250 E Street SW

Washington, D.C. 20525

202-606-5000 / 800-942-2677

202-606-5000 / 800-942-2677

TO: Program Leadership

FROM: Danielle Melfi, Chief Program Officer

DATE: June 2, 2023

RE: End of Public Health Emergency and Program Flexibilities

BACKGROUND

The COVID-19 public health emergency and national emergency were declared in January 

2020 and March 2020, respectively. The CARES Act, signed into law March 27, 2020,

provided a variety of flexibilities for AmeriCorps programs for the public health emergency. 

In addition, the National and Community Service Act of 1990 and the Domestic Volunteer 

Service Act of 1973 allow for programmatic flexibilities in national emergencies. The 

declaration of the national emergency and public health emergency expired on May 11, 

2023. In preparation for this expiration, AmeriCorps reviewed existing flexibilities and 

considered continuation, when possible, by current law. 

OPERATIONAL IMPACT: BUDGET, LEGAL AUTHORITY

The CARES Act authorized AmeriCorps to institute COVID-based program flexibilities. The

National and Community Service Act of 1990, and the Domestic Volunteer Service Act of 

1973 allow for programmatic flexibilities in national emergencies. In addition to review by 

Office of General Counsel, AmeriCorps Program Directors provided input for decision 

making on all flexibilities AmeriCorps has been utilizing that are listed below.

There is no budgetary impact related to the decisions below.

FINAL DECISION

The following flexibilities extended under the CARES Act will continue:

1. AmeriCorps NCCC Service Term Extension;

A. Under Section 3514 (d) AmeriCorps NCCC extended the term of service for NCCC 

members.

B. This flexibility will continue to be in effect until May 10, 2024; one year after the 

end of the declaration of the public health emergency.

2. AmeriCorps NCCC waiver to upper age limit for members;

1. Under Section 3514 (d) AmeriCorps NCCC increased the upper age limit for 

AmeriCorps NCCC members from 24 to 26.

A. Under Section 3514 (d) AmeriCorps NCCC increased the upper age limit for 

Summer Service members from 18 to 26 years old.

These flexibilities will continue to be in effect as long as CARES Act conditions apply. 

AmeriCorps NCCC will monitor conditions and regularly examine the use of the CARES Act 

authority as COVID-19 conditions change.
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250 E Street SW

Washington, D.C. 20525

202-606-5000 / 800-942-2677

202-606-5000 / 800-942-2677

The following flexibilities from the CARES Act expired as of May 10, 2023: 

1. Education Award Flexibilities; 

A. Under Section 3514 (a) AmeriCorps members serving in positions eligible for an 

education award who exited early for COVID-related reasons could, in some 

circumstances, receive a full education award.

B. This affects members in AmeriCorps State and National, AmeriCorps VISTA, and 

AmeriCorps NCCC.

This flexibility expires effective the date of this memo. 

1. AmeriCorps State and National fixed price grants; 

A. Under Section 3514 (c) recipients of AmeriCorps State and National fixed grants 

awards were permitted to maintain a pro-rata amount of grant funds, at the 

discretion of AmeriCorps, for participants who exited, were suspended, or are 

serving in a limited capacity due to COVID-19, to enable the grant recipients to 

maintain operations and to accept participants.

This flexibility will expire as of the date of this memo. 

The following requirement will remain in effect: 

1. Vaccination Requirement for members in the NCCC program; 

A. As of the date of this memo AmeriCorps members in the NCCC program are 

required to receive the COVID-19 vaccination as a condition of service. As COVID19 conditions change, AmeriCorps NCCC may reexamine this requirement.

The following flexibilities allowed under NSCA/DVSA Authorities will expire as of the 

date of this memo:

1. Alternative Service Methods; 

A. Under legal authorities provided in the NSCA and/or DVSA, certain AmeriCorps

members in State and National and VISTA, and AmeriCorps Seniors volunteers 

were able to serve remotely full time. 

Programs have developed new policies and practices related to this flexibility, which 

differ by program and include allowable exceptions. Please refer to individual 

program policies for guidance on teleservice moving forward.

i. AmeriCorps State and National Policy

ii. AmeriCorps VISTA Policy (English) 

iii. AmeriCorps Seniors Guidance 

a. RSVP Section (Section 7.2.3)

b. Foster Grandparents (Section 7.2.2) 

c. Senior Companions (Section 7.2.2) 

2. Evacuated Peace Corps volunteers and members who early terminated from a 

previous AmeriCorps term (NCCC, AmeriCorps State and National, VISTA) eligible to 

serve as VISTA Leaders. 

A. Under authority in 45 CFR § 2556.7, the AmeriCorps CEO temporarily waived, through 

the pendency of the COVID-19 national emergency, the length of prior service 

requirement as it relates to VISTA Leader eligibility as set forth at 45 CFR § 2556.605

AmeriCorps State and National, AmeriCorps VISTA, and AmeriCorps NCCC 
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250 E Street SW

Washington, D.C. 20525

202-606-5000 / 800-942-2677

202-606-5000 / 800-942-2677

members who have already completed more than 50% of their service term prior to 

being exited early from service due to COVID-19 are deemed to have satisfied the 

length of prior service requirement and are eligible to apply to serve as VISTA 

Leaders. Peace Corps Volunteers who have completed more than 50% of their 

service terms (i.e., more than one year of their two-year term of service), and who 

have been forced to evacuate from their posts and exit service early due to COVID19, are deemed to have satisfied the length of prior service requirement and are 

eligible to apply to serve as VISTA Leaders.

This temporary waiver to VISTA Leader eligibility requirements is valid only during 

the COVID-19 national emergency. Individuals who, for whatever reason, have not 

served at least one full term of service, in any of the three AmeriCorps programs or 

in the Peace Corps, will not be eligible to apply to serve as VISTA Leaders.

The following flexibilities will expire as of the date of this memo.

1. AmeriCorps VISTA End of Service Benefit Changes;

As a temporary COVID-19 related exception to policy, members were allowed to 

change their End-of-Service Award from the Education Award to the Cash Stipend up 

until one week prior to their end of service.

2. AmeriCorps VISTA Non-Competitive Eligibility for COVID-19 exits

As a temporary policy exception, if an AmeriCorps member demonstrated the ability 

to satisfactorily complete the full term of service, and early terminates due to COVID19, then they received non-competitive eligibility status, regardless of how long the 

member served.