps’ budgets, which are published on the AmeriCorps website.

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TABLE OF CONTENTS

CONTENTS

I. MESSAGE FROM THE CHIEF EXECUTIVE OFFICER........................................................ 5

II. MANAGEMENT’S DISCUSSION AND ANALYSIS........................................................... 8

A. MISSION AND ORGANIZATIONAL STRUCTURE ....................................................8

B. PERFORMANCE PRIORITIES AND EXAMPLES .....................................................12

C. ANALYSIS OF FINANCIAL STATEMENTS AND STEWARDSHIP INFORMATION ...16

D. ANALYSIS OF SYSTEMS, CONTROLS AND LEGAL COMPLIANCE .....................22

III. FINANCIAL SECTION ..................................................................................................24

PART A. MESSAGE FROM THE CHIEF FINANCIAL OFFICER ....................................24

PART B. INDEPENDENT AUDITORS’ REPORT ON CONSOLIDATED FINANCIAL

STATEMENTS AND MANAGEMENT'S RESPONSE.....................................................26

PART C. CONSOLIDATED FINANCIAL STATEMENTS ................................................66

PART D. NOTES TO CONSOLIDATED FINANCIAL STATEMENTS ..............................73

PART E. INDEPENDENT AUDITORS’ REPORT ON NATIONAL SERVICE TRUST FUNDS

FINANCIAL STATEMENTS AND MANAGEMENT'S 

RESPONSE............................................................................................................91

PART F. NATIONAL SERVICE TRUST FUND FINANCIAL STATEMENTS .......................124

PART G. NOTES TO NATIONAL SERVICE TRUST FUND FINANCIAL STATEMENTS ...128

IV. OTHER INFORMATION ................................................................................................134

PART A. SUMMARY OF FINANCIAL STATEMENT AUDIT & MANAGEMENT.............134

PART B. PAYMENT INTEGRITY ...................................................................................137

PART C. CIVIL MONETARY PENALTY ADJUSTMENT FOR INFLATION ......................138

PART D. NATIONAL SERVICE TRUST FUND STATUS REPORT (As of September 30, 

2021) ..................................................................................................................139

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I. MESSAGE FROM THE CHIEF EXECUTIVE OFFICER

November 15, 2021

For more than a quarter century, AmeriCorps has leveraged the nation’s greatest resource – the 

American people – to improve lives, strengthen communities, and foster civic engagement. Working 

hand in hand with thousands of local partners, AmeriCorps engages 250,000 individuals in resultsdriven service at 40,000 locations across the country. 

AmeriCorps members and AmeriCorps Seniors volunteers help communities tackle pressing 

challenges – addressing COVID-19 and other public health needs, preparing students for success, 

combating the opioid epidemic, responding to natural disasters, supporting veterans and military 

families, preserving public lands, addressing climate change, fostering economic opportunity, and 

much more.

AmeriCorps’ Fiscal Year 2021 Annual Management Report summarizes agency accomplishments 

and financial information in accordance with relevant federal guidance and laws. AmeriCorps’ work 

last year – during one of the most trying times in the nation’s history – demonstrates the agency’s 

continued commitment to put AmeriCorps’ resources in communities most in need, while also 

placing increased focus and resources in evidence-based approaches and operational efficiency. 

Despite the challenges presented by the pandemic and economic slowdown, AmeriCorps reached 

several important milestones in the agency’s efforts to strengthen the foundation of AmeriCorps and

respond to the nation’s current needs, and position the agency for future success. AmeriCorps’ FY 

2021 accomplishments include the following:

• AmeriCorps continued to provide pandemic assistance to millions of Americans – supporting

vaccination, contact tracing, testing, wellness checks, and other public health strategies;

assisting food banks and meal delivery programs; and helping students stay on track through

virtual teaching, tutoring, mentoring, and other services. The agency is also engaging in an allAmeriCorps program effort to support families in signing up for the Child Tax Credit.

AmeriCorps Seniors entered into an agreement with the National Head Start Association and

the Office of Head Start. The agency is partnering with the Department of Housing and Urban

Development through its AmeriCorps VISTA program. All programs hosted Child Tax Credit

trainings for all grantees and AmeriCorps members serving in VISTA and National Civilian

Community Corps (NCCC) programs.

• The agency began implementing the historic investment provided by the American Rescue

Plan Act to address community needs in public health, food insecurity, and education. The

agency expanded service opportunities in AmeriCorps and AmeriCorps Seniors, raised the

living allowance for AmeriCorps members in the State and National and VISTA programs, and

expanded outreach to underserved communities and individuals.

• AmeriCorps invested in and began embedding diversity, equity, inclusion, and accessibility

principles, strategies, and initiatives across programs, policies, and operations, taking steps to

build a more diverse workforce, promote equitable grantmaking, and recruit a more diverse

corps of members and volunteers.

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• AmeriCorps partnered with the Center for Disease Control and Prevention to develop Public

Health AmeriCorps, a new initiative to add capacity to strained public health systems and

build a career pipeline for the next generation of diverse, talented public health leaders to

enhance pathways to public health related careers.

Effective stewardship of federal resources remains a top priority for the agency, and in FY 2021 

AmeriCorps made progress improving core business operations through the shared services

stabilization of financial management, procurement, and travel functions. AmeriCorps also identified 

additional strategies and reforms to improve agency audit management and audit resolution.

AmeriCorps appreciates the Office of Inspector General’s continued communication and 

collaboration in addressing audit findings. Notable FY 2021 AmeriCorps accomplishments include:

• AmeriCorps continued efforts to improve grantee compliance with national service criminal

history check requirements, and in FY 2021 published a regulation designed to streamline and

simplify these requirements. The results of the agency’s years-long efforts to address this

important safety requirement have led to improvements.

• AmeriCorps developed and continued to refine a real-time, dynamic grantee risk assessment,

which informs the agency’s new risk-based monitoring structure. AmeriCorps continues to

prioritize resources for the Office of Monitoring to ensure effective compliance monitoring for

the AmeriCorps grant portfolio, including enhancing monitoring instruments and standardizing

protocols.

• AmeriCorps continued to optimize and invest in financial management systems and processes

within a shared services platform that seeks to improve accountability, standardizes business

processes, and ensures staff and partners receive timely and reliable mission support.

• Working with the OIG, the agency has taken additional steps to enhance fraud

prevention, detection, and response strategies by conducting an internal assessment,

engaging other federal agencies to identify leading practices in anti-fraud measures,

revising the grantee risk assessment module to emphasize fraud risk indicators, and

developing a fraud awareness training for grantees, among other actions. AmeriCorps

continues to work with the OIG to advance this work and prioritize investments needed

to balance the establishment of baseline compliance efforts and increased fraud

prevention.

While much work remains, these and other accomplishments reflect the agency’s commitment to 

improving core business practices, building capacity and systems, and strengthening operations to 

ensure the sustainability of national service. AmeriCorps’ responsibility is too great, and mission is too 

important, to not elevate these as essential agency priorities for where AmeriCorps invests time and 

federal resources. These improvements are intended to help AmeriCorps be more effective fiscal 

stewards, better serve partners and grantees, and effectively engage AmeriCorps members and 

AmeriCorps Seniors volunteers in service across the nation.

AmeriCorps is on track to help the nation recover from the impacts of the pandemic, advance racial 

and economic equity, address climate change, and respond to other community needs while 

continuing to improve financial management and operations. With a new strategic plan focused on 

balancing mission work and mission support functions, and new resources from the American Rescue 

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Plan, AmeriCorps will continue to improve lives and strengthen communities while ensuring the 

agency is an accountable steward of the taxpayer dollar.

In service,

Mal Coles

Acting Chief Executive Officer

AmeriCorps

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II. MANAGEMENT’S DISCUSSION AND ANALYSIS

A. MISSION AND ORGANIZATIONAL STRUCTURE

AmeriCorps’ mission is to engage Americans of all ages and backgrounds in community-based 

service to improve lives, strengthen communities, and foster civic engagement. AmeriCorps achieves

its mission through the administration of its eight major programs and initiatives.1

Agency Program Accounts and Descriptions

A description of each AmeriCorps program account in the agency’s annual appropriation is 

included below.

AmeriCorps State and National

The AmeriCorps State and National program provides funding to States, Territories, Tribes, and 

community-based organizations that manage members who serve full- or part-time on projects that 

align with priority focus areas. These include economic opportunity, education, healthy futures, 

disaster relief, environmental stewardship, and veterans and military families. This program supports 

organizations that see service as a solution to local and national challenges and creates powerful 

member experiences that foster a lifelong commitment to civic engagement.

AmeriCorps State and National is run through a combination of efforts managed by AmeriCorps and 

State Service Commissions. State Service Commissions (located in 49 states, the District of Columbia, 

Guam, and Puerto Rico) administer grant funds to programs within the states, which are awarded on 

both a competitive and formula basis. Programs that operate in more than one state (all of which

are awarded competitively) are part of the AmeriCorps State and National portfolio and managed 

through the Office of Regional Operations.

AmeriCorps VISTA

The AmeriCorps VISTA program was created to strengthen and support local efforts to address

poverty and poverty-related problems in the United States. It accomplishes this goal primarily by 

engaging AmeriCorps members to serve full time with community organizations and public agencies

build long-term sustainability of anti-poverty efforts within the communities in which they serve. These

members act as a catalyst for change, living and working alongside community members to meet 

the nation’s most pressing challenges, build capacity for nonprofits and public agencies, and 

advance local solutions. AmeriCorps provides the management infrastructure for this program, while 

members are supported and project activities are driven by the program’s project sponsors.

1 AmeriCorps’ authorizing statutes, which contain additional legislative detail for each program, can be found at: Statutes and 

regulations | AmeriCorps

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AmeriCorps National Civilian Community Corps (NCCC)

The AmeriCorps NCCC program is a 10 to 12 month residential national service program for people

ages 18–26. This program deploys AmeriCorps members to address needs related to natural and 

other disasters, infrastructure improvement, energy conservation, and urban and rural development. 

AmeriCorps members serving in NCCC construct and rehabilitate low-income housing, respond to 

natural disasters, clean-up streams, help communities develop emergency plans, and address 

countless other local needs. AmeriCorps directly operates the NCCC program.

Under AmeriCorps NCCC, the agency also administers the NCCC-FEMA Corps program, a

partnership with the Federal Emergency Management Agency to serve communities affected by 

disaster. This program also serves as a workforce development program to provide the next 

generation of disaster services professionals the skills necessary to take on future careers in the 

disaster services sector.

AmeriCorps State Service Commission Support Grants

In 1993, Congress created this shared federal-state partnership with a central role for Governors to 

design and implement national service through Governor-appointed State Service Commissions. 

More than 1,000 private citizens serve as Governor-appointed commissioners, leading and guiding 

national service efforts in their states by identifying local needs, directing federal and state resources, 

ensuring oversight and accountability, tracking performance and community outcomes, and

leading citizen service efforts in their states and territories.

AmeriCorps Seniors Foster Grandparent Program

The Foster Grandparent Program is an intergenerational program first established in 1965, through 

which volunteers help children in their communities develop academic and life skills important to 

their development and future success. Low-income volunteers age 55 and over engage in 

opportunities to provide one-on-one mentoring, tutoring, and social-emotional support to children 

with special or exceptional needs, or who are at an academic, social, or financial disadvantage. As 

a part of their service volunteers receive a stipend of $3.00 per hour. The agency renews grants for 

the Foster Grandparent program annually.

AmeriCorps Seniors Senior Companion Program

The Senior Companion Program engages low-income volunteers age 55 and over in providing inhome support and companionship to adults who have difficulty with daily living tasks. They provide

assistance, such as shopping or paying bills and provide respite to family caregivers. As a result, 

seniors are able to maintain their independence and decrease social isolation. The service volunteers 

provide help seniors age in place and avoid costly institutional care. As a part of their service 

volunteers receive a stipend of $3.00 per hour. The agency renews grants for the Senior Companion 

program annually.

AmeriCorps Seniors RSVP

The RSVP program is one of America’s largest volunteer networks for people age 55 and older and

engages the skills, talents, and experience of volunteers to meet a wide range of community needs. 

These AmeriCorps Seniors volunteers recruit and manage other volunteers, mentor and tutor children 

who are disadvantaged, support workforce development by providing job readiness training, offer 

free tax preparation, help seniors live independently in their homes, assist communities as they

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recover from disasters, and expand economic opportunities for veterans and their families. The 

agency awards grants for the RSVP program on a competitive basis.

Innovation and Demonstration

AmeriCorps aims to engage more Americans in service to meet pressing community needs through 

its Days of Service – Martin Luther King, Jr. National Day of Service and the September 11th National

Day of Service and Remembrance. Grants for Days of Service are awarded competitively.

AmeriCorps’ Volunteer Generation Fund supports the agency’s mission to improve lives and 

strengthen communities by strengthening volunteer management practices across the country. This

includes helping State Service Commissions broaden their volunteer base, more effectively recruit 

and retain volunteers, expand opportunity for those who serve, and improve their outcomes on 

community challenges. The agency awards these funds through a competitive, data driven process.

Evaluation

AmeriCorps’ Office of Research and Evaluation coordinates the agency’s learning agenda, which 

includes building its evidence base and facilitating the use of evaluation to inform decisions. To this 

end, the office conducts research and evaluation on AmeriCorps programs, helps build the capacity 

of agency-funded partners to conduct and understand evaluations, and facilitates evidence-based

and evidence-informed grantmaking.

National Service Trust

The National Service Trust provides Segal AmeriCorps Education Awards for AmeriCorps members

who successfully complete an eligible term of service in State and National, NCCC, or VISTA

programs.

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B. PERFORMANCE PRIORITIES AND EXAMPLES 

As mentioned earlier in this report, AmeriCorps is currently developing its FY 2022-2026 Strategic Plan, 

which will guide agency resources moving forward. This plan will define goals, objectives, and 

metrics. The information in this section reflects important results the agency achieved in FY 2021, 

aligned with new Administration priorities and consistent with AmeriCorps’ statutory purpose.

In FY 2021, AmeriCorps focused its resources on addressing the unprecedented challenges of the 

COVID-19 pandemic and resultant economic crisis that led to increased community needs in health, 

education, food security, and other areas. AmeriCorps continued to prioritize the health and safety 

of members and volunteers and support the agency’s large network of partners in helping to combat 

the COVID-19 pandemic, expand economic opportunity, and meet a wide range of community 

needs.

AmeriCorps also made progress in advancing Administration priorities to make service more 

accessible and inclusive, remove barriers to service, increase the diversity of members and 

volunteers, and strengthen pathways to education, employment, and lifelong civic engagement.

Examples of this progress are presented below and on the following pages. Also provided later in this 

report is data on the AmeriCorps Member Exit Survey (MES), which demonstrates the agency’s 

progress in promoting civic engagement.

Priority: Partner with communities to advance racial equity and alleviate poverty

• Since the outbreak of COVID-19, AmeriCorps members and AmeriCorps Seniors 

volunteers have provided pandemic related assistance to millions of Americans, 

including conducting more than 1.6 million wellness checks, assisting more than 2.5 

million people at 160 vaccination sites, and recruiting 60,000 volunteers; collecting and 

distributing 145 million pounds of food and providing more than 34 million meals; and 

helping students stay on track in school by providing virtual teaching, tutoring, 

mentoring, college counseling, and other services.

2

 

• At a time of unprecedented need in public health, AmeriCorps partnered with 

the Centers for Disease Control and Prevention (CDC) to develop Public Health 

AmeriCorps – a $400 million investment from the American Rescue Plan to respond to 

the public health needs of the nation and support the recruitment, training, and 

development of a new generation of leaders who will be ready to provide public 

health service in their own communities. 

• The agency directed American Rescue Plan program funding to communities in 

FY 2021, distributing resources to communities across the country to expand service 

opportunities in AmeriCorps and AmeriCorps Seniors, raise the living allowance for 

members in the AmeriCorps State and National and AmeriCorps VISTA programs, 

increase the sustainability of AmeriCorps grantees, and expand outreach to

underserved communities and individuals. This included supporting 1,000 additional 

AmeriCorps VISTA members to in the 2021 Summer Associates program to address

community needs in public health, food insecurity, and education, and issuing out

2 COVID statistics have been aggregated since March 2020. Actuals might be greater because reporting was voluntary.

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more than $220 million in formula dollars to Governor Appointed State Service 

Commissions to address pressing needs in their states.

• In collaboration with the U.S. Treasury Department’s Community Development 

Financial Institutions Fund (CDFI Fund), AmeriCorps awarded $2.5 million over two years

in grants to three organizations through the inaugural round of the AmeriCorps CDFI 

Economic Mobility Corps program. This new national service program places full-time 

national service members in Certified CDFIs to support their work in distressed and 

underserved communities, providing financial literacy, financial planning, budgeting, 

saving, and other financial counseling education. 

• AmeriCorps Seniors awarded $5.5 million in American Rescue Act supplemental 

appropriations to current grant recipients in the AmeriCorps Seniors Foster 

Grandparent, Senior Companion, and RSVP programs. This funding expanded activities 

focused on combating the COVID-19 pandemic, including contact tracing, 

vaccination programs, vaccination education and navigation services, and youth 

educational achievement. AmeriCorps Seniors closed a second Notice of Funding 

Opportunity (NOFO) for American Rescue Plan funding targeted to current grantees 

on October 18, 2021. This opportunity is focused on supporting current grantees to

grow their service and meet current community needs. These awards will be 

announced in March 2022. AmeriCorps Seniors has also released its American Rescue 

Plan Demonstration Program NOFO, which is for new organizations and communities 

who are not currently AmeriCorps Seniors grantees.

• To address conservation and climate challenges, AmeriCorps awarded more 

than $65 million in FY 2021 AmeriCorps State and National grants to support 138 

projects and more than 11,400 members to carry out projects to improve parks and 

public lands; increase reforestation; expand access to recreation; weatherize homes; 

create and maintain urban parks and greenspaces; and help communities prepare, 

respond, and recover from natural disasters and other climate-related challenges. 

Priority: Enhance the experience for AmeriCorps members and AmeriCorps Seniors volunteers

• Increased the FY 2021 AmeriCorps State and National minimum living allowance 

to $16,000 and the AmeriCorps VISTA living allowance to $15,002 using American 

Rescue Plan Act funds. This increase advances the Administration’s commitment to 

racial and economic equity and priorities to recruit and retain a diverse corps of 

AmeriCorps members and make service more accessible to Americans of all 

backgrounds. 

• Established mechanisms for collecting information about the socio-economic 

status of AmeriCorps Members participating in the AmeriCorps State and National and 

AmeriCorps NCCC programs to establish a baseline of understanding as to whether 

AmeriCorps is a viable pathway for individuals from all economic backgrounds. 

• Launched Schools of National Service, an initiative to encourage more colleges 

and universities to provide matching funds, tuition discounts, college credit, and other 

incentives to encourage AmeriCorps alumni to attend their institution. More than 280 

higher education institutions participate in the program, which makes postsecondary 

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education more accessible and affordable and helps colleges and universities recruit 

talented, mission-driven leaders to their institutions. The launch of Schools of National 

Service led to an increase in the number of participating colleges and universities and

inspired national service stakeholders to increase their outreach to enlist more School 

of National Service. 

Priority: Unite Americans by bringing them together in service 

• In conjunction with the Creative Artists Agency Foundation, MENTOR.org, 

VolunteerMatch, schoolhouse.world, and the U.S. Department of Education, the 

agency helped launch READY.SET, a national tutor, mentor, and service recruitment 

initiative designed to address learning and relational loss among K-12 public school 

students in the U.S., particularly in historically marginalized communities. The initiative 

encourages communities across the country to “Be a Part of America's Student 

Support Network" by committing to volunteering/serving. READY.SET is led by a nineperson advisory committee, including Education Secretary Miguel Cardona and 

former Secretary Arne Duncan. The member coalition includes nearly 50 nonprofit, 

corporate and community organizations including Arianna Huffington’s THRIVE Global, 

Will and Jada Smith Foundation, NAMI, United Way, and the Born This Way Foundation. 

The initiative continues to grow and AmeriCorps has engaged with several of the 

coalition partners directly to initiate collaborations to increase awareness and support 

of national service. Ongoing social media campaigns are in development for 

READY.SET to increase education and engagement in volunteerism and national 

service opportunities focused on supporting K-12 students and educators. 

• AmeriCorps’ Volunteer Generation Fund grants to State Service Commissions 

supported the recruitment of more than 163,000 volunteers in FY 2020 and built the 

capacity of a projected 5,500 nonprofit and community organizations to recruit and 

manage volunteers and increase the effectiveness of volunteers in addressing local 

challenges.3

• The agency also advanced the knowledge base of volunteer management 

capacity within the U.S. nonprofit sector through its sponsored research program (see 

Hager, M.A., and Brudney, J.L. (2021). Volunteer Management Capacity in America’s 

Charities: Benchmarking a Pre-Pandemic Field and Assessing Future Directions. Arizona 

State University.) The agency will use these findings to benchmark the Volunteer 

Generation Fund grantees participating in an evaluation initiated in 2021. 

• The Volunteer Generation Fund evaluation represents the first effort to examine 

state service commission models since the inception of the program. To prepare for this 

effort, AmeriCorps conducted a comprehensive review of grantee applications and 

external literature. The review shows that state commissions use multi-faceted 

approaches to increasing volunteers and volunteer organization capacity within their 

states. However, while there is scholarly literature that supports specific volunteer 

recruitment and management practices, AmeriCorps identified very few research or 

evaluation studies that examine statewide efforts to increase volunteer management 

practices across volunteer organizations. As a result, this demonstration will take an 

3 Updated data will be available in AmeriCorps’ FY 2023 Congressional Budget Justification. 

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exploratory and descriptive approach to look at 14 program models that have been 

active during FY 2021 and their perceived outcomes.

• AmeriCorps’ 2020 Day of Service grantees engaged more than 205,000 

Americans in service on the Martin Luther King Jr. Day of Service and the September 

11th National Day of Service and Remembrance. The MLK Day of Service focused on 

honoring Dr. King with projects that improved local communities, and 9/11 Day of 

Service projects focused on supporting veterans, soldiers, and military families.4 

Priority: Effectively steward federal resources 

During FY 2021, the agency continued efforts to improve core business operations, enhance 

customer service, and build long-term sustainability. 

• Continued to prioritize resources for the agency’s Office of Monitoring to ensure 

effective compliance monitoring for the AmeriCorps grant portfolio, including 

enhancement of monitoring instruments, standardizing monitoring protocols, and using 

a grant risk model to inform monitoring decisions and align individual activities to 

specific risks.

• Continued comprehensive efforts to improve grantee compliance with national 

service criminal history check requirements, and in FY 2021 published a regulation 

designed to streamline and simplify these requirements. 

• Continued to optimize and invest in financial management systems and 

processes within a shared services platform that enhances accountability, standardizes 

business processes, and ensures staff and partners receive timely and reliable mission 

support. 

• Continued the agency’s Scaling Evidence-Based Models project to deepen 

understanding of the most effective program innovations and scale them to better 

serve communities. As part of this initiative, the agency has produced tools and 

resources to strengthen grantees’ work in evidence building and share effective 

practices to help scale evidence-based interventions.5

4 Updated data will be available in AmeriCorps’ FY 2023 Congressional Budget Justification.

5 These tools can be found on AmeriCorps’ website at: Scaling Checklists: Assessing Your Level of Evidence and Readiness 

(SCALER) | AmeriCorps

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C.ANALYSIS OF FINANCIAL STATEMENTS AND STEWARDSHIP INFORMATION

The accompanying FY 2021 financial statements have been prepared in accordance with the 

accounting standards codified in the Statements of Federal Financial Accounting Standards and the 

Office of Management and Budget (OMB) Circular No. A-136, Financial Reporting Requirements.

Table of Key Measures (in thousands)

Unaudited Unaudited 

2021 2020 % Change

Assets

Fund Balance with Treasury $ 2,364,927 $ 2,058,467 15%

Investment (Net) 1,011,223 185,714 445%

Accounts Receivable, Net 3,267 1,165 180%

General Property, Plant, and 

Equipment, Net 3,235 3,651 -11%

Advances and Prepayments 87,092 66,399 31%

Total Assets $ 3,469,743 $ 2,315,397 50%

Liabilities 

Accounts Payable $ 157,927 $ 110,332 43%

Federal Employee [and Veteran] 

Benefits Payable 13,915 13,412 4%

Advances from Others and Deferred 

Revenue 6,446 10,244 -37%

Other Liabilities

 Trust Service Award Liability 356,024 438,294 -19%

 Accrued Funded Payroll and 

Leave 3,826 3,518 9%

 Benefit Program Contributions 

Payable 2,569 1,577 63%

 Tenant Improvement Allowance 2,485 2,779 -11%

 Other Liabilities 1,712 2,264 -24%

Total Liabilities $ 544,904 $ 582,421 -6%

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Net Position:

Unexpended Appropriations - Funds from 

Other than Dedicated Collections 2,132,473 1,098,387 94%

Cumulative Results of Operations - Funds 

from Other than Dedicated Collections 792,367 634,589 25%

Total Net Position $ 2,924,840 $ 1,732,976 69%

Net Cost of Operations

Gross Costs $ 920,468,348 $ 1,010,508,344 7%

Less: Earned Revenue 21,049,805 31,895,251 -3%

Net Cost of Operations $ 899,418,543 $ 978,613,093 8%

Budgetary Resources:

Unobligated balance from prior year 

budget authority, net $ 595,010 $ 395,538 50%

Appropriations 2,475,596 1,336,271 85%

Spending authority from offsetting 

collections 12,735 35,553 -64%

Total Budgetary Resources $ 3,083,341 $ 1,767,362 74%

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Balance Sheet

The Balance Sheet provides an overview of AmeriCorps’ financial position for the fiscal years ending 

September 30, 2021 and 2020. The statement displays the current and future economic benefits for

use (assets), amounts owed (liabilities) and the residual amount (net position).

Assets

For the fiscal years ending September 30, 2021 and 2020, AmeriCorps had $3.47 billion and $2.31 

billion in assets, respectively. Fund Balance with Treasury (FBWT) and Investments in Securities formed 

majority of the assets. The Balance Sheet also identifies governmental and non-governmental 

activities.

FBWT is the largest asset class, representing 68% of total assets. FBWT increased by 15% in FY 2021 due 

primarily to receipt of additional appropriated funds from the American Rescue Plan.

Investments are 29% of total assets making it the second largest class. Funding for the Trust

investments comes from appropriations and interest earned that are invested in Treasury bills and 

securities. In FY 2021, there was a 445% increase in investments due primarily to an increase in 

investment activities and reduced balances in Trust FBWT.

Total Assets, 

$3,469,743 

Total Liabilities, 

$544,904 

Total Net Position, 

$2,924,840 

Total Assets, 

$2,315,397 

Total Liabilities, 

$582,421 

Total Net Position, 

$1,732,976 

Total Assets Total Liabilities Total Net Position

Comparative Balance Sheet (in thousands)

2021 2020

18
Liabilities

AmeriCorps liabilities, or amounts owed, were $545 million and $582 million for the fiscal years ending 

September 30, 2021 and 2020, respectively. Most of the liabilities are $356 million in Trust Service

Award and $158 million in Accounts payable. The Trust Service Award Liability represents estimates of

unpaid and earned education award and interest forbearance costs that are likely to be paid. The 

Accounts Payables, on the other hand, represent funds due to grantees, suppliers, and contractors.

68%

29%

0%

3%

0%

Assets

Fund Balance with Treasury

Investments and Related

Receivables

Accounts Receivable, Net

Advances to Others

Property and Equipment, Net

29%

65%

1%

5%

Liabilities

Accounts Payable

Trust Service Award Liability

Advances from Others

Other Liabilities

19
Net Position

AmeriCorps’ Net Position is the difference between assets and liabilities. Changes in Net Position result

from changes in the cumulative results of operations. In FY 2021, there was a 94% increase in

unexpended appropriations due to receipt of additional appropriated funds from the American

Rescue Plan and 25% increase in cumulative results of operations, mostly caused by a decrease in

Segal AmeriCorps Education Awards in FY 2021.

Statement of Net Cost

The AmeriCorps Statement of Net Cost measures the use of appropriated funds by programs (VISTA,

NCCC, State and National, RSVP, FGP, SCP) authorized by Congress. The AmeriCorps net cost for the 

fiscal years ending September 30, 2021 and 2020 were $899 million and $979 million, respectively. The 

9% decrease in operating cost in FY 2021 is mostly due to the decrease in Service Award Expense.

AmeriCorps State and National is the largest contributor to the agency’s overall cost of operations.

The program cost includes grant expenses, direct and allocated personnel, and administrative cost.

Unexpended 

Appropriations , 

$2,132,473 

Cumulative Results of 

Operations , $792,367 

Net Position, 

$2,924,840 

Unexpended 

Appropriations , 

$1,098,387 

Cumulative Results of 

Operations , $634,589 

Net Position, 

$1,732,976 

Unexpended Appropriations Cumulative Results of Operations Net Position

Comparative Net Position (in thousands)

2021 2020

20
Statement of Budgetary Resources

The statement of budgetary resources represents AmeriCorps’ budgetary resources, which comes 

from unobligated balances from prior-year appropriations, new appropriations, spending authority 

from offsetting collections, and receipts from other sources such as collections of disallowed costs

from grantees at the end of the reporting fiscal year. In FY 2021, AmeriCorps had an 85% increase in 

appropriations due to additional appropriations received from the American Rescue Plan.

Gross Costs, $920,468 

Earned revenue, 

$21,049 

Net Cost of 

Operations, $899,419 

Gross Costs, 

$1,010,498 

Earned revenue, 

$31,885 

Net Cost of 

Operations, $978,613 

Gross Costs Earned revenue Net Cost of Operations

Comparative Net Cost (in thousands)

2021 2020

Unobligated 

Balance from 

prior year budget 

authority, 

$595,010 

Appropriations , 

$2,475,596 

Spending authority 

from offsetting 

collections, 

$12,735 

Total Budgetary 

Resources, 

$3,083,341 

Unobligated 

Balance from 

prior year 

budget 

authority, 

$395,538 

Appropriations , 

$1,336,271 

Spending authority 

from offsetting 

collections, 

$35,553 

Total 

Budgetary 

Resources, 

$1,767,362 

Unobligated Balance from prior

year budget authority

Appropriations Spending authority from

offsetting collections

Total Budgetary Resources

Comparative Budgetary Resources (in thousands)

2021 2020

21
D. ANALYSIS OF SYSTEMS, CONTROLS AND LEGAL COMPLIANCE

CEO Statement of No Assurance and Assessment of Internal Controls

AmeriCorps management is responsible for managing risks and maintaining effective internal control 

to meet the objectives of Sections 2 and 4 of the Federal Managers' Financial Integrity Act. 

AmeriCorps conducted its assessment of risk and internal control in accordance with OMB Circular 

No. A-123, Management Responsibility for Enterprise Risk Management and Internal Control. Based 

on the results of the assessment and the other factors stated below, the Agency is unable to provide 

assurance that internal control over operations, reporting, and compliance was operating 

effectively. 

During Fiscal Year 2021, AmeriCorps was in the process of executing its strategic decision to move its 

financial and certain other systems to shared services provider (the Administrative Resource Center 

within the US Department of the Treasury). This transition caused some disruption to AmeriCorps’ 

control environment. Moreover, AmeriCorps requested that certain areas that had been identified as 

material weaknesses in prior years’ audit be excluded from FY2021 financial statements audit while 

the Agency continued the remediation effort toward the goal of resolving the vast majority of the 

current material weaknesses in 2022. 

The agency is committed to continuing progress on what will be a multi-year journey toward a clean 

audit opinion and to leveraging the expertise and recommendations of our auditors and Inspector 

General.

Providing effective stewardship of federal resources is a key strategic goal for the agency, and the 

AmeriCorps management intends to continue to implement its strategy for progress toward a clean 

audit, addressing root cause drivers, such as capacity and systems, enforcing robust accountability 

mechanisms, and improving executive oversight.

Mal Coles

Acting Chief Executive Officer

AmeriCorps

22
List of FY 2021 Material Weaknesses 

Audit Area NFR

#

Description of Material Weakness First 

Year 

Report

ed

1. Trust 

Obligation and 

Liability Model 

(TOLM)* 

21-1 1. AmeriCorps’ inability to provide quality audit documents in a timely 

manner ultimately impacted CLA’s ability to perform required audit 

procedures. The areas include the following:

1. Undelivered Orders (UDO)

2. Advances from Others

3. Recoveries from Prior Year Obligations

2017

2. Undelivered 

Orders and 

Accounts 

Payable –

Procurement*

21-1 2018

3. Other 

Liabilities

21-1 2018

4. Undelivered 

Orders (Grant)*

21-5 2018

5. Recovery of 

Prior Year 

Obligations

21-5 2018

6. Internal 

Control 

Program 

(FMFIA)

21-8 1. AmeriCorps was unable to effectively implement CAPs to resolve 

eight out of nine material weaknesses and one significant deficiency. 

(New)

2. Three principles rated medium or low risk were not justified. (Modified 

Repeat)

3. Functional units such as AFMS and Office of Budget did not provide 

Assurance Statements.

2018

7. Financial 

System and 

Reporting**

21-5 

& 21-

6

1. Systemic deficiencies in the core financial system. (Repeat)

AmeriCorps did not properly use object class codes to record 

transactions.

2. Conduct a review of transactions processed in Momentum and 

converted to Oracle to ensure that they report the correct object class 

either prior to conversion or immediately after. (New)

2017

8. Grants 

Accrual 

Payable and 

Advances*

21-3 1. The grant accrual process is overly reliant on the accuracy of the 

undelivered order (UDO) balances to allocate the calculated accrual to 

the grantees. The underlying data of the UDO balance is not reliable 

based on unresolved FY 2019 audit findings. (New)

2018

23
*AmeriCorps Internal Control Program identified a material weakness in this process

**AmeriCorps Internal Control Program identified a significant deficiency in this process in FY 2021

III. FINANCIAL SECTION

PART A. MESSAGE FROM THE CHIEF FINANCIAL OFFICER

It is my privilege to join the acting CEO of AmeriCorps in presenting the FY 2021 Annual Management 

Report. The financial statements and accompanying information are an integral part of the AMR, 

providing an in-depth view of accomplishments and challenges in supporting national service and 

volunteering to improve communities. Further, the financial statements support AmeriCorps’

commitment to be transparent with and accountable stewards of taxpayer resources entrusted to 

us.

In FY 2021, the Office of the Inspector General conducted a limited scope financial statement audit, 

focused on areas of findings and recommendations the agency has begun to make progress on 

addressing. The auditors declined to express an opinion on the financial statements, and AmeriCorps 

is therefore presenting its unaudited financial statements. AmeriCorps continues to analyze, prioritize, 

and determine paths to resolve prior years’ open financial statement audit findings and 

unimplemented recommendations and will work closely with the OIG as the agency implements

corrective actions to address findings related to internal controls over financial reporting. 

2. AmeriCorps’ accrual methodology presumes that IBNR is already 

considered in the eGrants federal financial reports (FFRs) and relies on 

the grantees’ self-reporting of unliquidated obligations, which 

AmeriCorps has not validated. (New)

3. AmeriCorps did not take corrective action to address the 

overstatement of advances. (Repeat)

9. FY2021 

Migration to 

Shared Service

21-7 1. Interface issues relating to conversion from Momentum to Oracle.

2. Clean-up of significant general ledger accounts still ongoing/pending. 

(New)

2021

10. Fund 

Balance with 

Treasury*

No Fund Balance with Treasury reconciliation performed in one out of 

three quarters for those processes such as grants that were not 

transferred to ARC for processing.

2021

11. Property 

and 

Equipment*

Iss Issue with tracking capital equipment 2021

24
This year, the agency continued its journey toward increasing the quality, reliability, and value of core 

financial management services and enhanced operational productivity. FY 2021 marked the first full 

year of the agency’s financial management, procurement, and travel functions being carried out 

through a shared services platform. The agency is now being supported by expert technical support 

and has realized improved reporting capabilities in core areas including status of funds, trial balance, 

and financial statements; and has access to detailed schedules of subledger accounts, detailed 

payroll reports with complete line of accounting, and detailed PRISM and travel reports. AmeriCorps 

is able to run automatically GTAS and DATA Act data with very little manual adjustments, and 

moreover, the agency’s accounting systems are now fully compliant to Treasury and OMB standards. 

While this is a significant achievement, there is much work to do to improve and strengthen 

AmeriCorps’ ability to maintain the highest financial management and operational standards. 

Stabilization under shared services to improve our core financial functions and eGrants modernization

to improve grantee and subgrantee data quality and controls are two key efforts to strengthen the 

agency’s stewardship of resources. These efforts will be accompanied by an aggressive focus to 

address root cause drivers, such as staff capacity and antiquated systems, while enforcing robust 

accountability mechanisms, and improving executive oversight.

In FY 2021, the agency identified key strategies and reforms to improve agency audit management 

including making resource investments in staff capacity and expertise, making needed 

improvements to agency corrective action planning and oversight, and providing more robust 

training to ensure consistent audit management and follow-up practices agencywide. AmeriCorps is

continuing robust efforts to strengthen core business operations and will work in FY 2022 to make 

steady progress on a multi-year strategy towards improved agency audit management and audit 

resolution.

As Chief Financial Officer, I remain committed to working with AmeriCorps leadership to improve 

core financial management service, streamline operations and closely monitor how the agency uses

resources, and create sustainable business practices to ensure taxpayers’ dollars are utilized 

effectively in fulfilling the agency’s mission. While AmeriCorps may continue to uncover additional 

challenges from past practices and new ways of doing business, the agency will continue to identify 

and implement cross-agency strategies to advance AmeriCorps’ commitment to achieving 

improved financial controls and core operational infrastructure.

25
PART B. INDEPENDENT AUDITORS’ REPORT ON CONSOLIDATED FINANCIAL

STATEMENTS AND MANAGEMENT'S RESPONSE

26
AUDIT OF AMERICORPS’ FISCAL YEAR 2021 

CONSOLIDATED FINANCIAL STATEMENTS

OIG Report 22-01

Prepared by:

CliftonLarsonAllen LLP

901 North Glebe Road, Suite 200

Arlington, VA 22203

The attached Draft Evaluation Report is for review and comment only and not for 

distribution. Its content is confidential and should be safeguarded to prevent disclosure 

to parties other than those directly involved in commenting on the issues contained in 

this report.

OFFICE OF INSPECTOR GENERAL

27
AmeriCorpsOIG.gov 

Hotline@AmeriCorpsOIG.gov

Hotline: 800-452-8210

AmeriCorps

Office of Inspector General

250 E St., SW, Suite 4100

Washington, DC 20525

November 15, 2021

MEMORANDUM TO: Malcom Coles 

Acting Chief Executive Officer

FROM: Monique P. Colter /s/ 

Assistant Inspector General for Audit

SUBJECT: Audit of AmeriCorps’ Fiscal Year 2021 Consolidated Financial 

Statements, OIG Report 22-01

We contracted with the independent certified public accounting firm of CliftonLarsonAllen LLP 

(CLA) to audit the consolidated financial statements of AmeriCorps as of September 30, 2021, 

and for the year then ended. The contract required that that the audit be performed in 

accordance with the United States generally accepted government auditing standards and 

applicable Office of Management Budget audit guidance. In its audit of the fiscal year 2021 

AmeriCorps consolidated financial statements, CLA reported:

• Disclaimer of Opinion: AmeriCorps requested that certain line items in the financial 

statement be excluded from the FY 2021 financial statement audit. AmeriCorps also stated 

that other material line items would not be available for audit until after the close of the 

third quarter. In addition, AmeriCorps was unable to provide sufficient appropriate 

evidence on a significant number of transactions and account balances due to inadequate 

processes and controls to support transactions and estimates, and the ongoing remediation 

efforts from prior year findings.

• Nine material weaknesses and one significant deficiency in AmeriCorps’ internal control 

over financial reporting. CLA reported the following deficiencies in the areas below as 

material weaknesses and one significant deficiency, Information Technology Security 

Controls (Modified Repeat), as described in Exhibit A of this report: 

1. Migration to Shared Service (New)

2. Internal Controls Program (FMFIA)- (Modified Repeat)

3. Financial System and Reporting (Modified Repeat)

4. Grants Accrual Payable and Advances (Modified Repeat)

28
AmeriCorpsOIG.gov 

Hotline@AmeriCorpsOIG.gov

Hotline: 800-452-8210

AmeriCorps

Office of Inspector General

250 E St., SW, Suite 4100

Washington, DC 20525

Due to management’s request to exclude material line items, CLA continued to report 

AmeriCorps’ noncompliance with Single Audit Act and the following material weaknesses 

and related recommendations as unimplemented: 

5. Trust Obligations and Liability Model (Repeat)

6. Undelivered Orders and Accounts Payable - Procurement (Repeat)

7. Undelivered Orders – Grants (Repeat)

8. Recoveries of Prior Year Obligations (Repeat)

9. Other Liabilities (Repeat)

• CLA considered AmeriCorps’ compliance with certain provisions of laws, regulations, 

contracts, and grant agreements, noncompliance with which could have a direct effect on 

the determination of material financial statement amounts and disclosures. However, CLA 

was not able to perform the applicable tests of AmeriCorps’ compliance due to the scope 

limitation and inability to obtain sufficient appropriate audit evidence to allow them to 

express an opinion on the financial statement.

Had CLA been able to obtain sufficient appropriate audit evidence to express an opinion on the 

consolidated financial statements, other material weaknesses or significant deficiencies, or 

instances of noncompliance or other matters may have been identified and reported.

In connection with the contract, we reviewed CLA’s report and related documentation and 

inquired of its representatives. Our review, as differentiated from an audit of the financial 

statements in accordance with the United States generally accepted government auditing 

standards, was not intended to enable us to express, and we do not express, an opinion on the 

consolidated financial statements.

CLA is responsible for the attached independent auditors’ report, dated November 8, 2021, and 

the conclusions expressed therein. However, our review disclosed no instances where CLA did 

not comply, in all material respects, with the United States generally accepted government 

auditing standards.

cc: Jenny Mauk, Chief of Staff 

Gina Cross, Chief Operating Officer

Malena Brookshire, Chief Financial Officer

Pape Cissé, Chief Information Officer

Fernando Laguarda, General Counsel

Jill Graham, Chief Risk Officer

Rachel Turner, Audits and Investigations Program Manager

Mia Leswing, Principal, CliftonLarsonAllen LLP

29
CliftonLarsonAllen LLP

CLAconnect.com

CLA is an independent member of Nexia International, a leading, global network of independent 

accounting and consulting firms. See nexia.com/member-firm-disclaimer for details.

1

INDEPENDENT AUDITORS’ REPORT

To the Acting Chief Executive Officer and Inspector General of

AmeriCorps

Report on the Financial Statement

We were engaged by the AmeriCorps Office of Inspector General (OIG) to audit the 

accompanying consolidated financial statement of AmeriCorps, which comprise the balance 

sheet as of September 30, 2021; the related statements of net cost, changes in net position, and 

the combined statement of budgetary resources for the fiscal year then ended, and the related 

notes to the financial statement (referred to herein as financial statement).

Management’s Responsibility 

AmeriCorps management is responsible for the preparation and fair presentation of the financial 

statement in accordance with accounting principles generally accepted in the United States of 

America (U.S.); this includes the design, implementation, and maintenance of internal control 

relevant to the preparation and fair presentation of financial statement that isfree from material 

misstatement, whether due to fraud or error.

Auditors’ Responsibility

Our responsibility is to express an opinion on the financial statement based on conducting the

audit in accordance with U.S. generally accepted auditing standards; the standards applicable to 

financial audits contained in Government Auditing Standards, issued by the Comptroller General 

of the U.S.; and Office of Management and Budget (OMB) Bulletin No. 21-04, Audit Requirements 

for Federal Financial Statements (OMB Bulletin 21-04). Because of the matters described in the 

Basis for Disclaimer of Opinion below, we were not able to obtain sufficient appropriate audit 

evidence to provide a basis for an audit opinion.

Basis for Disclaimer of Opinion

AmeriCorps requested that certain line items in the financial statement be excluded from the

FY 2021 financial statement audit and further stated that other material line items would not be 

available for audit until after the close of the third quarter. These scope limitations were material 

to AmeriCorps’ financial statements. In addition, AmeriCorps was unable to provide sufficient

appropriate evidence on a significant number of transactions and account balances due to 

inadequate processes and controls to support transactions and estimates, and the ongoing 

remediation efforts of prior year findings.

Disclaimer of Opinion 

Because of the significance of the matters described in the preceding paragraph, we were not 

able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. 

Accordingly, we do not express an opinion on the fiscal year 2021 financial statement.

30
INDEPENDENT AUDITORS’ REPORT (Continued)

2

Other Matter

Following discussions with the Office of Management and Budget (OMB) and Congressional 

stakeholders, AmeriCorps and the OIG agreed to forgo the audit of AmeriCorps’ FY 2020 

consolidated financial statements. Forgoing the audit was intended to allow AmeriCorps to 

complete the actions necessary to prepare for the transition of its financial management, 

procurement and travel services to a shared services provider in FY 2021. AmeriCorps 

acknowledged that, if its FY 2020 financial statements were audited, the results would be the 

same as those in FY 2019: a disclaimer of opinion, nine material weaknesses and substantially 

the same unimplemented recommendations. In FY 2020, AmeriCorps predicted that the move 

to shared services would resolve many of the material weaknesses identified in the FY 2019 

financial statement audit and before.

Report on Internal Control over Financial Reporting (Internal Control)

In connection with our engagement to audit AmeriCorps’ FY 2021 financial statement, we 

considered AmeriCorps’ internal control over financial reporting to determine the audit 

procedures that were appropriate in the circumstances for the purpose of expressing our opinion 

on the financial statement, but not for the purpose of expressing an opinion on the effectiveness 

of AmeriCorps’ internal control. Accordingly, we do not express an opinion on the effectiveness 

of AmeriCorps’ internal control. We did not test all internal controls relevant to operating 

objectives as broadly defined by the Federal Managers’ Financial Integrity Act of 1982 (FMFIA)

nor did we test internal controls on the financial statement line items and related processes that 

were excluded by AmeriCorps management from the scope of our audit.

Our consideration of internal control was for the limited purpose described in the preceding 

paragraph and was not designed to identify all deficiencies in internal control that might be 

material weaknesses or significant deficiencies; therefore, material weaknesses or significant 

deficiencies may exist that have not been identified. However, as described in Exhibits A and B, 

we identified certain deficiencies in internal control that we consider to be material weaknesses

and significant deficiency.

A deficiency in internal control exists when the design or operation of a control does not allow 

management or employees, in the normal course of performing their assigned functions, to 

prevent, or detect and correct, misstatements on a timely basis. A material weakness is a 

deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable 

possibility that a material misstatement of the financial statement will not be prevented or

detected and corrected on a timely basis. We consider the deficiencies in the areas below and

described in Exhibit A to be material weaknesses. 

1. Migration to Shared Service (New)

2. Internal Controls Program (FMFIA)- (Modified Repeat)

3. Financial System and Reporting (Modified Repeat)

4. Grants Accrual Payable and Advances (Modified Repeat)

31
INDEPENDENT AUDITORS’ REPORT (Continued)

3

Further, the scope limitations requested by AmeriCorps prevented us from performing audit 

procedures related to the previous material weaknesses from prior years1 and compliance with 

laws and regulations listed below. Accordingly, we continue to report AmeriCorps’ 

noncompliance with Single Audit Act2 and the following material weaknesses and related 

recommendations as unimplemented: See Status of Prior Year Recommendations in Exhibit C.

5. Trust Obligations and Liability Model (Repeat)

6. Undelivered Orders and Accounts Payable - Procurement (Repeat)

7. Undelivered Orders – Grants (Repeat)

8. Recoveries of Prior Year Obligations (Repeat)

9. Other Liabilities (Repeat)

A significant deficiency is a deficiency, or combination of deficiencies, in internal control that is 

less severe than a material weakness, yet important enough to merit attention by those charged 

with governance. We consider the deficiencies in the Information Technology Security Controls

(Modified Repeat) described in Exhibit B to be a significant deficiency.

Had we been able to obtain sufficient appropriate audit evidence to express an opinion on the 

financial statement, other material weaknesses or significant deficiencies may have been 

identified and reported herein. 

Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements and Other 

Matters (Compliance)

In connection with our engagement to audit AmeriCorps’ FY 2021 financial statement, we 

considered AmeriCorps’ compliance with certain provisions of laws, regulations, contracts, and 

grant agreements, noncompliance with which could have a direct effect on the determination of 

material financial statement amounts and disclosures. However, providing an opinion on 

compliance with those provisions was not an objective of our audit, and accordingly, we do not 

express such an opinion.

We were not able to perform the applicable tests of AmeriCorps’ compliance due to the 

aforementioned scope limitation and inability to obtain sufficient appropriate audit evidence to 

enable us to express an opinion on the financial statement. 

1 CNCS OIG Report 20-01, Audit of the Corporation for National and Community Service’s Fiscal Year 2019 Consolidated Financial 

Statements, issued November 20, 2019. Although AmeriCorps did not undergo an audit of its financial statements in FY 2020, 

the agency acknowledged in its FY 2020 Annual Management Report that, if such an audit had been conducted, the results would 

have been the same as in FY 2019. 

2

The Single Audit Act of 1984 (P.L. 98-502) as amended in 1996 (P.L. 104-156)

32
INDEPENDENT AUDITORS’ REPORT (Continued)

4

Management’s Responsibility for Internal Control and Compliance

AmeriCorps management is responsible for (1) maintaining effective internal control over 

financial reporting, including the design, implementation, and maintenance of internal control 

relevant to the preparation and fair presentation of financial statement that are free from 

material misstatements, whether due to fraud or error, (2) providing a statement of assurance 

on the overall effectiveness on internal control over financial reporting, and (3) complying with 

laws, regulations, contracts, and grant agreements applicable to AmeriCorps.

Purpose of the Report on Internal Control and Report on Compliance 

The purpose of the Report on Internal Control and on Compliance is solely to describe the scope 

of our testing of internal control and compliance and the result of that testing, and not to provide 

an opinion on the effectiveness of AmeriCorps’ internal control or compliance. These reports are 

an integral part of an audit performed in accordance with Government Auditing Standards in 

considering AmeriCorps’ internal control and compliance. Accordingly, these reports are not 

suitable for any other purpose.

AmeriCorps’ Response to Audit Findings and Recommendations

AmeriCorps did not express concurrence or nonoccurrence to our findings and 

recommendations. AmeriCorps’ comments can be found in Exhibit D. AmeriCorps’ response was 

not subjected to the auditing procedures applied in the audit of the financial statement and, 

accordingly, we express no opinion on it.

CLIFTONLARSONALLEN LLP

Arlington, Virginia

November 8, 2021

33
EXHIBIT A

Material Weaknesses

FY 2021

5

1. Migration to Shared Service (New finding) 

AmeriCorps’ transition to a shared service platform offered by the Administrative Resource 

Center (ARC) within the U.S. Treasury Department’s Bureau of Fiscal Services (BFS), effective on 

October 1, 2020, created new challenges that affected AmeriCorps’ ability to produce complete, 

adequate, and reliable financial information. The pre-migration general ledger account clean-up 

process spilled over into FY 2021 and was not complete as of the end of this year’s audit 

fieldwork. As one example, AmeriCorps has not completed the process of allocating and 

reporting separately the revenue and expenses of certain advances received under interagency 

agreements. AmeriCorps is in the process of transferring all agreements into the Interagency 

Agreement Module in ARC’s Oracle system, which requires detailed reporting, rather than 

liquidation in the aggregate.

Also, AmeriCorps was not able to convert all of the transactions originally recorded in its 

Momentum legacy system with the reporting required by ARC’s financial system, Oracle. Despite 

the migration to shared services, AmeriCorps elected to continue to conduct critical financial 

transactions relating to its core business in Momentum. These include: grant activities, member 

payroll, cost share, and disbursements from the National Service Trust. Also, because 

Momentum is not configured to report object class codes3in accordance with Federal 

requirements, manual adjustments must be used to correct the issue after AmeriCorps reports 

this information from Momentum to ARC’s Oracle financial system. That results in additional 

work and delays and introduces human error into the reporting process. In addition, there were 

misclassification issues caused by mapping inconsistencies in the program and fund structures 

within the two accounting systems. In most of these instances, AmeriCorps had to rely on postconversion manual entries to temporarily fix the issues and meet financial reporting 

requirements. Total absolute values of manual entries significantly increased from $7 billion

(rounded) in FY 2019, to $45 billion (rounded) in FY 2020, to $27 billion (rounded) in FY 2021. 

Data for other key transactions did not migrate to ARC’s Oracle system due to interface issues. 

AmeriCorps’ portfolio of contracts initiated prior to October 1, 2020 did not transfer properly to 

ARC’s procurement system. The Deputy Director of the Office of Procurement Services, who is 

no longer with the agency, noted that certain underlying documentation did not make it over to 

ARC’s PRISM4 and that supporting documentation may no longer be available for some 

transactions. AmeriCorps did not specify what documents failed to transfer or were unavailable, 

did not explain the potential impact of these issues on financial reporting, or identify any possible 

legal ramifications. 

3 Object classes are categories in a classification system that present obligations by the items or services purchased by the Federal 

Government.

4 The Procurement Information System for Management (PRISM) is used to record and track requisitions, purchase orders and 

contracts issued by agencies. The module is maintained by ARC as part of its shared service function to AmeriCorps.

34
EXHIBIT A

Material Weaknesses

FY 2021

6

AmeriCorps was not prepared for the magnitude of the work required to ensure a successful 

conversion, because it did not conduct an effective or realistic risk assessment or planning to 

ensure that the conversion issues would not impede operations unduly. The agency did not have 

a plan to address unexpected issues prior to the actual conversion. AmeriCorps underestimated 

the level of resources needed for the conversion to proceed smoothly and completely and 

therefore under-resourced the effort, leading to ongoing financial accounting, reporting, and 

operation issues.

The Government Accountability Office’s (GAO) Standard for Internal Control in the Federal 

Government (Green Book) states that changes in conditions affecting the entity and its 

environment often require changes to the entity’s internal control system, as existing controls 

may not be effective for meeting objectives or addressing risks under changed conditions. 

Management should analyze the effect of identified changes on the internal control system and 

respond by revising the internal control system on a timely basis, when necessary, to maintain 

its effectiveness.5

Further, changing conditions often prompt new risks or changes to existing risks that need to be 

assessed. As part of analyzing and responding to change, management performs a risk 

assessment to identify, analyze, and respond to any new risks prompted by the changes. 

Additionally, existing risks may require further assessment to determine whether the defined risk 

tolerances and risk responses need to be revised.

6

We recommend that AmeriCorps:

1. Perform a risk assessment over the current state of the conversion to ARC and work jointly 

with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by 

the risk to develop a mitigation strategy and execute a realistic and properly designed 

corrective action plan. (New)

2. Fix incorrect outstanding balances, missing data, and missing supporting contract 

documentation resulting from financial system configuration issues and ensure future 

interfaces with Oracle do not have the same issues. (Modified Repeat).

3. Continue coordinating with ARC to ensure that its accounting platform is compatible with 

AmeriCorps’ operations and the type of accounting transactions that AmeriCorps 

processes. (Modified Repeat).

4. Conduct a review of transactions processed in Momentum and already migrated to Oracle

through interface or reported in Oracle using journal entries, to ensure that correct object 

class codes were applied. (New)

5 https://www.gao.gov/assets/gao-14-704g.pdf page 43, 9.04 

6 https://www.gao.gov/assets/gao-14-704g.pdf, page 43, 9.05

35
EXHIBIT A

Material Weaknesses

FY 2021

7

2. Internal Controls Program (FMFIA) (modified repeat finding)

An effective system of internal control is necessary to provide reasonable assurance that a 

Federal entity conducts its programmatic activities effectively and efficiently, has a reliable 

financial reporting system, and complies with applicable laws and regulations7. Without a fully 

functional internal controls program, AmeriCorps might not meet itsfinancial, programmatic and 

compliance objectives. Establishing internal controls that meet Federal standards is a core 

responsibility of the management of a Federal agency, as required by the Federal Managers 

Financial Integrity Act of 1982 (FMFIA), OMB Circular No. A-123 and GAO’s Standards for Internal 

Control in the Federal Government.

AmeriCorps’ internal control program remains ineffective, despite some areas of improvement. 

We note, for example, that the agency now has a formal, documented process for collecting and 

providing the Chief Executive Officer (CEO) with comprehensive information to consider in 

deciding the level of assurance and substantive content of the required Annual Management 

Report (AMR)statement concerning the effectiveness of internal control. In the AMR for FY 2021, 

AmeriCorps’ CEO acknowledges the continuing deficiencies and provided a statement of no 

assurance as to effectiveness of internal control over financial reporting, operations, including of 

the agency’s grant programs, and compliance.

AmeriCorps has made little progress at correcting the pervasive problems that have left the 

agency unable to obtain an opinion on its financial statements since FY 2017. Eight of the nine 

material weaknesses that we identify in this report were first reported in FY 2017 or FY 2018. 

Only ten of the 75 recommendations from FY 2019 have been implemented. In most areas, 

AmeriCorps has not even developed meaningful corrective action plans (CAPs) to address the 

identified material weaknesses and significant deficiency. Until AmeriCorps can create and 

implement focused and well-resourced CAPs, it cannot expect to resolve these longstanding 

problems. To date, only the Office of the Chief Risk Officer (OCRO) has consistently developed 

and implemented effective CAPs, which has contributed to that office’s track record of closing 

recommendations.

Below are some of the new and recurring deficiencies that we identified in the internal control 

program:

• The OIG’s FY 2020 limited performance audit of AmeriCorps’ internal control program8

identified deficiencies such as (a) the omission of risk factors from the risk assessment 

process, (b) lack of documentation to support the conclusions reached on entity level 

assessments, (c) unexplained inconsistencies between risk assessments by the functional 

offices and the independent assessments conducted by OCRO, (d) missing, incomplete, 

or inadequate documentation to support the internal control assessment, (e) untimely 

7 OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, Policy section.

8 AmeriCorps OIG Report Number OIG-AR-21-02 Performance Audit of AmeriCorps’ FY 2020 Internal Control Program and 

National Service Trust Liability Model

36
EXHIBIT A

Material Weaknesses

FY 2021

8

review of key underlying documents, and (f) incomplete assessment of test of design and 

test of effectiveness, as well as sampling errors. There were eight recommendations of 

which AmeriCorps is continuing to address or complete implementation of corrective 

actions.

• The directors of the functional offices participating in the entity-level control assessment 

continue to lack a full understanding of internal control principles and how they relate to 

their respective operations. In addition, they did not consider the significant changes in 

FY 2021 and outstanding audit recommendations when assessing the entity-level 

controls.

• AmeriCorps conducts its entity-level internal control assessment according to GAO’s 17 

principles in the Standard for Internal Control in the Federal Government. In FY 2021, 

AmeriCorps concluded that it had low risk as to two of the principles and moderate risk

as to 12 of them. Those decisions are difficult to reconcile with the identified material 

weaknesses and the obvious risks flowing from the ongoing issues related to the 

migration to shared services. We found that certain of the risk ratings were not based on 

adequate information, were not fully supported by the assessment documentation or 

were inconsistent with the results of our audit.

• AmeriCorps failed to obtain subsidiary statements of assurance and internal control 

assessments from Accounting and Financial Management Services (AFMS), Office of 

Procurement Services, and Office of Budget and other functional units. These critical 

components were not asked to provide assurance as to the effectiveness of internal 

control in their respective areas. 

• OCRO’s internal control assessment and testing did not identify ongoing issues arising 

from the transition to shared services as a material weakness, despite their significant 

impact on the financial operations and reporting in FY 2021. 

• OCRO downgraded financial reporting and procurement management from material 

weaknesses in FY 2019 to significant deficiencies in FY 2021, without apparent 

justification. The downgrade is not consistent with AmeriCorps’ acknowledged inability 

to remedy the material weaknesses from prior audits. 

• OCRO is still in the process of developing a risk register that records identified risks at the 

mission and business process level, or Tier 2, as defined by the National Institute of 

Standards and Technology. 

• While OCRO took the initiative to complete and/or update nine business process 

narratives to reflect the transition to shared serves, other business process narratives 

have not been revised or updated to reflect significant changes in the current financial 

and control environment. For example, the Grants Financial Management Business 

Process narrative has not been revised to address the control gap related to the 

estimation and verification of the accuracy of the Advances Repayment balance. 

37
EXHIBIT A

Material Weaknesses

FY 2021

9

We recommend that AmeriCorps:

5. For each material weakness and significant deficiency, develop an appropriate and 

actionable corrective plan (CAP) that specifies the interim steps for long-term CAPs, 

milestones and target completion dates, person(s) responsible for executing the 

corrective action and the resources available to assist, sufficient and appropriate 

documentation required, and quality review and approval process. (New)

6. Develop a process to explain the discrepancies between material weaknesses reported 

on the CEO Statement of Assurance and those identified by the external auditors, and 

document the explanation, as well as the basis for classifying internal control findings as 

either material weakness or significant deficiency. (New)

7. Complete updating or revising the business process narratives to adapt to the significant 

changes in the current financial and control environment. (Modified Repeat)

8. Establish controls and training to ensure that each functional office/unit performs an 

independent assessment of internal controlsto inform the CEO’s statement of assurance, 

even if unfavorable outcomes are expected. This proactive approach will promote the 

early detection of potential findings and allow for prompt remediation. (New).

3. Financial System and Reporting (modified repeat finding)

AmeriCorps’ financial reporting process and the internal control over it remain inadequate to 

ensure accuracy and quality control in the preparation financial statements. While AmeriCorps 

predicted that migration to ARC would resolve the majority of its unimplemented 

recommendations, it has not realized these results, in part because the pervasive deficiencies in 

AmeriCorps’ Momentum financial system have carried over into ARC. AmeriCorps continued to 

experience lingering effects of Momentum throughout FY 2021. These are essentially the same 

weaknesses and system limitations that prevented AmeriCorps from issuing auditable financial 

statements for the last five years. AmeriCorps continued to rely on temporary manual 

adjustments to address these pervasive longstanding issues in FY 2021. 

Our audit procedures found that the following conditions continue to exist, despite the migration 

to shared services: 

A. Financial Statement Audit Scope Limitation

B. Inability to produce quality, reliable, and complete financial information in a timely 

manner

C. Inadequate internal controls in preparing and reviewing financial reports 

D. Improper design of internal control over the use of journal entries (JEs)

38
EXHIBIT A

Material Weaknesses

FY 2021

10

OMB Circular No. A-123 requires agency management to establish and maintain internal controls 

to achieve the objectives of effective and efficient operations, reliable financial reporting, and 

compliance with applicable laws and regulations.

A. Financial Statement Audit Scope Limitation 

Despite a one-year grace period with no financial statement audit in FY 2020 and the shift to 

shared services at the beginning of FY 2021, AmeriCorps was unprepared for a full scope audit in 

FY 2021. The lack of progress in addressing the prior year (PY) internal control material 

weaknesses led AmeriCorps to acknowledge their continued noncompliance with Single Audit 

and also requested that the audit exclude the following material financial statement lines and 

significant processes, noting that audit of these areas would likely yield the same or similar results 

in FY 2019: 

• Grants Single Audit Compliance 

• Other Liabilities – Include VISTA Stipend 

• Undelivered Orders and Accounts Payable – Procurement 

• Trust Obligation and Liabilities – Validation of the Data for the Trust Obligation Liability 

Model (TOLM, Trust liability).

Additionally, AmeriCorps advised that it would not be able to implement planned changes that 

would affect their calculation of (1) Grant Accrual and Grant Advances, and (2) the Trust 

Obligation and Liabilities, both material financial statement lines, until reporting results for the 

third quarter of FY 2021. As a result, those lines were only available for audit until after 

preparation of the June 30, 2021 interim financial statements and the receipt of all required audit 

documentation. Notwithstanding the delay in implementation, we performed audit procedures 

over the Grants Accrual Payable and Advances and reported our findings in material weakness 

number 4. The time limitation imposed by AmeriCorps left us unable to conclude our work on 

the Trust Obligation and Liabilities. 

We recommend that AmeriCorps:

9. Develop a strategic plan and corrective actions that will include steps and milestones to 

eventually achieve an audit opinion on AmeriCorps’ financial statement. The plan should 

align directly with and describes in detail the implementation plans, specific steps to be 

taken, resources to be devoted to implementation, responsible personnel and their 

assigned duties, clear accountability, project management and target dates to complete. 

It should also include a quality assurance plan to verify effective and timely 

implementation. (New)

39
EXHIBIT A

Material Weaknesses

FY 2021

11

B. Inability to produce quality, reliable, and complete financial information timely

Throughout FY 2021, AmeriCorps continued to struggle in preparing, reviewing, and providing 

accounting information and documentation for audit. Although we set forth a clear schedule 

without objection at the beginning of the audit and conducted regular status meetings, 

AmeriCorps frequently responded long after the requested due date, months late in some cases. 

Also, AmeriCorps didn’t have defined roles and responsibilities for providing information and 

documents requested by the auditors. Often, the documentation provided had not undergone 

quality review to ensure that the information was without errors, complete, and responsive to 

the request. The lack of quality control and timely response caused delays and wasted effort. 

Ultimately, AmeriCorps’ inability to provide timely, complete, and high quality audit schedules 

and documents, including incomplete populations for sampling, interfered with our ability to 

evaluate and test financial information.

We recommend that AmeriCorps:

10. Develop and implement audit readiness procedures to ensure that audit information is 

complete, accurate, has undergone proper quality control procedures, and readily 

available or can be retrieved timely. The audit readiness procedures should include audit

coordination protocol with ARC that clearly define roles and responsibilities of all parties 

involved in the process. (New)

C. Inadequate internal controls over preparing and reviewing financial reports 

AmeriCorps’ internal control over preparing and reviewing financial reports was inadequate. 

Examples of the inadequacies were as follows: 

• AmeriCorps did not properly research, follow up and effectively document explanations 

for account balance differences. The agency’s monthly trial balance review was 

incomplete and ineffective. The budgetary-to-proprietary analysis (tie point) performed 

was incomplete, because AmeriCorps did not follow up to explain or reconcile significant 

variances. The purpose of the high-level tie point analysis is to detect anomalies in 

balances and correct them or provide fact-specific explanations for the discrepancies. 

Instead, AmeriCorps continued to provide generic explanations that do not address the 

root cause of the differences. Without a root cause analysis, AmeriCorps may not be able 

to correct the problem, which will recur. The lack of a rigorous process may cause 

AmeriCorps to overlook substantial but correctible financial management errors.

• We identified uncorrected misstatements on the financial statements, abnormal 

balances, and incomplete financial statement and notes as part of our audit of the June 

30, 2021, (interim) financial statement. Other examples of issues identified were 

reconciliation differences between AmeriCorps internal trial balance and the U.S. 

Treasury’s Governmentwide Treasury Account Symbol Trial Balance (GTAS), which were

40
EXHIBIT A

Material Weaknesses

FY 2021

12

caused by untimely recording of accounting transactions and failure to remove cancelled 

funds activity in its trial balance. Also, inadequate or lack of subsidiary support for 

advances of funds received were due to inability to maintain and track trading partner 

agreements and transaction level activities from inception to close-out.

• AmeriCorps did not perform a complete and reliable fluctuation analysis of the June 30, 

2021, account balances. The explanations provided for significant balance fluctuations 

were generic and did not address the specific nature of the transactions or the change in 

operations or trends that would identify the root causes of the fluctuations. AmeriCorps

did not document its expectations based on its operating environment and compare 

those expectations to the identified significant balance fluctuations for reasonableness or 

unexpected change. 

We recommend that AmeriCorps:

11. Develop comprehensive policies and procedures to document its financial statement 

preparation process. The policies and procedures should clearly delineate responsibilities 

among various members of the Accounting and Financial Management Service (AFMS) 

group and team leads and those performed by AmeriCorps’ shared services provider, 

clarifying the responsibility of AmeriCorps for the accuracy of the reported information. 

The policies and procedures should address the following aspects: (Modified Repeat)

a. The process to determine and document AmeriCorps’ balance fluctuation 

expectations based on a combination of internal and external operating factors, 

and program and financial relevant information available. 

b. Detailed process to research significant balance fluctuations. AmeriCorps should 

research and explain all significant balance fluctuations at the account and 

transaction level. Maintain and have the supporting documentation readily 

available.

c. Research and retain supporting documents required for any identified account 

balance differences derived from its abnormal balance review or the tie point 

analysis. 

d. Address fatal and non-fatal Government-wide Treasury Account Symbol edit 

failures prior to GTAS certification.

e. Document resolution for all balance differences and retain supporting 

documentation of related research.

These open repeat recommendations can be found Status of Prior Year Recommendations in 

Exhibit C, Status of Prior Year Recommendations for open repeat recommendations.

D. Improper design of internal control over the use Journal Entries (JE)

Journal entries are both recurring and non-recurring manual accounting adjustments used to 

record (usually large) transactions in the financial system. They are used to fix errors, reclassify 

balances, or record amounts that were not reported due to timing and period cut-offs in the 

41
EXHIBIT A

Material Weaknesses

FY 2021

13

financial system. However, they do not go through the established system of controls designed 

to record normal recurring transactions, and thus reliance on JE increases AmeriCorps 

susceptibility to errors and misstatement in the financial statements. As of June 30, 2021, 

AmeriCorps used JEs to record approximately $27 billion in absolute value transactions, a 

significant increase from the prior year. AmeriCorps over relied on the JEs to fix issues that 

initially existed in the Momentum environment that were not remediated prior to conversion to 

Oracle.

Also, AmeriCorps used JEs to address significant recurring financial reporting issues across 

multiple funds, instead of addressing the underlying root causes. For example, JEs were used to

fix transactions recorded under reimbursable funds using an account code that identified them 

as Direct. This is a long-standing issue that requires repeated adjustments to the expended and 

unexpended appropriation general ledger accounts. 

We also identified other control deficiencies such as duplication in the use of JEs, missing 

document numbers, and lack of documentation explaining the need for or root cause for the 

adjustment and approval. Further, there was no evidence of proper segregation of duties,

reconciliation issues between JE detail and JE log, and instances in which AmeriCorps and ARC 

approved and processed JEs with the incorrect general ledger account, requiring another JE to 

correct the error. The over-reliance, incorrect usage, and inaccurate JEs create a high risk of 

material misstatements in the financial statement.

We recommend that AmeriCorps:

12. Continue working with Administrative Resource Center to review and correct AmeriCorps’ 

balances in detail to ensure they are properly supported and that balances migrated to 

the ARC platform are complete, accurate, and reliable. (Modified Repeat)

13. Strengthen its policies and procedures over the processing of JEs going forward now that

AmeriCorps has transitioned to the shared service environment. The policies and 

procedures should cover the following: 

a. A process to track the sequence of JE transactions for completeness.

b. A policy as to when it is appropriate to use a JE and approval procedures for JEs 

recorded to ensure segregation of duties.

c. A requirement to provide a fact-specific description of the purpose of the JE, along 

with adequate supporting documentation.

d. Documentation needed to support JEs and how it will be maintained. (Modified 

Repeat). 

14. Validate and ensure JEs are properly supported, documented, and are readily available 

for examination. (Modified Repeat)

42
EXHIBIT A

Material Weaknesses

FY 2021

14

Additional open repeat recommendations from the FY 2019 audit report can be found in

Exhibit C, Status of Prior Year Recommendations. 

4. Grant Accrual Payable and Advances (modified repeat finding)

In FY 2021, AmeriCorps changed its grant accrual methodology to include the “incurred but not 

reported” (IBNR) estimated costs9 provided from the Payment Management System (PMS)10 for 

estimating its grant expenses and liabilities to be reported in a future Federal Financial Report. 

Consideration of the IBNR in AmeriCorps grant accrual estimates is necessary for AmeriCorps to 

account for its financial transactions in accordance with GAAP. Per FASAB, Accrual Estimates for 

Grant Programs, Federal Financial Accounting Technical Release 12, a Federal grant-making 

entity must demonstrate the reliability of its grant accrual estimates. 

AmeriCorps must verify that the facts used in the HHS’ PMS IBNR estimation methodology are 

relevant and accurate for AmeriCorps grants. This baseline validation is important to ensure that 

the HHS PMS IBNR estimate is reasonable when applied to AmeriCorps, i.e., that the 

methodology, factors, and assumptions are applicable to the nature of AmeriCorps grantees’

operations.

Using estimates based on assumptions that are not documented and validated based on 

historical data analysis and grantees’ actual spending patterns increases the risk of errors and 

misstatements in the grant accrual, related expenses and advances reported in the financial 

statement. 

We recommend that AmeriCorps:

15. Develop a process to validate grant advances, IBNR and payable estimates. Such 

validation should be performed over a few years to show a trend of the estimates. Any 

benchmarks to assess reasonableness should be vetted for completeness and reliability. 

For example, the use of eGrants FFRS should be vetted to ensure inclusion of IBNR. Large 

(exceeding AmeriCorps acceptable range) and unusual fluctuations, if any, should be 

investigated and the research conclusions documented by management. Fluctuations 

should be reviewed at the absolute variances level and not using net differences.

(Modified Repeat)

16. Validate that the underlying data used in the accrual methodology, such as the use of 

grantee Undelivered Order balances to allocate accrual amounts, is reliable by ensuring 

previously reported conditions are remediated and recommendations are implemented.

(New)

9 These amounts represent the estimated liability for costs already incurred by the grantees but will be reported in the following 

quarter.

10 The PMS is a tool by the Department of Health and Human Services (HHS) help grant recipients draw down funds and file the 

Federal Financial Report (FFR). AmeriCorps uses HHS services to manage grantee drawdowns and disbursement reporting 

activities. 

43
EXHIBIT A

Material Weaknesses

FY 2021

15

Additional open recommendations from FY 2019 audit report related to grant accrual and 

advances can be found in Exhibit C, Status of Prior Year Recommendations. 

We also continue to report the following five prior year material weaknesses and the related 

unimplemented recommendations: Trust Obligations and Liability Model (Repeat); Undelivered 

Orders and Accounts Payable - Procurement (Repeat); Undelivered Orders – Grants (Repeat), 

Recoveries of Prior Year Obligations (Repeat); and Other Liabilities (Repeat). A listing of these 

unimplemented recommendation is in Exhibit C.

44
EXHIBIT B

Significant Deficiency

FY 2021

16

Information Technology Security Controls (modified repeat finding)

AmeriCorps relies extensively on information technology (IT) systems to initiate, authorize,

record, process, summarize and report financial transactions in the preparation of its financial 

statement. Internal controls over these financial and supporting operations are essential to

ensure the integrity, confidentiality, and reliability of critical data while reducing the risk of

errors, fraud, and other illegal acts.

To balance high levels of service and reduce costs, AmeriCorps’ Office of Information Technology 

has outsourced the operation, maintenance, and support of most of its IT systems. AmeriCorps 

outsourced its financial operations to a shared service provider for the first time this fiscal year. 

The new financial system of record interfaces with Momentum for the purpose of retrieving 

grants management data from eSPAN. Outsourcing introduces special considerations and risks

regarding the protection of information and information systems. Despite the outsourcing of IT 

systems, AmeriCorps by law retains responsibility for complying with the requirements of the 

security control implementation.

Our review of IT controls covered general and application controls at the AmeriCorps 

Washington, D.C. Headquarters. Our current year audit identified security control weaknesses 

that were corrected for certain control activities. Examples of AmeriCorps’ improvements in its 

IT control environment include conducting background investigations and reinvestigations of 

current employees and enhancing physical access controls to safeguard personally identifiable 

information.

While AmeriCorps has taken some steps to remediate previously identified information security

control weaknesses, AmeriCorps continues to face challenges in the consistent implementation 

of its information security program and monitoring of security controls. In addition, we identified

new and continued control weaknesses in the information security program that need to be

addressed, most importantly pertaining to configuration management controls, including 

vulnerability management, access controls, and organization-wide risk management. 

Specifically, we identified enterprise findings for each of the following domains:

Configuration Management

• AmeriCorps did not resolve critical and high-risk vulnerabilities within the timeframes 

specified by its internal operating policies. As a result, vulnerabilities related to patch 

management, configuration management, and unsupported software continue to expose 

AmeriCorps’ network to critical and high severity vulnerabilities. While our independent 

vulnerability scans indicated that the number of vulnerabilities has decreased since last year, 

issues remain with applying older patches and remediating older configuration weaknesses. 

(Modified Repeat)

• AmeriCorps did not develop baseline configuration documentation for all platforms in its 

environment and ensure that these standard baseline configurations are appropriately 

45
EXHIBIT B

Significant Deficiency

FY 2021

17

implemented, tested, and monitored for compliance with established security standards. 

(Modified Repeat)

• The tracking of IT components in the asset inventory was incomplete, and software 

assurance controls have not been fully implemented for mobile devices due to delays in 

implementing a new mobile device management tool. (Modified Repeat)

• Change management documentation was not consistently recorded for system changes 

made to the General Support System (GSS), Electronic-Systems for Program Agreements and

National Service Participants (eSPAN), and Momentum applications. (New)

Access Control

• AmeriCorps did not adequately manage user accounts and/or passwords for the network 

and the Momentum application. For example, AmeriCorps did not disable all network and 

Momentum accounts of separated employees, did not disable inactive privileged accounts, 

and did not properly manage passwords that were not changed after a designated 

timeframe as specified in AmeriCorps’ policies. (Modified Repeat) 

• In March 2020, AmeriCorps removed mandatory enforcement of Personal Identity 

Verification (PIV) multifactor authentication11 in response to the COVID-19 pandemic and 

has not reinstated the control. Agency management attributes this to the need for full-time 

telework during the COVID-19 pandemic. However, this conflicts with government-wide 

guidance issued by the Cybersecurity and Infrastructure Security Agency (CISA) directing 

agencies to use multifactor authentication during pandemic-related telework. (Modified 

Repeat)

• AmeriCorps did not conduct an annual incident response test as required by AmeriCorps 

policy. (New)

In addition, prior weaknesses related to access controls at AmeriCorps’ field offices have not 

been remediated.

Security Management

• AmeriCorps did not develop, document, and communicate an overall Supply Chain Risk 

Management strategy, implementation plan, and related policies and procedures to guide 

and govern supply chain risk management activities. (New)

• AmeriCorps did not maintain an Interconnection Security Agreement between AmeriCorps 

and Social Security Administration. (New)

• AmeriCorps did not complete a risk register to record identified risks at the mission and 

11 Multifactor authentication requires two or more credentials when logging on to information systems. Credentials include 

something an individual knows, such as a password, and something an individual possess, such as a PIV card or fingerprint.

46
EXHIBIT B

Significant Deficiency

FY 2021

18

business process level, as defined by the National Institute of Standards and Technology.

12

(Repeat)

• AmeriCorps did not ensure individuals with access to personal identifiable information (PII) 

completed annual privacy-role based training. (Repeat)

Contingency Planning

• AmeriCorps did not conduct an annual disaster recovery test and train its disaster recovery 

personnel for the GSS and eSPAN as required by AmeriCorps policy. (New)

Many of these weaknesses can be attributed to inconsistent enforcement of the agency-wide 

information security program across the enterprise. These deficiencies can increase the risk of 

unauthorized access to AmeriCorps’ systems used to capture, process, and report financial 

transactions and balances. Effective system security begins with strong governance, including 

agency-level oversight and controls monitoring of AmeriCorps’ field offices. This includes 

ensuring accountability within the Office of Information Technology leadership for 

accomplishing milestones and achieving measurable results in support of a strategy to achieve 

an effective level of information security at AmeriCorps.

Further, the Federal Information Security Management Act (FISMA) legislation requires each 

agency to have a Chief Information Security Officer (CISO), whose principal duty is cybersecurity.

However, AmeriCorps allowed this position to remain vacant from October 2020 to June 2021, 

with an acting official in the role. Given the agency’s weaknesses in key information security 

controls and the importance of this function, the lack of a permanent CISO, with the ability to 

advise the agency head on key issues of cybersecurity policy, enforcement and needed 

improvements, detracted from the opportunity to make progress. 

By not effectively implementing and enforcing IT policies and procedures and working towards

automation, continuous monitoring and consistent application of controls, there is an increased

risk that financial information and PII may be inadvertently or deliberately misused and may 

result in improper disclosure or theft without detection. Without remediatingall significant 

security vulnerabilities, systems could be compromised resulting in potential harm to 

confidentiality, integrity, and availability of AmeriCorps’ financial and sensitive data.

12 NIST Special Publication 800-39, Revision 1, Managing Information Security Risk Organization, Mission, and Information System 

View, specifies an integrated risk management process three-tiered approach for managing risk across an organization that 

“addresses risk at the: (i) organization level; (ii) mission/business process level; and (iii) information system level. The risk 

management process is carried out seamlessly across the three tiers with the overall objective of continuous improvement in 

the organization’s risk-related activities and effective inter-tier and intra-tier communication among all stakeholders having a 

shared interest in the mission/business success of the organization.”

47
EXHIBIT B

Significant Deficiency

FY 2021

19

We recommend that AmeriCorps:

Since AmeriCorps has not implemented consistent automated processes to address continued 

control weaknesses in its information security program, we reiterate the prior year’s

recommendations to assist AmeriCorps in holding individual stakeholders accountable for 

remediation of control weaknesses and ensuring information technology security controls

operate as intended agency wide. The recommendations for these conditions can be found in 

Exhibit C, Status of Prior Year Recommendations.

48
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

20

AmeriCorps’ latest full scope financial statement audit was in fiscal year 2019. As there was no financial statement audit conducted in FY 2020, 

we are presenting the status of FY 2019 recommendations in FY 2021. As the scope of audit in FY 2021 was limited, many of the FY 2019 

recommendations were still open in FY 2021. These open recommendations were not duplicated as recommendations in the report on internal 

control and report on compliance (reports). The modified repeat recommendations in FY 2021 were recommendations from FY 2019 but were 

adapted to the FY 2021 results. The summary of the status of the FY 2019 financial statement audit recommendations in FY 2021 is in

Table 1. The detail of each recommendation is presented in Table 2. 

Table 1: Summary of the Status of FY 2019 Financial Statement Audit Recommendations in FY 2021

Status in FY 2021

Count of 

Recommendations 

in FY 2019

FY19 Audit Report 

Recommendation Number

Recommendation Closed 10 1, 3, 4, 6, 7, 19, 20, 39, 45, 52

Open and Modified Repeat Recommendations 65

Total: 75

Table 2: Status in FY 2021 and Detail Description of Each Recommendation from FY 2019 Financial Statement Audit 

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

Material 

Weakness 

(MW)

Internal 

Control 

1

Establish a formal process that provides the CEO with comprehensive information on the results 

of AmeriCorps’ internal control assessment, status of open material weaknesses and significant 

deficiencies from prior year’s financial statement audits, and information on issues that could be 

reported as a significant deficiency or a material weakness in the current year’s financial 

statement audit for consideration in preparing the AmeriCorps assurance statement. This 

should also include the status of open recommendations from other audits that have a 

significant impact on AmeriCorps operations or financial reporting.

Closed

49
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

21

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

Program 

(FMFIA)

2

Provide training to AmeriCorps officials participating in the entity-level control assessment to 

ensure that they have a full understanding of the internal control principles and how these 

principles relate to their operations. The training shall also address how the outstanding audit 

recommendations concerning their operations should be considered when assessing the entitylevel controls.

Repeat – Material 

Weakness (MW)

Open Recommendation

3

Revise the AmeriCorps Statement of Assurance Preparation and Submission Guidance (March 

2019) to:

a. Require the functional offices to consider external and internal audits and investigations in 

identifying and reporting on control deficiencies.

b. Require the functional offices to identify the impact that the material weakness or significant 

deficiency has on the financial statements or on AmeriCorps’ operations in their assurance 

statements. 

Closed

4

Revise the AmeriCorps Financial Reporting Testing Plan to include verifying that the fluctuation 

analyses are conducted properly within the required thresholds. Closed

5

Revise the FY 2019 AmeriCorps Grants Financial Management Business Process Narrative to 

address the control gap concerning the verification of the Advances to Others balance accuracy. 

Modified Repeat

MW

Recommendation #7

6

Provide training to appropriate AmeriCorps personnel regarding the purpose of the Data Quality 

Plan. Closed

7

Update and maintain the Data Quality Plan in accordance with OMB Circular No. A-123, 

Appendix A, Management of Reporting and Data Integrity Risk (M-18-16, June 6, 2018), and 

subsequent amendments. 

Closed

8

Update AmeriCorps’ Standard Operating Procedure: Statement on Standards for Attestation 

Engagements (SSAE) 18 Report Review to explain how AmeriCorps will address the SSAE 18 audit 

reporting gaps for its external systems’ service providers and establish time requirement for

conducting the SSAE 18 report reviews.

Repeat - MW

Open Recommendation

50
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

22

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

Material 

Weakness 

Financial 

System and 

Reporting

9

Establish a process to maintain executed agreements with Federal trading partners and track all 

associated costs against the inter-agency agreements from inception until the agreement closeout. 

Repeat - MW

Open Recommendation

10

Develop comprehensive policies and procedures for the financial statements preparation 

process and related internal controls. The policies and procedures should address, among other 

subjects:

a. The process to determine and document AmeriCorps balance fluctuation expectations. 

Expectations should be documented based on a combination of internal and external operating 

factors, and program and financial relevant information available.

b. The materiality threshold used to determine significant balance fluctuations that require 

further research should be more conservative than that used by external auditors.

c. Detailed process to research significant balance fluctuations. AmeriCorps should research and 

explain all significant balance fluctuations at the account and transaction level. Maintain and 

have the supporting documentation readily available.

d. Research and retain supporting documents required for any identified account balance 

differences derived from its abnormal balance review or the tie point analysis.

e. Address fatal and non-fatal Government-wide Treasury Account Symbol Trial Balance edit 

failures.

f. Address all balance differences and retain supporting documentation of related research.

g. Document and maintain support for all prior period adjustments and changes to Net Position 

accounts, Cumulative Result of Operations, and Unexpended Appropriations. 

Modified Repeat - MW

Recommendation #11

11

Monitor outstanding balances resulting from financial system configuration issues and fix these 

issues prior to data migration to the future shared service provider (Department of Treasury’s 

Administrative Resource Center) in FY 2021. While waiting to transition, AmeriCorps should 

strengthen its current trial balance review including tie-point analysis and review of abnormal 

balances.

Modified Repeat – MW

Recommendation #2

12

Coordinate with the future shared service provider to ensure that its accounting platform is 

compatible with AmeriCorps operations and the type of accounting transactions that the 

AmeriCorps process.

Modified Repeat - MW

Recommendation #3

51
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

23

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

13

Develop a plan to clean up AmeriCorps balances prior to migration to the shared service 

provider’s system (Department of Treasury’s Administrative Resource Center). The plan should 

include coordination with the future service provider to review AmeriCorps’ balances in detail to 

ensure they are properly supported and can be mapped into the Administrative Resource 

Center’s platform. Maintain all documentation regarding meeting minutes and any mapping of 

account balances developed as part of the migration effort.

Modified Repeat – MW 

Recommendation #12

14 Complete its efforts to be fully compliant with the Office of Management and Budget Circular 

No. A-11, Preparing, Submitting, and Executing the Budget. 

Repeat – MW

Open Recommendation

15

Provide mandatory training to AmeriCorps accounting staff on the proper use of object class, sub 

general ledger accounts, and document/transaction types on all obligation and expense 

transactions. 

Repeat – MW

Open Recommendation

16 Validate and ensure standard Journal entries are properly supported, documented, and are 

readily available for examination.

Modified Repeat - MW

Recommendation #14

17 Strengthen coordination between Accounting and Financial Management Services and the Office 

of Budget to ensure that transactions are recorded accurately and timely.

Repeat - MW

Open Recommendation

18

Develop and implement policies and procedures for the Journal entries (JE) process that include:

a. tracking the sequence of JEs for completeness;

b. appropriate use of JEs;

c. determining and maintaining relevant documentation to support each JE’s;

d. use of specific and accurate JE descriptions; and

e. timely review and approval of JEs for accuracy and propriety. 

Modified Repeat – MW

Recommendation #13

52
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

24

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

19

Finalize its research to establish the amount to capitalize for tenant improvement costs and 

retain proper documentation of the research. While the research is ongoing, AmeriCorps should 

disclose non-GAAP accounting and the impact on the financial statements. 

Closed

20

Evaluate AmeriCorps compliance with all sections of OMB Circular No. A-136, Financial Reporting 

Requirements, including preparing comparative financial statements and notes to comply with 

the financial reporting framework for federal government agencies. 

Closed

Material 

Weakness

Trust 

Obligations 

and Liability 

Model

21

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust 

Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including 

establishing control activities; finalize materiality thresholds applied; update accounting 

transactions, and clearly identify periods when adjustments will be made regardless of 

materiality. 

Repeat – MW 

Open Recommendation

22

Develop for a more standardized, secure, and automated method to estimate the Trust 

obligations and Trust Service Award Liability that ensures minimal human errors. As part of the 

ongoing AmeriCorps transition to shared service, coordinate with the service provider to 

determine methods that would enhance the security and quality of the existing estimation 

models. 

Repeat – MW 

Open Recommendation

23

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

a. Conduct detailed analysis and validation of data sources.

b. Review and ensure the reasonableness of assumptions used and document the rationale 

behind estimation assumptions.

c. Consider changes in conditions or programs that require further research and analysis. Update 

the assumptions when necessary.

d. Compare estimates with subsequent results to assess the reliability of the assumptions and 

data used to develop estimates.

Repeat – MW 

Open Recommendation

53
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

25

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

24

Document and implement policies and procedures to include the following:

a. establish a thorough and robust quality control process to ensure that the Trust Obligation 

and Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are 

reviewed by qualified AmeriCorps personnel prior to relying on its outputs to record 

transactions. All errors identified for which management ultimately decided against making 

updates to the TOLM or Calculator should be documented along with an explanation as to how 

management arrived at the final decision;

b. perform monthly reviews and reconciliations of the recorded new and outstanding obligations 

to ensure the accounting information is valid and proper;

c. review obligation amounts to ensure amounts accurately reflect the status of the obligation;

d. review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected 

in the obligation);

e. ensure obligations are sufficiently supported (i.e., by documentary evidence); and

f. perform complete reconciliations of all outstanding obligations monthly, and ensure any 

discrepancies identified are promptly researched and resolved. 

Repeat – MW

Open Recommendation

25

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National 

Service Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual 

testing of key controls.

Repeat – MW 

Open Recommendation

26

Develop a succession plan to ensure the required expertise is available in anticipation of planned 

employee turnover, particularly with respect to the complex trust calculations. AmeriCorps

needs to:

a. Train, mentor, and work to retain qualified employees;

b. Cross-train employees so that knowledge of the model will reside with multiple staff rather 

than with one person; and

c. Implement a peer review process to carry out the necessary quality control reviews of the 

Trust Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Repeat – MW 

Open Recommendation

54
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

26

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

Material 

Weakness 

Grants Accrual 

Payable and 

Advances

27

Coordinate with the program and grant officers to gather and analyze key grant programs’ 

(AmeriCorps State and National and Senior Corps) historical data and the grantees’ spending 

pattern to develop the following key factors for grant accrual estimation:

• Percentage of AmeriCorps grantees who drawdown funds in advance versus those on a 

reimbursable basis and their related grant amounts to its grant spending as a whole. If different 

key programs have different spending patterns, perform this analysis at the program level;

• An inventory of relevant and reliable grant data to be used for the grant accrual assumptions 

and documentation to support what data is considered relevant and reliable;

• Grantees' incurred but not reported (IBNR) reporting pattern from when the expenses have 

been incurred to the time those expenses are included the grantees' Federal Financial Reports 

(FFR). Grantee surveys may be conducted to confirm the reasonableness of an IBNR estimate 

methodology. When alternative procedures are used, management should provide its databased analysis to validate its assertion; and

Post-accrual analysis to compare the accrual (without the IBNR) and the expenditures reported 

in the FFRs for the same quarter. Thresholds should be established and documented based on 

materiality and the degree of risk that management is willing to accept. When grantees' 

reported spending pattern deviates from its methodology, an analysis should be performed to 

determine whether any deviation is acceptable, or the methodology should be further refined to 

reflect the actual grantees' reported expenditure pattern. 

Repeat – MW 

Open Recommendation

28

Revise and implement policies and procedures for the grant accrual methodology so that:

• A validation process is established for management to verify the accuracy of the grant accrual, 

so that management can make any necessary adjustments to improve the precision of the grant 

accrual and to account for grant advances and payables to ensure the resulting amounts are 

materially consistent with grantees’ drawdown and spending patterns;

• It addresses how the calculations are used to arrive at the Grants Payable and Advances to 

Other line items in the financial statements. 

Repeat – MW 

Open Recommendation

55
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

27

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

29

Develop a process to validate grant advances, incurred but not reported and payable estimates.

Such validation should be performed for all program elements included in the estimation process 

and over a few years to show a trend of the estimates. Unusual fluctuations, if any, should be 

investigated and the research conclusions documented. 

Modified Repeat – MW 

Recommendation #13

Material 

Weakness 

Undelivered 

Orders and 

Accounts 

Payable -

Procurement

30 Centralize the storage of all procurement documents in contract files and maintain them 

electronically. 

Repeat – MW 

Open Recommendation

31 Strengthen internal control to ensure procurement documents are properly approved and 

retained. 

Repeat – MW 

Open Recommendation

32 Analyze procurement undelivered orders balances quarterly to verify that balances are still valid 

for those without financial activities for an extended period. 

Repeat – MW 

Open Recommendation

33 Research, resolve and document the disposition of any abnormal undelivered orders 

transactions/balances. 

Repeat – MW 

Open Recommendation

34 Correct the financial system’s posting logic to ensure all future transactions are recorded 

properly in accordance with United States Standard General Ledger. 

Repeat – MW 

Open Recommendation

35

Document the accounts payable accrual methodology to include the recognition and reporting of 

the incurred but not reported. The methodology should also document key controls related to 

review and approval process of the accrual estimation; materiality and how it is applied; 

reviewing, approving, and recording of invoices prior to processing payments; inputs to be used 

in the validation; consideration of payment types; and the basis for including or excluding typical 

factors in estimating accruals, such as period of performance, type of contract, billing patterns, 

and others. 

Repeat – MW 

Open Recommendation

56
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

28

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

36

Conduct validation assessment of amounts accrued for the incurred but not reported on a 

periodic basis. As part of the validation, AmeriCorps should consider the following:

a. Subsequent activities against the amount estimated to determine the level of precision in the 

estimation;

b. Trend the validation results and adjust the incurred but not reported estimation process to 

address any recurring significant fluctuations; and

c. Update the incurred but not reported estimation process as necessary to reflect changes in 

payment patterns. 

Repeat – MW 

Open Recommendation

37

Evaluate the materiality thresholds used in the accrual estimation to ensure it is appropriate to 

prevent misstatements. The materiality threshold used should be appropriate that, in the 

aggregate, identified misstatements would not rise to a level that will significantly impact 

management’s assertions on the financial statements. 

Repeat – MW 

Open Recommendation

38 Implement controls to ensure that transactions interfaced from eGrants are reflected in 

Momentum for the correct amounts, accounts, and number of transactions. 

Repeat – MW 

Open Recommendation

Former 

Material 

Weakness 

Property and 

Equipment13

39 Analyze contractor-developed software costs that were expensed but not capitalized in 

accordance with accounting standards. Closed

40 Update AmeriCorps policy to recognize and record capitalized costs in the period incurred. Repeat

Open Recommendation

41

Update AmeriCorps policy to include requirements for compliance with accounting standards; 

track direct labor and other indirect costs, including hours, worked and payroll costs dedicated 

to existing and new software-in-development projects; track and amortize tenant improvement 

costs in accordance with the lease agreement. 

Repeat

Open Recommendation

13 Property and Equipment was removed from a material weakness as the conditions related to the finding were not found in our FY 2021 testing. However, the recommendations in

FY 2019 were still not corrective so the recommendations will remain as open. 

57
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

29

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

42 Review the GMM contract status to ensure proper and timely deobligation of any remaining 

unliquidated obligations that are no longer needed. 

Repeat

Open Recommendation

43

Consult with the future shared service provider and other stakeholders to determine the 

feasibility of procuring and using project management software to track project costs from the 

inception to completion. The results of the analysis should be documented and made readily 

available. 

Repeat

Open Recommendation

44

Establish and implement periodic training on capitalization accounting standard, and AmeriCorps

Capitalization Policy for accounting, program, Office of Facility Support Services, and information 

technology staff. 

Repeat

Open Recommendation

45

Develop and perform a periodic analysis of expenses incurred, e.g., software-in-development 

costs and repairs and maintenance, to determine if they meet the capitalization requirements 

and conduct any follow-up to ensure costs are properly capitalized. 

Closed

Material 

Weakness 

Undelivered 

Orders - Grants

46

Determine the root cause behind the differences noted in the Undelivered Orders balance 

between Momentum and the Undelivered Orders balance derived from the net of grant award 

amount from the Notice of Grant Award and the grant expenditures from the Payment 

Management System and take the appropriate steps in resolving the reason behind the 

variances that are occurring. 

Repeat – MW 

Open Recommendation

47 Determine the root causes and resolve discrepancies in the grant award amounts recorded in 

the NGA in eGrants and in Momentum to prevent such differences from occurring in the future. 

Repeat – MW 

Open Recommendation

48 Determine the root causes and resolve expenditure differences between the Payment 

Management System and Momentum. 

Repeat – MW 

Open Recommendation

58
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

30

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

49

Strengthen controls around the review of expired grant obligations by ensuring that:

a. All financial, performance and other required reports are submitted no later than 90 calendar 

days after the end date of the period of performance.

b. Document justifications for all required reports submission extensions granted to the grantee. 

Repeat – MW 

Open Recommendation

50 Update the AmeriCorps transaction code posting logic for recording grant expenditures to 

comply with the United States Standard General Ledger guidance. 

Repeat – MW 

Open Recommendation

Material 

Weakness 

Recoveries of 

Prior Year 

Obligations

51

Establish a requirement for Grant Officer/Portfolio Managers to provided documented 

certification that all required grantee information has been received, accepted, and documented 

before the grant is closed out. 

Repeat – MW 

Open Recommendation

52 Revise its OMB Circular No. A-123 internal control program testing to include a review of 

contract modifications. Closed

53

Establish a control requiring the Grant Officer/Portfolio Manager to provide documented 

certification, upon grant closeout, verifying the total award amount to total award expenses for 

the deobligated recovery amount. 

Repeat – MW 

Open Recommendation

54 Determine the cause for the travel cost recovery difference to ascertain what corrective action is 

needed and to prevent issues from recurring. 

Repeat – MW 

Open Recommendation

55

Inform all Grant Officers/Portfolio Managers to ensure that a reduction in funding to the award 

of a grant should be documented in eGrants which would result in modified Notice of Grant 

Awards. (new)

Repeat – MW 

Open Recommendation

Material 

Weakness 56 Reconcile the amounts reported in Other Liabilities to supporting documents to verify that Other 

Liabilities are supported by valid transactions and properly classified. 

Repeat – MW 

Open Recommendation

59
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

31

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

Other 

Liabilities

57

Strengthen financial reporting internal controls and ensure that financial statements accounting 

line items are reviewed and reconciled to supporting documents prior to recording. The internal 

control activities should ensure proper posting of Member Payroll related liabilities on the 

Balance Sheet. 

Repeat – MW 

Open Recommendation

Significant 

Deficiency (SD)

IT Security 

Controls

58

Develop a multi-year strategy to better strategically prioritize and allocate resources to address 

the new and continuing weaknesses identified and work towards automation, continuous 

monitoring, and consistent application of controls. 

Repeat - SD

Open Recommendation

59 Enforce the agency-wide information security program across the enterprise and improve 

performance monitoring to ensure controls are operating as intended at all facilities. 

Repeat - SD

Open Recommendation

60

Strengthen and refine the process for communicating AmeriCorps facility-specific control 

deficiencies to AmeriCorps facility personnel, and coordinate remediation of the control 

deficiencies. 

Repeat - SD

Open Recommendation

61

Strengthen and refine the process for holding system owners and information system security 

officers accountable for remediation of control deficiencies and ensuring that the appropriate 

security posture is maintained for AmeriCorps information systems. 

Repeat - SD

Open Recommendation

62 Strengthen and refine the process for holding contractors accountable for remediation of control 

deficiencies in AmeriCorps information systems. 

Repeat - SD

Open Recommendation

63 Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. Repeat - SD

Open Recommendation

Significant 

Deficiency 64 Reconcile the Accounts Receivable subsidiary ledger to the general ledger monthly. 

Repeat – Control 

Deficiency (CD) 

Open Recommendation

60
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

32

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

AR & 

Allowance for 

Doubtful 

Accounts

65

Reevaluate the policies and procedures for calculating the allowance for doubtful accounts. 

Related policies and procedures should include: (a) CFO Office’s staff’s periodic review of the 

accounts receivable aging report, (b) assessment of the collectability of outstanding balances 

based on the age of the debt, collections attempted and received thus far and other information 

about the debtor and (c) determination for possible write-offs. 

Repeat – CD 

Open Recommendation

66 Revise the Allowance for Doubtful Accounts methodology to be consistent with the Debt 

Management Policy. 

Repeat – CD 

Open Recommendation

67 Develop a process and proactively monitor and follow-up on delinquent accounts receivables.

Document any procedures performed and results reached as part of the follow-up process. 

Repeat – CD 

Open Recommendation

68

Track and revise collection efforts based on data analysis to understand vendor payment 

characteristics. A reasonable timeframe for write-offs should be established for accounts 

receivable without any activity. Once an outstanding receivable is deemed uncollectible, it 

should be written off in accordance with management’s established policy. 

Repeat – CD 

Open Recommendation

69

Establish a documented process between accounting and the Office of Chief Risk Officer (OCRO) 

to ensure that key controls related to the Accounts Receivable cycle are properly identified and 

implemented. These key controls should be considered for testing as part of OCRO’s annual 

internal control assessments. 

Repeat – CD 

Open Recommendation

NonCompliance 

Single Audit 

Compliance

70 Develop, implement, and document procedures to identify all AmeriCorps grantees that are 

required to submit single audit reports with their due dates. 

Repeat – NonCompliance 

Open Recommendation

71

Develop, implement, and document procedures on timely follow-up for those grantees whose 

audits have become past due, and to ascertain why report submission was late, when the audit 

report will be submitted to the Federal Audit Clearinghouse, and what corrective action has been 

taken to prevent a report submission delay in future. 

Repeat – NonCompliance 

Open Recommendation

72 Develop a practice to capture the single audit data to assess the effectiveness of the single audit 

report submission for all its grantees. 

Repeat – NonCompliance 

Open Recommendation

61
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

33

FY19 Audit 

Report Finding

Area

FY19 Audit 

Report Rec. 

Number

Recommendation Description

Status of FY19 

Recommendations in 

FY21

73

Develop, implement, and document procedures for implementing Office of Budget and 

Management (OMB) approved single audit report submission extensions, so that OMB approved 

extension approvals are documented and tracked as part of the single audit monitoring process. 

Repeat – NonCompliance 

Open Recommendation

74

Update the Single Audit Resolution Policy to:

• Reflect the current monitoring process to track all audit findings related to AmeriCorps-funded 

grants, and

• Address AmeriCorps’ responsibilities as the cognizant/oversight agency and how these 

responsibilities would be carried out. 

Repeat – NonCompliance 

Open Recommendation

75

Develop and implement procedures to monitor the effectiveness of the single audit monitoring 

process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 

Responsibilities, (a) (3) (iv), related to monitoring the effectiveness of single audit findings 

follow-up and the effectiveness of single audits in improving grantee accountability and in their 

use by AmeriCorps in making award decisions. 

Repeat – NonCompliance 

Open Recommendation

62
EXHIBIT D

Management’s Response

FY 2021

34

63
EXHIBIT D

Management’s Response

FY 2021

35

64
250 E St., SW, Suite 4100

Washington, DC 20525

OFFICE OF INSPECTOR GENERAL

HOTLINE: 1.800.452.8210 

HOTLINE@AmeriCorpsOIG.gov | AmeriCorpsOIG.gov

 

65
PART C. CONSOLIDATED FINANCIAL STATEMENTS 

AMERICORPS

BALANCE SHEET

AS OF SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited 

2021 2020

Assets:

Intragovernmental:

Fund Balance with Treasury (Note 2) $ 2,364,927 $ 2,058,467

Investment (Net) (Note 3) 1,011,223 185,714

Accounts Receivable, Net (Note 4) 1,931 166

Advances and Prepayments 894 -

Total Intragovernmental 3,378,975 2,244,348

With the Public:

Accounts Receivable, Net (Note 4) $ 1,336 $ 999

General Property, Plant, and Equipment, Net (Note 5) 3,235 3,651

Advances and Prepayments 86,198 66,399

Total With the Public 90,769 71,049

Total Assets $ 3,469,743 $ 2,315,397

Liabilities (Note 6):

Intragovernmental:

Accounts Payable (Note 6) $ 1,580 $ -

Advances from Others and Deferred Revenue 6,360 9,919

Other Liabilities (Note 7)

Liability to the General Fund for Non-Entity 

Assets (349) 94

Benefit Program Contributions Payable 2,569 1,577

Tenant Improvement Allowance 2,485 2,779

Total Intragovernmental 12,646 14,369

With the Public:

66
Accounts Payable $ 156,347 $ 110,332

Federal Employee [and Veteran] Benefits Payable 

(Note 7) 13,915 13,412

Advances from Others and Deferred Revenue (Note 7) 85 325

Other Liabilities (Note 7)

 Trust Service Award Liability 356,024 438,294

 Accrued Funded Payroll and Leave 3,826 3,518

 Other Liabilities 2,061 2,170

Total With the Public 532,259 568,052

Total Liabilities $ 544,904 $ 582,421

Net Position:

Unexpended Appropriations - Funds from Other than

Dedicated Collections 2,132,473 1,098,387

Total Unexpended Appropriations 2,132,473 1,098,387

Cumulative Results of Operations - Funds from Other 

than Dedicated Collections 792,367 634,589

Total Cumulative Results of Operations 792,367 634,589

Total Net Position 2,924,840 1,732,976

Total Liabilities and Net Position $ 3,469,745 $ 2,315,397

The accompanying notes are an integral part of these statements.

67
AMERICORPS

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Gross Program Costs:

VISTA:

Gross Costs $ 139,292 $ 129,847

Less: Earned Revenue (8,108) (8,325)

Net Program Costs $ 131,184 $ 121,522

NCCC:

Gross Costs $ 50,434 $ 35,922

Less: Earned Revenue (6,459) (7,488)

Net Program Costs $ 43,975 $ 28,434

STATE AND NATIONAL:

Gross Costs $ 508,070 $ 624,879

Less: Earned Revenue (5,682) (15,193)

Net Program Costs $ 502,388 $ 609,685

STATE COMISSION:

Gross Costs $ 20,158 $ 19,918

Less: Earned Revenue - -

Net Program Costs 20,158 19,918

SENIOR CORPS:

Gross Costs $ 192,682 $ 188,176

Less: Earned Revenue (209) (889)

Net Program Costs $ 192,473 $ 187,288

Other Programs:

68
Gross Costs $ 9,833 $ 11,767

Less: Earned Revenue (591)

Net Program Costs $ 9,242 $ 11,767

Net Cost of Operations $ 899,419 $ 978,613

The accompanying notes are an integral part of these statements.

69
AMERICORPS

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Consolidated 

Total

Consolidated 

Total

Unexpended Appropriations:

Beginning Balances $ 1,098,387 $ 1,009,845

Adjustments

Corrections of Errors - (1,581)

Beginning Balances, as Adjusted 1,098,387 1,008,264

Appropriations Received $ 2,121,102 $ 1,128,708

Other Adjustments (33,441) (49,616)

Appropriations Used (1,053,575) (988,969)

Net Change in Unexpended Appropriations 1,034,086 90,123

Total Unexpended Appropriations - Ending $ 2,132,473 $ 1,098,387

Cumulative Results of Operations:

Beginning Balances $ 634,702 $ 617,375

Adjustments

Corrections of Errors 91 3,640

Beginning Balances, as Adjusted 634,793 621,015

Other Adjustments $ (1,278) $ (2,539)

Appropriations Used 1,053,575 988,969

Nonexchange Revenue 582 -

Donations and Forfeitures of Cash and Cash

Equivalents 23 21

Transfers In/Out Without Reimbursement - (155)

Imputed Financing 3,760 5,872

70
Other 330 19

Net Cost of Operations (899,419) (978,613)

Net Change in Cumulative Results of Operations 157,574 13,574

Cumulative Results of Operations - Ending $ 792,367 $ 634,589

Net Position $ 2,924,840 $ 1,732,976

The accompanying notes are an integral part of these statements.

71
AMERICORPS

STATEMENT OF BUDGETARY RESOURCES

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Budgetary Resources:

Unobligated balance from prior year budget 

authority, net $ 595,010 $ 395,538

Appropriations 2,475,596 1,336,271

Spending authority from offsetting collections 12,735 35,553

Total Budgetary Resources $ 3,083,341 $ 1,767,362

Status of Budgetary Resources:

New obligations and upward adjustments (total) $ 1,548,278 $ 1,220,451

Unobligated balance, end of year:

 Apportioned, unexpired accounts 527,650 289,075

 Unapportioned, unexpired accounts 857,645 105,462

Unexpired unobligated balance, end of year 1,385,294 394,537

Expired unobligated balance, end of year 149,769 152,375

Unobligated balance, end of year (total) 1,535,063 546,912

Total Budgetary Resources $ 3,083,341 $ 1,767,362

Outlays, Net and Disbursements, Net:

Outlays, net (total) $ 1,159,916 $ 1,154,240

Distributed Offsetting Receipts (2,002) 7,660

Agency outlays, net $ 1,157,914 $ 1,161,900

Disbursements, net (total) (mandatory) $ 1,174,426 $ 1,164,262

The accompanying notes are an integral part of these statements.

72
PART D. NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

AMERICORPS 

NOTES TO THE UNAUDITED FINANCIAL STATEMENTS 

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

A. Reporting Entity

AmeriCorps was created by the National and Community Service Trust Act of 1993 (Public Law 103-

82). AmeriCorps’s mission is to improve lives, strengthen communities, and foster civic engagement 

through service and volunteering. To meet its mission, AmeriCorps provides grants and other 

assistance to states, local communities, and nonprofit organizations to help communities meet 

challenges in the areas of education, healthy futures, environmental stewardship, economic 

opportunity, disaster services, and assisting veterans and military families through volunteer service. 

AmeriCorps’s major programs are as follows:

AmeriCorps. AmeriCorps provides opportunities for Americans to make an ongoing, intensive

commitment to service through the following programs:

• AmeriCorps State, National, Tribes, and Territories (State and National) offers grants supporting

a broad range of local service programs that engage thousands of Americans in intensive

service to meet community needs.

• AmeriCorps VISTA helps community organizations and public agencies create and expand

programs that bring low-income individuals and communities out of poverty.

• AmeriCorps NCCC strengthens communities while developing leaders through direct, teambased national and community service.

• AmeriCorps State Service Commission Support Grants (State Commission Support) offers grants

supporting shared federal-state partnership with a central role for governors in designing and

implementing national service through governor-supported State Service Commissions.

AmeriCorps Seniors. AmeriCorps Seniors offers a network of programs that tap into the rich 

experience, skills, and talents of older citizens to meet community challenges. AmeriCorps Seniors

comprises the RSVP, the Foster Grandparent Program, and the Senior Companion Program. 

B. Basis of Presentation

73
The financial statements have been prepared to report the financial position and results of 

operations of AmeriCorps. The Balance Sheet presents the financial position of the agency. The 

Statement of Net Cost presents the agency’s operating results; the Statement of Changes in Net 

Position displays the changes in the agency’s equity accounts. The Statement of Budgetary 

Resources presents the sources, status, and uses of the agency’s resources and follows the rules for 

the Budget of the United States Government.

The statements are a requirement of the Chief Financial Officers Act of 1990, the Government 

Management Reform Act of 1994 and the Accountability of Tax Dollars Act of 2002. They have been 

prepared from, and are fully supported by, the books and records of AmeriCorps in accordance with 

the hierarchy of accounting principles generally accepted in the United States of America, standards 

issued by the Federal Accounting Standards Advisory Board (FASAB), Office of Management and 

Budget (OMB) Circular A-136, Financial Reporting Requirements, as amended, and AmeriCorps 

accounting policies which are summarized in this note. These statements, with the exception of the 

Statement of Budgetary Resources, are different from financial management reports, which are also 

prepared pursuant to OMB directives that are used to monitor and control AmeriCorps’s use of 

budgetary resources. The financial statements and associated notes are presented on a 

comparative basis. Unless specified otherwise, all amounts are presented in dollars.

C. Basis of Accounting

Transactions are recorded on both an accrual accounting basis and a budgetary basis. Under the 

accrual method, revenues are recognized when earned, and expenses are recognized when a 

liability is incurred, without regard to receipt or payment of cash. Budgetary accounting facilitates 

compliance with legal requirements on the use of federal funds.

D. Fund Balance with Treasury

FBWT is an asset of a reporting entity and a liability of the General Fund. It is the aggregate amount of 

the AmeriCorps’s funds with Treasury in expenditure, receipt, revolving, trust, and deposit fund 

accounts. Appropriated funds recorded in expenditure accounts are available to pay current 

liabilities and finance authorized purchases. 

AmeriCorps does not maintain bank accounts of its own, has no disbursing authority, and does not 

maintain cash held outside of Treasury. When the reporting entity seeks to use FBWT or investments in 

Government securities to liquidate budgetary obligations, Treasury will finance the disbursements in 

the same way it finances all other disbursements, which is to borrow from the public if there is a

budget deficit (and to use current receipts if there is a budget surplus). Funds are disbursed for the 

agency on demand. 

E. Investment in U.S. Government Securities

AmeriCorps has the authority to invest in U.S. Government securities. The securities include 

marketable Treasury securities and/or nonmarketable, market-based securities issued by the Bureau 

of the Fiscal Service. Market-based securities are Treasury securities that are not traded on any 

securities exchange but mirror the prices of marketable securities with similar terms. It is expected that 

investments will be held until maturity; therefore, they are classified as investment securities held to 

maturity and are carried at historical cost, adjusted for amortization of premiums and discounts. The 

amortization of premiums and discounts are recognized as adjustments to interest income using the 

level-yield, scientific method of effective interest amortization over the term of the respective issues. 

Interest on investments is accrued as it is earned.

F. Accounts Receivable

74
Accounts receivable consists of amounts owed to AmeriCorps by federal agencies and the general 

public. Amounts due from federal agencies are considered fully collectible. Accounts receivable 

from the public include reimbursements from employees. An allowance for uncollectible accounts 

receivable from the public is established when, based upon a review of outstanding accounts and 

the failure of all collection efforts, management determines that collection is unlikely to occur 

considering the debtor’s ability to pay.

G. Property, Equipment, and Software

Property, equipment, and software represent furniture, fixtures, equipment, and information 

technology hardware and software which are recorded at original acquisition cost and are 

depreciated or amortized using the straight-line method over their estimated useful lives. Major 

alterations and renovations are capitalized, while maintenance and repair costs are expensed as 

incurred. AmeriCorps’s capitalization threshold is $50,000 for individual purchases and $250,000 for 

bulk purchases. Property, equipment, and software acquisitions that do not meet the capitalization 

criteria are expensed upon receipt. Applicable standard governmental guidelines regulate the 

disposal and convertibility of agency property, equipment, and software. The useful life classifications 

for capitalized assets are as follows:

Description Useful Life (Years)

Equipment 10

Telecommunication Equipment 6

Automated Data Processing 

Equipment 3

Software 2

H. Advances and Prepaid Charges

Advance payments are generally prohibited by law. There are some exceptions, such as 

reimbursable agreements, subscriptions, and payments to grantees, contractors and employees. 

Payments made in advance of the receipt of goods and services are recorded as advances or 

prepaid charges at the time of prepayment and recognized as expenses when the related goods 

and services are received.

I. Liabilities

Liabilities represent the amount of funds likely to be paid by AmeriCorps as a result of transactions or 

events that have already occurred.

AmeriCorps reports its liabilities under two categories, Intragovernmental and With the Public. 

Intragovernmental liabilities represent funds owed to another government agency. Liabilities With the 

Public represent funds owed to any entity or person that is not a federal agency, including private 

sector firms and federal employees. Each of these categories may include liabilities that are covered 

by budgetary resources and liabilities not covered by budgetary resources.

75
Liabilities covered by budgetary resources are liabilities funded by a current appropriation or other 

funding source. These consist of accounts payable and accrued payroll and benefits. Accounts 

payable represent amounts owed to another entity for goods ordered and received and for services 

rendered except for employees. Accrued payroll and benefits represent payroll costs earned by 

employees during the fiscal year which are not paid until the next fiscal year.

Liabilities not covered by budgetary resources are liabilities that are not funded by any current 

appropriation or other funding source. These liabilities consist of accrued annual leave, Actuarial 

FECA, and the amounts due to Treasury for collection. 

J. Annual, Sick, and Other Leave

Annual leave is accrued as it is earned, and the accrual is reduced as leave is taken. The balance in 

the accrued leave account is adjusted to reflect current pay rates. Liabilities associated with other 

types of vested leave, including compensatory, restored leave, and sick leave in certain 

circumstances, are accrued at year-end, based on latest pay rates and unused hours of leave. 

Funding will be obtained from future financing sources to the extent that current or prior year 

appropriations are not available to fund annual and other types of vested leave earned but not 

taken. Nonvested leave is expensed when used. Any liability for sick leave that is accrued but not 

taken by a Civil Service Retirement System (CSRS)-covered employee is transferred to the Office of 

Personnel Management (OPM) upon the retirement of that individual. Credit is given for sick leave 

balances in the computation of annuities upon the retirement of Federal Employees Retirement 

System (FERS)-covered employees.

K. Accrued and Actuarial Workers’ Compensation

The Federal Employees' Compensation Act (FECA) administered by the U.S. Department of Labor 

(DOL) addresses all claims brought by AmeriCorps employees for on-the-job injuries. The DOL bills 

each agency annually as its claims are paid, but payment of these bills is deferred for two years to 

allow for funding through the budget process. Similarly, employees that AmeriCorps Service 

terminates without cause may receive unemployment compensation benefits under the 

unemployment insurance program also administered by the DOL, which bills each agency quarterly 

for paid claims. Future appropriations will be used for the reimbursement to DOL. The liability consists 

of (1) the net present value of estimated future payments calculated by the, and (2) the 

unreimbursed cost paid by DOL for compensation to recipients under the FECA.

L. Retirement Plans

AmeriCorps employees participate in either the CSRS or the FERS. The employees who participate in 

CSRS are beneficiaries of AmeriCorps matching contribution, equal to seven percent of pay, 

distributed to their annuity account in the Civil Service Retirement and Disability Fund.

Prior to December 31, 1983, all employees were covered under the CSRS program. From January 1, 

1984 through December 31, 1986, employees had the option of remaining under CSRS or joining FERS 

and Social Security. Employees hired as of January 1, 1987 are automatically covered by the FERS 

program. Both CSRS and FERS employees may participate in the federal Thrift Savings Plan (TSP). FERS

employees receive an automatic agency contribution equal to one percent of pay and AmeriCorps 

matches any employee contribution up to an additional four percent of pay. For FERS participants, 

AmeriCorps also contributes the employer’s matching share of Social Security.

FERS employees and certain CSRS reinstatement employees are eligible to participate in the Social 

Security program after retirement. In these instances, AmeriCorps remits the employer’s share of the 

required contribution.

76
AmeriCorps recognizes the imputed cost of pension and other retirement benefits during the 

employees’ active years of service. OPM actuaries determine pension cost factors by calculating the 

value of pension benefits expected to be paid in the future and communicate these factors to 

AmeriCorps for current period expense reporting. OPM also provides information regarding the full 

cost of health and life insurance benefits. AmeriCorps recognized the offsetting revenue as imputed 

financing sources to the extent these expenses will be paid by OPM.

AmeriCorps does not report on its financial statement information pertaining to the retirement plans 

covering its employees. Reporting amounts such as plan assets, accumulated plan benefits, and 

related unfunded liabilities, if any, is the responsibility of the OPM, as the administrator.

M. Other Post-Employment Benefits

AmeriCorps employees eligible to participate in the Federal Employees' Health Benefits Plan (FEHBP) 

and the Federal Employees' Group Life Insurance Program (FEGLIP) may continue to participate in 

these programs after their retirement. The OPM has provided the AmeriCorps with certain cost factors 

that estimate the true cost of providing the post-retirement benefit to current employees. The 

AmeriCorps recognizes a current cost for these and Other Retirement Benefits (ORB) at the time the 

employee's services are rendered. The ORB expense is financed by OPM and offset by the 

AmeriCorps through the recognition of an imputed financing source. 

N. Use of Estimates

The preparation of the accompanying financial statements in accordance with generally accepted 

accounting principles requires management to make certain estimates and assumptions that affect 

the reported amounts of assets, liabilities, revenues, and expenses. Actual results could differ from 

those estimates. 

O. Contingencies

Liabilities are deemed contingent when the existence or amount of the liability cannot be 

determined with certainty pending the outcome of future events. AmeriCorps recognizes contingent

liabilities in the accompanying balance sheet and statement of net cost when it is both probable 

and can be reasonably estimated. AmeriCorps discloses contingent liabilities in the notes to the 

financial statements when the conditions for liability recognition are not met or when a loss from the 

outcome of future events is more than remote. 

P. Reclassification

Due to the migration to ARC, certain FY 2021 balances have been reclassified, retitled, or combined 

with other financial statement line items for consistency with the current year presentation.

Q. Classified Activities

Accounting standards require all reporting entities to disclose that accounting standards allow 

certain presentations and disclosures to be modified, if needed, to prevent the disclosure of classified 

information. 

77
NOTE 2. FUND BALANCE WITH TREASURY

Fund Balance with Treasury account balances as of September 30, 2021 and 2020, were as follows:

Unaudited 2021 Unaudited 2020

Status of Fund Balance with Treasury:

Unobligated Balance

 Available $ 677,649 $ 289,075 

 Unavailable 857,413 407,837 

Obligated Balance Not Yet Disbursed 1,838,674 1,544,740 

Net of Unamortized Discount (1,010,870) (185,200)

Non-Budgetary FBWT 2,061 2,015 

Total $ 2,364,927 $ 2,058,467 

No discrepancies exist between the Fund Balance reflected on the Balance Sheet and the balances 

in the Treasury accounts. The available unobligated fund balances represent the current period 

amount available for obligation or commitment. At the start of the next fiscal year, this amount will 

become part of the unavailable balance as described in the following paragraph.

The unavailable unobligated fund balances represent the amounts of appropriations for which the 

period of availability for obligation has expired. These balances are available for upward adjustments 

of obligations incurred only during the period for which the appropriation was available for obligation 

or for paying claims attributable to the appropriations.

The obligated balance not yet disbursed includes accounts payable, accrued expenses, and 

undelivered orders that have reduced unexpended appropriations but have not yet decreased the 

fund balance on hand.

NOTE 3. INVESTMENTS

Investments as of September 30, 2021 consist of the following:

Cost

Amortization 

Method

Amortized

(Premium)

Discount

Interest 

Receivable

Investments

Net

Market 

Value 

Disclosure

Intragovernmental:

Market-Based

 Bills

$ 

641,000 Interest $ 140 $ -

$ 

641,140 

$ 

641,141 

 Notes 369,870 Interest 97 115 370,083 369,726

Total

$ 

1,010,870 $ 237 $ 115 

$ 

1,011,223 

$ 

1,010,867 

78
Investments as of September 30, 2020 (Unaudited) consist of the following:

Cost

Amortization 

Method

Amortized

(Premium)

Discount

Interest 

Receivable

Investments

Net

Market 

Value 

Disclosure

Intragovernmental:

 

Marketable

 Bills

$ 

115,800 Interest $ 45 $ - $ 115,844 

$ 

115,853 

 Notes 69,400 Interest 276 194 69,870 70,015 

 Total

$ 

185,200 $ 321 $ 194 $ 185,714 

$ 

185,868 

Non-marketable, market-based securities are Treasury notes and bills issued to governmental 

accounts that are not traded on any securities exchange but mirror the prices of marketable 

securities with similar terms. 

NOTE 4. ACCOUNTS RECEIVABLE, NET

Accounts receivable balances as of September 30, 2021 and 2020, were as follows:

Unaudited 2021 Unaudited 2020 

Intragovernmental

Accounts Receivable

$ 

1,931 $ 166 

Total Intragovernmental Accounts 

Receivable

$ 

1,931 $ 166 

With the Public

Accounts Receivable

$ 

2,393 $ 4,622 

Allowance 1,057 3,623 

Total Public Accounts Receivable

$ 

1,336 $ 999 

Total Accounts Receivable

$ 

3,267 $ 1,165 

79
Accounts Receivable represents amounts due to AmeriCorps primarily under federal and nonfederal 

reimbursable agreements, grantee audit resolution determinations, outstanding travel advances due 

from employees and Criminal History Check requirements. An allowance for doubtful accounts is 

established for reporting purposes based on experience.

Historical experience has indicated that the majority of the receivables are collectible. There are no 

material uncollectible accounts as of September 30, 2021 and 2020.

NOTE 5. GENERAL PROPERTY, PLANT AND EQUIPMENT, NET

Schedule of General Property, Plant and Equipment, Net as of September 30, 2021:

Major Class

Acquisition 

Cost

Accumulated 

Amortization/Depreciation

Net Book 

Value

Leasehold 

Improvements

 $ 5,125 $ 2,068 $ 3,057 

Furniture & Equipment 1,532 1,354 178 

Total $ 6,657 $ 3,422 $ 3,235 

Schedule of General Property, Plant and Equipment, Net as of September 30, 2020 (Unaudited):

Major Class

Acquisition 

Cost

Accumulated 

Amortization/Depreciation

Net Book 

Value

Leasehold 

Improvements

 $ 5,125 $ 1,632 $ 3,493 

Furniture & Equipment 1,264 1,107 158 

Total $ 6,389 $ 2,739 $ 3,651 

80
NOTE 6. LIABILITIES NOT COVERED BY BUDGETARY RESOURCES

The liabilities for AmeriCorps as of September 30, 2021 and 2020, include liabilities not covered by 

budgetary resources. Congressional action is needed before budgetary resources can be provided. 

Although future appropriations to fund these liabilities are likely and anticipated, it is not certain that 

appropriations will be enacted to fund these liabilities. 

Unaudited 2021 Unaudited 2020

Intragovernmental – FECA $ 1,403 $ 1,577 

Intragovernmental – Unemployment Insurance 554 841 

Unfunded Leave 4,370 4,502 

Actuarial FECA 8,689 7,497 

Deferred Lease Liabilities 2,485 2,779 

Other Liabilities - -

Total Liabilities Not Covered by Budgetary 

Resources

 $ 

17,501 

 $ 

17,196 

Total Liabilities Covered by Budgetary 

Resources 527,753 565,131 

Total Liabilities Not Requiring Budgetary 

Resources (350) 94 

Total Liabilities $ 544,904 $ 582,421 

FECA and the Unemployment Insurance liabilities represent the unfunded liability for actual workers 

compensation claims and unemployment benefits paid on AmeriCorps’s behalf and payable to the 

DOL. AmeriCorps also records an actuarial liability for future workers compensation claims based on 

the liability to benefits paid (LBP) ratio provided by DOL and multiplied by the average of benefits 

paid over three years.

Unfunded leave represents a liability for earned leave and is reduced when leave is taken. The 

balance in the accrued annual leave account is reviewed quarterly and adjusted as needed to 

accurately reflect the liability at current pay rates and leave balances. Accrued annual leave is paid 

from future funding sources and, accordingly, is reflected as a liability not covered by budgetary 

resources. Sick and other leave is expensed as taken. 

81
NOTE 7. OTHER LIABILITIES

Other liabilities account balances as of September 30, 2021 were as follows:

Current

Non 

Current Total

Intragovernmental

Advances from Others and Deferred 

Credits

 $ 

6,360 

$ 

- $ 6,360 

Non-Entity Assets (Non-Custodial) (349) 

 

- (349) 

Benefit Program Contributions 2,569 

 

- 2,569 

Tenant Improvement Allowance 2,485 2,485

Total Intragovernmental Other Liabilities $ 8,580 $ 2,485 $ 11,065 

With the Public

 Trust Service Award Liability $ 356,024 

$ 

- $ 356,024 

 Accrued Funded Payroll and Leave

 

3,826 

 

- 3,826 

 Liability to Unclaimed Stipend to 

Members

 

2,061 

 

- 2,061 

 Federal Employee and Veterans 

Benefits

 

13,915 - 13,915

 Advances from Others and Deferred 

Credit

 

85 - 85

Total Public Other Liabilities $ 375,911 

$ 

- $ 375,911 

Other liabilities account balances as of September 30, 2020 (Unaudited) were as follows:

Current

Non 

Current Total

Intragovernmental

Advances from Others and Deferred 

Credits

$ 

9,919 

$ 

- $ 9,919 

Non-Entity Assets (Non-Custodial) 94 

 

- 94 

82
Unfunded FECA 1,577 

 

- 1577 

Tenant Improvement Allowance 2,779 2,799

Total Intragovernmental Other Liabilities

$ 

11,590 

$ 

2,779 $ 14,369 

With the Public

 Trust Service Award Liability

$ 

438,294 

$ 

-

$ 

438,294 

 Accrued Funded Payroll and Leave 3,518 

 

- 3,518 

 Liabilities to Unclaimed Stipend to 

Members 2,170 

 

- 2,170 

 Federal Employee and Veterans 

Benefits 13,412 - 13,412

 Advances from others and Deferred 

Credits 325 - 325

Total Public Other Liabilities

$ 

457,719 

$ 

-

$ 

457,719 

In accordance with FAM Part 1002 and FASAB Handbook, Interpretation 2, AmeriCorps recognizes a 

contingent liability from a pending litigation matter. The likelihood of an unfavorable outcome in the 

case is probable, but there remains no basis to estimate the potential loss. Additionally, should the 

litigation result in an unfavorable outcome, the Judgment Fund, rather than AmeriCorps, will pay for 

the loss. 

83
NOTE 8. LEASES

AmeriCorps leases office space through the General Services Administration (GSA). GSA charges 

AmeriCorps a Standard Level Users Charge that approximates commercial rental rates for similar 

properties. The NCCC also leases housing facilities for its campuses. Additionally, AmeriCorps leases 

motor vehicles on an annual basis through GSA under an Interagency Fleet Management Service 

agreement for the NCCC. The leases are renewable with no purchase or escalation clause. The 

following schedule presents future minimum rental commitments under operating leases as of 

September 30 of each year.

2021 (in thousands)

Fiscal Year Facilities Space Vehicles Other Total

2022 $ 10,144 $ 

774 

$ 162 $ 11,080 

2023 10,458 784 159 11,401 

2024 10,782 794 159 11,735 

2025 11,117 804 159 12,080 

2026 11,462 814 159 12,435 

Total $ 53,963 

$ 

3,970 $ 798 $ 58,731 

Unaudited 2020 (in thousands)

Fiscal 

Year Facilities Space Vehicles Other Total

2021 $ 9,788 $ 

790 

$ 148 $ 10,726 

2022 10,091 799 66 10,956 

2023 10,403 808 66 11,277 

2024 10,726 818 66 11,610 

2025 11,058 828 66 11,952

Total $ 52,066 

$ 

4,043 $ 412 $ 56,521 

The operating lease amount does not include estimated payments for leases with annual renewal 

options.

84
NOTE 9. INTER-ENTITY COSTS

AmeriCorps recognizes certain inter-entity costs for goods and services that are received from other 

federal entities at no cost or at a cost less than the full cost. Certain costs of the providing entity that 

are not fully reimbursed are recognized as imputed cost and are offset by imputed revenue. Such 

imputed costs and revenues relate to employee benefits and claims to be settled by the Treasury 

Judgement Fund. AmeriCorps recognizes as inter-entity costs the amount of accrued pension and 

post-retirement benefit expenses for current employees. The assets and liabilities associated with such 

benefits are the responsibility of the administering agency, OPM. For the periods ended September 

30, 2021 and 2020, respectively, inter-entity costs were as follows:

Unaudited 2021 Unaudited 2020

Office of Personnel Management $ 3,760 $ 5,872 

Total Imputed Financing Sources $ 3,760 $ 5,872 

NOTE 10. UNDELIVERED ORDERS AT THE END OF THE PERIOD

As of September 30, 2021, budgetary resources obligated for undelivered orders were as follows:

Federal Non-Federal Total

Paid Undelivered Orders $ 894 $ 86,198 $ 87,092 

Unpaid Undelivered Orders 6,359 1,318,260 1,324,620

Total Undelivered Orders $ 7,253 $ 1,404,458 $ 1,411,712 

As of September 30, 2020, budgetary resources obligated for undelivered orders were as follows:

Federal Non-Federal Total

Paid Undelivered Orders $ (90) $ 66,489 $ 66,399 

Unpaid Undelivered Orders 6,619 992,856 999,475 

Total Undelivered Orders $ 6,529 $ 1,059,345 $ 1,065,874 

NOTE 11. EXPLANATION OF DIFFERENCES BETWEEN THE SBR AND THE BUDGET OF THE U.S. GOVERNMENT

SFFAS No. 7, Accounting for Revenue and Other Financing Sources and Concepts for Reconciling 

Budgetary and Financial Accounting, calls for explanation of material differences between amounts 

reported in the Statement of Budgetary Resources and the actual balances published in the Budget 

of the U.S. Government (the President’s Budget). The FY 2022 President’s Budget, with actual amounts 

for FY 2020, has been reconciled to the Statement of Budgetary Resources. The FY 2023 President’s 

Budget, with actual amounts for FY 2021, will not be published until February 2022. (Note Presentation 

in Millions.)

85
New 

Obligations Distributed

Budgetary & Upward Offsetting Net

Resources

Adjustments 

(Total) Receipts Outlays

Combined Statement of 

Budgetary Resources

$ 

1,767 

$ 

1,220 

$ 

8 

$ 

1,162 

Spending Authority from 

Offsetting Collections

 

(35)

 

-

 

-

 

-

Unobligated Balance Not

Available

 

(152)

 

-

 

-

 

-

Difference - Due to Rounding

 

16 

 

(16)

 

(7)

 

(9)

Budget of the U.S. Government

$ 

1,596 

$ 

1,204 

$ 

1 

$ 

1,153 

86
NOTE 12. RECONCILIATION OF NET COST TO NET OUTLAYS 

The reconciliation of net outlays, presented on a budgetary basis, and the net cost, presented on an 

accrual basis, provides an explanation of the relationship between budgetary and financial 

accounting information. 

RECONCILIATION OF NET COST TO NET OUTLAYS

BUDGET AND ACCRUAL RECONCILIATION

FOR THE YEARS ENDED SEPTEMBER 30, 2021

(In Thousands)

Intra

Governmental 

With the 

Public Total 

Net Operating Cost (SNC) $ 25,749 $ 873,670 $ 899,419

Components of Net Cost Not Part of the 

Budgetary Outlays

Property, Plant, and Equipment 

Depreciation Expense - (684) (684)

Accounts Receivable, Net 1,931 171 2,101

Securities and Investments (162) - (162)

Other Assets 894 19,799 20,693

(Increase)/Decrease in Liabilities:

Accounts Payable (4,067) (46,014) (50,080)

Federal Employee and Veteran Benefits 

Payable - (503) (503)

Other Liabilities 1,624 85,924 87,548

Financing Sources:

Imputed Cost (3,760) - (3,760)

Total Components of Net Operating Cost 

Not Part of the Budgetary Outlays $ (3,540) $ 58,693 $ 55,153

87
Components of the Budget Outlays That 

Are Not Part of Net Operating Cost

Acquisition of Capital Assets - 268 268

Donated Revenue - (23) (23)

Total Components of the Budget Outlays

That Are Not Part of Net Operating Cost $ - $ 246 $ 246

Misc Items

Distributed Offsetting Receipts (SBR 

4200) $ (2,002) $-

$

(2,002)

Custodial/Non-Exchange Revenue (109) (473) (582)

Non-Entity Activity 1,278 - 1,278

Other Temporary Timing Differences - (91) (91)

Appropriated Receipts for Trust/Special 

Funds 204,472 23 204,494

Total Other Reconciling Items $ 203,638 $ (541) $ 203,097

Total Net Outlays (Calculated Total) $ 225,847 $ 932,067 $ 1,157,914

Budgetary Agency Outlays, Net (SBR 4210)

Budgetary Agency Outlays, Net $ 1,157,914

88
NOTE 13. TRUST SERVICE AWARD 

SERVICE AWARD LIABILITY

Individuals who successfully complete terms of service in AmeriCorps programs earn education 

awards, which can be used to make payments on qualified student loans or for educational 

expenses at qualified educational institutions. The education award generally must be used within 

seven years of completion date of an approved term of national service. If the education award is 

transferred to an eligible individual or is a Summer of Service award (which was available to youth 

enrolled in grades 6 through 9), the use period is ten years. These awards, as well as interest 

forbearance payments on qualified student loans during the period members perform their service, 

are paid from the National Service Trust Fund. The Service Award Liability as of September 30, 2021 

and 2020 is as follows:

(In Thousands) Unaudited 2021 Unaudited 2020

Cumulative Education Awards Earned $ 

4,326,854 

$ 

4,137,288 

Cumulative Interest Forbearance Earned 

132,417 

 

126,057 

Total Cumulative Awards Earned 

4,459,271 

 

4,263,345 

Less: Discount for Usage and Statistics 

(1,483,523)

 

(888,003)

Less: Cumulative Awards paid 

(3,282,989)

 

(3,153,340)

Total Liability for Awards Earned 

(307,241)

 

(318,276)

Total Liability for Awards not yet Earned 

(48,583)

 

(120,016)

Total $ 

(355,824)

$ 

(438,292)

As of September 30, 2021 and 2020, the National Service Trust received $185 Million and $208.3 million 

respectively (unaudited). Under the provisions included in its annual appropriations and under 42 

U.S.C. 12601a, AmeriCorps is also authorized to transfer additional amounts from subtitle C program 

funds to the National Service Trust to support the activities of national service participants. 

SERVICE AWARD EXPENSE

Members serving in approved national service positions are eligible to earn a service award to pay 

for qualified education expenses. The National Service Trust also pays interest forbearance costs on 

qualified student loans during the period members perform community service.

AmeriCorps estimates the expense for national service awards based on the increase in its 

cumulative service award liability during the year (see Note 6). The total service award liability as of 

89
September 30, 2021 and 2020 respectively, has been adjusted to reflect the fact that earned awards 

are not always used. 

(In Thousands) Unaudited 2021 Unaudited 2020

Estimated Education Awards

$ 

44,782 

$ 

210,766 

Estimated Interest Forbearance

 

2,351 6,004 

National Service Award Expense $ 

47,133 

$ 

216,770 

NOTE 14. GRANTS ACCRUAL

AmeriCorps awards grants to nonprofit organizations, educational institutions, states, 

municipalities, and other external organizations. Grants become budgetary obligations, but not 

liabilities, at the time they are awarded. Although most grantees request funds prior to incurring 

expenses (Grants Advances), some incur expenditures prior to initiating a request for disbursement, 

based on the nature of the expenditures. At the end of each quarter, AmeriCorps calculates and 

reports an estimate of the amount of unreimbursed grantee expenses as grants payable.

AmeriCorps performs a compound method as of the end of each quarter. AmeriCorps’ first step was 

to use eGrants FFR data to estimate the unreported expenses (IBNR) as of the end of each quarter.

The eGrants FFR data covers roughly 90% of the grants issued by the agency. The grants not covered 

are the fixed price grants not requiring FFRs in eGrants. AmeriCorps assumed flat spending for these 

non-covered grants to calculate the spending as of a quarter-end and then subtracted the HHS 

reported spending to calculate an IBNR. The calculated IBNR for each grant was then summed for 

each quarter. The calculated accrual represents the total financial statement level estimate. The 

total calculated accrual estimate is then allocated by each individual grant’s percentage of the

90
PART E. INDEPENDENT AUDITORS’ REPORT ON NATIONAL SERVICE TRUST 

FUNDS FINANCIAL STATEMENTS AND MANAGEMENT'S RESPONSE

91
AUDIT OF AMERICORPS’ FISCAL YEAR 2021

NATIONAL SERVICE TRUST FUND FINANCIAL

STATEMENTS

OIG Report 22‐02

Prepared by:

CliftonLarsonAllen LLP

901 North Glebe Road, Suite 200

Arlington, VA 22203

The attached Draft Evaluation Report is for review and comment only and not for

distribution.  Its content is confidential and should be safeguarded to prevent disclosure

to parties other than those directly involved in commenting on the issues contained in

this report.

OFFICE OF INSPECTOR GENERAL

92
AmeriCorpsOIG.gov 

Hotline@AmeriCorpsOIG.gov

Hotline: 800-452-8210

AmeriCorps

Office of Inspector General

250 E St., SW, Suite 4100

Washington, DC 20525

November 15, 2021

MEMORANDUM TO: Malcom Coles 

Acting Chief Executive Officer

FROM: Monique P. Colter /s/ 

Assistant Inspector General for Audit

SUBJECT: Audit of AmeriCorps’ Fiscal Year 2021 National Service Trust Fund 

Financial Statement, OIG Report 22-02

We contracted with the independent certified public accounting firm of CliftonLarsonAllen LLP 

(CLA) to audit AmeriCorps’ National Service Trust Fund financial statements (Trust financial 

statements) as of September 30, 2021, and for the year then ended. The contract required that 

that the audit be performed in accordance with the United States generally accepted 

government auditing standards and applicable Office of Management Budget audit guidance. 

In its audit of the fiscal year 2021 Trust financial statements, CLA reported:

• Disclaimer of Opinion: AmeriCorps requested that the Trust Service Award Liability and 

related accounts in the financial statement be excluded from the FY 2021 financial 

statement audit. AmeriCorps also stated that that Trust Obligation and Liabilities would not 

be available to be audited until the close of the third quarter. In addition, AmeriCorps was 

unable to provide sufficient appropriate evidence on a significant number of transactions 

and account balances due to inadequate processes and controls to support transactions and 

estimates, and the ongoing remediation efforts from prior year findings.

• Four material weaknesses and one significant deficiency in the Trust’s internal control over 

financial reporting. CLA reported the following deficiencies in the areas below as material 

weaknesses and one significant deficiency, Information Technology Security Controls

(Modified Repeat): 

o Material Weaknesses:

1. Migration to Shared Service- New

2. Internal Controls Program (FMFIA)- Modified Repeat

3. Financial System and Reporting- Modified Repeat

4. Trust Obligations and Liability Model- Repeat

93
AmeriCorpsOIG.gov 

Hotline@AmeriCorpsOIG.gov

Hotline: 800-452-8210

AmeriCorps

Office of Inspector General

250 E St., SW, Suite 4100

Washington, DC 20525

• CLA considered AmeriCorps’ compliance with certain provisions of laws, regulations, 

contracts, and grant agreements, noncompliance with which could have a direct effect on 

the determination of material financial statement amounts and disclosures. However, CLA 

was not able to perform the applicable tests of AmeriCorps’ compliance due to the scope 

limitation and inability to obtain sufficient appropriate audit evidence to allow them to 

express an opinion on the financial statement.

Had CLA been able to obtain sufficient appropriate audit evidence to express an opinion on the 

Trust financial statements, other material weaknesses or significant deficiencies, or instances of 

noncompliance or other matters may have been identified and reported.

In connection with the contract, we reviewed CLA’s report and related documentation and 

inquired of its representatives. Our review, as differentiated from an audit of the financial 

statements in accordance with the United States generally accepted government auditing 

standards, was not intended to enable us to express, and we do not express, an opinion on the 

Trust financial statements.

CLA is responsible for the attached independent auditors’ report, dated November 12, 2021, 

and the conclusions expressed therein. However, our review disclosed no instances where CLA 

did not comply, in all material respects, with the United States generally accepted government 

auditing standards.

cc: Jenny Mauk, Chief of Staff 

Gina Cross, Chief Operating Officer

Malena Brookshire, Chief Financial Officer

Pape Cissé, Chief Information Officer

Fernando Laguarda, General Counsel

Jill Graham, Chief Risk Officer

Rachel Turner, Audits and Investigations Program Manager

Mia Leswing, Principal, CliftonLarsonAllen LLP

94
CliftonLarsonAllen LLP

CLAconnect.com

CLA is an independent member of Nexia International, a leading, global network of independent 

accounting and consulting firms. See nexia.com/member-firm-disclaimer for details.

1

INDEPENDENT AUDITORS’ REPORT

To the Acting Chief Executive Officer and Inspector General of

AmeriCorps

Report on the Financial Statement

We were engaged by the AmeriCorps Office of Inspector General (OIG) to audit the 

accompanying AmeriCorps National Service Trust Fund (Trust) financial statement, which 

comprise the balance sheet as of September 30, 2021; the related statements of net cost,

changes in net position, and the combined statement of budgetary resources for the fiscal year 

then ended, and the related notes to the financial statement (referred to herein as financial 

statement).

Management’s Responsibility 

AmeriCorps management is responsible for the preparation and fair presentation of the financial 

statement in accordance with accounting principles generally accepted in the United States of 

America (U.S.); this includes the design, implementation, and maintenance of internal control 

relevant to the preparation and fair presentation of financial statement that isfree from material 

misstatement, whether due to fraud or error.

Auditors’ Responsibility

Our responsibility is to express an opinion on the financial statement based on conducting the

audit in accordance with U.S. generally accepted auditing standards; the standards applicable to 

financial audits contained in Government Auditing Standards, issued by the Comptroller General 

of the U.S.; and Office of Management and Budget (OMB) Bulletin No. 21-04, Audit Requirements 

for Federal Financial Statements (OMB Bulletin 21-04). Because of the matters described in the 

Basis for Disclaimer of Opinion below, we were not able to obtain sufficient appropriate audit 

evidence to provide a basis for an audit opinion.

Basis for Disclaimer of Opinion

AmeriCorps requested that Trust Service Award Liability and related accounts in the financial 

statement be excluded from the FY 2021 financial statement audit and further stated that Trust 

Obligation and Liabilities would not be available for audit until after the close of the third quarter. 

These scope limitations were material to AmeriCorps’ financial statement. In addition,

AmeriCorps was unable to provide sufficient appropriate evidence on a significant number of 

transactions and account balances due to inadequate processes and controls to support 

transactions and estimates, and the ongoing remediation efforts of prior year findings.

Disclaimer of Opinion 

Because of the significance of the matters described in the preceding paragraph, we were not 

able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion. 

Accordingly, we do not express an opinion on the fiscal year 2021 financial statement.

95
INDEPENDENT AUDITORS’ REPORT (Continued)

2

Other Matter

Following discussions with the Office of Management and Budget (OMB) and Congressional 

stakeholders, AmeriCorps and the OIG agreed to forgo the audit of AmeriCorps’ FY 2020 Trust 

financial statements. Forgoing the audit was intended to allow AmeriCorps to complete the 

actions necessary to prepare for the transition of its financial management services to a shared 

services provider in FY 2021. AmeriCorps acknowledged that, if its FY 2020 Trust financial 

statements were audited, the results would be the same as those in FY 2019; a disclaimer of 

opinion, three material weaknesses and substantially the same unimplemented 

recommendations. In FY 2020, AmeriCorps predicted that the move to shared services would 

resolve many of the material weaknesses identified in the FY 2019 Trust financial statement audit 

and before. 

Report on Internal Control over Financial Reporting (Internal Control)

In connection with our engagement to audit AmeriCorps FY 2021 Trust financial statement, we 

considered AmeriCorps’ internal control over financial reporting to determine the audit 

procedures that were appropriate in the circumstances for the purpose of expressing our opinion 

on the financial statement, but not for the purpose of expressing an opinion on the effectiveness 

of AmeriCorps’ internal control. Accordingly, we do not express an opinion on the effectiveness 

of AmeriCorps’ internal control. We did not test all internal controls relevant to operating 

objectives as broadly defined by the Federal Managers’ Financial Integrity Act of 1982 (FMFIA)

nor did we test internal control on the financial statement line items and related processes that 

were excluded by AmeriCorps management from the scope of our audit.

Our consideration of internal control was for the limited purpose described in the preceding 

paragraph and was not designed to identify all deficiencies in internal control that might be 

material weaknesses or significant deficiencies; therefore, material weaknesses or significant 

deficiencies may exist that have not been identified. However, as described Exhibits A and B, we 

identified certain deficiencies in internal control that we consider to be material weaknesses and 

significant deficiency.

A deficiency in internal control exists when the design or operation of a control does not allow 

management or employees, in the normal course of performing their assigned functions, to 

prevent, or detect and correct, misstatements on a timely basis. A material weakness is a 

deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable 

possibility that a material misstatement of the financial statement will not be prevented or 

detected and corrected on a timely basis. We consider the deficiencies in the areas below and

described in Exhibit A to be material weaknesses. 

1. Migration to Shared Service (New)

2. Internal Controls Program (FMFIA)- (Modified Repeat)

3. Financial System and Reporting (Modified Repeat)

96
INDEPENDENT AUDITORS’ REPORT (Continued)

3

Further, the scope limitations requested by AmeriCorps prevented us from performing audit 

procedures related to the previous Trust Obligations and Liability Model material weakness1 and 

the Single Audit Act compliance. Accordingly, we continue to report the material weakness and 

noncompliance item and related recommendations as unimplemented. See Status of Prior Year

Recommendations in Exhibit C.

A significant deficiency is a deficiency, or combination of deficiencies, in internal control that is 

less severe than a material weakness, yet important enough to merit attention by those charged 

with governance. We consider the deficiencies in the Information Technology Security Controls

(Modified Repeat) described in Exhibit B to be a significant deficiency.

Had we been able to obtain sufficient appropriate audit evidence to express an opinion on the 

financial statement, other material weaknesses or significant deficiencies may have been 

identified and reported herein. 

Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements and Other 

Matters (Compliance)

In connection with our engagement to audit AmeriCorps’ FY 2021 Trust financial statement, we 

considered AmeriCorps’ compliance with certain provisions of laws, regulations, contracts, and 

grant agreements, noncompliance with which could have a direct effect on the determination of 

material financial statement amounts and disclosures. However, providing an opinion on 

compliance with those provisions was not an objective of our audit, and accordingly, we do not 

express such an opinion.

We were not able to perform the applicable tests of AmeriCorps’ compliance due to the 

aforementioned scope limitation and inability to obtain sufficient appropriate audit evidence to 

enable us to express an opinion on the financial statement. 

Management’s Responsibility for Internal Control and Compliance

AmeriCorps management is responsible for (1) maintaining effective internal control over 

financial reporting, including the design, implementation, and maintenance of internal control 

relevant to the preparation and fair presentation of financial statement that are free from 

material misstatements, whether due to fraud or error, (2) providing a statement of assurance 

on the overall effectiveness on internal control over financial reporting, and (3) complying with 

laws, regulations, contracts, and grant agreements applicable to AmeriCorps.

Purpose of the Report on Internal Control and Report on Compliance 

The purpose of the Report on Internal Control and on Compliance is solely to describe the scope 

of our testing of internal control and compliance and the result of that testing, and not to provide 

1 CNCS OIG Report 20-01, Audit of the Corporation for National and Community Service’s Fiscal Year 2019 Consolidated Financial 

Statements, issued November 20, 2019. Although AmeriCorps did not undergo an audit of its financial statements in FY 2020, 

the agency acknowledged in its FY 2020 Annual Management Report that, if such an audit had been conducted, the results would 

have been the same as in FY 2019. 

97
INDEPENDENT AUDITORS’ REPORT (Continued)

4

an opinion on the effectiveness of AmeriCorps’ internal control or compliance. These reports are 

an integral part of an audit performed in accordance with Government Auditing Standards in 

considering AmeriCorps’ internal control and compliance. Accordingly, these reports are not 

suitable for any other purpose.

AmeriCorps’ Response to Audit Findings and Recommendations

AmeriCorps did not express concurrence or nonoccurrence to our findings and 

recommendations. AmeriCorps’ comments can be found in Exhibit D. AmeriCorps’ response was 

not subjected to the auditing procedures applied in the audit of the financial statement and, 

accordingly, we express no opinion on it.

CLIFTONLARSONALLEN LLP

Arlington, Virginia

November 12, 2021

98
EXHIBIT A

Material Weaknesses

FY 2021

5

1. Migration to Shared Service (New finding) 

AmeriCorps’ transition to a shared service platform offered by the Administrative Resource 

Center (ARC) within the U.S. Treasury Departments’ Bureau of Fiscal Services (BFS), effective on 

October 1, 2020, created new challenges that affected AmeriCorps’ ability to produce complete, 

adequate, and reliable financial information. The pre-migration general ledger account clean-up 

process spilled over into FY 2021 and was not complete as of the end of this year’s audit 

fieldwork.

Also, AmeriCorps was not able to convert all of the transactions originally recorded in its 

Momentum legacy system to the reporting required by ARC’s financial system, Oracle. Despite 

the migration to shared services, AmeriCorps elected to continue to conduct critical financial 

transactions relating to its core business in Momentum. Also, because Momentum is not 

configured to report object class codes2in accordance with Federal requirements, manual 

adjustments must be used to correct the issue after AmeriCorps reports this information from 

Momentum to ARC’s Oracle financial system. That results in additional work and delays and 

introduces human error into the reporting process. In addition, there were misclassification 

issues caused by mapping inconsistencies in the program and fund structures within the two 

accounting systems. In most of these instances, AmeriCorps had to rely on post-conversion 

manual entries to temporarily fix the issues and meet financial reporting requirements. Total 

absolute values of manual entries significantly increase from $4 billion (rounded) in FY 2019, to 

$7 billion (rounded) in FY 2020, to $13 billion (rounded) in FY 2021.

AmeriCorps was not prepared for the magnitude of the work required to ensure a successful 

conversion, because it did not conduct an effective or realistic risk assessment or planning to 

ensure that the conversion issues would not impede operations unduly. The agency did not have

a plan to address unexpected issues prior to the actual conversion. AmeriCorps underestimated 

the level of resources needed for the conversion to proceed smoothly and completely and 

therefore under-resourced the effort, leading to ongoing financial accounting, reporting, and 

operation issues.

The Government Accountability Office’s (GAO) Standard for Internal Control in the Federal 

Government (Green Book) states that changes in conditions affecting the entity and its 

environment often require changes to the entity’s internal control system, as existing controls 

may not be effective for meeting objectives or addressing risks under changed conditions. 

Management should analyze the effect of identified changes on the internal control system and 

respond by revising the internal control system on a timely basis, when necessary, to maintain 

its effectiveness.3

2 Object classes are categorized in a classification system that present obligations by the items or services purchased by the Federal 

Government.

3 https://www.gao.gov/assets/gao-14-704g.pdf page 43, 9.04

99
EXHIBIT A

Material Weaknesses

FY 2021

6

Further, changing conditions often prompt new risks or changes to existing risks that need to be 

assessed. As part of analyzing and responding to change, management performs a risk 

assessment to identify, analyze, and respond to any new risks prompted by the changes. 

Additionally, existing risks may require further assessment to determine whether the defined risk 

tolerances and risk responses need to be revised.

4

We recommend that AmeriCorps:

1. Perform a risk assessment over the current state of the conversion to ARC and work jointly 

with ARC, senior leadership, Office of Chief Risk Officer, and functional groups affected by 

the risk to develop a mitigation strategy and execute a realistic and properly designed 

corrective action plan. (New)

2. Fix incorrect outstanding balances and missing data resulting from financial system 

configuration issues and ensure future interfaces with Oracle do not have the same 

issues. (Modified Repeat)

3. Continue coordinating with ARC to ensure that its accounting platform is compatible with 

AmeriCorps’ operations and the type of accounting transactions that AmeriCorps 

processes. (Modified Repeat)

4. Conduct a review of transactions processed in Momentum and already migrated to Oracle

through interface or reported in Oracle using journal entries, to ensure that correct object 

class codes were applied. (New)

2. Internal Controls Program (FMFIA) (modified repeat finding)

An effective system of internal control is necessary to provide reasonable assurance that a 

Federal entity conducts its programmatic activities effectively and efficiently, has a reliable 

financial reporting system and complies with applicable laws and regulations5. Without a fully 

functional internal controls program, AmeriCorps might not meet itsfinancial, programmatic and 

compliance objectives. Establishing internal controls that meet Federal standards is a core 

responsibility of the management of a Federal agency, as required by the Federal Managers 

Financial Integrity Act of 1982 (FMFIA), OMB Circular No. A-123 and the GAO’s Standards for 

Internal Control in the Federal Government.

AmeriCorps’ internal control program remains ineffective, despite some areas of improvement. 

We note, for example, that the agency now has a formal, documented process for collecting and 

providing the Chief of Executive Officer (CEO) with comprehensive information to consider in 

deciding the level of assurance and substantive content of the required Annual Management 

4 https://www.gao.gov/assets/gao-14-704g.pdf, page 43, 9.05

5 OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, Policy section.

100
EXHIBIT A

Material Weaknesses

FY 2021

7

Report (AMR) statement concerning the effectiveness of internal control. In the AMR for FY 2021,

AmeriCorps’ CEO acknowledges the continuing deficiencies and provided a statement of no 

assurance as to effectiveness of internal control over financial reporting, operations, including of 

the agency’s grant programs, and compliance.

AmeriCorps has made little progress at correcting the pervasive problems that have left the 

agency unable to obtain an opinion on its financial statements since FY 2017. All three material 

weaknesses that we identified in the Trust financial statement audit report were first reported in 

FY 2017. Only seven of the 37 recommendations from FY 2019 have been implemented. In most 

areas, AmeriCorps has not even developed meaningful corrective action plans (CAPs) to address 

the identified material weaknesses and significant deficiency. Until AmeriCorps can create and 

implement focus and well-resourced CAPs, it cannot expect to resolve these longstanding 

problems. To date, only the Office of the Chief Risk Officer (OCRO) has consistently developed 

and implemented effective CAPs, which has contributed to that office’s track record of closing 

recommendations.

Below are some of the new and recurring deficiencies that we identified in the internal control 

program:

• The OIG’s FY 2020 limited performance audit of AmeriCorps’ internal control program6

identified deficiencies such as (a) the omission of risk factors from the risk assessment 

process, (b) lack of documentation to support the conclusions reached on entity level 

assessments, (c) unexplained inconsistencies between risk assessments by the functional 

offices and independent validations conducted by OCRO, (d) missing, incomplete, or 

inadequate documentation to support the internal control assessment, (e) untimely 

review of key underlying documents, and (f) incomplete assessment of test of design and 

test of effectiveness, as well as sampling errors. There were eight recommendations of 

which AmeriCorps is continuing to address or complete implementation of corrective 

actions.

• The directors of the functional offices participating in the entity-level control assessment 

continue to lack a full understanding of internal control principles and how they relate to 

their respective operations. In addition, they did not consider the significant changes in 

FY 2021 and outstanding audit recommendations when assessing the entity-level 

controls.

• AmeriCorps conducts its entity-level internal control assessment according to GAO’s 17 

principles in the Standard for Internal Control in the Federal Government. In FY 2021, 

AmeriCorps rated two of them as low risk and 12 as moderate risk. Those decisions are 

difficult to reconcile with the identified material weaknesses and the obvious risks flowing 

6 AmeriCorps OIG Report Number OIG-AR-21-02 Performance Audit of AmeriCorps’ FY 2020 Internal Control Program 

and National Service Trust Liability Model

101
EXHIBIT A

Material Weaknesses

FY 2021

8

from the ongoing issues related to the migration to shared services. We found that 

certain of the risk ratings were not based on adequate information, were not fully 

supported by the assessment documentation or were inconsistent with the results of our 

audit. 

• AmeriCorps failed to obtain subsidiary statements of assurance and internal control 

assessments from the Accounting and Financial Management (AFMS), Office of 

Procurement Services, and Office of Budget and other function units. These critical 

components were not asked to provide assurance as to the effectiveness of internal 

control in their respective areas.

• OCRO’s internal control assessment and testing did not identify ongoing issues arising 

from the transition to shared services as a material weakness, despite their significant 

impact on the financial operations in FY 2021. 

• OCRO downgraded financial reporting and procurement management from material 

weaknesses in FY 2019 to significant deficiencies in FY 2021, without apparent

justification. The downgrade is not consistent with AmeriCorps’ acknowledged inability 

to remedy the material weaknesses from prior audits.

• OCRO is still in the process of developing a risk register that records identified risks at the 

mission and business process level, or Tier 2, as defined by the National Institute of 

Standards and Technology. 

We recommend that AmeriCorps:

5. For each material weakness and significant deficiency, develop an appropriate and 

actionable corrective plan (CAP) that specifies the interim steps for long-term CAPs, 

milestones and target completion dates, person(s) responsible for executing the 

corrective action and the resources available to assist, sufficient and appropriate 

documentation required, and quality review and approval process. (New)

6. Develop a process to explain the discrepancies between material weaknesses reported 

on the CEO Statement of Assurance and those identified by the external auditors, and 

document the explanation, as well as the basis for classifying internal control findings as 

either material weakness or significant deficiency. (New)

7. Establish controls and training to ensure that each functional office/unit performs 

independent assessment of internal controls to inform the CEO’s statement of assurance, 

even if unfavorable outcomes are expected. This proactive approach will promote the 

early detection of potential findings and allow for prompt remediation. (New)

102
EXHIBIT A

Material Weaknesses

FY 2021

9

3. Financial System and Reporting (modified repeat finding)

AmeriCorps’ financial reporting process and the internal control over it remains inadequate to 

ensure accuracy in the preparation and quality control of financial statements. While AmeriCorps 

predicted that migration to ARC would resolve the majority of its unimplemented 

recommendations, it has not realized these results, in part because the pervasive deficiencies in 

AmeriCorps’ Momentum financial system have carried over into ARC. AmeriCorps continued to 

experience lingering effects of Momentum throughout FY 2021. These are essentially the same 

weaknesses and system limitations that prevented AmeriCorps from issuing auditable financial 

statements for the last five years. AmeriCorps continued to rely on temporary manual 

adjustments to address these pervasive longstanding issues in FY 2021.

Our audit procedures found that the following conditions continue to exist, despite the migration 

to shared services:

A. Financial Statemen Audit Scope Limitation

B. Inability to produce quality, reliable, and complete financial information in a timely 

manner

C. Inadequate internal controls in preparing and reviewing financial reports 

D. Improper design of internal control over the use of journal entries (JEs)

OMB Circular No. A-123 requires agency management to establish and maintain internal controls 

to achieve the objectives of effective and efficient operations, reliable financial reporting, and 

compliance with applicable laws and regulations.

A. Financial Statement Audit Scope Limitation 

Despite a one-year grace period with no financial statement audit in FY 2020 and the shift to 

shared services at the beginning of FY 2021, AmeriCorps was unprepared for a full scope audit in 

FY 2021. The lack of progress in addressing the prior year (PY) internal control material 

weaknesses led AmeriCorps to acknowledge their continued noncompliance with Single Audit 

and also requested that the audit exclude the following material financial statement lines and 

significant processes, noting that audit of these areas would likely yield the same or similar results

in FY 2019:

• Grants Single Audit Compliance 

• Trust Obligation and Liabilities – Validation of the data to the Trust Obligation Liability 

Model (TOLM, Trust liability)

Additionally, AmeriCorps advised that it would not be able to implement planned changes that 

would affect their calculation of the Trust Obligation and Liabilities, a material financial statement 

line, until reporting results of the third quarter of FY 2021. As a result, this line was only available 

103
EXHIBIT A

Material Weaknesses

FY 2021

10

for audit until after preparation of the June 30, 2021 interim financial statements and the receipt 

of all required audit documentation. The time limitation imposed by AmeriCorps left us unable 

to conclude our work on the Trust Obligation and Liabilities.

We recommend that AmeriCorps:

8. Develop a strategic plan and corrective actions that will include steps and milestones to 

eventually achieve an audit opinion on AmeriCorps’ financial statement. The plan should 

align directly with and describe in detail the implementation plans, specific steps to be 

taken, resources to be devoted to implementation, responsible personnel and their 

assigned duties, clear accountability, project management and target dates to complete. 

It should also include a quality assurance plan to verify effective and timely 

implementation. (New)

B. Inability to produce quality, reliable, and complete financial information timely

Throughout FY 2021, AmeriCorps continues to struggle in preparing, reviewing, and providing 

accounting information and documentation for audit. Although we set forth a clear schedule 

without objection at the beginning of the audit and conducted regular status meetings, 

AmeriCorps frequently responded long after the requested due date, months late in some cases. 

Also, AmeriCorps didn’t have defined roles and responsibilities for providing information and 

documents requested by the auditors. Often, the documentation provided had not undergone 

quality review to ensure that the information was without errors, complete, and responsive to 

the request. The lack of quality control and timely response caused delays and wasted effort. 

Ultimately, AmeriCorps’ inability to provide timely, complete, and high-quality audit schedules 

and documents, including incomplete populations for sampling, interfered with our ability to 

evaluate and test financial information.

We recommend that AmeriCorps:

9. Develop and implement audit readiness procedures to ensure that audit information is 

complete, accurate, has undergone proper quality control procedures, and readily 

available or can be retrieved timely. The audit readiness procedures should include audit 

coordination protocol with ARC that clearly define roles and responsibilities of all parties 

involved in the process. (New)

C. Inadequate internal controls over preparing and reviewing financial reports 

AmeriCorps’ internal control over preparing and reviewing financial reports was inadequate.

Examples of the inadequacies were as follows: 

• AmeriCorps did not properly research, follow up and effectively document explanations 

for account balance differences. The agency’s monthly trial balance review was 

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EXHIBIT A

Material Weaknesses

FY 2021

11

incomplete and ineffective. The budgetary-to-proprietary analysis (tie point) performed 

was incomplete; because AmeriCorps did not follow up to explain or reconcile significant 

variances. The purpose of the high-level tie point analysis is to detect anomalies in 

balances and correct them or provide fact-specific explanations for the discrepancies. 

Instead, AmeriCorps continued to provide generic explanations that do not address the 

root cause of the differences. Without a root cause analysis, AmeriCorps may not be able 

to correct the problem, which will recur. The lack of a rigorous process may cause 

AmeriCorps to overlook substantial but correctible financial management errors.

• We identified uncorrected misstatements on the financial statements; abnormal 

balances; and incomplete financial statement and notes as part of our audit of the June 

30, 2021, (interim) financial statement. Other examples of issues identified were 

reconciliation differences between AmeriCorps internal trial balance and the U.S. 

Treasury’s Governmentwide Treasury Account Symbol Trial Balance (GTAS), which were

caused by untimely recording of accounting transactions and failure to remove cancelled 

funds activity in its trial balance.

• AmeriCorps did not perform a complete and reliable fluctuation analysis of the June 30, 

2021, account balances. The explanations provided for significant balance fluctuations 

were generic and did not address the specific nature of the transactions or the change in 

operations or trends that would identify the root causes of the fluctuations. AmeriCorps 

did not document its expectations based on its operating environment and compare 

those expectations to the identified significant balance fluctuations for reasonableness or 

unexpected change. 

We recommend that AmeriCorps:

10. Develop comprehensive policies and procedures to document its financial statement 

preparation process. The policies and procedures should clearly delineate responsibilities 

among various members of the Accounting and Financial Management Service (AFMS) 

group and team leads and those performed by AmeriCorps’ shared service provider, 

clarifying the responsibility of AmeriCorps for the accuracy of the reported information. 

The policies and procedures should address the following aspects: (Modified Repeat)

a. The process to determine and document AmeriCorps’ balance fluctuation 

expectations based on a combination of internal and external operating factors, 

and program and financial relevant information available. 

b. Detailed process to research signification balance fluctuations. AmeriCorps 

should research and explain all significant balance fluctuations at the account and 

transaction level. Maintain and have the supporting documentation readily 

available. 

c. Research and retain supporting documents required for any identified account 

balance differences derived from its abnormal balance review or the tie point 

analysis. 

105
EXHIBIT A

Material Weaknesses

FY 2021

12

d. Address fatal and non-fatal Government-wide Treasury Account Symbol edit 

failures prior to GTAS certification. 

e. Document resolution for all balance differences and retain supporting 

documentation of related research.

These open repeat recommendations can be found in Exhibit C, Status of Prior Year 

Recommendations, for open repeat recommendations.

D. Improper design of internal control over the use Journal Entries (JE)

Journal entries are both recuring and non-recuring manual on top adjustments used to record, 

usually large, transactions into the financial system. They are used to fix errors, reclassify 

balances, or record amounts that were not reported dur to timing and period cut-offs in the 

financial systems. However, they do not go through the established system of controls designed 

to record normal recurring transactions, and thus reliance on JEs increase AmeriCorps’ 

susceptibility to errors and misstatement in the financial statements. As of June 30, 2021, 

AmeriCorps used JEs to record approximately $12.6 billion in absolute value transactions, a 

significant increase from the prior year. AmeriCorps over relied on the JEs to fix issues that 

initially existed in the Momentum environment that were not remediated prior to conversion to 

Oracle.

Also, AmeriCorps used JEs to address significant recurring financial reporting issues across 

multiple funds, instead of addressing the underlying root causes. 

We also identified other control deficiencies such as duplication in the use of JEs, missing 

document numbers, and lack of documentation explaining the need for or root cause for the 

adjustment and approval. Further, there was no evidence of proper segregation of duties,

reconciliation issues between JE detail and JE log, and instances in which AmeriCorps and ARC 

approved and processed JEs with incorrect general ledger account, requiring another JE to 

correct the error. The over-reliance, incorrect usage, and inaccurate JEs create a high risk of 

material misstatements in the financial statement.

We recommend that AmeriCorps:

11. Continue working with Administrative Resource Center to review and correct AmeriCorps’ 

balances in detail to ensure they are properly supported and that balances migrated to 

the ARC platform are complete, accurate, and reliable. (Modified Repeat)

12. Strengthen its policies and procedures over the processing of JEs going forward now that

AmeriCorps has transitioned to the shared service environment. The policies and 

procedures should cover the following: 

a. A process to track the sequence of JE transactions for completeness.

106
EXHIBIT A

Material Weaknesses

FY 2021

13

b. A policy as to when it is appropriate to use a JE and approval procedures for JEs 

recorded to ensure segregation of duties.

c. A requirement to provide a fact-specific description of the purpose of the JE, along 

with adequate supporting documentation.

d. Documentation needed to support JEs and how it will be maintained. (Modified 

Repeat)

13. Validate and ensure JEs are properly supported, documented, and are readily available 

for examination. (Modified Repeat)

Additional open repeat recommendations from the FY 2019 audit report can be found in

Exhibit C, Status of Prior Year Recommendations. 

We also continue to report the Trust Obligations and Liability Model as a material weakness and

the related unimplemented recommendations are listed in Exhibit C

107
EXHIBIT B

Significant Deficiency

FY 2021

14

Information Technology Security Controls (modified repeat finding)

AmeriCorps relies extensively on information technology (IT) systems to initiate, authorize,

record, process, summarize and report financial transactions in the preparation of its financial 

statement. Internal controls over these financial and supporting operations are essential to

ensure the integrity, confidentiality, and reliability of critical data while reducing the risk of

errors, fraud, and other illegal acts.

To balance high levels of service and reduce costs, AmeriCorps’ Office of Information Technology 

has outsourced the operation, maintenance, and support of most of its IT systems. AmeriCorps 

outsourced its financial operations to a shared service provider for the first time this fiscal year. 

The new financial system of record interfaces with Momentum for the purpose of retrieving 

grants management data from eSPAN. Outsourcing introduces special considerations and risks

regarding the protection of information and information systems. Despite the outsourcing of IT 

systems, AmeriCorps by law retains responsibility for complying with the requirements of the 

security control implementation.

Our review of IT controls covered general and application controls at the AmeriCorps 

Washington, D.C. Headquarters. Our current year audit identified security control weaknesses 

that were corrected for certain control activities. Examples of AmeriCorps’ improvements in its 

IT control environment include conducting background investigations and reinvestigations of 

current employees and enhancing physical access controls to safeguard personally identifiable 

information.

While AmeriCorps has taken some steps to remediate previously identified information security

controlweaknesses, AmeriCorps continues to face challenges in the consistent implementation 

of its information security program and monitoring of security controls. In addition, we identified

new and continued control weaknesses in the information security program that need to be

addressed, most importantly pertaining to configuration management controls, including 

vulnerability management, access controls, and organization-wide risk management. 

Specifically, we identified enterprise findings for each of the following domains:

Configuration Management

• AmeriCorps did not resolve critical and high-risk vulnerabilities within the timeframes 

specified by its internal operating policies. As a result, vulnerabilities related to patch 

management, configuration management, and unsupported software continue to expose 

AmeriCorps’ network to critical and high severity vulnerabilities. While our independent 

vulnerability scans indicated that the number of vulnerabilities has decreased since last year, 

issues remain with applying older patches and remediating older configuration weaknesses. 

(Modified Repeat)

• AmeriCorps did not develop baseline configuration documentation for all platforms in its 

108
EXHIBIT B

Significant Deficiency

FY 2021

15

environment and ensure that these standard baseline configurations are appropriately 

implemented, tested, and monitored for compliance with established security standards. 

(Modified Repeat)

• The tracking of IT components in the asset inventory was incomplete, and software 

assurance controls have not been fully implemented for mobile devices due to delays in 

implementing a new mobile device management tool. (Modified Repeat)

• Change management documentation was not consistently recorded for system changes 

made to the General Support System (GSS), Electronic-Systems for Program Agreements and

National Service Participants (eSPAN), and Momentum applications. (New)

Access Control

• AmeriCorps did not adequately manage user accounts and/or passwords for the network 

and the Momentum application. For example, AmeriCorps did not disable all network and 

Momentum accounts of separated employees, did not disable inactive privileged accounts, 

and did not properly manage passwords that were not changed after a designated 

timeframe as specified in AmeriCorps’ policies. (Modified Repeat)

• In March 2020, AmeriCorps removed mandatory enforcement of Personal Identity 

Verification (PIV) multifactor authentication7in response to the COVID-19 pandemic and has 

not reinstated the control. Agency management attributes this to the need for full-time 

telework during the COVID-19 pandemic. However, this conflicts with government-wide 

guidance issued by the Cybersecurity and Infrastructure Security Agency (CISA) directing 

agencies to use multifactor authentication during pandemic-related telework. (Modified 

Repeat)

• AmeriCorps did not conduct an annual incident response test as required by AmeriCorps 

policy. (New)

In addition, prior weaknesses related to access controls at AmeriCorps’ field offices have not 

been remediated.

Security Management

• AmeriCorps did not develop, document, and communicate an overall Supply Chain Risk 

Management strategy, implementation plan, and related policies and procedures to guide 

and govern supply chain risk management activities. (New)

• AmeriCorps did not maintain an Interconnection Security Agreement between AmeriCorps 

and Social Security Administration. (New)

7 Multifactor authentication requires two or more credentials when logging on to information systems. Credentials include 

something an individual knows, such as a password, and something an individual possess, such as a PIV card or fingerprint.

109
EXHIBIT B

Significant Deficiency

FY 2021

16

• AmeriCorps did not complete a risk register to record identified risks at the mission and 

business process level, as defined by the National Institute of Standards and Technology.

8

(Repeat)

• AmeriCorps did not ensure individuals with access to personal identifiable information (PII) 

completed annual privacy-role based training. (Repeat)

Contingency Planning

• AmeriCorps did not conduct an annual disaster recovery test and train its disaster recovery 

personnel for the GSS and eSPAN as required by AmeriCorps policy. (New)

Many of these weaknesses can be attributed to inconsistent enforcement of the agency-wide 

information security program across the enterprise. These deficiencies can increase the risk of 

unauthorized access to AmeriCorps’ systems used to capture, process, and report financial 

transactions and balances. Effective system security begins with strong governance, including 

agency-level oversight and controls monitoring of AmeriCorps field offices. This includes 

ensuring accountability within the Office of Information Technology leadership for 

accomplishing milestones and achieving measurable results in support of a strategy to achieve 

an effective level of information security at AmeriCorps.

Further, the Federal Information Security Management Act (FISMA) legislation requires each 

agency to have a Chief Information Security Officer (CISO), whose principal duty is cybersecurity. 

However, AmeriCorps allowed this position to remain vacant from October 2020 to June 2021, 

with an acting official in the role. Given the agency’s weaknesses in key information security 

controls and the importance of this function, the lack of a permanent CISO, with the ability to 

advise the agency head on key issues of cybersecurity policy, enforcement and needed 

improvements, detracted from the opportunity to make progress.

By not effectively implementing and enforcing IT policies and procedures and working towards

automation, continuous monitoring and consistent application of controls, there is an increased

risk that financial information and PII may be inadvertently or deliberately misused and may 

result in improper disclosure or theft without detection. Without remediatingall significant 

security vulnerabilities, systems could be compromised resulting in potential harm to 

confidentiality, integrity, and availability of AmeriCorps’ financial and sensitive data.

8 NIST Special Publication 800-39, Revision 1, Managing Information Security Risk Organization, Mission, and Information System 

View, specifies an integrated risk management process three-tiered approach for managing risk across an organization that 

“addresses risk at the: (i) organization level; (ii) mission/business process level; and (iii) information system level. The risk 

management process is carried out seamlessly across the three tiers with the overall objective of continuous improvement in 

the organization’s risk-related activities and effective inter-tier and intra-tier communication among all stakeholders having a 

shared interest in the mission/business success of the organization.”

110
EXHIBIT B

Significant Deficiency

FY 2021

17

We recommend that AmeriCorps:

Since AmeriCorps has not implemented consistent automated processes to address continued 

control weaknesses in its information security program, we reiterate the same prior year’s 

recommendations to assist AmeriCorps in holding individual stakeholders accountable for 

remediation of control weaknesses and ensuring information technology security controls 

operate as intended agency wide. The recommendations for these conditions can be found in 

Exhibit C, Status of Prior Year Recommendations.

111
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

18

AmeriCorps’ latest full scope Trust financial statement audit was in fiscal year 2019. As there was no Trust financial statement audit conducted 

in FY 2020, we are presenting the status of FY 2019 recommendations in FY 2021. As the scope of audit in FY 2021 was limited, many of the 

FY 2019 recommendations were still open in FY 2021. These open recommendations were not duplicated as recommendations in the report 

on internal control and report on compliance (reports). The modified repeat recommendations in FY 2021 were recommendations from

FY 2019 but were adapted to the FY 2021 results. The summary of the status of the FY 2019 Trust financial statement audit recommendations 

in FY 2021 is in Table 1. The detail of each recommendation is presented in Table 2. 

Table 1: Summary of the Status of FY 2019 Trust Financial Statement Audit Recommendations in FY 2021

Status in FY 2021

Count of 

Recommendations 

in FY 2019

FY19 Audit Trust Report 

Recommendation Number

Recommendation Closed 7 1, 3, 4, 5, 6, 18, 19

Open and Modified Repeat Recommendations 30

Total: 37

112
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

19

Table 2: Status in FY 2021 and Detail Description of Each Recommendation from FY 2019 Financial Statement Audit

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

Material 

Weakness 

(MW)

Internal 

Control 

Program 

(FMFIA)

1 (1)

Establish a formal process that provides the CEO with comprehensive information on the results of 

AmeriCorps’ internal control assessment, status of open material weaknesses and significant 

deficiencies from prior year’s financial statement audits, and information on issues that could be 

reported as a significant deficiency or a material weakness in the current year’s financial statement 

audit for consideration in preparing the AmeriCorps assurance statement. This should also include 

the status of open recommendations from other audits that have a significant impact on AmeriCorps

operations or financial reporting. 

Closed

2 (2)

Provide training to AmeriCorps officials participating in the entity-level control assessment to ensure 

that they have a full understanding of the internal control principles and how these principles relate 

to their operations. The training shall also address how the outstanding audit recommendations 

concerning their operations should be considered when assessing the entity-level controls.

Repeat – Material 

Weakness (MW)

Open 

Recommendation

3 (3)

Revise the AmeriCorps Statement of Assurance Preparation and Submission Guidance (March 2019) 

to:

a. Require the functional offices to consider external and internal audits and investigations in 

identifying and reporting on control deficiencies.

b. Require the functional offices to identify the impact that the material weakness or significant 

deficiency has on the financial statements or on AmeriCorps’ operations in their assurance 

statements. 

Closed

4 (4)

Revise the AmeriCorps Financial Reporting Testing Plan to include verifying that the fluctuation 

analyses are conducted properly within the required thresholds. Closed

5 (6) Provide training to appropriate AmeriCorps personnel regarding the purpose of the Data Quality 

Plan. Closed

113
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

20

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

6 (7)

Update and maintain the Data Quality Plan in accordance with OMB Circular No. A-123, Appendix A, 

Management of Reporting and Data Integrity Risk (M-18-16, June 6, 2018), and subsequent 

amendments. 

Closed

7 (8)

Update AmeriCorps Standard Operating Procedure: Statement on Standards for Attestation 

Engagements (SSAE) 18 Report Review to explain how AmeriCorps will address the SSAE 18 audit 

reporting gaps for its external systems’ service providers and establish time requirement for 

conducting the SSAE 18 report reviews.

Repeat - MW

Open 

Recommendation

Material 

Weakness 

Financial 

System and 

Reporting

8 (9)

Establish a process to maintain executed agreements with Federal trading partners and track all 

associated costs against the inter-agency agreements from inception until the agreement close-out. 

This 

recommendation is 

not applicable to 

Trust but 

applicable to 

AmeriCorps 

Consolidated FS. 

Will consider 

closed for Trust 

recommendation. 

9 (10)

Develop comprehensive policies and procedures for the financial statements preparation process 

and related internal controls. The policies and procedures should address, among other subjects:

a. The process to determine and document AmeriCorps’ balance fluctuation expectations. 

Expectations should be documented based on a combination of internal and external operating 

factors, and program and financial relevant information available.

b. The materiality threshold used to determine significant balance fluctuations that require further 

research should be more conservative than that used by external auditors.

c. Detailed process to research significant balance fluctuations. AmeriCorps should research and 

explain all significant balance fluctuations at the account and transaction level. Maintain and have 

Modified Repeat -

MW

Recommendation

#10

114
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

21

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

the supporting documentation readily available.

d. Research and retain supporting documents required for any identified account balance differences 

derived from its abnormal balance review or the tie point analysis.

e. Address fatal and non-fatal Government-wide Treasury Account Symbol Trial Balance edit failures.

f. Address all balance differences and retain supporting documentation of related research.

g. Document and maintain support for all prior period adjustments and changes to Net Position 

accounts, Cumulative Result of Operations, and Unexpended Appropriations. 

10 (11)

Monitor outstanding balances resulting from financial system configuration issues and fix these 

issues prior to data migration to the future shared service provider (Department of Treasury’s 

Administrative Resource Center) in FY 2021. While waiting to transition, AmeriCorps should 

strengthen its current trial balance review including tie-point analysis and review of abnormal 

balances.

Modified Repeat –

MW

Recommendation 

#2

11 (12)

Coordinate with the future shared service provider to ensure that its accounting platform is 

compatible with AmeriCorps’ operations and the type of accounting transactions that the 

AmeriCorps process.

Modified Repeat -

MW

Recommendation 

#3

12 (13)

Develop a plan to clean up AmeriCorps’ balances prior to migration to the shared service provider’s 

system (Department of Treasury’s Administrative Resource Center). The plan should include 

coordination with the future service provider to review AmeriCorps’ balances in detail to ensure they 

are properly supported and can be mapped into the Administrative Resource Center’s platform.

Maintain all documentation regarding meeting minutes and any mapping of account balances 

developed as part of the migration effort.

Modified Repeat –

MW 

Recommendation 

#11

13 (14) Complete its efforts to be fully compliant with the Office of Management and Budget Circular No. A11, Preparing, Submitting, and Executing the Budget. 

Repeat – MW

Open 

Recommendation

115
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

22

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

14 (15) Provide mandatory training to AmeriCorps accounting staff on the proper use of object class, sub 

general ledger accounts, and document/transaction types on all obligation and expense transactions. 

Repeat – MW

Open 

Recommendation

15 (16) Validate and ensure Journal entries are properly supported, documented, and are readily available 

for examination.

Modified Repeat -

MW

Recommendation 

#13

16 (17) Strengthen coordination between Accounting and Financial Management Services and the Office of 

Budget to ensure that transactions are recorded accurately and timely.

Repeat - MW

Open 

Recommendation

17 (18)

Develop and implement policies and procedures for the Journal entries (JE) process that include:

a. Tracking the sequence of JEs for completeness;

b. Appropriate use of JEs;

c. Determining and maintaining relevant documentation to support each JEs;

d. Use of specific and accurate JE descriptions; and

e. Timely review and approval of JEs for accuracy and propriety. 

Modified Repeat –

MW

Recommendation

#12

18 (19)

Finalize its research to establish the amount to capitalize for tenant improvement costs and retain 

proper documentation of the research. While the research is ongoing, AmeriCorps should disclose 

non-GAAP accounting and the impact on the financial statements. 

Closed

19 (20)

Evaluate AmeriCorps’ compliance with all sections of OMB Circular No. A-136, Financial Reporting 

Requirements, including preparing comparative financial statements and notes to comply with the 

financial reporting framework for federal government agencies. 

Closed

116
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

23

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

Material 

Weakness

Trust 

Obligations 

and Liability 

Model

20 (21)

Complete the Trust Accounting Handbook to clearly reflect the assumptions used in the Trust 

Obligation and Liability Model and the Monthly Obligation and Liability Calculator, including 

establishing control activities; finalize materiality thresholds applied; update accounting transactions, 

and clearly identify periods when adjustments will be made regardless of materiality. 

Repeat – MW 

Open 

Recommendation

21 (22)

Develop for a more standardized, secure, and automated method to estimate the Trust obligations 

and Trust Service Award Liability that ensures minimal human errors. As part of the ongoing 

AmeriCorps’ transition to shared service, coordinate with the service provider to determine methods 

that would enhance the security and quality of the existing estimation models. 

Repeat – MW 

Open 

Recommendation

22 (23)

Strengthen controls to ensure the Trust modeling is performed by trained personnel to:

a. Conduct detailed analysis and validation of data sources.

b. Review and ensure the reasonableness of assumptions used and document the rationale behind 

estimation assumptions.

c. Consider changes in conditions or programs that require further research and analysis. Update the 

assumptions when necessary.

d. Compare estimates with subsequent results to assess the reliability of the assumptions and data 

used to develop estimates.

Repeat – MW 

Open 

Recommendation

23 (24)

Document and implement policies and procedures to include the following:

a. Establish a thorough and robust quality control process to ensure that the Trust Obligation and 

Liability Model (TOLM) and Monthly Obligation and Liability Calculator (Calculator) are reviewed by 

qualified AmeriCorps personnel prior to relying on its outputs to record transactions. All errors 

identified for which management ultimately decided against making updates to the TOLM or 

Calculator should be documented along with an explanation as to how management arrived at the 

final decision;

b. Perform monthly reviews and reconciliations of the recorded new and outstanding obligations to 

ensure the accounting information is valid and proper;

Repeat – MW

Open 

Recommendation

117
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

24

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

c. Review obligation amounts to ensure amounts accurately reflect the status of the obligation;

d. Review obligations to verify that amounts, timeframe (i.e., grant dates are correctly reflected in 

the obligation);

e. Ensure obligations are sufficiently supported (i.e., by documentary evidence); and

f. Perform complete reconciliations of all outstanding obligations monthly, and ensure any 

discrepancies identified are promptly researched and resolved. 

24 (25)

Coordinate with the Office of the Chief Risk Officer (OCRO) to properly identify the National Service 

Trust Fund’s financial reporting risks and incorporate those risks into the OCRO’s annual testing of 

key controls.

Repeat – MW 

Open 

Recommendation

25 (26)

Develop a succession plan to ensure the required expertise is available in anticipation of planned 

employee turnover, particularly with respect to the complex trust calculations. AmeriCorps needs to:

a. Train, mentor, and work to retain qualified employees;

b. Cross-train employees so that knowledge of the model will reside with multiple staff rather than 

with one person; and

c. Implement a peer review process to carry out the necessary quality control reviews of the Trust 

Obligation and Liability Model and the Monthly Obligation and Liability Calculator. (repeat)

Repeat – MW 

Open 

Recommendation

Significant 

Deficiency 

(SD)

IT Security 

Controls

26 (58)

Develop a multi-year strategy to better strategically prioritize and allocate resources to address the 

new and continuing weaknesses identified and work towards automation, continuous monitoring,

and consistent application of controls. 

Repeat - SD

Open 

Recommendation

27 (59)

Enforce the agency-wide information security program across the enterprise and improve 

performance monitoring to ensure controls are operating as intended at all facilities. 

Repeat - SD

Open 

Recommendation

28 (60)

Strengthen and refine the process for communicating AmeriCorps facility-specific control deficiencies 

to AmeriCorps facility personnel, and coordinate remediation of the control deficiencies. 

Repeat - SD

Open 

Recommendation

118
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

25

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

29 (61)

Strengthen and refine the process for holding system owners and information system security 

officers accountable for remediation of control deficiencies and ensuring that the appropriate 

security posture is maintained for AmeriCorps information systems. 

Repeat - SD

Open 

Recommendation

30 (62)

Strengthen and refine the process for holding contractors accountable for remediation of control 

deficiencies in AmeriCorps information systems. 

Repeat - SD

Open 

Recommendation

31 (63) Implement all detailed recommendations in the FY 2019 FISMA Evaluation report. 

Repeat - SD

Open 

Recommendation

NonCompliance 

Single Audit 

Compliance

32 (70)

Develop, implement, and document procedures to identify all AmeriCorps grantees that are required 

to submit single audit reports with their due dates. 

Repeat – NonCompliance 

Open 

Recommendation

33 (71)

Develop, implement, and document procedures on timely follow-up for those grantees whose audits 

have become past due, and to ascertain why report submission was late, when the audit report will 

be submitted to the Federal Audit Clearinghouse, and what corrective action has been taken to 

prevent a report submission delay in future. 

Repeat – NonCompliance 

Open 

Recommendation

34 (72)

Develop a practice to capture the single audit data to assess the effectiveness of the single audit 

report submission for all its grantees. 

Repeat – NonCompliance 

Open 

Recommendation

119
EXHIBIT C

Status of Prior Year Recommendations

FY 2021

26

FY19 Audit 

Report 

Finding

Area

FY19 Trust Audit 

Report Rec. 

Number (FY 19

Consolidated FS 

Report 

Recommendation 

Number)

Recommendation Description

Status of FY19 

Recommendations 

in FY21

35 (73)

Develop and implement and document procedures for implementing Office of Budget and 

Management (OMB) approved single audit report submission extensions, so that OMB approved 

extension approvals are documented and tracked as part of the single audit monitoring process. 

Repeat – NonCompliance 

Open 

Recommendation

36 (74)

Update the Single Audit Resolution Policy to:

• Reflect the current monitoring process to track all audit findings related to AmeriCorps-funded 

grants, and

• Address AmeriCorps’ responsibilities as the cognizant/oversight agency and how these 

responsibilities would be carried out. 

Repeat – NonCompliance 

Open 

Recommendation

37 (75)

Develop and implement procedures to monitor the effectiveness of the single audit monitoring 

process in accordance with the Uniform Grant Guidance, 2 Code of Federal Regulation §200.513 

Responsibilities, (a) (3) (iv), related to monitoring the effectiveness of single audit findings follow-up 

and the effectiveness of single audits in improving grantee accountability and in their use by 

AmeriCorps in making award decisions. 

Repeat – NonCompliance 

Open 

Recommendation

120
EXHIBIT D

Management’s Response

FY 2021

27

121
EXHIBIT D

Management’s Response

FY 2021

28

122
   

250E St., SW, Suite 4100

Washington, DC  20525

OFFICE OF INSPECTOR GENERAL

HOTLINE: 1.800.452.8210

HOTLINE@AmeriCorpsOIG.gov| AmeriCorpsOIG.gov

     

123
PART F. NATIONAL SERVICE TRUST FUND FINANCIAL STATEMENTS

AMERICORPS TRUST

BALANCE SHEET

AS OF SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Assets:

Intragovernmental:

Fund Balance with Treasury (Note 2) $ 145,848 $ 896,650

Investments, Net (Note 3) 1,011,223 185,714

Total Intragovernmental 1,157,071 1,082,365

Total Assets $ 1,157,071 $ 1,082,365

Liabilities:

With the Public:

Trust Service Award Liability $ 355,824 $ 438,294

Total With the Public 355,824 438,294

Total Liabilities $ 355,824 $ 438,294

Net Position:

Cumulative Results of Operations - Funds from Other 

than Dedicated Collections $ 801,247 $ 644,070

Total Cumulative Results of Operations 801,247 644,070

Total Net Position 801,247 644,070

Total Liabilities and Net Position $ 1,157,071 $ 1,082,365

The accompanying notes are an integral part of these statements.

124
AMERICORPS TRUST

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Gross Program Costs:

VISTA:

Gross Costs $ 5,543 $ 24,585

Less: Earned Revenue - -

Net Program Costs $ 5,543 $ 24,585

NCCC B:

Gross Costs 880 1,578

Less: Earned Revenue - -

Net Program Costs $ 880 $ 1,578

STATE AND NATIONAL C:

Gross Costs $ 40,710 $ 190,607

Less: Earned Revenue (930) (14,831)

Net Program Costs $ 39,780 $ 175,777

Net Cost of Operations $ 46,203 $ 201,940

The accompanying notes are an integral part of these statements.

125
AMERICORPS TRUST

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Unexpended Appropriations:

Beginning Balances $ 644,070 $ 624,138

Net Change in Cumulative Results of Operations 157,177 19,932

Cumulative Results of Operations - Ending $ 801,247 $ 644,070

Net Position $ 801,247 $ 644,070

The accompanying notes are an integral part of these statements.

126
AMERICORPS TRUST

STATEMENT OF BUDGETARY RESOURCES

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(In Thousands)

Unaudited Unaudited

2021 2020

Budgetary Resources:

Unobligated balance from prior year budget 

authority, net $ 365,281 $ 216,312

Appropriations 354,472 231,893

Spending authority from offsetting collections - 18,300

Total Budgetary Resources $ 719,753 $ 466,504

Status of Budgetary Resources:

New obligations and upward adjustments (total) $ 99,180 $ 101,287

Unobligated balance, end of year:

 Apportioned, unexpired accounts 140,071 282,339

 Unapportioned, unexpired accounts 480,503 82,878

Unexpired unobligated balance, end of year 620,574 365,217

Expired unobligated balance, end of year - -

Unobligated balance, end of year (total) 620,574 365,217

Total Budgetary Resources $ 719,753 $ 466,504

Outlays, Net and Disbursements, Net:

Outlays, net (total) $ 129,604 $ 136,010

Distributed Offsetting Receipts - 9,188

Agency outlays, net $ 129,604 $ 145,198

The accompanying notes are an integral part of these statements.

127
PART G. NOTES TO NATIONAL SERVICE TRUST FUND FINANCIAL STATEMENTS

AMERICORPS

NOTES TO NATIONAL SERVICE TRUST UNAUDITED FINANCIAL STATEMENTS

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES

A. Reporting Entity

AmeriCorps was created by the National and Community Service Trust Act of 1993 (Public Law 103-

82). AmeriCorps’s mission is to improve lives, strengthen communities, and foster civic engagement 

through service and volunteering. To meet its mission, AmeriCorps provides grants and other 

assistance to states, local communities, and nonprofit organizations to help communities meet 

challenges in the areas of education, healthy futures, environmental stewardship, economic 

opportunity, disaster services, and assisting veterans and military families through volunteer service. 

AmeriCorps’s major programs are as follows:

AmeriCorps. AmeriCorps provides opportunities for Americans to make an ongoing, intensive 

commitment to service through the following programs:

• AmeriCorps State, National, Tribes, and Territories (State and National) offers grants supporting

a broad range of local service programs that engage thousands of Americans in intensive

service to meet community needs.

• AmeriCorps VISTA helps community organizations and public agencies create and expand

programs that bring low-income individuals and communities out of poverty.

• AmeriCorps NCCC strengthens communities while developing leaders through direct, teambased national and community service.

• AmeriCorps State Service Commission Support Grants (State Commission Support) offers grants

supporting shared federal-state partnership with a central role for governors in designing and

implementing national service through governor-supported State Service Commissions.

Senior Corps. Senior Corps offers a network of programs that tap into the rich experience, skills, and 

talents of older citizens to meet community challenges. Senior Corps comprises the RSVP, the Foster 

Grandparent Program, and the Senior Companion Program. 

B. Basis of Presentation

The financial statements have been prepared to report the financial position and results of 

operations of AmeriCorps. The Balance Sheet presents the financial position of the agency. The 

Statement of Net Cost presents the agency’s operating results; the Statement of Changes in Net 

Position displays the changes in the agency’s equity accounts. The Statement of Budgetary 

128
Resources presents the sources, status, and uses of the agency’s resources and follows the rules for 

the Budget of the United States Government.

The statements are a requirement of the Chief Financial Officers Act of 1990, the Government 

Management Reform Act of 1994 and the Accountability of Tax Dollars Act of 2002. They have been 

prepared from, and are fully supported by, the books and records of AmeriCorps in accordance with 

the hierarchy of accounting principles generally accepted in the United States of America, standards 

issued by the Federal Accounting Standards Advisory Board (FASAB), Office of Management and 

Budget (OMB) Circular A-136, Financial Reporting Requirements, as amended, and AmeriCorps 

accounting policies which are summarized in this note. These statements, with the exception of the 

Statement of Budgetary Resources, are different from financial management reports, which are also 

prepared pursuant to OMB directives that are used to monitor and control AmeriCorps’s use of 

budgetary resources. The financial statements and associated notes are presented on a 

comparative basis. Unless specified otherwise, all amounts are presented in dollars.

C. Basis of Accounting

Transactions are recorded on both an accrual accounting basis and a budgetary basis. Under the 

accrual method, revenues are recognized when earned, and expenses are recognized when a 

liability is incurred, without regard to receipt or payment of cash. Budgetary accounting facilitates 

compliance with legal requirements on the use of federal funds.

D. Fund Balance with Treasury

FBWT is an asset of a reporting entity and a liability of the General Fund. It is the aggregate amount of 

the AmeriCorps’s funds with Treasury in expenditure, receipt, revolving, trust, and deposit fund 

accounts. Appropriated funds recorded in expenditure accounts are available to pay current 

liabilities and finance authorized purchases. 

AmeriCorps does not maintain bank accounts of its own, has no disbursing authority, and does not 

maintain cash held outside of Treasury. When the reporting entity seeks to use FBWT or investments in 

Government securities to liquidate budgetary obligations, Treasury will finance the disbursements in 

the same way it finances all other disbursements, which is to borrow from the public if there is a 

budget deficit (and to use current receipts if there is a budget surplus). Funds are disbursed for the 

agency on demand. 

E. Investment in U.S. Government Securities

AmeriCorps has the authority to invest in U.S. Government securities. The securities include 

marketable Treasury securities and/or nonmarketable, market-based securities issued by the Bureau 

of the Fiscal Service. Market-based securities are Treasury securities that are not traded on any 

securities exchange but mirror the prices of marketable securities with similar terms. It is expected that 

investments will be held until maturity; therefore, they are classified as investment securities held to 

maturity and are carried at historical cost, adjusted for amortization of premiums and discounts. The 

amortization of premiums and discounts are recognized as adjustments to interest income using the 

level-yield, scientific method of effective interest amortization over the term of the respective issues. 

Interest on investments is accrued as it is earned.

F. Use of Estimates

The preparation of the accompanying financial statements in accordance with generally accepted 

accounting principles requires management to make certain estimates and assumptions that affect 

129
the reported amounts of assets, liabilities, revenues, and expenses. Actual results could differ from 

those estimates. 

G. Contingencies

Liabilities are deemed contingent when the existence or amount of the liability cannot be 

determined with certainty pending the outcome of future events. AmeriCorps recognizes contingent 

liabilities in the accompanying balance sheet and statement of net cost when it is both probable 

and can be reasonably estimated. AmeriCorps discloses contingent liabilities in the notes to the 

financial statements when the conditions for liability recognition are not met or when a loss from the 

outcome of future events is more than remote. 

H. Reclassification

Certain FY 2021 and 2020 balances have been reclassified, retitled, or combined with other financial 

statement line items for consistency with the current year presentation.

I. Trust Service Award Liability

The Trust Service Award Liability represents unpaid education awards and eligible student loan 

interest forbearance costs, which are expected to be used upon certification. These amounts relate 

to participants who have completed service based on AmeriCorps’s historical experience.

J. National Service Award Expense

Members serving in approved national service positions are eligible to earn a service award to pay 

for qualified education expenses. The National Service Trust also pays interest forbearance costs on 

qualified student loans during the period members perform community service.

NOTE 2. FUND BALANCE WITH TREASURY

Fund Balance with Treasury account balances as of September 30, 2021 and 2020, were as follows:

Unaudited

2021 Unaudited 2020

Status of Fund Balance with Treasury:

Unobligated Balance

 Available $ 290,070 $ 282,339 

 Unavailable 330,503 232,878 

Obligated Balance Not Yet Disbursed 536,145 566,787 

Investments (Net) (1,010,870) (185,200)

Total $ 145,848 $ 896,650

No discrepancies exist between the Fund Balance reflected on the Balance Sheet and the balances 

in the Treasury accounts.

The available unobligated fund balances represent the current period amount available for 

obligation or commitment. At the start of the next fiscal year, this amount will become part of the 

unavailable balance as described in the following paragraph.

130
The unavailable unobligated fund balances represent the amounts of appropriations for which the 

period of availability for obligation has expired. These balances are available for upward adjustments 

of obligations incurred only during the period for which the appropriation was available for obligation 

or for paying claims attributable to the appropriations.

The obligated balance not yet disbursed includes accounts payable, accrued expenses, and 

undelivered orders that have reduced unexpended appropriations but have not yet decreased the 

fund balance on hand.

NOTE 3. INVESTMENTS

Investments as of September 30, 2021 consist of the following:

Cost

Amortization 

Method

Amortized

(Premium)

Discount

Interest 

Receivable

Investments

Net

Market 

Value 

Disclosure

Intragovernmental:

Market-Based

 Bills

$ 

641,000 Interest $ 140 $ -

$ 

641,140 

$ 

641,141 

 Notes 369,870 Interest 97 115 370,083 369,726

Total

$ 

1,010,870 $ 237 $ 115 

$ 

1,011,223 

$ 

1,010,867 

Investments as of September 30, 2020 consist of the following:

Cost

Amortization 

Method

Amortized

(Premium)

Discount

Interest 

Receivable

Investments

Net

Market 

Value 

Disclosure

Intragovernmental:

 

Marketable

 Bills

$ 

115,800 Interest $ 45 $ - $ 115,844 $ 115,853 

 Notes

 

69,400 Interest 276 194 69,870 70,015 

 Total

$ 

185,200 $ 321 $ 194 $ 185,714 $ 185,868 

131
Non-marketable, market-based securities are Treasury notes and bills issued to governmental 

accounts that are not traded on any securities exchange but mirror the prices of marketable 

securities with similar terms. 

NOTE 4. TRUST SERVICE AWARD LIABILITY

Individuals who successfully complete terms of service in AmeriCorps programs earn education 

awards, which can be used to make payments on qualified student loans or for educational 

expenses at qualified educational institutions. The education award generally must be used within 

seven years of completion date of an approved term of national service. If the education award is 

transferred to an eligible individual or is a Summer of Service award (which was available to youth 

enrolled in grades 6 through 9), the use period is ten years. These awards, as well as interest 

forbearance payments on qualified student loans during the period members perform their service, 

are paid from the National Service Trust Fund. The Service Award Liability as of September 30, 2021 

and 2020 is as follows:

(In Thousands) Unaudited 2021 Unaudited 2020

Cumulative Education Awards Earned $ 

4,326,854 

$ 

4,137,288 

Cumulative Interest Forbearance Earned 

132,417 

 

126,057 

Total Cumulative Awards Earned 

4,459,271 

 

4,263,345 

Less: Discount for Usage and Statistics 

(1,483,523)

 

(888,003)

Less: Cumulative Awards paid 

(3,282,989)

 

(3,153,340)

Total Liability for Awards Earned 

(307,241)

 

(318,276)

Total Liability for Awards not yet Earned 

(48,583)

 

(120,016)

Total $ 

(355,824)

$ 

(438,292)

As of September 30, 2021, and 2020, the National Service Trust received $185 Million and $208.3 

million respectively (unaudited). Under the provisions included in its annual appropriations and under 

42 U.S.C. 12601a, AmeriCorps is also authorized to transfer additional amounts from subtitle C 

program funds to the National Service Trust to support the activities of national service participants. 

NOTE 5. NATIONAL SERVICE AWARD EXPENSE

Members serving in approved national service positions are eligible to earn a service award to pay 

for qualified education expenses. The National Service Trust also pays interest forbearance costs on 

qualified student loans during the period members perform community service.

132
AmeriCorps estimates the expense for national service awards based on the increase in its 

cumulative service award liability during the year (see Note 6). The total service award liability as of 

September 30, 2020 respectively, has been adjusted to reflect the fact that earned awards are not 

always used. The dollar amounts for FY 2021 will be reported on the quarter 4 footnotes as of 

September 30, 2021.

(In Thousands) Unaudited 2021 Unaudited 2020

Estimated Education Awards

$ 

44,782 

$ 

210,766 

Estimated Interest Forbearance

 

2,351 6,004 

National Service Award Expense $ 

47,133 

$ 

216,770 

133
IV. Other Information

PART A. SUMMARY OF FINANCIAL STATEMENT AUDIT & MANAGEMENT 

ASSURANCES

Table 1. Summary of Financial Statement Audit

Audit Opinion Disclaimer

Restatement No

Material

Weaknesses

Beginning

Balance6

New Resolved Consolidated Ending

Balance

Trust Obligation and 

Liability Model (TOLM)

1 1

Undelivered Orders 

and Accounts Payable 

– Procurement

1 1

Other Liabilities 1 1

Undelivered Orders 

(Grant)

1 1

Property, Plant &

Equipment

1 1 0

Recovery of Prior Year 

Obligations

1 1

Internal Control 

Program (FMFIA)

1 1

Financial System and 

Reporting

1 1

Grants Accrual 

Payable and 

Advances

1 1

FY 2021 Migration to 

Shared Service

0 1 1

Total Material 

Weaknesses

9 1 1 9

6 The beginning balance was from the FY 2019 financial statement audit, as there was no financial statements audit 

conducted in FY 2020.

134
Table 2. Summary of Management Assurances

Effectiveness of Internal Control over Financial Reporting (FMFIA § 2)

Statement of

Assurance

No Assurance

Material Weaknesses Beginning 

Balance

New Resolved Consolidated Reassessed Ending 

Balance

Trust Fund Unpaid 

Obligations and 

Liability

1 1

Undelivered Orders

– Grant

1 1

Undelivered Orders 

and Accounts

Payable

1 1

Property, Plant &

Equipment

1 1 1 1

Fund Balance with 

Treasury

1 1

Total Material

Weaknesses

4 2 1 5

135
Effectiveness of Internal Control over Operations (FMFIA § 2)

Statement of

Assurance

No Assurance

Material Weaknesses Beginning 

Balance

New Resolved Consolidated Reassessed Ending 

Balance

Grant Operations 1 1 0

[Name of weakness]

Total Material

Weaknesses

1 1 0

Conformance with Federal Financial Management System Requirements (FMFIA § 4)

Statement of 

Assurance

Systems conform

Non-Conformances Beginning

Balance

New Resolved Consolidated Reassessed Ending

Balance

[Name of nonconformance]0 0 0

Total nonconformances0 0 0

136
PART B. PAYMENT INTEGRITY

AmeriCorps reports its payment integrity information to OMB through the Annual Data Call and that 

information can be found on PaymentAccuracy.gov. 

A recovery audit program is not cost effective for AmeriCorps; therefore, it does not have actions 

around recovery auditor recommendations to report. 

137
PART C. CIVIL MONETARY PENALTY ADJUSTMENT FOR INFLATION

Statutory 

Authority

Penalty Year 

Enacted

Latest Year of 

adjustment

Current 

Penalty 

Level

SubAgency/Bureau 

Unit

Location of

Penalty 

Update 

Details

Pub. L. 101-121,

Sec. 319, (31

U.S.C. 1352); 

Pub.

L. 93-113; 42

U.S.C. 4951, et 

seq.; 42 U.S.C. 

5060

The penalty 

associated 

with 

Restrictions 

on Lobbying 

(45 CFR

1230.400)

1990 2019 The current 

range of civil 

monetary 

penalties 

related to 

Restrictions 

on Lobbying 

is from

$20,489 to

$204,892.

AmeriCorps* 84 Fed. 

Reg.

70902

(Dec. 26,

2019)

Pub. L. 99-509,

Secs. 6101-

6104,

100 Stat. 1874

(31

U.S.C. 3801-

3812);

42 U.S.C.

12651c12651d

The penalty 

associated 

with the 

Program 

Fraud Civil 

Remedies 

Act (45 CFR

2554.1)

2006 2019 The upper 

limit

for civil 

monetary 

penalties for 

the Program 

Fraud Civil 

Remedies

Act of 1986 

is

$11,665.

AmeriCorps* 84 Fed. 

Reg.

70902

(Dec. 26,

2019)

*The Federal Register changes were posted under the Corporation for National and Community

Service, which is the legal name of the AmeriCorps agency.

138
PART D. NATIONAL SERVICE TRUST FUND STATUS REPORT (As of September 

30, 2021)

AmeriCorps

National Service Trust Fund Status Report

September 30, 2021 

The National Service Trust Fund (the Trust) was established by the National and Community Service 

Trust Act of 1993 (the Act), 42 USC 12601, et seq. to provide funds for Segal AmeriCorps Education 

Awards for eligible participants who complete AmeriCorps service. Funding comes from 

appropriations, interest earned, transfer of program dollars, proceeds from the sale or redemption 

of Trust investments, partnerships with other agencies, and funds collected from disallowed or 

improperly awarded Education Awards. The Trust is also authorized to accept gifts or bequests, 

Sponsorships, and funds from federal partners. Under the Act, funds are available to repay qualified 

student loans, pay educational expenses at qualified educational institutions, and repay eligible 

interest expense on student loans. 

The value of an education award depends on the term of service performed by an AmeriCorps 

member. For Program Year 2021, completion of a full-time term of service, requiring a minimum of 

1,700 hours of service, entitles an AmeriCorps member to an education award of $6,345.00. 

Completion of a part-time term, requiring a minimum of 900 hours of service, entitles an AmeriCorps 

member to an education award of $3,172.50. Reduced parttime terms, which provide awards of 

$357.08 to $2,417.14, are also offered. The education award is indexed to the maximum Federal Pell 

grants therefore these amounts may change each year. 

Education awards earned by AmeriCorps members are generally available to be used for seven 

years from the completion of the service. Payments are made directly to the educational 

institutions and the loan holders as directed by the members and by the institutions. Trust funds are 

not used to pay member stipends or other grant costs. Beginning in Program Year 2010, AmeriCorps 

State and National and Silver Scholar members who are age 55 or older when they begin service 

may also transfer the education award to a qualified child, grandchild, or foster child. 

Table 1a shows the planned activity for the current Program Year and actual enrollments to date 

against the plan. 

Table 1a

AmeriCorps Member Position Award Activity

Program Year 2021

Program

Awarded 

Enrolled

Awarded 

Not 

Enrolled

Certified

Not Awarded

Planned

Not 

Certified Total

State & National 21,723 53,046 326 - 75,095

VISTA 5,423 - 828 0 6,251

NCCC 987 - 373 - 1,360

Total 28,133 53,046 1,527 0 82,706

139
Table 1b includes similar data on the prior Program Year for comparative purposes. Member positions 

(slots) classified as “Certified Not Awarded” have been approved by AmeriCorps' Chief Executive 

Officer (CEO) for award to grantees, but for which the final grant award has not been executed. For 

budgetary purposes these positions are considered commitments in the Trust Fund. Positions classified 

as Planned not Certified have not yet been approved by the CEO.

Table 1b

AmeriCorps Member Position Award Activity

Program Year 2020

Program

Awarded 

Enrolled

Awarded 

Not 

Enrolled

Certified

Not 

Awarded

Planned

Not 

Certified Total

State & National 

50,194

 

12,625 

 

134 -

62,953

VISTA 6,060 0 192 - 6,252

NCCC 1,183 0 257 - 1,440

Total 57,437 12,625 583 - 70,645

The 82,706 Trust positions planned for Program Year 2021 do not include an estimated 1,350 

AmeriCorps VISTA members (1150 full time and 200 Summer Associates) who elected an end-ofservice stipend instead of an education award. Total estimated member positions for Program Year 

2021, including VISTA members electing a stipend, is 84,006. Member enrollment and slot data are 

periodically adjusted to reflect corrections and slot reconfigurations by grantees therefore they may 

change slightly from month to month.

The 70,645 Trust positions for Program Year 2020 do not include an estimated 1,500 AmeriCorps VISTA 

members (1,300 full time and 200 Summer Associates) who elected an end-of-service stipend instead 

of an education award. 

Total estimated member positions for Program Year 2020, including VISTA members electing a 

stipend, is 72,145. Of the 6,252 VISTA member positions in the Trust for 2020, 1,835 positions are for 

Summer Associates who receive a Trust award of $1,311.

Trust Awards

Since AmeriCorps' inception in 1993, AmeriCorps members have earned over $4.33 billion in Segal 

AmeriCorps Education Awards and used over $3.15 billion of that amount to fund their education 

and repay student loans. In addition, AmeriCorps has made $132.41 million in interest forbearance 

payments. Approximately $581.08 million in education awards earned have expired without being 

used. The Trust obligation formula has been adjusted to reflect these expired awards.

140
Refilled Positions

AmeriCorps policy allows grantees limited flexibility to refill positions vacated by a member who has 

served less than 30 percent of his or her service term, provided that the departing member had not 

earned a pro-rated education award. To prevent over-enrollment, the policy includes “fail safe” 

triggers that restrict the overall number of refills to no more than 5 percent of awarded positions and 

suspends refilling altogether if total AmeriCorps enrollment reaches 97 percent of awarded positions. 

Table 3 provides information on the number of positions refilled. Positions in Program Years 2010 and 

earlier can no longer be refilled.

Table 3

Number of Refilled Positions

Program Years

2016 2017 2018 2019 2020 2021

Fail-safe 

Trigger

Number of Refilled Positions 1,026 890 998 714 597 13 N/A

Refills as a Percent of 

Awarded 

State & National Positions

1.57% 1.37% 1.50% 1.12% 0.95% 0.02% 5%

State & National Enrollment 

as a 

Percentage of Awarded 

Positions

93.60% 91.70% 86.90% 81.50% 79.90% 29.10% 97%

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

Table 2 Segal AmeriCorps Education Awards Earned and Used 

Earned Used

141
Table 4 shows the most significant factors used to calculate Trust obligations on a historical basis. It is 

important to note that Program Year refers to positions awarded with a particular fiscal year’s grant 

funds. Positions are often filled in time periods after the year in which they are awarded. For 

example, a grantee may receive a grant in FY 2020 but not fill all positions until FY 2021. All positions 

related to this grant would be considered Program Year 2020 positions, irrespective of the fiscal year 

in which they are filled. The Reduced Part-time category below includes Reduced Halftime, Quarter 

time, Minimum time, and AmeriCorps Affiliates.

Table 4

Factors Affecting the National Service Trust Fund

Program Year

2017 2018 2019 2020 2021

Member enrollments in the Trust 68,085 65,574 59,478 57,661 28,385

Percent of members who earned 

an education award

81.34% 80.24% 84.63% 83.99% 64.01%

Percent of earned education 

awards used

63.07% 55.91% 42.96% 24.69% 18.74%

Breakout of enrollment by term 

type:

 Full-time 50% 48% 49% 47% 69%

 Part-time 14% 13% 12% 11% 6%

 Reduced Part-time 35% 39% 39% 41% 25%

The Program Year data used throughout these tables reflect all enrollments recorded through the 

reporting period. 

Prior year enrollment numbers may change slightly from time to time due to corrections or late 

reporting by grantees. The percentage of members who earned an award in Table 4 is calculated by 

taking the number of members who earned an award divided by the total number of members who 

have ended service. For example, for 2020:

Enrolled 57,661

Still Earning 7,190

Completed 50,471 (Enrolled less Still Earning)

142
Awards 42,390

Earned (%) 83.99% (Awards Earned divided by Completed)

Tables 5 and 6 present information on the budgetary resources and obligations of the Trust, including 

the Trust Reserve. The schedules present information on a budgetary basis, which represents the 

accounting used to determine compliance with the Anti-Deficiency Act. AmeriCorps records Trust 

obligations at the time it awards AmeriCorps State & National grants or at the time it enters into an 

enforceable agreement with AmeriCorps VISTA and NCCC members.

The amounts obligated in the Trust are based on the estimated value of the education benefit 

discounted for the estimated enrollment, earning and usage rate and the time value of money. For 

FY 2021, these factors are the ratio of 59.36% between authorized awards and ultimate payments, a 

ratio of 63.88% between awards expected for members currently earning and ultimate payments 

and a ratio of 80.15% between earned awards and ultimate payments. Under the National and 

Community Service Act, as amended, awards earned by members over age 55 can be transferred 

to an eligible beneficiary. For budgetary purposes, AmeriCorps projects that all transferable awards 

will eventually be used. Obligations are periodically adjusted to reflect current earning and usage 

projections.

FEMA Corps is a unit of AmeriCorps' National Civilian Community Corps (NCCC) whose members are 

devoted solely to FEMA disaster response, and recovery efforts. The five-year agreement provides for 

a service corps which compliments and supports FEMA's current disaster workforce. While FEMA 

provides funding for the Education Awards for the FEMA Corps members, they are shown in Tables 5 

and 6 as part of AmeriCorps’ budgetary and obligation activity.

143
Table 5

AmeriCorps

National Service Trust

Schedule of Budgetary Activity 

For the Year Ended September 30, 2021

(In Thousands)

Recovery 

Act

Other FEMA Corps General 

Fund

Consolidated

Unobligated balance from prior 

year 

$ 

1,971

$ 

3

$ 

4,570

$ 

308,476 $ 315,020

Reserve Funds 3,500 46,697 50,197

Unobligated balance from prior 

year budget authority, net 5,471 3 4,570 355,173 365,217

Budgetary Resources

Fiscal Year 2021 Appropriation - - - 204,472 204,472

Temporary Rescission - - - 150,000 150,000

Deobligation Prior Year Positions 

(net) - - - 64 64

Total Budgetary Resources $ 

5,471

$ 

3

$ 

4,570

$ 

709,709 719,753

Less Increase in Obligations (99,179)

Total Available Funds 620,574

Less: Funds in Reserve (50,197)

Recommended Additional 

Reserve (37,334)

Temporary Rescission (150,000)

Unobligated balance, Net $ 383,043

144
Table 6

AmeriCorps

National Service Trust

Schedule of Trust Obligations 

As of September 30, 2021

(In Thousands)

Resources Recovery 

Act

Trust 

Other

Trust FEMA 

Corps

General 

Fund

Consolidated

Fund Balance with Treasury

$ 8,594

$ 

56

$ 

533

$ 

136,666 $ 145,848

Investments, Net 

-

 

-

 

7,804

 

1,003,303 1,011,107

Interest Receivable 

-

 

-

 

-

 

113 113

Accounts Receivable 

-

 

-

 

-

 

(0)

 

(0)

Subtotal 

8,594

 

56

 

8,337

 

1,140,082 1,157,068

Less:

Cumulative Trust Reserve 

(3,500) 

 

-

 

-

 

(46,697) (50,197)

Receivables Not Available for 

Obligation -

 

- (14)

 

(336) (350)

Unapportioned 

-

 

-

 

- (480,503) (480,503)

Total Resources

 5,094 56

 

8,323 612,546 626,019

Unliquidated Obligations

Education Awards 

(3,015) (50)

 

(4,696)

 

(506,938) (514,699)

Interest Forbearance 

(126)

 

(2)

 

(196)

 

(21,122) (21,446)

Total Unliquidated Obligations 

(3,140) (52) (4,892)

 

(528,060) (536,145)

Commitments

145
Education Awards 

-

 

-

 

-

 

(79,424) (79,424) 

Interest Forbearance 

-

 

-

 

-

 

(3,309) (3,309)

Total Commitments 

- -

 

-

 

(82,734) (82,734)

Funds Available for Obligation $ 

1,954

$ 

3

$ 

3,431

$ 

1,753 $ 7,140

Enrollment Activity Table 7 presents cumulative data to date on Trust enrollments, education awards 

earned and used for Program Years 1994 through 2021, as well as Recovery Act positions.

Table 7

Trust Enrollment Activity

Program Years 1994 through September 30, 2021

Program 

Year

Type Members 

Enrolled

Earning or 

Not Exited

Earned an 

Award

Did Not 

Earn

Amount 

Earned

Amount 

Used 

1994 Full Time

487,371 5 396,253 91,113

$ 

1,875,551,793

$ 

1,528,059,783

through Part-time 188,946 6 129,094 59,846 301,086,753 215,142,055

2011 Reduced Parttime 306,437 8 243,652 62,777 280,404,861 211,515,457

 Total 982,754 19 768,999 213,736 2,457,043,408 1,954,717,296

2012 Full Time 36,273 3 31,895 4,375 171,041,134 143,347,133

2012 Part-time 9,577 1 7,771 1,805 21,026,223 14,480,883

2012 Reduced Parttime 29,144 0 23,841 5,303 31,582,835 22,717,728

 Total 74,994 4 63,507 11,483 223,650,192 180,545,744

2013 Full Time 37,044 0 32,240 4,804 173,385,567 144,179,778

2013 Part-time 8,783 0 6,889 1,894 18,664,779 12,151,741

2013 Reduced Parttime 25,315 1 20,518 4,796 27,591,639 19,326,465

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 Total 71,142 1 59,647 11,494 219,641,985 175,657,984

2014 Full Time 37,969 6 32,783 5,180 179,126,649 142,427,709

2014 Part-time 8,662 0 6,746 1,916 18,555,164 11,055,737

2014 Reduced Parttime 24,018 3 19,380 4,635 26,423,117 17,699,640

 Total 70,649 9 58,909 11,731 224,104,929 171,183,087

2015 Full Time 37,187 11 31,598 5,578 174,751,985 131,615,684

2015 Part-time 9,173 5 7,146 2,022 19,879,307 11,215,925

2015 Reduced Parttime 22,587 1 18,532 4,054 25,653,681 16,457,046

 Total 68,947 17 57,276 11,654 220,284,973 159,288,655

2016 Full Time 35,513 39 29,754 5,720 165,672,400 116,129,890

2016 Part-time 9,577 0 7,383 2,194 20,693,057 10,899,545

2016 Reduced Parttime 24,498 14 20,228 4,256 28,204,596 17,701,223

2016 Affiliate 579 0 548 31 178,100 42,510

 Total 70,167 53 57,913 12,201 214,748,153 144,773,167

2017 Full Time 34,109 24 28,228 5,857 157,440,510 103,191,596

2017 Part-time 9,382 3 6,810 2,569 19,166,171 9,355,478

2017 Reduced Parttime 24,145 20 19,888 4,237 27,992,274 16,555,236

2017 Affiliate 449 1 413 35 135,154 28,779

 Total 68,085 48 55,339 12,698 204,734,109 129,131,089

2018 Full Time 31,795 53 26,201 5,541 148,112,359 86,505,891

2018 Part-time 8,302 14 6,057 2,231 17,286,758 7,029,008

2018 Reduced Parttime 25,394 28 20,207 5,159 32,109,579 16,888,395

2018 Affiliate 83 14 62 7 20,656 6,996

 Total 65,574 109 52,527 12,938 197,529,351 110,430,290

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Program 

Year

Type Members 

Enrolled

Earning or 

Not Exited

Earned an 

Award

Did Not 

Earn

Amount

Earned

Amount

Used

2019 Full Time 28,950 115 24,468 4,367 141,652,747 64,010,924

2019 Part-time 7,115 170 5,641 1,304 16,060,655 4,596,977

2019 Reduced Parttime 23,401 170 19,828 3,403 33,738,149 13,644,149

2019 Affiliate 12 0 12 0 4,116 515

 Total 59,478 455 49,949 9,074 191,455,667 82,252,564

2020 Full Time 27,303 1,928 21,571 3,804 128,131,861 33,885,727

2020 Part-time 6,620 1,939 3,488 1,193 10,230,397 1,283,720

2020 Reduced Parttime 23,662 3,317 17,269 3,076 30,490,140 6,520,148

2020 Affiliate 76 6 62 8 21,616 2,789

 Total 57,661 7,190 42,390 8,081 168,874,013 41,692,384

2021 Full Time 19,532 18,098 403 1,031 2,418,666 430,639

2021 Part-time 1,825 1,786 0 39 0 0

2021 Reduced Parttime 7,022 5,108 1,765 149 2,368,294 466,216

2021 Affiliate 6 6 0 0 0 0

 Total 28,385 24,998 2,168 1,219 4,786,960 896,855

Cumulative to Date 1,617,836 32,903 1,268,624 316,309 

4,326,853,740

 

3,150,569,116

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Supplemental Information – AmeriCorps Member Exit Survey

The following information provides evidence of the extent to which AmeriCorps promotes civic 

engagement, which is a foundation of the agency’s mission.

The three AmeriCorps programs foster a lifelong commitment to civic engagement. Data from the 

AmeriCorps Member Exit Survey (MES) from 2015 to 2020 that describe how members finishing their 

terms of service in ASN, NCCC, and VISTA think about how likely they may become involved in 

various dimensions of civic life. Illustrative responses to the following two questions from this survey are 

summarized next.

1. Question 12: Think about how likely you were to participate in the following activities before 

you did AmeriCorps, and how likely you are now. Would you say that your AmeriCorps 

experience has made you more or less likely to:

1. Participate in community organizations (school, religious, issue-based, recreational). 

2. Vote in elections. 

3. Keep informed about news and public issues. 

4. Help to keep the community safe and clean. 

5. Volunteer for a cause or issue that you care about. 

6. Donate money or goods to a cause or issue that you care about.

2. Question 18: If you found out about a problem in your community that you wanted to do 

something about, how well do you think you would be able to do each of the following:

a. Create a plan to address the problem. 

b. Contact an elected official about the problem.

The following charts reflect actual response trend data.

7

7 [1]See all material: https://americorps.gov/evidence-exchange/AmeriCorps-Alumni-Outcomes-Study; The final report: 

Friedman, E., et al. (2016). New Methods for Assessing AmeriCorps Alumni Outcomes: Final Survey Technical Report. 

(Prepared for the Corporation for National and Community Service, Office of Research and Evaluation). Cambridge, 

MA: Abt Associates 

Inc.https://americorps.gov/sites/default/files/evidenceexchange/FR_AmeriCorpsAlumniOutcomesFinalTechReport_1.

pdf7

149
150
Below are findings from the AmeriCorps Alumni Study (2016)[1] that used questions from the MES and 

followed up with alumni whose last term of service corresponded to 10, 5, and 2 years before the 

study’s administration (n=3,772 responses). 

151