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Washington, D.C. 20525

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CORONAVIRUS (COVID-19) FREQUENTLY ASKED QUESTIONS

General Questions

Last update 4/15/21

AmeriCorps is closely monitoring the latest developments related to COVID-19. As America responds to 

the COVID-19 pandemic, you may have concerns about the potential impacts on your program. The 

below FAQs address questions posed by the outbreak. Check back as they are updated regularly.

These FAQs do not have the force and effect of law and are not meant to bind the public in any way. 

This document is intended only to provide clarity to the public regarding existing requirements under the 

law or agency policies. You should refer to AmeriCorps’ statute and regulations for applicable 

requirements.

Information for Members and Volunteers:

1. May AmeriCorps designate AmeriCorps members or AmeriCorps Seniors volunteers as 

“essential workers”, or as otherwise eligible, for COVID-19 vaccine priority groups?

No, AmeriCorps does not have the authority to designate AmeriCorps members or AmeriCorps 

Seniors volunteers as “essential workers”, or as otherwise eligible, for COVID-19 vaccine priority 

groups. 

Neither members nor volunteers are considered employees at the organizations where they 

serve. However, to the extent possible, if a grantee is vaccinating employees in line with state 

and local guidance based on priority group designation, we recommend that they do the 

same for members who are engaged in the same or similar activities that would fall within the 

same designation.

Also, members and volunteers are encouraged to research and follow their state guidelines 

regarding vaccine distribution. [updated 3/1/21]

2. May I leave my site for a compelling health reason, such as I have a compromised immune 

system?

Yes, members and volunteers who are unable to serve at their assigned service location 

should work individually with their project sponsor and program to determine an appropriate 

alternative. Members/volunteers must notify their project sponsor/program about their risk to 

potential exposure. See CDC guidance for how to conduct a risk assessment of their potential 

exposure. [updated 3/12]
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3. If I am serving in AmeriCorps NCCC or AmeriCorps VISTA, will AmeriCorps pay for the return 

to my Home of Record (HOR)?

If you are unable to complete your service term, we will follow normal VISTA and NCCC 

program protocols for returning members to their Home of Records, where appropriate.

[updated 3/12]

4. Can we teleserve?

For AmeriCorps State and National and AmeriCorps VISTA members, please refer to the 

teleservice policies AmeriCorps State and National Teleservice Guidance and AmeriCorps 

VISTA Teleservice Guidance. AmeriCorps Seniors grantees, please follow the appropriate 

guidance as outlined in the Operations Handbook. [updated 3/12]

5. Will I still qualify for forbearance if my term of service is in a Suspended Status, or if I am in an 

Administrative Hold status or on emergency leave, due to COVID-19?

Per AmeriCorps regulations 45 CFR § 2529.20, your lender is responsible for approving or 

denying your forbearance request. AmeriCorps provides verification that you are serving in an 

approved AmeriCorps position (which includes positions in the AmeriCorps State and National 

Program (ASN), the AmeriCorps NCCC Program, and the AmeriCorps VISTA Program). 

Once you are enrolled in the National Service Trust, you can submit a request online through 

My AmeriCorps to verify your involvement in AmeriCorps and request that your qualified loans 

be put in forbearance during your service period. Generally, your loan remains in forbearance 

until you exit from the program. Exiting from the program includes both exiting at the 

scheduled end of your service term and exiting early from the program, before the scheduled 

end. After you exit from the program, you are responsible for repaying your loan according to 

its terms. For more information, visit our website. [updated 4/10]

6. Will I still qualify for interest accrual benefits if I was prevented from completing my full term 

of service due to COVID-19?

Individuals who have successfully completed a term of service in an AmeriCorps program are 

eligible to have the National Service Trust (Trust) pay up to 100% of the interest that accrued 

on their qualified student loan during their service. These are the conditions that apply:

• An interest payment can only be made after you have exited the program and have 

earned a full, partial, or pro-rated education award.

• The percentage of interest accrual benefit that you are eligible to receive is based 

upon your total service hours accrued, or the amount of time (in days) you were 

enrolled when you exited. 

• If you qualify for additional hours/time under the CARES Act, such hours/time will be 

provided to the Trust and be considered “hours/time served.” 

• The Trust will only pay interest on qualified student loans, as described on the Using Your 

Segal AmeriCorps Education Award web page.
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For the AmeriCorps State and National Program, the portion of interest that the Trust will pay is 

determined by the type of service (full or part-time) and how many national service hours 

were certified by your program. If you are exited for CPC, you may be eligible for a pro-rated 

education award, and therefore some payment of the interest accrued on your loan. If you 

are serving in the AmeriCorps State and National program, it is up to your individual program 

to determine CPC. Circumstances related to COVID-19 could reasonably justify a CPC exit. 

Please see the ASN FAQs regarding your eligibility for additional hours under the CARES Act. If 

you exited your ASN program early, and your exit was not for a CPC, you are not eligible to 

have the Trust pay the interest that accrued while you served. 

For the AmeriCorps VISTA Program, if you successfully completed your term of service, the Trust 

will pay the interest accrued for the entire term of service. If you exited early from the VISTA 

program due to CPC, the Trust will pay the interest accrued during the days you were enrolled 

in the VISTA program before your early exit. If you exited the VISTA program early, and your exit 

was not for a CPC, you are not eligible to have the Trust pay the interest that accrued while 

you served. 

For AmeriCorps NCCC, if your graduation date was advanced and you were exited from the 

program earlier than planned due to COVID-19, the Trust will pay 100 percent of the interest 

that accrued on your qualified student loan for 1,700 hours of service. If you decided to exit 

the AmeriCorps NCCC program early and your exit was a resignation from the program, you 

are not eligible to have the Trust pay the interest that accrued. 

[updated 4/10]

7. AmeriCorps Seniors volunteers (SCP, FGP and RSVP volunteers) are not normally covered by 

state or federal unemployment benefits. Are AmeriCorps Seniors volunteers whose service 

ends due to COVID-19 covered by the Pandemic Unemployment Assistance benefit created 

by the CARES Act? 

Eligibility for Pandemic Unemployment Assistance is not determined by AmeriCorps. Please 

contact the government agency in your state that administers the Pandemic Unemployment 

Assistance benefit with any questions you may have regarding the benefit or contact the US 

Department of Labor. [updated 5/18]

8. As an AmeriCorps Seniors volunteer whose service site has closed or who had to discontinue 

service due to COVID-19, can I get unemployment?

As a general matter, AmeriCorps Seniors volunteers (SCP, FGP, and RSVP volunteers) are not 

eligible for unemployment because they are not employees. See 42 U.S.C. §§ 5055 (a), 5058, 

12511 (30), and 12620 (a). To determine whether you qualify for Pandemic Unemployment 

Assistance, please contact the agency in your state administering the benefit. [updated 5/28]

9. My service ended due to COVID-19, and I did not complete my full term of service, am I 

eligible for the one-time Pandemic Unemployment Assistance (PUA)? 
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The U.S. Department of Labor (DOL) has indicated that AmeriCorps members who are no 

longer serving because their site is closed due to COVID-19 and suffered a loss of income are 

eligible for PUA. While DOL’s guidance speaks to AmeriCorps members, DOL has not indicated 

that AmeriCorps Seniors volunteers who are no longer serving due to COVID-19 are eligible for 

PUA. [updated 5/11]

10. How do I claim the Pandemic Unemployment Assistance? 

If you performed your AmeriCorps member service in the same state where you live, 

you may submit a PUA application with your state unemployment benefits office. [updated 

5/11]

11. What if I live in a different state than I was serving in? Which state do I apply for PUA?

Contact your local state unemployment office to determine where you should apply for 

PUA. [updated 5/11]

12. I successfully completed my full term of AmeriCorps service (e.g. my contract was for 1700 

hours 10 months or 12 months, and I completed 1700 hours, or I successfully served all 12 

months in my VISTA term of service) but have been unable to secure new employment. Am I 

eligible for the Pandemic Unemployment Assistance (PUA)?   

Generally, no. There is a limited list of exceptions to this, to include if you are the primary 

caregiver for children who cannot attend school or another facility because it is closed due to 

COVID-19, are unable to obtain employment because you have COVID-19, or you live with 

and are providing care for a family member who has COVID-19. You can find the full list of 

exceptions here. [updated 5/11]

13. I had a job offer for employment after graduation from AmeriCorps that was rescinded due 

to the impacts of COVID-19, am I eligible for PUA?

Yes, per Sec. 2102(a)(3)(A)(ii)(I)(gg)) of the CARES Act, if an AmeriCorps member completed 

his or her full term of AmeriCorps service and subsequently had a bona fide job offer but was 

unable to start due to a COVID-19-related disruption, then that individual is eligible for PUA. 

[updated 5/11]

Information for Grantees and Sponsors:

1. What should we share with our members/volunteers about Coronavirus/COVID-19?

All of us can take measures to reduce the spread of COVID-19. Everyone can do their part to 

help respond to this emerging public health issue. The best source of COVID-19 resources is the 

Centers for Disease Control (CDC). 
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The CDC with the Department of Health and Human Services is the lead government agency 

on the management of the Coronavirus outbreak. They have created resource guides on 

preventing the spread of COVID-19 in specific communities. This includes specific guidance for 

childcare centers and schools, colleges and universities, community events, and first 

responders, among many others. These guides, along with additional resources and up-todate information from the CDC, can be found at the following links. [updated 3/12]

• CDC Coronavirus Hub

• Preventing COVID-19 Spread in Communities

2. I am an AmeriCorps State and National, AmeriCorps VISTA, or AmeriCorps Seniors grantee 

or project sponsor. Who should I contact with questions?

AmeriCorps State and National, AmeriCorps VISTA, or AmeriCorps Seniors project sponsors

should contact their Portfolio Manager. [updated 3/12]

3. I am an AmeriCorps NCCC Project Sponsor. Who should I contact with questions?

NCCC Project Sponsors should contact their NCCC Region campus staff with questions. 

[updated 3/12]

4. What if a volunteer is showing symptoms of illness or respiratory problems? Should they stay 

home?

Yes. Grantees and project sponsors should instruct volunteers to stay home, seek medical 

attention, and not return to their service sites. If a volunteer feels ill, is showing symptoms of 

illness, or thinks they may have COVID-19, they should be directed to consult with their health 

care providers. For further guidance, they should be directed to the CDC guidelines. The 

decision whether to discontinue isolation should be made in consultation with their health care 

providers and federal, state, and local health departments. Grantees and sponsors should 

consistently apply and clearly communicate their policies regarding under what conditions 

they will instruct volunteers to self-quarantine. Grantees and project sponsors should also 

document when they have instructed a volunteer to stay home due to illness.

To prevent stigma and discrimination during service, do not make a determination to send a 

member or volunteer home based on race or country of origin. Also, grantees and sponsors 

must ensure that they maintain confidentiality of any member(s) and volunteer(s) who are 

believed, or confirmed, to have COVID-19, or other illnesses, as required by the Americans with 

Disabilities Act of 1990, as amended (ADA). [updated 4/10]

5. What if a member or volunteer lives with or has been in close contact with someone known 

to have COVID-19? What should grantees and project sponsors do?

Service members and volunteers who are well but live with, or have been in close contact 

with, someone who is known to have COVID-19 should promptly notify their respective 

program/project director. More importantly, the individual should self-report to their physician, 
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and in consultation with their physician, to the state health department responsible for the 

local management of COVID-19 issues.

The grantee or project sponsor should also refer to CDC guidance for how to conduct a risk 

assessment of their potential exposure. While maintaining confidentiality, the grantee or 

project sponsor should inform fellow service members and volunteers of their possible exposure 

to COVID-19 at the service site. [updated 3/12]

6. Should my organization cancel planned congregate events (e.g.: training, recognition 

ceremonies or other special events)?

Each organization should make the decision on whether to proceed with upcoming 

congregant events by consulting information from the Centers for Disease Control (CDC) and 

other relevant state and local agencies. A list of state and territorial health organizations can 

be found at the CDC State Health Department Portal. [updated 3/12]

7. Will AmeriCorps be cancelling upcoming trainings and convenings such as the AmeriCorps 

Seniors (formerly Senior Corps) Convening or upcoming AmeriCorps VISTA Sponsor Events?

Yes, the agency has cancelled and/or postponed all meetings, convenings and events or is 

conducting them on line. The agency is monitoring the situation in locations where events are 

planned and will make a determination on whether to proceed with the advice and counsel 

of federal and local health officials for each jurisdiction. Grantees or project sponsors should

continue to monitor the AmeriCorps website and other communication for updates. [updated 

3/12]

8. What if our organization has paid for staff, member, and/or volunteer travel that is canceled 

by the host organization or it is otherwise imprudent for the travel to happen as planned?

Due to safety concerns, AmeriCorps would treat these scenarios like a weather-related travel 

cancellation and would allow the costs if they are otherwise reasonable and necessary. You 

should clearly document the reasons for the cancellation as they relate to the specific costs 

incurred. [updated 3/12]

9. May members be exited for Compelling Personal Circumstances if they are unable to serve?

Within AmeriCorps State and National, grantees determine compelling personal 

circumstances. Extended site closures and sustained disruptions could reasonably justify a 

compelling personal circumstances exit under 45 CFR § 2522.230 (a) Release for compelling 

personal circumstances. [updated 3/12]

For AmeriCorps VISTA and AmeriCorps NCCC members, the agency will follow established 

protocols. Grantees and project sponsors should direct specific questions to their Portfolio 

Manager, or NCCC campus staff.
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10. If an AmeriCorps State and National program allows members to do additional training at a 

time that they cannot serve at their sites, will they be allowed to exceed the maximum 20 

percent aggregate training hours?

No, per 45 CFR § 2520.50 How much time may AmeriCorps members in my program spend in 

education and training activities?, “No more than 20 percent of the aggregate of all 

AmeriCorps member service hours in your program, as reflected in the member enrollments in 

the National Service Trust, may be spent in education and training activities.” [updated 3/12]

11. If we have a member or volunteer who is exposed to or diagnosed with COVID-19, do we 

need to notify AmeriCorps?

On a voluntary basis, please notify your Portfolio Manager if you have a member or volunteer 

who is diagnosed with COVID-19. Share the project name, city location and number of 

members or volunteers diagnosed. In order to protect the privacy of the individual, please do 

not share their name or other personally identifiable information. You should follow guidance 

provided by the CDC and your local health department. [updated 3/17]

12. I understand that the Office of Management and Budget (OMB) granted relief to some 

provisions in 2 CFR 200, Uniform Administrative Requirements, Cost principles and Audit 

Requirements for Federal Awards. Does this apply to my organization?

OMB has provided federal agencies with the discretion to provide their recipients with a 

number of flexibilities from 2 CFR 200 as a result of COVID-19. Those flexibilities are outlined in 

the following four memos below. Please note that the flexibilities within these memos have 

differing effective periods.

M-20-11 (issued 3/9/20): Administrative Relief for Recipients and Applicants of Federal Financial 

Assistance Directly Impacted by the Novel Coronavirus (COVID-19) (Not rescinded by M-20-26 

but expired 7/26/2020.)

M-20-17 (issued 3/19/20): Administrative Relief for Recipients and Applicants of Federal 

Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of 

Operations (Rescinded by M-20-26 with two exceptions, allowability of salaries and other 

project activities, extended through September 30; and extension of Single Audit submission 

(number 13 in M-20-17), extended through December 31)

M-20-20: (issued 4/9/20): Repurposing Existing Federal Financial Assistance Programs and 

Awards to Support the Emergency Response to the Novel Coronavirus (COVID-19) (Rescinded 

by M-20-27.)

M-20-26 (issued 6/18/20): Extension of Administrative Relief for Recipients and Applicants of 

Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19) due to 

Loss of Operations and rescinded M-20-17 (with two exceptions) and M-20-20.
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Of note, for M-20-26, awarding agencies, in their capacity as cognizant or oversight agencies 

for audit, may allow recipients and subrecipients that have not yet filed their Single Audits with 

the Federal Audit Clearinghouse as of March 19, 2020 that have normal due dates from March 

30, 2020 through June 30, 2020 to delay the completion and submission of the Single Audit 

reporting package, as required under Subpart F of 2 CFR § 200.501 -Audit Requirements, up to 

six (6) months beyond the normal due date. Audits with normal due dates from July 31, 2020 

through September 30, 2020 will have an extension up to three (3) months beyond the normal 

due date. No further action by awarding agencies is required to enact this extension. This 

extension does not require individual recipients and subrecipients to seek approval for the 

extension by the cognizant or oversight agency for audit; however, recipients and 

subrecipients should maintain documentation of the reason for the delayed filing. Recipients 

and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" 

under the criteria of 2 CFR § 200.520 (a)Criteria for a low-risk auditee. [updated 8/24]

13. What is the impact of COVID-19 on access to national service criminal history check 

(NSCHC) vendors Truescreen and Fieldprint, and how should programs handle Livescan 

location closures? 

As of March 18, 2020, agency-contracted national service criminal history check (NSCHC) 

vendors Fieldprint and Truescreen are operating. However, certain Livescan fingerprint 

locations may be closed due to business-specific reasons and/or local government 

requirements. To see which Livescan sites are closed, you may check site availability on 

https://fieldprintcncs.com/. 

AmeriCorps communicates closely with Truescreen and Fieldprint and will issue further notice 

and guidance if closures become nationwide and/or the sources (FBI/states/NSOPW) become 

unable to provide results to grant recipients. 

Livescan locations closed due to Covid-19 are allowing appointments to be scheduled for 

future dates. Grant recipients may elect to order fingerprint cards or schedule Livescan 

appointments for a future time when a local site expects to reopen. Scheduling an 

appointment or having documentation showing that the individual completed their fingerprint 

card satisfies the requirement to “initiate” the background check (i.e., the requirement that 

programs initiate the check before member/volunteer/staff begins work or service in a 

covered position). 

The results of the NSOPW must be reviewed and documented prior to the person beginning 

work or starting service (before work, service, or training hours are charged to the grant, 

federal or match). A person may not accrue hours towards their work or service without first 

having cleared the NSOPW component of the NSCHC. Checks that are not within these time 

frames are noncompliant. 
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Please note: Grant recipients who use Truescreen need to refer to the Truescreen preapproved ASP (https://www.nationalservice.gov/CHCFAQs). The criminal history information 

components (state of service check, state of residence check, and FBI checks) of the NSCHC 

must be initiated no later than the first day of the start of service or work. Checks that are not 

within these time frames are noncompliant.

Initiating state and FBI checks is going one step further than getting permission to conduct an 

NSCHC. This could include, for example, fingerprinting, sending requests to a state repository to 

get checks, or having candidates fill out official forms for getting the required checks. You 

must be able to document how and when checks were initiated. You must have policies and 

procedures outlining how you initiate checks and apply them consistently. [updated 3/27]

14. Are members or volunteers or staff who are suspended for over 120 days, but not exited 

from service or employment, required to conduct a new National Service Criminal History 

Check?

A break in service means that a person is no longer providing service through or receiving 

salary from a recipient or subrecipient. Temporary interruption of work or service without 

termination of employment or expiration of the agreement under which service is being 

provided is not a break in service.

With regard to members, volunteers, or staff suspended or not serving due to COVID-19, such 

temporary interruption is not a break in service and no new criminal history check needs to be 

conducted when the members or staff resume service. [updated 3/19]

15. How is the requirement to accompany those for whom State and/or FBI check components 

are pending affected by COVID-19?

Covid-19 has not changed the requirement to accompany those who are serving when State 

and/or FBI check components of the NSCHC are pending.

Individuals in covered positions are required to be accompanied during service or work while 

state check(s) or FBI check components are pending. A person is accompanied when he or 

she is in the physical presence of a person who is cleared for access to a vulnerable 

population.

One possible way to document accompaniment is to indicate on the covered person’s 

timesheet

1. who accompanied during the covered individual’s access to a person in a vulnerable 

population,

2. on what dates and hours the accompaniment took place, and
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3. have the person who performed the accompaniment incrementally sign off and attest 

to the accuracy of the documentation.

You should have policies and procedures that clearly describe your accompaniment 

guidelines and documentation procedures. The documentation should show the day, times, 

accompanier and individual accompanied. If you need to amend the policy to reflect 

necessary adjustments due to the COVID-19 pandemic, your organization should document 

the change, and the organizational approval of the change.

For individuals who will be teleserving as a result of the COVID-19 pandemic, programs must 

ensure that communication with vulnerable populations includes accompaniment. This may 

be done via conference call, carbon copy on emails, or other means specific to the 

teleservice. 

Please direct questions regarding NSCHC vendors or NSCHC access to CHC@cns.gov. 

[updated 3/27]

16. COVID-19 is impacting my organization’s ability to prepare and submit a Federal Financial 

Report (FFR). Can I have an extension to submit my FFR?

AmeriCorps recognizes that COVID-19 is significantly impacting operations for a number of our 

grantees and sponsors. The reporting period for all FFRs remains the same at this time. As 

always, AmeriCorps will consider requests for extensions on a case by case basis pursuant 2 

CFR §§ 200.327. Additionally, all recipients must still submit their 272 reports to the Payment 

Management System on the required schedule or funds will be placed on hold. [updated 

4/13]

17. How should grantees manage subrecipient oversight monitoring given the impact of 

COVID-19 on scheduled monitoring compliance reviews?

AmeriCorps recognizes the impact COVID-19 has had on grantee operations but grant 

recipients should continue their oversight of subawards to the extent possible. In fact, 

monitoring is particularly important during this time of disruption and uncertainty. Please 

monitor to the extent possible. 

AmeriCorps’ on-site monitoring visits are currently postponed. AmeriCorps monitoring plans are 

being modified to conduct virtual and remote monitoring activities. We recognize that grant 

recipients may also have to modify existing monitoring plans and procedures or postpone 

monitoring activities, due to circumstances that inhibit abilities to travel or conduct 

compliance assessments on-site.

Similar to documenting grant program exemptions or justifications due to COVID-19, grant 

recipients should document any internal decisions to modify monitoring plans. We can’t stress 

enough how important it is that grantees document any and all deviations due to COVID-19. 
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This documentation is particularly important given the fact that grantees’ usual means of 

documentation and document retention is being disrupted. We appreciate all your efforts 

and recognize that you are dealing with many unique challenges. [updated 4/16]

18. If my organization receives a Small Business Administration (SBA) Paycheck Protection 

Program (PPP) loan, and it is used to cover the payroll costs of staff, can I reflect those payroll 

costs that were paid with PPP loan funds on my AmeriCorps or AmeriCorps Seniors grant 

budget as match funds?

For FY 2019-2020, our agency has waived the match requirements for the following grants: 

AmeriCorps State and National program, Commission Support, Volunteer Generation Fund, 

and for all AmeriCorps Seniors programs. While currently there is no match requirement for 

these grants, match funds support expenditures that are tied to proposed outcomes, meaning 

that reduced match funds may result in reduced impact within the communities your grant 

serves. As a result, a grantee with a match waiver in FY 2019 and FY 2020 is encouraged to 

record all eligible match funds that they receive. 

 

For AmeriCorps State and National program cost-reimbursement grants made under the 

authority of 42 U.S.C. §12571(a), and AmeriCorps Seniors grants staff whose salaries/wages are 

covered by SBA Paycheck Protection Program loans, SBA has made a general determination 

that those funds may be reflected as match funds, provided their expenditure is consistent 

with the authorized uses of PPP loan funds. For guidance on the permitted use of PPP funds, 

please see here. For guidance on match funds, see 42 U.S.C. §12571(e)(5); 45 CFR 

2521.45(b)(1); see also 42 U.S.C. 5048. Note, in your Federal Financial Report (FFR) you must 

reflect how much of your match funding for the AmeriCorps State and National program 

grant came from non-AmeriCorps federal sources, such as the SBA.

Please also note, the statutory language governing SIF and Commission Support grants 

specifically prohibits funds from other federal agencies be used as matched funding on those 

grant awards. 42 U.S.C. §§ 12576(a)(2), 12653k(i)(2)(A) and (k)(2).

For all other AmeriCorps and AmeriCorps Seniors grants, the national service laws do not 

provide express authority to use other federal funds as match. Therefore, unless the other 

agency’s statute provides such authority, funds from other federal agencies may not be used 

as match funds. 2 C.F.R. § 200.306. [updated 9/18]

19. If I received a Paycheck Protection Program (PPP) loan from the SBA, are there any 

potential issues?

The Paycheck Protection Program (PPP) is a federal loan program, managed through the U.S. 

Small Business Administration (SBA). Rules and guidance concerning the PPP are available on 

SBA’s website and specific technical assistance questions concerning the PPP should be 

directed to your lender and your legal counsel. AmeriCorps cannot provide guidance on 
12

other governmental programs; however, here are several things to keep in mind should you 

apply for and receive a PPP loan: 

1. If a grantee receives a PPP federally-guaranteed loan to cover staff costs instead of 

using its own funding, and later, the grantee seeks reimbursement for those same costs, 

the grantee should take care to ensure that the funds are properly accounted for and 

are not improperly duplicating or supplanting other funding. 

2. Duplication is prohibited. Duplication occurs when a grant recipient uses federal funds 

to pay for specific costs associated with the grant that are already covered by other 

monetary sources. For example, if the grant recipient uses the PPP loan to pay the 

salary of a staff position, then charges agency funds to cover the same staff position, 

the grantee may have duplicated the costs for that position, or otherwise made an 

improper payment per 2 CFR 200.53. Please note that if a PPP loan is forgiven, in whole 

or in part, that does not cure any duplication. Furthermore, even if the PPP loan is paid 

back, there may still be a duplication issue. 

3. Supplantation is prohibited. Supplantation occurs when a grant recipient replaces its 

state, local, or other federal funding sources with agency funding. However, assistance 

provided by AmeriCorps under the National Community Service Act of 1993, as 

amended (NCSA) may be used to supplement the level of state and local public funds 

expended for services of the type assisted under NCSA in the previous fiscal year. 42 

U.S.C. §12633.

[updated 9/18]

20. Can a SIF award recipient use funds from a Paycheck Protection Program (PPP) loan as the 

SIF match requirement? 

No, 42 U.S.C. § 12653k(k)(2) states that matching funds are required by law to be non-federal 

cash, therefore federal PPP funds cannot be used for the SIF match See General FAQ 

# 18 above. [updated 6/9]

21. What are important reminders as we continue to receive flexibilities related to COVID-19?

When the federal government makes additional flexibilities to handle major disasters or 

national emergencies, there is an increased opportunity for fraud, waste, and abuse. If you 

suspect or observe waste, fraud, and abuse, you must contact the AmeriCorps-OIG and your 

Program Officer/Portfolio Manager without delay. 

The AmeriCorps-OIG maintains a hotline to receive this information about, or suspicions of, 

waste, fraud and abuse and can be reached by email at hotline@cncsoig.gov or by 

telephone at (800) 452-8210. Upon request, AmeriCorps-OIG will take appropriate measures to 

protect the identity of any individual who reports misconduct, as authorized by the Inspector 

General Act of 1978, as amended. Reports to the AmeriCorps-OIG may also be made 

anonymously. More details are available in the FY 2020 General Terms and Conditions 

available here. 
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Because of temporary changes in grant requirements, it is especially critical right now to 

ensure that eGrants has your current authorized representative and project director. We rely 

on this information to provide critical communications and oversight. We received a number 

of undeliverable messages following a recent communication. You can access eGrants and 

confirm your authorized representative and project director and/or make any changes here. 

As always, it is also critical that you retain documentation in accordance with all applicable 

record retention requirements that show you are using your funds on federal grants 

appropriately. This includes the federal share as well as any matching funds. Specific to 

flexibilities due to COVID-19, AmeriCorps’ Office of Monitoring recognizes that grant recipients 

may experience challenges related to documenting grant program activities and expenditure 

changes due to COVID-19. If this occurs, grant recipients are encouraged to include a memo 

to the file that clearly describes the compliance limitations related to documentation, 

including applicable dates and references, Agency specific guidance (i.e. FAQs) that support 

the grant recipient’s approach to documentation during this period. To assist in development 

of your memo to file, AmeriCorps recommends that the following details be included in your 

memo to the file, if applicable:

• Information, if available, from the sponsoring agency regarding restrictions of program 

operations. Include specific dates.

• Information regarding any local government orders, such as shelter in place, stay-athome, or non-essential business closures. Include specific dates or local orders.

• Statement regarding what policies or procedures have been temporarily modified and 

a description of the changes.

• Indicate the timeframe for the change in policy or procedure.

• Project Director signature, if applicable and may be electronic, and date signed.

[updated 8/24]

22. May AmeriCorps designate members serving in AmeriCorps programs or AmeriCorps 

Seniors volunteers as “essential workers”, or as otherwise eligible, for COVID-19 vaccine 

priority groups

No, AmeriCorps does not have the authority to designate AmeriCorps members or AmeriCorps 

Seniors volunteers as “essential workers”, or as otherwise eligible, for COVID-19 vaccine priority 

groups.

Neither members nor volunteers are considered employees at the organizations where they 

serve. However, to the extent possible, if a grantee is vaccinating employees in line with state 

and local guidance based on priority group designation, we recommend that they do the 

same for members who are engaged in the same or similar activities that would fall within the 

same designation. 
14

Also, members and volunteers are encouraged to research and follow their state guidelines 

regarding vaccine distribution. [updated 3/5/21]

23. If a grantee or sponsor makes available COVID-19 vaccines for their employees, can the 

sponsor include members or volunteers in any vaccination plans? 

AmeriCorps encourages grantees and sponsors to exercise flexibility and extend the 

opportunity to AmeriCorps members and AmeriCorps Seniors volunteers to participate in any 

vaccination plans, to the extent permissible by state guidelines. [updated 3/5/21]

For more information, please visit:

• CDC Coronavirus

• U.S. Government Response to Coronavirus

24. Can a grantee, sponsor, or subsite require me to receive a vaccine for COVID-19 to serve 

onsite?

AmeriCorps and AmeriCorps Seniors do not mandate vaccination for our members and 

volunteers to serve. However, whether a grantee, sponsor, or subsite may mandate 

vaccination for members or volunteers to serve on site is a determination for the sponsor to 

make, consistent with federal, state, and local law. The Centers for Disease Control (CDC) and 

the Equal Employment Opportunity Commission (EEOC) provide guidance applicable to the 

COVID-19 vaccination at the links provided below. If a grantee or sponsor does mandate 

vaccination, there may be medical or religious exemptions. Generally, grantees and sponsors 

are encouraged to follow state and local law, and CDC and EEOC guidance around 

workplace vaccination plans.

Updated as of March 5, 2021: CDC: Workplace Vaccination Program

Updated as of December 16, 2020: EEOC FAQs: What You Should Know About COVID-19 and 

the ADA, the Rehabilitation Act, and Other EEO Laws [updated 4/15/21]