AmeriCorps Policies and Procedures

Policy Number: 102 Effective Date: January 6, 2022

Revision Number: 4

Title: Reporting Waste, Fraud, and Abuse, Cooperating with Office of Inspector General (OIG) 

Inquiries, and Whistleblower Protections

Purpose: This policy sets forth the obligations of all AmeriCorps personnel at all levels (e.g., 

employees, contract employees, and members of the Board of Directors) to (a) report waste, 

fraud, and abuse to the OIG without taking further investigative steps; (b) cooperate with OIG 

inquiries; and (c) protect whistleblowers.

Who is Covered: AmeriCorps employees, contract employees, and members of the Board 

of Directors. Contractor and grantee staff are covered—and protected—by the reporting 

requirements and whistleblower protections discussed in this policy as provided for by law 

and the applicable contract or grant terms.

Policies Replaced: Previous version.

Originating Office: Office of the Chief Executive Officer.

Approved By:

Jenny Mauk

Chief of Staff
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Reporting Waste, Fraud, and Abuse, Cooperating with Office of Inspector General 

Inquiries, and Whistleblower Protections

1. What is the purpose of this policy?

This policy is designed to protect the integrity of AmeriCorps programs, activities, and 

operations by requiring that waste, fraud, and abuse be timely reported to the appropriate 

authorities. It also describes the responsibilities of all AmeriCorps personnel at all levels (e.g., 

employees, contract employees, and members of the Board of Directors) (collectively 

AmeriCorps employees) to cooperate with the Office of Inspector General (OIG) in the course 

of OIG inquiries, as well as the protections accorded to whistleblowers.

2. What should be reported to the OIG?

All AmeriCorps employees, contract employees, and Board members are required to report to 

the OIG, without delay, any reasonable or actual suspicion of, or information or evidence that 

suggests, waste, fraud, or abuse in connection with AmeriCorps operations, programs, 

activities, contracts, or grants at any level. See Standards of Ethical Conduct for Employees of 

the Executive Branch, 5 CFR §2635.101(b)(11) (requiring federal employees including 

AmeriCorps board members to “disclose waste, fraud, abuse, and corruption to appropriate 

authorities”). Any question about whether a particular matter should be reported to the OIG 

should be directed to the OIG Hotline.

• The phrase “without delay” indicates that reporting allegations to the OIG is an 

urgent priority. Only an emergency or comparable time-sensitive priority takes 

precedence over the reporting obligation.

• AmeriCorps employees, contract employees, and Board members always have a right 

to communicate directly with OIG. You do not need permission from anyone before 

reporting to the OIG.

Other than reporting to the OIG, any individual who becomes aware of possible waste, fraud,

or abuse should take no further steps to investigate, except as directed by OIG staff or to 

prevent the destruction of evidence or information. After reporting to the OIG, individuals or 

their managers may consult with Office of the General Counsel regarding appropriate 

prospective actions. Before initiating any management or supervisory actions, AmeriCorps 

employees will inform the OIG of their plans and any timing exigencies. It is the OIG’s 

practice to work expeditiously with agency managers upon request to deconflict (i.e., identify 

potential conflicts and seek to resolve) management and supervisory actions from investigative 

activities and equities. After seeking to deconflict, the agency may take appropriate actions.

a. Definitions

• Waste occurs when taxpayers do not receive reasonable value for their money in 

connection with a government-funded activity due to an inappropriate act or omission by 

people with control over or access to government resources.

• Fraud occurs when someone uses intentional misrepresentation or misleading omission 

to obtain something of value or to deprive someone, including the government, of 
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something of value.

• Abuse is behavior that is deficient, objectively unreasonable, or improper under the 

circumstances. Abuse also includes the “arbitrary or capricious exercise of power by a 

federal official or employee that adversely affects the rights of any person or that results 

in personal gain or advantage to her/him or to preferred other persons. There is no de 

minimis standard for abuse of authority.”

b. Examples of matters to be reported to the OIG:

• any suspected criminal activity or violations of law

• fraud, theft, conversion, misappropriation, embezzlement, or misuse of funds or property

from AmeriCorps or an AmeriCorps grantee, subgrantee, contractor, or subcontractor, 

even if no federal funds were involved

• submission of a false claim or a false statement to AmeriCorps by any person, including 

an AmeriCorps employee, grantee, subgrantee, contractor, subcontractor, AmeriCorps 

member, AmeriCorps Seniors volunteer, or any other recipient of AmeriCorps funds

• concealment, removal, obliteration, falsification, forgery, alteration, or unauthorized 

destruction of government records or records required to be retained in connection with 

any AmeriCorps program, operations, or activities

• fraud or conspiracy to defraud the government or a government official in connection 

with any matter relating to the programs and operations of AmeriCorps

• kickbacks, acceptance of illegal gratuities, bribery, extortion, blackmail, or conflicts of 

interest in connection with AmeriCorps programs, activities, or operations, including any 

violations of the standards of ethical conduct by an AmeriCorps employee

• gross mismanagement, gross waste of funds, or abuse of authority in AmeriCorps 

programs, activities, and operations

• arrest, indictment, or other formal charge of criminal conduct in any federal, state, or 

local court involving an employee of AmeriCorps, a grantee, or a subgrantee

• allegations of whistleblower retaliation in connection with any AmeriCorps programs, 

activities, or operations brought to the attention of any AmeriCorps personnel

• matters relating to an AmeriCorps program, AmeriCorps employee, grantee, subgrantee, 

contractor, subcontractor, AmeriCorps member, AmeriCorps Seniors volunteer, or any 

other recipient of AmeriCorps funds brought to the attention of AmeriCorps personnel 

by an outside investigatory or law enforcement agency.

3. How should I report waste, fraud, and abuse?

Reports to the OIG may be made:

• in person
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• phone: 1-800-452-8210

• the OIG Hotline at https://www.americorpsoig.gov/hotline.

The OIG takes appropriate measures to protect the identity of any individual who reports 

misconduct, in accordance with Section 7(b) of the Inspector General Act of 1978. The 

telephone and email hotlines both allow (but do not require) anonymous reporting.

AmeriCorps non-supervisory staff may report directly to the OIG, or have their supervisor do so 

on their behalf, which will include informing the OIG of the staff member’s identity. Contractor 

or grantee staff members are encouraged to report directly to the OIG but may choose to have 

their AmeriCorps point-of-contact do so on their behalf, including informing the OIG of the 

identity of the contractor or grantee staff member. AmeriCorps supervisors or contractor/grantee 

points-of-contact who receive such a report (or are told by staff that a report was made) are 

required to immediately communicate the information to the OIG.

Any (a) delays in reporting waste, fraud, or abuse, (b) unauthorized investigatory actions,

(c) unauthorized disclosures of allegations, or (d) unauthorized disclosures of whistleblower 

identities may impede OIG investigations and penalize and deter individuals from reporting 

problems. Failure to comply with the requirements in Sections 2 and 3 of this policy may be 

grounds for disciplinary action.

4. What is AmeriCorps’s policy on cooperating with OIG inquiries?

The OIG provides independent oversight of AmeriCorps programs and operations. As part of its 

oversight responsibilities, the OIG has the authority to conduct audits, inspections, 

investigations, and other reviews of AmeriCorps operations, programs, activities, contracts, and 

grants, (collectively, OIG inquiries).

AmeriCorps’ policy is to fully support the OIG’s oversight work, to fully assist and cooperate 

with OIG inquiries, and to expect AmeriCorps personnel to fully assist and cooperate with the 

OIG.

a. Full cooperation

Full cooperation means that the employee must:

• take reasonable and necessary steps to prevent the destruction of evidence or 

information related to an OIG inquiry

• timely disclose complete and accurate information pertaining to matters underreview by

the OIG

• upon written request, promptly provide the OIG (including other personnel authorized 

by the OIG) access to personnel, facilities, records, files, information systems, and other 

sources of information pertaining to AmeriCorps programs, operations, activities, 

grants, and contracts, without burdensome administrative requirements or screening 

procedures that might impede the OIG’s access. To ensure proper handling, AmeriCorps

staff should, to the maximum extent practicable, identify for the OIG any records 

provided that contain privacy-protected materials, attorney-client or deliberative 
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communications, other sensitive information, or materials from entities outside of 

AmeriCorps. Where necessary, an AmeriCorps employee may consult with the Office of 

General Counsel as needed, provided that doing so does not delay or prevent reporting 

or responding to the OIG.

• upon request, assist the OIG in arranging requested interviews

• provide a sworn statement if requested by the OIG, unless that statement could lead to 

self-incrimination

• maintain the confidentiality of communications with the OIG in connection with an 

investigation, if requested by the OIG to do so.

It is the OIG’s practice, where practicable and consistent with its mission, to coordinate 

with agency personnel to minimize disruption of their ongoing work in connection with 

their responses to OIG inquiries. Concerns about the burden of responding to an OIG 

request for assistance should be raised with the investigator. Where the OIG has not 

directed the AmeriCorps employee to maintain the confidentiality of the investigation, those 

concerns may also be raised with the Audits and Investigations Program Manager.

b. Consequences of failure to cooperate 

Personnel failing to cooperate with the OIG may be subject to (a) disciplinary action for 

refusing to provide documents or information or to answer questions posed in an OIG inquiry, 

unless the employee’s statement could lead to self-incrimination and (b) criminal prosecution 

and disciplinary action, up to and including removal, for concealing information, obstructing 

the OIG’s work, or knowingly and willfully furnishing false or misleading information in an 

OIG inquiry.

c. Employees’ rights

Employees’ rights include:

• An AmeriCorps bargaining unit employee who reasonably believes that they would be 

subject to discipline as the result of an OIG interview may have a union representative 

present at the employee’s investigatory interview. Bargaining unit employees who wish 

to request a union representative should do so at least two days in advance unless the 

circumstances prevent advanced notice.

• In accordance with OIG policy, an AmeriCorps employee or Board member may, at 

their own expense, have personal counsel present at an investigatory interview.

• By law, OIG investigators will provide AmeriCorps personnel potentially implicated 

in misconduct with an appropriate advisement of their rights, including the potential 

use of any statement made by the individual in administrative and/or criminal 

proceedings against them.

d. Preserving confidentiality

Sharing information with the OIG is not intended to, and does not, waive AmeriCorps’ 
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ability to assert privileges or other protections against third parties in any forum. It is OIG 

practice to handle and store records and information produced by AmeriCorps in a manner 

appropriate to preserve any applicable privileges for assertion by AmeriCorps.

5. What protections exist for whistleblowers?

A whistleblower is an individual who discloses information to certain individuals or entities that 

the whistleblower reasonably believes to show:

• a violation of law, rule, or regulation

• gross mismanagement

• a gross waste of funds

• an abuse of authority

• a substantial and specific danger to public health and safety

The Whistleblower Protection Act of 1989, as amended, protects federal employee

whistleblowers from reprisal or retaliation for their disclosures. The Whistleblower Protection 

Provisions of the National Defense Authorization Act protect federal grantee and contractor 

employees from reprisal or retaliation for whistleblowing.

AmeriCorps does not tolerate reprisal or retaliation against whistleblowers for reporting 

concerns or otherwise cooperating with the OIG, whether they are federal employees or 

contractor or grantee personnel. Violations of this policy may result in disciplinary action, 

including dismissal if warranted.

AmeriCorps personnel who believe they have been retaliated against for reporting 

wrongdoing may file a complaint with:

• Office of Special Counsel (www.osc.gov) at (800) 572-2249

• OIG’s Whistleblower Protection Coordinator at (800) 452-8210 

or by email to Coordinator@AmeriCorpsOIG.gov

• The OIG Hotline at https://www.americorpsoig.gov/hotline.

Employees of contractors, subcontractors, grantees, and subgrantees who believe they 

have been retaliated against for reporting may file a complaint with the OIG 

Whistleblower Protection Coordinator at (800) 452-8210 or by email to

Coordinator@AmeriCorpsOIG.gov.

OIG’s Whistleblower Protection Coordinator is available to educate AmeriCorps employees

about prohibitions on retaliation for protected disclosures and can also inform anyone who has 

made or is contemplating making a protected disclosure about the rights and remedies against 

retaliation.

More information on whistleblower protections can be obtained online at https://osc.gov/ or 
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https://www.americorpsoig.gov/whistleblower-protection.