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Alternative Evaluation Approach 

(AEA) Guidance 

AmeriCorps State and National

June 13, 2023
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Table of Contents

Background...................................................................................................................................... 1

Alternative Evaluation Approach Authority.................................................................................. 2

Request and Approval Process ...................................................................................................... 2

Bases for AEA Approval.................................................................................................................. 3

1. Structure of AmeriCorps program or grantee organization (large grantees only)... 3

2. Previous impact evaluation (large grantees only)......................................................... 3

3. Replication (large grantees only).................................................................................... 4

4. Timing (large or small grantees) ..................................................................................... 4

5. Funding Threshold (large grantees only) ...................................................................... 5

6. AmeriCorps National Evaluation (large or small grantees) ......................................... 5

Insufficient Bases.............................................................................................................................. 5

Eligibility ........................................................................................................................................... 6

Background 

AmeriCorps believes that program evaluation is a critical component of building the 

evidence base for national service and demonstrating that programs are making a difference 

in communities. Per 45 CFR 2522.710-730, all recompeting AmeriCorps State and National 

competitive grantees are required to conduct an evaluation covering at least one program 

year for the same project and to submit the completed evaluation to AmeriCorps with their 

next recompete evaluation. Grantees receiving $500,000 or more per year from AmeriCorps 

are required to conduct an independent impact evaluation that aligns with the language in 

45 CFR 2522.700. While rigorous impact evaluation is the only definitive way to demonstrate 

that changes in outcomes were caused by the AmeriCorps intervention, AmeriCorps 

recognizes that impact evaluations as defined in the CFR are not appropriate in all cases. 

AmeriCorps also recognizes that there may be situations in which the evaluation 

requirements specified in the CFR may not align with a program’s life cycle or meet a 

grantee’s most critical information needs. AmeriCorps has therefore created a process for 

grantees to request approval of an Alternative Evaluation Approach (AEA) that would allow 

them to use a different type of evaluation design or timeline when appropriate. 

For some program designs, it is extremely difficult to conduct an impact evaluation that 

requires comparing outcomes for service beneficiaries or members to outcomes for a 

comparison group or control group because some programs face insurmountable 

challenges to forming a comparison group. We also recognize that some programs are 

conducting evaluations for which there is value in measuring and reporting results in a 

timeframe that extends beyond the current grant cycle. Finally, AmeriCorps recognizes the 

value of aligning evaluation activities with the program’s developmental stage and position 

on the evidence continuum; as such, an impact evaluation may not always be appropriate. 

Approving an AEA in these circumstances allows AmeriCorps to maintain evaluation rigor 

while recognizing that there are limited circumstances under which some flexibility will help 
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achieve the underlying goals of the evaluation requirement, which are to support program 

improvement and demonstrate that AmeriCorps investments are making a difference. 

Grantees requesting an AEA are required to demonstrate that they are using the most 

rigorous evaluation design that is feasible for their particular circumstances. Furthermore, the 

evaluation must meet all AmeriCorps evaluation requirements that are not superseded by the 

approved Alternative Evaluation Approach. 

Alternative Evaluation Approach Authority 

Under 45 CFR 2522.710, “The Corporation may, in its discretion, supersede [the evaluation 

requirements] with an alternative evaluation approach, including one conducted by the 

Corporation at the national level.” 

Request and Approval Process 

Grantees requesting an AEA must provide: 

• A written AEA request that includes: 

o The AEA type(s) requested 

o Why the proposed alternative approach is the most rigorous option feasible 

o How the proposed approach will help the grantee build their evidence base or is 

otherwise necessary 

o Any other required information or attachments based on the requested AEA type 

(see below)

• A written evaluation plan that is consistent with the AEA request and that includes, at a 

minimum, the required evaluation plan elements referenced in the Notice of Funding 

Opportunity. 

Requests for AEA approval should typically be submitted as part of the recompete grant 

application. Requests submitted outside of the recompete grant application process may be 

considered under limited circumstances; such requests must be submitted as email 

attachments to EvaluationPlans@cns.gov using the AEA Request Form. 

AmeriCorps will assess the request for an Alternative Evaluation Approach and the evaluation 

plan. Grantees may be asked to revise their submitted evaluation plan to ensure that it (1) 

fully aligns with the AEA request and (2) is the most rigorous option feasible. If needed, 

AmeriCorps may also follow up directly with the grantee to gather additional information 

needed in order to make a determination. If the AEA request and the written evaluation plan 

are approved, the grantee will be authorized to conduct an evaluation for that grant cycle as 

specified in the AEA review form and written evaluation plan. If the evaluation is carried out 

as specified, the grantee will have met the evaluation requirements for that grant cycle. 

AEA approvals are granted for one three-year grant cycle only. The grantee must submit a 

new request for approval of an Alternative Evaluation Approach and a new written evaluation 

plan during the grant application process when recompeting for future funding. 
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Bases for AEA Approval 

1. Structure of AmeriCorps program or grantee organization (large grantees only) 

Grantees approved for this AEA type are permitted to conduct a non-impact evaluation

Grantees may request approval of an Alternative Evaluation Approach if either of the 

following two conditions apply:

• The grantee demonstrates insurmountable challenges to forming a comparison 

group. AmeriCorps anticipates that relatively few program designs will be approved 

for an Alternative Evaluation Approach on this basis.

o Grantees requesting an AEA on this basis must explain why (1) the challenges 

to forming a comparison group are not surmountable due to the nature of the 

program design, and (2) the proposed alternative approach is the most 

rigorous option feasible

• It is not developmentally appropriate for the grantee to conduct an impact 

evaluation due to significant changes in program design or other evaluation 

readiness factors such as variability or lack of confirmed fidelity in the program 

model. 

o Grantees requesting an AEA on the basis of changes to program design must 

explain (1) how their program design has changed significantly enough that it 

no longer meets the definition of “same project” (45 CFR 2522.340), and (2) 

why the proposed alternative approach is the most rigorous option feasible

o Grantees requesting an AEA on the basis of evaluation readiness must explain 

(1) why it is not developmentally appropriate for the program to conduct an 

impact evaluation at this time and (2) why the proposed alternative approach 

is the most rigorous option feasible. If desired, grantees may provide a copy 

of a completed Impact Evaluability Assessment Tool and explain how the 

results of the assessment justify the request for an Alternative Evaluation 

Approach. 

2. Previous impact evaluation (large grantees only)

Grantees approved for this AEA type are permitted to conduct a non-impact evaluation

Grantees may request approval of an Alternative Evaluation Approach if they have 

previously conducted an impact evaluation of the same project. The impact evaluation 

must have been well-designed and well-implemented and must have demonstrated 

evidence of effectiveness on one or more key desired outcomes of interest.

• Grantees requesting an AEA on this basis must: (1) submit their previous impact 

evaluation report as part of their recompete application, (2) specify in the written 

AEA request the name and date of completion of the impact evaluation, and (3) 

describe in the AEA request how the impact evaluation is still applicable to the 

grantee’s current program design. In order for an AEA request of this type to be 

approved, the recompete application must be assessed by reviewers as having 

Moderate or Strong evidence and must receive satisfactory assessments on the 

Evidence Quality review criteria.

• If AEA approval is granted, the grantee is strongly encouraged to conduct an 

evaluation that builds on the findings from the previous impact evaluation in order 
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to strengthen the evidence-base for their program and make continuous 

improvements. 

3. Replication (large grantees only)

Grantees approved for this AEA type are permitted to conduct a non-impact evaluation

Grantees may request approval of an Alternative Evaluation Approach if they are 

implementing an evidence-based intervention with fidelity in a new setting. Such an 

intervention must be supported by strong, consistent findings from experimental or 

quasi-experimental study/ies in contexts and with beneficiary populations similar to the 

ones in which the grantee is operating. Examples could include a specific site of a multistate program for which evidence exists from other sites, or a grantee implementing the 

same intervention that has been rigorously evaluated by another AmeriCorps grantee.

• Grantees requesting an AEA on this basis must: (1) submit copies of the 

experimental/quasi-experimental study report(s) being replicated as part of their 

recompete application, (2) specify in the written AEA request the name(s) and 

date(s) of completion of the study/ies being replicated, and (3) describe in the AEA 

request (a) how the intervention described in the study/ies will be implemented with 

fidelity in the new setting, and (b) how the beneficiary population is similar. In order 

for an AEA request of this type to be approved, the recompete application 

must be assessed by reviewers as having Moderate or Strong evidence and 

must receive satisfactory assessments on the Evidence Quality review criteria. 

• If AEA approval is granted, the grantee is strongly encouraged to conduct a welldesigned implementation study during the current grant cycle. 

4. Timing (large or small grantees)

Grantees approved for this AEA type are permitted to submit an implementation report 

describing the progress they have made to date in conducting their evaluation

Grantees may request approval of an Alternative Evaluation Approach if they are planning 

to conduct an evaluation that will not be completed during the current grant cycle and for 

which findings will not be available until a later date. This type of timing extension may be 

considered if there is articulated value in longer-term measurement and reporting or 

because the outcomes of interest follow natural cycles that are not aligned with the grant 

cycle. If interim findings will be available during the current grant cycle and such interim 

findings are aligned with the final outcomes to be measured, the grantee should submit 

such findings in an interim evaluation report when they recompete for funding. AEA 

approval is only required if the interim evaluation report will not meet the grantee’s 

evaluation requirements. 

• Grantees requesting an AEA on the basis of timing must: (1) explain in their AEA 

request why the nature of the research questions or outcomes being studied require 

longer-term measurement that will extend beyond the three-year grant cycle, (2) 

explain why it will not be possible to submit an interim evaluation report with their 

recompete application that would meet their evaluation requirements, and (3) 

specify the timeframe in which they will submit their final evaluation report to 

AmeriCorps. 

• If AEA approval is granted, the grantee will be required to submit an 

implementation report when they recompete for funding. The implementation 
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report must describe the progress the grantee has made to date in conducting their 

evaluation. 

5. Funding Threshold (large grantees only)

Grantees approved for this AEA type are permitted to conduct an internal non-impact 

evaluation

Grantees may request approval of an Alternative Evaluation Approach if the total 

awarded federal share of their budget averages under $1 million per year for the full life 

of the grant. The total awarded federal share includes all AmeriCorps funding (initial 

award plus any supplemental funds) awarded to support the program.

• Grantees requesting this AEA type must state their total awarded or requested federal 

share for each year in their current grant cycle. These figures will be verified by 

AmeriCorps. In order for an AEA request of this type to be approved, the official 

eGrants record must confirm that the average yearly AmeriCorps funding 

awarded for this grant cycle is less than $1 million per year.

• If additional funding is awarded after AEA approval that pushes the average yearly 

federal share for the grant above $1 million per year, the AEA will be rescinded.

• If AEA approval is granted, the grantee is encouraged to conduct the most rigorous 

evaluation feasible for their program. The use of an external evaluator is encouraged 

but not required for this AEA type.

6. AmeriCorps National Evaluation (large or small grantees)

Grantees approved for this AEA type are permitted to submit the AmeriCorps evaluation

AmeriCorps’ Office of Research and Evaluation periodically undertakes national 

evaluations, such as bundled evaluations and Return on Investment studies. AmeriCorps 

State and National encourages grantees to participate in national evaluations if invited to 

do so.

Grantees may request approval of an Alternative Evaluation Approach if they are 

participating in an AmeriCorps evaluation (i.e., bundled evaluation or Return on 

Investment) that will not be completed during the current grant cycle and for which 

findings will not be available until a later date. Grantees may also request approval of this 

AEA if the design of the AmeriCorps evaluation does not fulfill the evaluation 

requirements for a large grantee. 

• Grantees requesting this AEA type must (1) provide the name of the of the evaluator, 

(2) the topic of the evaluation, and (3) describe their participation in the evaluation. 

• If the grantee does not fully participate in the AmeriCorps national evaluation, the 

AEA will be rescinded. AmeriCorps will verify the participation of the grantee.

• If AEA approval is granted, the grantee will be required to submit the AmeriCorps 

evaluation, which may be either an implementation report or the final report, when 

they recompete for funding. 

Insufficient Bases

Expectations for conducting comparison group impact evaluations have been articulated in 

the CFR, and grantees are expected to comply with these expectations if they do not meet 
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the criteria listed above. The following are not sufficient to support approval of an Alternative 

Evaluation Approach: 

• Lack of necessary funds budgeted for evaluation 

• Challenges in data collection such as setting up a data collection system or accessing 

administrative data 

• Failure to conduct timely planning of the evaluation or avoidable delays in planning or 

implementing the evaluation 

• Failure to successfully implement a planned evaluation for which forming a 

comparison group was feasible and for which reasonable challenges should have 

been anticipated and accounted for in the evaluation plan

Eligibility 

AmeriCorps State and National grantees receiving over $500,000 (“Large grantees”) are 

eligible to apply for approval of an Alternative Evaluation Approach for any of the reasons 

outlined in the document. 

AmeriCorps State and National grantees receiving less than $500,000 or EAP/No Cost Slot 

grantees (“Small grantees”) are eligible to apply for approval of an Alternative Evaluation 

Approach on the basis of timing or participating in an AmeriCorps evaluation. 

Produced and published at US taxpayer expense