NATIONAL& 

COMMUNITY 

SERVICEttt:C 

1201 New York Avenue, NW 

Washington, DC 20525 

202-606-5000 

NationaiService.gov 

To: Deborah Jeffrey 

Inspector General 

From: Jeffrey Page 

Chief Oper""' c "TH>r,. 

verpayments for Q1 ending December 31, 2015 

Date: January 29, 2016 

The purpose of this Document is to comply with the High-Dollar overpayments' 

reporting requirements addressed in the Office of Management and Budget (OMB) 

implementation guidance M-15-02 Circular A-123, Appendix C, dated October 20,2014, 

relative to Executive Order 13520. The OMB implementation guidance makes necessary 

for agency heads to submit reports quarterly on High-Dollar overpayments to the Office 

of Inspector General. 

The Corporation for National and Community Service (CNCS) identifies high-dollar 

overpayments through improper payments testing, which was completed in October 

2015 (Q1). CNCS has identified the AmeriCorps, RSVP, FGP, and SCP grant programs 

as susceptible to significant improper payments. The high-dollar overpayment 

threshold is based upon aggregate payments to an individual or entity during a quarter. 

CNCS projected all payments identified as improper to reflect the quarterly amount 

paid. For the reporting period covering 10/01/2015 through 12/31/2015, CNCS did not 

identify any high-dollar overpayments. 

This report upholds CNCS's commitment to carrying out the Executive Order's goals of 

eliminating payment errors. Reducing improper payments remains vital for CNCS. We 

continue to monitor programs in order to reduce the amount of overpayments. 

DISASTER SERVICES I ECONOMIC OPPORTUNITY I EDUCATION I ENVIRONMENTAL STEWARDSHIP I HEALTHY FUTURES I VETERANS AND MILITARY FAMILIES 

AMERICORPS I SENIOR CORPS I SOCIAL INNOVATION FUND 
NATIONAL& 

COMMUNITY 

SERVICEtf#: 

High-Dollar Overpayment Reporting 

Office of Management and Budget (OMB) Circular A-123, Appendix C requires that agencies 

with programs susceptible to significant improper payments under the Improper Payments 

Information Act of 2002, (Pub. L. No. 107-300, 31 U.S. C. 3301 note, as amendedl (!PIA) are 

required to report quarterly on high-dollar overpayments that occurred within those 

specific programs. This information must be reported to the agency's Inspector General 

and to the public through the agency's website or other means of information. A report 

must be made, even if there are no high-dollar overpayments found. 

OMB A-123, Appendix C was last updated in October of 2014, which changed the reporting 

threshold for high-dollar overpayments (HOOP). Now, a HOOP is one made to an individual 

that exceeds $25,000 in a quarter or a payment to an entity that exceeds $100,000 in a 

quarter. An agency must identify HOOPs through one or more relevant sources of 

information available to the agency, as cost-effective, such as: Annual improper payment 

testing samples; payment recapture audits; or other sources identified by the agency. 

CNCS has identified three programs that are susceptible to significant improper payments, 

triggering quarterly HOOP reporting. These programs are: AmeriCorps State and National, 

the Foster Grandparents Programs, and RSVP. Currently, CNCS is identifying HOOPs 

through IPERA testing. Given the nature of our CNCS's grant programs, it is unlikely that 

many, if any high-dollar overpayments will be identified. Staff and member payroll are 

approximately 80% of all payments made throughout the different grant programs. Most 

staff are not typically compensated at a rate where improper overpayments reach the 

HOOP threshold level within a 3-month period. 

1201 New York Avenue, NW 

Washington, DC 20525 

202-606-5000 

NationaiService.gov 

1 !PIA was amended by the Improper Payments Elimination and Recovery Act of 2010 (IPERA; Pub. L. No. 111-204) and 

the Improper Payments Elimination and Recovery Improvement Act of 2012 (I PERlA; Pub. L. No. 111-204). 

DISASTER SERVICES I ECONOMIC OPPORTUNITY I EDUCATION I ENVIRONMENTAL STEWARDSHIP I HEALTHY FUTURES I VETERANS AND MILITARY FAMILIES 

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2 

The Office of Accountability and Oversight (OAO) has spoken with CNCS's Office of General 

Counsel (OGC) to determine the methodology used to track HDOPs. When performing 

IPERA testing, OAO tracks the amount, date, and person and or entity of each tested 

transaction. When a payment is identified as improper, OAO will identify whether the 

specific payment qualifies as an HDOP. If it is not an HDOP on its face, OAO will then assess 

the potentiality that other payments made to that individual and/or entity over the current 

quarter are also improper and in aggregate could reach the level of an HDOP. We will do 

this by extrapolating the data collected during IPERA testing to the entire quarter (i.e. for 

payroll we will determine the number of payments in that quarter and determine the 

amount overpayment which likely occurred in each payment). If the extrapolation shows 

that payments to the individual or entity could reach the HDOP threshold, OAO will work 

with Program Officers and Grants Officers to collect all the necessary information to make a 

final determination as to whether any actual HDOPs were made. 

Part of HDOP reporting includes reporting on any efforts made to recover the cost of the 

payment. Although no HDOPs have been identified yet, OAO will work with the Program 

and Grants Offices to recover costs associated with the HDOP in the same way that OAO 

recovers identified improper payments. 

DISASTER SERVICES I ECONOMIC OPPORTUNITY I EDUCATION I ENVIRONMENTAL STEWARDSHIP I HEALTHY FUTURES I VETERANS AND MILITARY FAMILIES 

AMERICORPS I SENIOR CORPS I SOCIAL INNOVATION FUND