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CORONAVIRUS (COVID-19) FREQUENTLY ASKED QUESTIONS

AmeriCorps State and National Program Specific Questions

Last update 6/11/20

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.

I am an AmeriCorps State and National member with questions about my service/benefits, 

who should I contact?

AmeriCorps State and National members with questions can review the FAQs below, or 

contact their program director or State Service Commission. Additional information is available 

by contacting the National Service Hotline at 1-800-942-2677, via webform, or LIVE CHAT.

1. In the event that AmeriCorps State and National service locations are closed (e.g., schools, 

etc.), or the grantee cannot continue its funded service activity because of disruption at one 

or more service site due to COVID-19, will AmeriCorps permit service activities that are not 

included in approved notice of grant agreement, such as food delivery to families under 

quarantine?

If a service activity is disrupted due to COVID-19, grant recipients may develop other types of 

service activities that are not specifically defined in the grant and should obtain written (email) 

approval from their Program Officer/Portfolio Manager as soon as practicable.

New activities must not be otherwise prohibited or unallowable (e.g., lobbying). The new 

approved service activity can begin immediately, and the grant recipient should expect to 

take steps to amend the grant. In the meantime, the grantee should carefully document all 

the costs associated with the new service activities. [updated 3/12]

Is AmeriCorps Program Officer/Portfolio Manager approval needed before programs may 

begin engaging in alternative member activities given the language in the Program Specific 

Grant Terms and Conditions regarding requests during officially declared state or national 

disasters?

Yes, an email confirmation is required from a AmeriCorps Program Officer/Portfolio Manager 

before you start alternative activities. Once you have the email confirmation, the AmeriCorps

Program Officer/Portfolio Manager may request additional information but your request for 
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alternative member activities does not have to be completed before you redirect your 

members. Review of the alternative activities will be focused on ensuring no proposed 

activities are prohibited, unallowable, duplicate or supplant existing staff or volunteer roles.

An officially declared national emergency is distinct from an officially declared state or 

federal disaster. Therefore, grantees should follow the COVID-19 FAQ on alternative service 

activities where a state or federal disaster has not been declared.

Where an officially declared state or national disaster has been declared, the AmeriCorps 

State and National Program Specific Terms and Conditions on disaster-related programmatic 

changes are applicable. But please remember, the terms and conditions also state: “While 

written approval from AmeriCorps is not required before making disaster-related 

programmatic changes, AmeriCorps reserves the right to limit or deny disaster-related 

programmatic changes, including disallowing costs associated with the disaster-related 

activities.” [updated 03/20, moved to FAQ 1 4/7, updated 4/14]

2. Can AmeriCorps State and National grant funds be used to pay for exceptional expenses 

incurred to ensure safety of members, staff and students, including temporary housing?

There is no specific prohibition against a program providing housing, temporary or otherwise, 

to AmeriCorps members. Member benefits, such as housing, that are temporarily amended to 

address issues arising because of COVID-19 need to be documented and applied consistently 

across the program. To the extent that a program is not following its usual policies and 

procedures, like providing housing when housing is not typically provided to members, such 

deviation should be approved at the highest level of the grantee organization that is 

practicable. Formal amendment of the organization’s existing policies and procedures is not 

required. [updated 3/12]

3. Given that the CDC has issued a recommendation to businesses and schools to waive 

requirements for medical documentation of illness, may we waive the requirement to secure 

documentation for AmeriCorps members who are suspended for medical reasons?

From the CDC website:

“Do not require a healthcare provider’s note for employees who are sick with acute 

respiratory illness to validate their illness or to return to work, as healthcare provider offices and 

medical facilities may be extremely busy and not able to provide such documentation in a 

timely way.”

The requirement to provide medical documentation is not an AmeriCorps State and National 

requirement. Thus, grantees can deviate from whatever medical documentation requirements 

they have in their existing policies and procedures related to compelling personal 

circumstances (CPC) as long as the programs retains contemporaneous documentation that 

the deviation from the requirement was related to COVID-19 (i.e., the member was exited for 

CPC because a sibling came in contact with COVID-19 and did not want to contaminate 
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other members in the program) and the program recognizes that this health reason was 

beyond the member’s control pursuant to 45 CFR § 2522.230. [updated 3/12]

4. May ASN members earn hours when their service sites are closed due to COVID-19?

To earn hours, a member must engage in service activity. 42 U.S.C. §12602 (a)(2). Accordingly, 

grant recipients may not give members constructive credit for hours that were not served. 

However, to the extent training or teleservice is possible, AmeriCorps will generously approve 

such deviations from the grantee’s normal policies and practices if the deviation is 

documented and approved by the grantee’s leadership and the planned national service is 

disrupted due to COVID-19. [updated 3/12]

5. In light of the FAQ related to payment of stipends during service interruptions, should 

programs suspend members from the program if service locations are closed?

Programs may decide to suspend AmeriCorps members during a service interruption because 

COVID-19 temporarily halts the member’s service period. Grant recipients may develop 

alternative activities for the members. [updated 3/12]

6. Do you anticipate a change to the teleservice policy for AmeriCorps State and National 

members? If a site were to close for more than 2 days within a pay period, are members 

allowed to teleserve for more than those 2 days?

Our agency considers the COVID-19-related challenges facing AmeriCorps State and National 

grantees to be a rare and unique circumstance where programs might increasingly employ 

teleservice when it is appropriate and compatible for achieving program objectives.

AmeriCorps State and National’s policy is that teleservice should be rare and thus does not 

specify a maximum number of days that teleservice is allowed. AmeriCorps State and National 

does not anticipate changing existing teleservice guidance. The AmeriCorps State and 

National guidance on teleservice can be found here:

https://www.nationalservice.gov/sites/default/files/documents/ASN%20006%20Teleservice%20

Guidance.pdf.

[updated 3/12]

7. Is AmeriCorps going to cut the number of required service hours to be eligible for a full Segal 

Education Award if an AmeriCorps State and National member’s site is closed due to COVID19?

Please see FAQ #20. [updated 3/12, 4/7]

8. If we have a member who is exposed to or diagnosed with COVID-19, do we need to notify 

AmeriCorps?

Yes, on a voluntary basis, please notify your Program Officer or Portfolio Manager if you have a 

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

of members diagnosed. In order to protect the privacy of the individual, please do not share 
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their name or other personally identifiable information. You should follow guidance provided 

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

9. May AmeriCorps State and National members be paid living allowances and benefits while 

Suspended from service due to program closures related to the COVID-19?

In order to provide grantees the maximum flexibility as a result of COVID-19, AmeriCorps has 

determined that AmeriCorps State and National members may be paid living allowances and 

benefits while they are in a Suspended from Service status, if the reason for suspension is due 

to COVID-19. Programs can elect to: 

• Provide members with both living allowance and health benefits;

• Provide members with health benefits only; or

• Provide members with no living allowance and no benefits.

If an individual is suspended for any other reason, the living allowance and other benefits are 

also to be suspended. 

If a grantee organization decides to continue to pay members while they are in a Suspended 

status, they must be prepared to obtain additional funding to cover living allowance and 

benefit expenses once members are reinstated.

Programs should keep in mind that if or when they re-start the program and take members off 

suspension, they will have to continue paying the living allowance and benefits as members 

accrue hours. This may necessitate some programs raising additional funds for those costs as 

they are unlikely to have budgeted for living allowances and benefits beyond their initial 

program duration. [updated 3/13, 4/6, 5/8] 

10. I have a fixed-amount grant. If the members don’t serve hours, may I draw down and 

retain more than what is supported by the hours served?

Please see FAQ #23. [updated 3/13, 4/7]

11. How can Full-Cost, Fixed-Amount Grant recipients cover the cost of continuing to pay living 

allowances and benefits to AmeriCorps members if the members are not able to perform 

service hours? Can Full-Cost, Fixed-Amount grant recipients draw funding amounts based on 

the total award value for filled member positions?

Please see FAQ #23. 

Four alternatives available to grantees with Full-Cost, Fixed-Amount awards, include:

1. Identify alternative service activities that members can perform to earn service hours so 

programs may continue drawing funds;

2. Continue to pay member living allowance but suspend members because service 

activities have been disrupted by COVID-19;

3. Let members remain in In-Service status and continue paying the living allowance and 

benefits; or

4. Exit the member for Compelling Personal Circumstances (CPC) due to the disruption of 

service activities related to COVID-19.
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[updated 3/13, 4/7]

12. When a member is suspended for COVID-19 reasons, can he or she continue to receive 

childcare and health care?

It depends. If a member is enrolled in a program that does not decide to continue to pay the 

living allowance and benefits, then no.

If a member is enrolled in a program that decides to continue to pay the living allowance and 

benefits, then yes – a member suspended due to COVID-19 activities may continue to receive 

the child care benefit (for up to 12 weeks) and health care benefit provided by the grant 

recipient. To prevent a lapse in child care coverage, the AmeriCorps State and National 

grantee must notify GAP Solutions in writing within five business days after a member’s status 

changes. Costs incurred due to the grantee’s failure to keep GAP Solutions immediately 

informed of changes in a member’s status may be charged to the grantee’s 

organization. [updated 3/13, 4/7]

13. May members be exited for Compelling Personal Circumstances (CPC) if they are unable 

to serve?

Within AmeriCorps State and National, grantees determine compelling personal 

circumstances (CPC). Extended site closures and sustained disruptions could reasonably justify 

a CPC exit under 45 CFR § 2522.230(a).

Before exiting a member, please see FAQ #20 and FAQ #21. 

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

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

Manager, Program Officer, or NCCC campus staff. [updated 3/16, 4/7, 4/14]

What if a member’s service cannot restart due to COVID-19?

Per Section 3514(a)(2) of the CARES Act, if AmeriCorps requires a member to exit because 

AmeriCorps determines that completion of the originally scheduled service term is no longer 

practicable due to COVID-19, AmeriCorps may determine that the member is entitled to an 

education award consistent with the percentages specified above. 

[updated 3/31, 4/7, 4/14]

What qualifies as "no longer practicable due to COVID-19"? 

Under the CARES Act, when service is no longer practicable due to COVID-19, a member is 

required by AmeriCorps to exit. Such members may receive an education award consistent 

with the percentages specified in FAQ #20. Circumstances indicating service is no longer 

practicable due to COVID-19 include, but are not limited to:

• Lack of service activities, such as lack of on-site or teleservice assignments, lack of 

teleservice resources, or project closure;
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• Continued service would pose a risk to the health or safety of the AmeriCorps member 

or others, for example, the AmeriCorps member tests positive for COVID-19 or the 

AmeriCorps member self-identifies to be high risk and unable to serve due to risk(s) 

posed by COVID-19;

• AmeriCorps member has full-time caregiver responsibilities, including situations in which 

the member’s regularly scheduled caregiver services have been canceled or disrupted 

due to COVID-19.

AmeriCorps will rely on grant recipient certification when exiting the members that service is no 

longer practicable, consistent with this guidance. Members who are not required by 

AmeriCorps to exit are not entitled to a full education award. [updated 4/14]

14. 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 3/16]

15. When a commission is seeking approval for alternative AmeriCorps State and National 

member service activities for one or more of their subrecipients, are commissions required to 

submit separate requests for each program or could a commission submit a request for all of 

its competitive programs?

When a commission is seeking approval for alternative AmeriCorps member service activities, 

they need to identify a specific subrecipient and the associated alternative member activities 

for that subrecipient. Blanket approval is not possible because we need to fully understand the 

possible alternative member service activities available. To that end, please describe the 

member service activities as specifically as possible and avoid using terms such as “assist,” 

“support,” or other ambiguous terms. The more specificity you provide, the faster AmeriCorps

will be able to provide approval.

We want to balance the possible administrative burden to grantees, so if two or more 

subrecipients will engage in the same alternative member service activities, the requests can 

be aggregated into a single email or document. The information submitted by a grantee is 

intended to be used to determine if an amendment to the Notice of Grant Agreement is 

necessary and to reduce the possibility of later disallowance and financial burden on 

grantees.

Some important reminders:

1. Programs should, of course, prioritize protecting the health and safety of members. If 

the members will need specific training, protective equipment, or other precautions to 
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carry out the new service activities safely, the program should ensure that it can be 

provided.

2. It is always the responsibility of the grantee/program to ensure that the service activities 

are compliant. Even though a PO/PM can give preliminary approval for an activity, if it 

is determined later that the activities were not compliant, the grantees may be subject 

to disallowance or other sanctions.

[updated 03/20]

16. Is AmeriCorps Program Officer/Portfolio Manager approval needed before programs may 

begin engaging in alternative member activities given the language in the Program Specific 

Grant Terms and Conditions regarding requests during officially declared state or national 

disasters?

Moved answer to be part of FAQ #1 [moved 4/7]

17. As an alternative member service activity, can AmeriCorps State and National members 

assist grocery markets or pharmacies in delivering foods and medicines to quarantined 

people or other disadvantaged people?

No, AmeriCorps State and National members are statutorily prohibited from engaging in any 

service that “provides a direct benefit to” a business organized for profit. AmeriCorps members 

may be engaged in the distribution of food or medicine on behalf of public-school districts, 

other public entities, or nonprofit organizations. We invite programs to think creatively so that 

we can approve your alternative member service activities. [updated 03/20]

18. I am currently conducting an evaluation of my AmeriCorps-funded program, but closures 

of service locations and/or disruptions to service activities due to COVID-19 are interfering with 

data collection for the evaluation. Can the timeline for my evaluation be extended?

Yes, grantees whose evaluations are affected by COVID-19 are eligible to apply for this type 

of relief – Alternative Evaluation Approach (AEA). The AmeriCorps State and National 

Alternative Evaluation Approach (AEA) guidance allows grantees to request an extended 

timeline for an evaluation that cannot be completed during the current grant cycle. Please 

follow the instructions in the AEA guidance for how to submit an AEA request outside of the 

recompete grant application process. [updated 03/20]

19. Closures and disruptions due to COVID-19 are making it difficult for me to complete my 

Grantee Progress Report. Can the GPR due date be extended?

The Grantee Progress Report instructions state the following:

If you cannot meet the submission deadline for the progress report, you must request an 

extension from your Program Officer/Portfolio Manager. Requests for extensions may be 

granted when:

1. The report cannot be finished in a timely manner for reasons legitimately beyond the 

control of the grantee, and
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2. AmeriCorps receives a request explaining the need for an extension before the due 

date of the report.

Closures and service disruptions related to COVID-19 qualify as “reasons legitimately beyond 

the control of the grantee,” and so are a legitimate basis to request a GPR due date 

extension. Please contact your Program Officer/Portfolio Manager if you need to request an 

extension. [updated 03/20]

20. Can AmeriCorps State and National members get a full Education Award if they were not 

able to obtain their full hours due to circumstances related to COVID-19?

It depends. There are three situations that have different outcomes:

1. AmeriCorps State and National members that have served less than 15 percent of the 

minimum required hours for the Term of Service at time of exit. AmeriCorps State and 

National members who have served less than 15 percent of the minimum required 

hours for a Term of Service at the time they are exited are not eligible for a partial 

education award. Nor are these members eligible for a full education award with a 

compelling personal circumstance exit related to COVID-19. 45 CFR § 2522.230(a)(2).

2. AmeriCorps State and National members that have served between 15 percent and 50 

percent of the minimum required hours for the Term of Service at the time they are 

exited. AmeriCorps State and National members that complete between 15 and 50 

percent of the minimum required hours for the Term of Service may be exited for 

compelling personal circumstances proportional to the number of hours they have 

served. They are not eligible for a full education award with a compelling personal 

circumstance exit related to COVID-19. 45 CFR § 2522.230(a)(2).

3. AmeriCorps State and National members that have served more than 50 percent of the 

minimum required hours for the Term of Service at the time they are exited. An 

AmeriCorps State and National member who has completed more than 50 percent of 

the minimum number of hours required to successfully complete their Term of Service 

will be eligible to receive the full education award amount with a compelling personal 

circumstance exit related to COVID-19. Compelling personal circumstances are the 

determination of the AmeriCorps program. 45 CFR § 2522.230(a)(2). Please see Q22 and 

Q23.

21. What process will grantees use to exit those members who have served more than 50 

percent of the minimum required hours for a Term of Service?

This is a two-part process:

1. Exit of the member and

2. Document the difference between the served hours and the hours entered on the exit 

form.

Part 1. Exit of the member

If an AmeriCorps State and National member is no longer able to serve as a result of 

circumstances related to COVID-19, a program may enter the minimum number of hours 
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needed for a full award for the member’s Term of Service; and exit the member with a status 

of “Eligible for Partial Award (member did not complete service for compelling personal 

reasons).” See example below:

Part 2. Noting the difference between the served hours and the hours entered on the exit form

Programs/Subgrantees/Operating Sites will submit a report for their prime grant identifying:

1. Each member who was exited for a partial award for a compelling personal 

circumstance due to COVID-19 and their NSPID,

2. The hours served by the member,

3. Confirm that those hours were more than 50 percent of the minimum required hours for 

the Term of Service, and

4. The hours that were not served due to COVID-19 to equal the full hours reported on the 

member exit form.

This will be submitted to the prime grantee concurrent with the deadline for information to be 

submitted as part of the Annual Progress Report due to AmeriCorps in December 2020.

The prime grantee will not submit that information to AmeriCorps but rather the 

documentation and approvals will be retained by the prime grantee and the 

programs/subgrantees/operating sites in member files. [updated 3/31]

22. What if a member’s service cannot restart due to COVID-19?

Moved to FAQ #13. [moved 4/14]

23. How will AmeriCorps determine the amount of funds a program may retain for an awarded 

full-cost, fixed-amount grant?

Per Section 3514(c) of the CARES Act, AmeriCorps has determined that grantees with full-cost, 

fixed-amount grants whose program operations have been disrupted by COVID-19 may retain 
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the amount of awarded funds based on the total Member Service Years (MSY) value of 

regular enrolled member service positions multiplied by the awarded cost per MSY up to the 

amount of award funds as stated on the Notice of Grant Award. This is consistent with how 

Education Award Program (EAP) grantees draw down their funds. [updated 3/31, 4/7, 4/14]

24. COVID-19 is impacting my ability to meet my match requirements. Will AmeriCorps provide 

relief regarding this requirement?

AmeriCorps is waiving all match requirements for all AmeriCorps State and National (ASN) cost 

reimbursement grants that were awarded in FY 2019 and FY 2020, including ASN grants that will 

be awarded during the remainder of FY 2020. AmeriCorps has the authority to issue a blanket 

waiver under 42 U.S.C. § 12571(e)(4) and consistent with 45 CFR 2521.70 when AmeriCorps

“determines that such a waiver would be equitable due to lack of available financial 

resources at the local level.” ASN grantees who wish to take advantage of this waiver in full or 

part do not have to take any action at this time. AmeriCorps will provide additional FAQs in 

the near future that outline the implementation process. [updated 4/9]

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

Report (FFR) due April 30, 2020, for the report period ending March 31, 2020. 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. As a result, AmeriCorps is extending the due date for semi-annual FFRs. 

The FFRs that were due April 30, 2020, are now due May 30, 2020. We are in the process of 

updating the due date in eGrants for all applicable awards. The reporting period for these

FFRs remains the same. Grantees and sponsors who can submit their semi-annual FFRs sooner 

are encouraged to do so. This flexibility is only for FFRs submitted to AmeriCorps. At this time, all 

recipients must still submit their 272 reports to the Payment Management System on the 

required schedule or funds will be placed on hold.

AmeriCorps may consider extending the due date for final FFRs in the future, if needed. 

However, as recipients have 90 days to submit their final FFRs following the end of the 

performance period, this deadline should not impose an undue hardship on the majority of our 

recipients. 

AmeriCorps is offering this relief pursuant to the Office of Management and Budget memo M20-17: Administrative Relief for Recipients and Applicants of Federal Financial Assistance 

Directly Impacted by the Novel Coronavirus (COVID-19) due to Loss of Operations. [updated 

4/15]

26. 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 are prevented from completing their full term of service due to COVID-19 may 

still qualify to receive interest accrual benefits. In accordance with 45 CFR § 2529.10, the 
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National Service Trust (Trust) pays up to 100 percent of the interest that accrued on an 

AmeriCorps member’s qualified student loans 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.

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. [updated 4/14]

27. 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—the federal agency that oversees 

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 4/15]
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28. Site closures and service disruptions related to COVID-19 will make it difficult for my ASN 

program to collect output and outcome data and meet performance measure targets by the 

end of the program year. How should I handle this?

Grantees are encouraged to use flexible strategies for collecting performance measure data, 

such as delaying collection timeframes and/or using different data collection instruments 

(including online tools), as long as the new data collection strategies are still consistent with 

the Performance Measure Instructions. However, given the disruptions in service experienced 

by many grantees as a result of COVID-19, AmeriCorps understands that it may not be possible 

for affected grantees to meet their performance targets for the current grant year. Please 

follow the existing Grantee Progress Report guidance for how to report unmet performance 

measure targets. AmeriCorps intends to be as flexible as possible when reviewing and 

assessing compliance with the Performance Measures. AmeriCorps will also not take any 

actions for failing to timely notify AmeriCorps that your program will not be able to meet the 

Performance Measures (45 C.F.R. § 2522.630; 2 C.F.R. § 200.338.). [updated 5/8]

29. How does a full-cost, fixed-amount grantee show that their program operations have been 

disrupted by COVID-19? Must the disruption in program operations interrupt the members’ 

service? What documentation will qualify for the program to be able to retain program funds 

based on enrollment rather than member completion? 

Per Section 3514(c) of the CARES Act, full-cost, fixed-amount grantees may only retain funds 

based on the total Member Service Years (MSY) value of regular enrolled member service 

positions multiplied by the awarded cost per MSY up to the amount of award funds as stated 

on the Notice of Grant Award for those members who were exited early, were suspended, or 

who served in a limited capacity. 

Fixed Amount grantees must document how their member’s service was disrupted by COVID19. Grantees documentation must show that the “participants who exited, were suspended, or 

are serving in a limited capacity due to COVID-19.” 

If the members exited early or departed from the program for non- COVID-19 related reasons, 

such funds cannot be retained by the program. Grantees must retain this documentation as a 

grant record, consistent with 2 C.F.R. §200.333. AmeriCorps will require that full-time fixed 

amount grant programs that do not have this required documentation return the appropriate 

funds to AmeriCorps. 

Additionally, the process for drawing funds from the Payment Management System has not 

changed. Once you have determined the amount earned, you may draw funds 

accordingly. Please note that you should only draw based on immediate cash needs, to 

minimize the amount of cash on hand.

All other requirements about drawing funds remain intact, including, that federal recipients 

should request “...funds from the Payment Management System only for immediate 
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disbursement (3 business days) and reimbursement.” as stated on the PMS homepage. This is 

also consistent with the Cash Management Improvement Act. [updated 5/28]

30. COVID-19 is impacting my ability to secure local resources that will support agency and 

program goals and objectives. Since AmeriCorps is waiving all match requirements for all 

AmeriCorps State and National (ASN) cost reimbursement grants that were awarded in FY 2019 

and FY 2020, can I submit a request to replace match funds that were previously accounted 

for and reported with federal grant funds? 

AmeriCorps recognizes that the COVID-19 pandemic is seriously affecting economic 

conditions in communities throughout the nation and that this lack of resources in a 

community adversely impacted by COVID-19 may prevent grantees from providing all or a 

portion of their required non-federal contribution. Consequently, grantees may have the 

ability to address this resource deficit by replacing previously reported match funds with 

federal grant funds for AmeriCorps and AmeriCorps Seniors projects that are active and have 

not surpassed the project end date. 

Please note that this is not a recommended practice and may result in unintended risks to an 

organizations financial health. Therefore, grantees should consider all options before 

processing a replacement of previously reported match funds with our agency grant funds. 

Assuming this action falls within your organization’s policies and procedures, a grant project’s 

match funds remain tied to specific expenses and corresponding activities that were identified 

as necessary to achieve the goals of your approved program. 

ASN grantees who wish to take this action must clearly document that the justification for such 

financial accounting procedures is due to COVID-19, as records may be subject to review 

under the Improper Payments Elimination and Recovery Improvement Act (IPERIA) or

AmeriCorps monitoring activities. This would be true for prime and subgrantees. Additionally, 

please refer to the program-specific terms and conditions to determine whether these actions 

must be approved by AmeriCorps. Further, every effort should be made to maintain the same 

level of service that was funded. [updated 6/11]