Grants Management: Monitoring Efforts by Corporation for National and Community Service Could Be Improved
Published: 2017-03-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Created in 1993, CNCS distributes about $750 million in grants annually to volunteer and national service programs for needs ranging from disaster recovery to improving education. A 2014 CNCS Office of Inspector General (OIG) report cited problems with grant management. GAO was asked to review CNCS's efforts to improve its grant monitoring.
This report examines (1) CNCS's process for grant monitoring; (2) the extent that this process aligns with relevant internal controls for identifying, analyzing, and responding to risk; and (3) the extent that CNCS has the capacity necessary to monitor grantees' compliance with grant requirements. GAO reviewed agency documents for fiscal years 2015 and 2016; analyzed fiscal year 2015 assessment and monitoring data (the most recent complete year of data available); interviewed agency officials and a nongeneralizable sample of program and grant officers who had experience with grants with negative outcomes, such as greater-than-expected monitoring needs or audit findings; and held discussion groups with a small nongeneralizable number of grantees attending two 2016 training conferences.
section_title: What GAO Found
paragraphs: The Corporation for National and Community Service (CNCS) assesses its grants before the beginning of each fiscal year and prioritizes its grant monitoring based on the scoring of certain indicators, such as potential performance or financial problems and the length of time since the last compliance visit. For fiscal year 2015, CNCS identified about 2,200 grants for assessment and prioritized 16.4 percent for compliance visits and 5.4 percent for other types of visits and financial reviews. In addition, each year CNCS selects a sample of grant records to review for improper payments.
CNCS's process for grant monitoring is not fully aligned with the internal controls for identifying, analyzing, and responding to risks (see fig.). Specifically, because CNCS's assessment process does not include all grants, risks may go unidentified. Further, the assessment process uses a scoring model of 19 indicators to analyze and prioritize grants for monitoring visits rather than to identify the highest-risk grants. For example, multiple financial risks are grouped together under one indicator, including for improper payments, and a grant found to have such risks would not be scored as high priority for monitoring based on this indicator alone. In addition, while nearly half of CNCS grant dollars are passed through to other organizations (referred to as subrecipients) and evidence indicates that subrecipient oversight is a key risk area, CNCS's monitoring of grantees' oversight of subrecipients is limited, leaving the agency's response to risk vulnerable in this area.
CNCS has not conducted the strategic workforce planning necessary to determine whether it has the people and resources to effectively monitor grantees' compliance with grant program requirements, as key principles for effective strategic workforce planning suggest. CNCS's workforce management activities to address vacancies have been largely ad-hoc, including vacancies in a key office responsible for grant monitoring, at senior levels across the agency, and among program and grant officers. Some of these vacancies reduced the number of fiscal year 2015 monitoring activities conducted. Further, program and grant officers' workloads varied across the agency, and CNCS has not evaluated whether staff have been deployed where they are most needed. Officials said they had not developed a strategic workforce planning process because of limited resources. Without such a process, CNCS's efforts to address workforce challenges may continue to be ad hoc and reactive.
section_title: What GAO Recommends
paragraphs: GAO is making six recommendations to CNCS, including to ensure that all grants are assessed for risk and that its scoring model prioritizes risk; to review its monitoring protocols; and to develop a strategic workforce planning process. CNCS and CNCS OIG provided technical comments, which were incorporated as appropriate.

section_title: Letter
paragraphs: Created in 1993, the Corporation for National and Community Service  (CNCS) administers a variety of volunteer and national service programs  for needs ranging from disaster recovery to improving education. In fiscal  year 2015, CNCS administered grants totaling about $750 million to  support national service, and CNCS reported that nearly 350,000  Americans participated in its major programs. CNCS is the nation’s  largest federal grantmaker for service and volunteering, and the agency’s  mission is to improve lives, strengthen communities, and foster civic  engagement through service and volunteering. However, recent reports  from the CNCS Office of Inspector General (OIG) have cited problems  with the agency’s grants management, noting that the agency does not  have a comprehensive risk management strategy and that its grant  monitoring system is inefficient and ineffective. You asked us to review  CNCS’s efforts to improve its grant monitoring. In this report, we examine  (1) CNCS’s process for grant monitoring; (2) the extent to which CNCS’s  process for grant monitoring aligns with relevant internal controls for  identifying, analyzing and responding to risk; and (3) the extent to which  CNCS has the capacity necessary to monitor grantees’ compliance with  grant program requirements.
To describe CNCS’s process for grant monitoring and improvements  under way, we reviewed agency documents, including policies,  procedures on assessment and monitoring, and reports from the CNCS  OIG for fiscal years 2015 and 2016. We also analyzed assessment and  monitoring data from eGrants, CNCS’s system of record for grant  monitoring activities, to identify the number of grants prioritized for  monitoring and the number and types of monitoring activities conducted  during fiscal year 2015 (the most recent complete fiscal year of data at  the time of our analysis). We determined that CNCS’s processes have  generally not changed since fiscal year 2015, and as a result, that the  data were reliable for the purpose of illustrating aspects of CNCS’s  current approach to grant monitoring. To further understand CNCS’s  monitoring processes and any efforts under way to improve monitoring,  we also interviewed agency officials in the Office of the Chief Risk Officer  (OCRO), Office of Grants Management, and Field Financial Management  Center, as well as officials from CNCS’s four largest programs, and  observed a compliance visit of a grantee in South Bend, Indiana, selected  based on geographic location from a list of visits to be conducted in late  summer 2016. Views of the program officials and observations from the  compliance visit are not generalizable to all programs or grantees.
To evaluate the extent to which CNCS’s grant monitoring process and  plans for improvement align with relevant internal controls for identifying,  analyzing, and responding to risk, we reviewed the internal control  principles in the Standards for Internal Control in the Federal Government  and selected those we determined to be most relevant to conducting  assessment and monitoring activities: principles on risk assessment,  control activities, and monitoring. We compared CNCS’s process—as  documented in policies, procedures, and plans—against these principles.  We also compared CNCS’s process with effective practices in federal  grants management, identified in prior GAO work. To obtain examples of  how CNCS’s monitoring activities can help identify and mitigate grantee  risk, we examined a small judgmental, nongeneralizable sample of eight  grants from those that eGrants data identified as having additional  monitoring needs, that were terminated early, or that OIG had cited as  having audit findings. We selected these eight grants to reflect a range of  different programs, geographic locations, and CNCS priority designations.  We then conducted semi-structured interviews with the seven program  officers and four grant officers responsible for monitoring these eight  grants. To gather grantee perspectives on CNCS’s assessment and  monitoring process, we also conducted four discussion groups with  grantees from two CNCS programs (AmeriCorps and Senior Corps) in  attendance at two 2016 agency-sponsored training conferences: one in  Reno, Nevada, and the other in Springfield, Massachusetts. We also  interviewed two grantees representing AmeriCorps State and National  (one state commission, and one grantee that operates in several states)  as well as officials from two professional associations that include CNCS  grantees: The National Council of Nonprofits and America’s Service  Commissions. The perspectives gathered from these interviews with  grantees and grantee organizations are not generalizable.
To evaluate the extent to which CNCS has the necessary capacity  (people and resources) to effectively monitor grantee compliance, we  assessed CNCS’s workforce management efforts against key principles  for effective strategic workforce planning identified in prior GAO work.  We also reviewed CNCS’s training practices against the federal internal  control standard relevant to workforce planning and competence and our  guide for assessing strategic training and development efforts. We  obtained CNCS documents regarding its workforce status and needs, and  analyzed eGrants data on the number of monitoring activities completed  in fiscal year 2015.
We conducted this performance audit from November 2015 to March  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: CNCS provides grants and technical assistance to organizations  throughout the United States to strengthen communities and foster civic  engagement. In fiscal year 2015, CNCS received appropriations totaling  over $750 million to fund a variety of grant programs, as shown in table  1. CNCS grants are typically for multiple years in duration.
In 1993, the National and Community Service Trust Act of 1993 was  enacted, which created CNCS and established the AmeriCorps State  and National grant programs. This law also gave the agency responsibility  for administering VISTA and Senior Corps. In 2009, the Serve America  Act was enacted, which gave CNCS responsibility to administer several  newly-established programs including the Social Innovation Fund. This  act also directed CNCS to focus more on evaluating its programs’  performance, and in 2012 we reported on the extent to which CNCS  funded activities were covered by its performance measures and on  performance measurement challenges. In addition, the Serve America  Act generally requires that grantees conduct criminal history checks on  volunteers and program employees in national service programs. Criminal  history check regulations have been in effect since November 2007 and  were expanded after the enactment of the Serve America Act to all  national service programs. Beginning April 21, 2011, the law generally  required that entities conduct three-part checks—including Federal  Bureau of Investigation, statewide registry or repository, and sex offender  registry checks—on individuals who will have recurring contact with  vulnerable populations.
CNCS’s Chief Risk Officer, Chief of Program Operations, and Chief  Financial Officer share responsibility for assessing and monitoring the  agency’s grants. Program officers and grant officers implement grant  monitoring activities and review grant applications. Program officers,  located in program offices overseen by the Chief of Program Operations,  focus on issues related to grantee performance and compliance with  program objectives. Grant officers, overseen by the Chief Financial  Officer, focus on grantees’ financial issues and performance. (See fig. 1.)
Federal law requires federal agencies administering programs identified  as susceptible to improper payments to estimate the improper payments  made by those programs and report annually on their efforts to reduce  improper payments. An improper payment is defined by statute as any  payment that should not have been made or that was made in an  incorrect amount (including overpayments and underpayments) under  statutory, contractual, administrative, or other legally applicable  requirements. In addition, the Office of Management and Budget’s (OMB)  guidance instructs agencies to report as improper payments any  payments for which insufficient or no documentation was found. Since  fiscal year 2012, the OIG has reported annually that the agency faced  challenges complying with improper payment laws. For example, the  OIG found that CNCS did not complete valid fiscal year 2015 improper  payment assessments for two of its programs: Senior Companion  Program (a Senior Corps program) and Social Innovation Fund.
section_title: CNCS Has a Process for Assessing Grants Annually to Prioritize Various Monitoring Activities
paragraphs: CNCS program and grant officers are responsible for implementing the  agency’s grant monitoring process, which includes activities from the time  before the grant award is made to when the grant is closed out, as shown  in figure 2.
Pre-Award. According to CNCS policy, during the pre-award phase  (before CNCS makes a grant award), grant officers are to assess the  applicant’s financial management capabilities and other aspects, such as  whether the grantee has any open audit findings on any current or prior  grants. CNCS officials generally are to perform these reviews before  making an award to a new or current grantee to determine if the grant  should be made.
Annual Assessment. To implement the annual assessment (performed  between August and October) CNCS personnel are to take the following  steps:
Step 1: determine which grants will be assessed. The universe of  grants to be assessed is to include all grants that are active at the  time CNCS is ready to begin the assessment, typically in mid-August  of each year, and that are expected to be active during the following  fiscal year.
Step 2: assess each grant in the universe identified in step 1 for  potential vulnerabilities related to program compliance, financial  weakness, or other issues.
Step 3: rate each grant as a high-priority, medium-priority, or low- priority for various monitoring activities, based on the assessment in  step 2.
Step 4: prepare an annual monitoring plan that identifies which grants  will receive monitoring visits, desk reviews, or financial reviews during  the coming year, based on the ratings in step 3. The plan is to be  prepared by the end of October.
More specifically, during step 2 of the annual assessment phase, CNCS  program and grant officers are to jointly assess each grant on 19 criteria  that are intended to reflect potential vulnerabilities related to program  compliance, financial weakness, or other issues. They are to enter their  responses into eGrants, which applies certain weights to each criterion  and calculates a score for each grant, up to a possible total of 760 points.  During step 3, CNCS officials group grants into three categories based on  the grant’s total score to determine the grant’s monitoring priority: high- priority (150 points or more), medium-priority (80 to 149 points), and low- priority (0 to 79 points). According to CNCS policy, each grant recipient  must generally receive a compliance visit by either the program or grant  officer every 6 years, so the grant is to be rated high priority for  monitoring if 5 years or more have elapsed since the last visit. Also, if a  grant receives a high-priority rating, CNCS program officers must  generally conduct a compliance visit, or an on-site training and technical  assistance visit in the upcoming fiscal year. If a grant receives a medium-  or low-priority rating, CNCS program officers can conduct a visit, with  supervisory approval, if they determine that it could help address known  issues or help prevent future problems.
To illustrate CNCS’s process, we reviewed CNCS grant data for fiscal  year 2015 (the most recent complete fiscal year of data available at the  time of our review). We found that in August 2014, CNCS had identified a  universe of 2,188 grants that were active at the time and expected to be  active during fiscal year 2015, and had assessed these grants to plan its  monitoring activities for fiscal year 2015. As shown in figure 3, CNCS  rated about 14 percent of these grants overall as high-priority for  monitoring, with some variation across the agency’s grant programs. For  example, 17 percent of AmeriCorps State and National grants included in  the assessment were rated high-priority, compared to 9 percent of VISTA  grants.
Finally, during step 4 of the annual assessment phase, CNCS officials are  to set the monitoring plan—which consists of compliance and other types  of visits, desk reviews, and financial reviews (such as drawdown  analyses)—for the fiscal year. A compliance site visit occurs on-site  where the grantee does its work, and reviews a wide range of compliance  issues following a structured protocol. Other types of visits which may be  included in the monitoring plan include:  follow-up visits, conducted to follow-up on a previous compliance site  visit, desk review, or a targeted / issue-based site visit;  targeted / issue-based site visits, conducted to address specific  issues, such as observing CNCS providers delivering  training/technical assistance services; and  training and technical assistance visits, conducted when the grantee  is a new grant recipient or there is a new program director, among  other situations.
Desk reviews also address compliance issues and can be targeted or  comprehensive in scope. For example, a program officer may conduct a  desk review of a grantee’s AmeriCorps position description to ensure the  description complies with legal requirements and agency policy.  Drawdown analyses are financial reviews that are conducted to determine  whether certain grantees are drawing down their funds in a timely manner  and whether the rate at which they draw down their funds is consistent  with the length of time (period of performance) for their award. For  example, if a grant has completed 50 percent of its period of  performance, then one would expect to see about 50 percent of funds  drawn down.
Monitoring. During the monitoring phase (performed between October  and August), program and grant officers generally are to implement the  monitoring activities described in the plan, but can either add or omit an  activity with supervisory approval for a number of reasons. For example,  program and grant officers may consider adding a monitoring activity for a  grant after the initial monitoring plan is set based on issues such as that  the OIG has identified findings with the grantee suggesting that the  grantee might be spending grant funds inappropriately. Also, CNCS  officials told us there are instances when a compliance visit is canceled,  which creates an opportunity to add a grant to the site visit schedule. To  illustrate, our analysis of CNCS grant data for fiscal year 2015 indicates  that the initial monitoring plan called for 358 grants to receive a  compliance visit; by the end of the fiscal year, 385 had been conducted  (see table 2). Most compliance visits were conducted with Senior Corps  and VISTA grants (programs with the highest number of grants).
When conducting a compliance visit, CNCS personnel—typically the  program officer—are to use a standard protocol to interview grantee staff  regarding compliance with program regulations and policy, including  financial accounting for grant funds. During these interviews, CNCS  personnel also are to review grantee documentation indicated by the  protocol to verify compliance. For example, program officers may ask  grantee staff how they are complying with the criminal history background  checks required by the Serve America Act, and may ask for  documentation such as reports received from law enforcement agencies.
Close-out. Finally, the close-out phase is to take place at the end of a  grant’s performance period. During this phase, CNCS officials are to  close out the grant by reviewing the recipient’s transactions and  expenditures reports, and reconciling them with records on the amounts  disbursed under the grant. Grantees may also submit a final  programmatic report of activities under the grant.
Improper payments. CNCS has a separate process for estimating  improper payments, although many of the items reviewed during  traditional grant monitoring are also reviewed during improper payment  reviews. To determine the extent of improper payments being made  through its grant programs, CNCS’s process calls for selecting a random  sample of Federal Financial Reports (the standard form approved by  OMB that federal agencies use to collect financial information) from each  program. The sampling is conducted such that records with a higher  dollar value have a proportionally higher chance of being included. For  each sampled Federal Financial Report, CNCS selects transactions and  reviews and tests related documentation in place at the time of the  payment. Because most of CNCS’s grant funds go to personnel-type  costs, CNCS primarily evaluates payments by grantees to individuals  working for or serving with that grantee, and verifies the eligibility of the  individual to receive those payments according to law, based on the  documentation produced at the time of the review. If all the required  documentation is not provided, the payment is considered an improper  payment in the estimation process. For example, in fiscal year 2015,  based on documentation provided during the improper payment review,  the Americorps State and National program was estimated to have $14.5  million in improper payments, mostly due to lack of documentation  confirming that criminal history checks were completed prior to making 15  payments to individuals. However, subsequent to the review, CNCS  confirmed that in several cases, individuals receiving payments were fully  eligible at the time of payment even though the criminal history check was  not yet complete, and that although some individuals received payment  prior to their documentation being provided, no payments were made to  ineligible individuals.
In a 2016 report, the OIG recommended that CNCS take action to  improve its methodology and reporting on improper payments, as well as  to implement procedures to hold grantees accountable for providing  documentation. In response, CNCS said it would take several steps to  improve its process for estimating improper payments, such as updating  its statistical sampling plan and revisiting the improper payment testing  and reporting approach, and developing more training. In addition, as of  fiscal year 2016, responsibility for conducting reviews and other activities  pursuant to improper payment laws was moved to the newly established  Office of the Chief Risk Officer (OCRO). Created in fiscal year 2016, the  OCRO is now responsible for overseeing and collaborating with agency  program and grant offices to develop and implement CNCS policies,  procedures, and guidance related to the agency’s risk framework, and to  coordinate the development and implementation of documentation and  reporting processes, including the improper payment review. The  OCRO is also responsible for developing and for delivering select training  and providing technical guidance and support to CNCS staff regarding the  implementation of the annual assessment.
In addition, according to CNCS officials, further changes to the grant  monitoring process are anticipated as the agency implements Enterprise  Risk Management (ERM). In 2014, OMB recommended that agencies  consider adopting ERM, which is an approach for addressing the full  spectrum of risks and challenges related to achieving the agencies’  missions. In 2016, OMB issued the revised Circular No. A-123, which  required that agencies begin to implement ERM in fiscal year 2017.
section_title: CNCS’s Process Is Not Fully Aligned with Internal Controls for Risk Assessment, Control Activities, and Monitoring
paragraphs: CNCS’s grant monitoring process includes efforts to identify and mitigate  risks but does not fully align with relevant internal control principles for  risk assessment, control activities, and monitoring (see fig. 4).  Specifically, the agency’s annual assessment process may not result in  the riskiest grants receiving a high-priority for monitoring because of  limitations in its scoring model. Also, the annual assessment process  does not ensure all grants are included. Further, the agency’s monitoring  of grantees’ oversight of subrecipients is limited. Finally, CNCS has not  systematically evaluated its monitoring efforts to identify opportunities to  improve its assessment of and response to risks.
subsections: section_title: Limitations in CNCS’s Scoring Model Affect Identification and Monitoring of Risk
paragraphs: CNCS’s indicators used in its scoring model have limitations that may  result in the riskiest grants not receiving a high priority designation for  monitoring and that do not meaningfully cover all identifiable risks, such  as fraud and improper payments. This is largely because the scoring  model is designed to support CNCS’s monitoring policy by identifying  grants due for a monitoring visit, rather than for specifically assessing risk  and using this risk information to drive prioritization of monitoring  activities. To this end, we found that CNCS’s process for assessing and  monitoring its grant portfolio has a number of limitations that prevent it  from being fully aligned with the internal control standard stating that  management should identify, analyze, and respond to risks related to  achieving the defined objectives.
First, we found that some indicators that are not based on risk are given  considerable weight in the rating process, while others that are based on  risk are given much less weight—far less than the 150 points needed to  be designated high priority for monitoring. As shown in figure 5, only one  indicator is given sufficient weight on its own to result in a grant being  assigned a high-priority for monitoring: “time since last on-site compliance  visit” (150 points). According to CNCS guidance, this indicator supports  the agency’s efforts to ensure compliance monitoring visits are conducted  every 6 years, in accordance with agency policy. Agency guidance further  states that this indicator is important because potential vulnerabilities may  increase as time between visits lengthens. It is important to conduct  monitoring visits periodically as required; however, as noted by one  officer we spoke with, the amount of time elapsed since the last visit does  not necessarily indicate risk. In contrast, the indicator for “prohibited  activities” is given much less weight (30 points), even though prohibited  activities constitute a significant risk because they are an unallowable use  of federal funds. As a result, a check for this indicator may only result in a  grant being assigned medium-priority for monitoring and, according to  CNCS policy, a monitoring visit or desk review is not required for a grant  that receives a medium-priority rating. Of the 25 grant awards with “yes”  on the prohibited activities indicator in fiscal year 2015, nearly two-thirds  were designated as medium priority, and 17 of the 25 did not receive a  compliance visit or other monitoring activity that year. Similarly, the  indicator for “financial competency” is given even less weight (20 points).  A grant would get a “yes” on this indicator if a bankruptcy filing had been  made or an intent to file had been announced, or if another federal or  state agency had notified CNCS regarding a weakening of an  organization’s financial competency. However, a “yes” on this indicator  only contributes 20 points to the 150 needed to be designated high  priority for monitoring.
Second, we found that several potential risk factors were included in a  single indicator: “other key concerns and challenges” (80 points).  According to CNCS’s scoring model, a grant would receive a score for  this indicator only once, even if it demonstrated the potential for multiple  risks. For example, this indicator includes open compliance findings,  improper payment findings, and the potential for financial management  problems. This indicator also includes any findings from the pre-award  review, which CNCS conducts under federal grants management  guidance established by the Office of Management and Budget (OMB),  referred to as the Uniform Guidance. A grant that receives a “yes” for  this indicator in the scoring model would not receive a high-priority  designation on its own, regardless of the severity of the risk or how many  of these concerns are noted. Several CNCS grant and program officers  we spoke with noted that it may be more useful if some of these potential  risks stood alone rather than grouping them together in a single indicator.  For example, to give improper payment findings greater weight, one  officer suggested there should be an indicator solely based on these  findings. Other officers suggested that compliance findings regarding  criminal history checks should be elevated to its own indicator, to flag  potential or past compliance problems in this area. Another officer  suggested that compliance findings regarding concerns with supervision  of volunteers should be highlighted through an indicator of its own,  because this can indicate problems with prohibited activities.
Third, we found that some indicators may not be calibrated effectively to  capture risk. For example, CNCS’s scoring model includes an indicator  that identifies whether a grantee has problems with volunteer retention  (“participant enrollment and retention”), but this indicator is only marked  “yes” if the retention is below 50 percent for 1 year, or 75 percent for 2  years. AmeriCorps State and National program office staff we interviewed  told us that 50 percent retention is considered very low, and they would  prefer to intervene before performance had dropped to this level.
Lastly, we found that several indicators are too frequently applicable to be  useful in distinguishing relative risk among grants. For example, 4 of the  19 indicators were checked ”yes” for more than a quarter of the grants  assessed, which could indicate that they have minimal impact in  distinguishing among grants to determine their priority status for  monitoring. One indicator—”multiple awards”—was checked for nearly  half the grants assessed.
In addition to these limitations in the scoring model, CNCS has not clearly  documented its assessment scoring process, although internal controls  suggest that documentation could contribute to the effectiveness of this  activity. The rationale is unclear for why CNCS has defined its indicators  and assigned their weights the way it has, and outcomes from this  process are not well-documented. CNCS has a monitoring workgroup that  is charged with, among other duties, reviewing the indicators used for the  annual assessment and determining whether the point value for each  indicator needs to be changed. However, CNCS does not have  documentation on the criteria used for selecting the 19 indicators or  determining their weights. Decisions on changes to the scoring are also  not well-documented, and it is unclear how the group decides which  indicators are most important. CNCS officials said that the original  documentation on indicator selection was not maintained because it was  outside the records retention time frame, and in recent years, limited staff  capacity contributed to the agency not documenting its decisions on  changes to the indicators. Improving documentation on the rationale for  CNCS’s decisions on indicators and scoring could help the agency revise  its indicators in the future to improve their relevance and effectiveness.
CNCS has begun various efforts that could lead to improvements in the  scoring model used to support the agency’s assessment process, but all  of these efforts are in the early stages of development and their ultimate  effect is not yet clear. For example, according to the agency’s first Chief  Risk Officer, who came on board in April 2016, the OCRO is undertaking  an effort to benchmark CNCS’s assessment criteria and process against  other federal agencies and programs with similar grantee profiles (that is,  the agency or program funds grantees with varying levels of financial,  administrative, and staff capacity). As of July 2016, the OCRO had  gathered information from six federal programs and planned to contact  several more. In addition, officials said that the Field Financial  Management Center, one of CNCS’s two grant offices, had also begun  development of a pilot to develop additional indicators of risk, based on a  review of past performance of 10 Senior Corps grants and analysis of  related data. They said they hope that the results of the pilot will inform  future changes to the assessment process, but it is too early to tell at this  point how relevant the results will be to other programs. Finally, officials  also told us that, as part of the agency’s plan for implementing Enterprise  Risk Management (ERM) under OMB’s revised Circular A-123, CNCS  held listening sessions with senior management in spring 2016 to gather  their perspectives on key agency risks and began conducting similar  sessions with CNCS staff in fall 2016. Officials said that they plan to use  this information to create an agency-wide risk profile. Also, in response to  the focus on fraud in OMB’s revised circular, CNCS had included fraud as  a topic in its listening sessions with senior management. However, it  remains to be seen the extent to which identification of these top risks  agency-wide, including the potential for fraud, will result in changes to the  assessment indicators for grant monitoring. As of September 2016,  CNCS had not included any indicators of fraud risk in its assessment  process.
section_title: CNCS Does Not Have a Policy to Assess All Grants Annually, and Some Are Not Assessed
paragraphs: CNCS does not have a policy to ensure all grants, including those  awarded after the annual assessment is complete, are assessed for  potential risk in the current year. Delaying grants from being included in  this process limits CNCS’s ability to identify and analyze the significance  of certain risks in its grant portfolio, which is inconsistent with internal  controls for risk assessment and control activities. As described earlier,  CNCS’s policy and procedures call for its assessment process to begin in  August each year to guide its monitoring activities for the fiscal year that  will start in October. CNCS determines the universe of grants to be  assessed and uses its tool of 19 indicators to assign a priority rating  category for monitoring the grants in this universe. CNCS officials said  that new grants are particularly vulnerable to being omitted from the  assessment process, as these grants tend to be finalized just before the  beginning of the new fiscal year when the annual assessment may  already have been completed. However, without including new grants in  the annual assessment process, CNCS cannot identify and analyze the  significance of these risks, and use this information to prioritize these  grants for monitoring activities, such as a site visit. As noted by one  program officer we spoke with, an initial visit to a first-time grantee can  identify issues that would not have otherwise been raised, and can  prevent future problems.
Officials acknowledged that the agency does not have a policy regarding  how and when to assess grants made after the annual assessment  process is conducted in August, and that in practice, these grants are not  assessed using its tool of 19 indicators until the following fiscal year’s  assessment process if the grant is expected to be active for a second  year. This was the case with one grant included in our selected review of  eight grants with negative outcomes. The grant, funded at over $200,000  in each of 3 years, was awarded on September 30, 2012, but was not  assessed until the summer of the following year. Once assessed, it was  deemed high-priority, but was nevertheless subsequently relinquished by  the grantee in light of non-compliance findings. Had the grant been  assessed as high-priority in its first year, and had it been assigned  monitoring activities accordingly from the beginning, the compliance  problems may have been avoided.
Due to data limitations, we were unable to determine the extent to which  new grants were not included in the annual assessment and received no  monitoring in fiscal year 2015. However, using data on monitoring  activities, we identified 44 newly-awarded grants that were not assessed,  but nevertheless had received monitoring. It is unclear how CNCS  determined that these grants, but not others, warranted monitoring.  Without establishing and implementing a policy to ensure that all grants  are assessed for potential vulnerabilities in the current year, CNCS may  not be using its monitoring resources most effectively, focusing on the  highest-risk grants.
section_title: CNCS Conducts Limited Monitoring of Grantee Oversight of Subrecipients
paragraphs: CNCS conducts limited monitoring of grantees’ oversight of their  subrecipients, despite the large amount of grant dollars involved and  evidence indicating that subrecipient oversight is a key risk area.  According to CNCS, two of CNCS’s largest programs, AmeriCorps State  and National and Social Innovation Fund (SIF), allow their grantees to  have subrecipients, involving a significant amount of grant funds— almost half of CNCS’s total grant budget in fiscal year 2015. Data  included in the agency’s fiscal year 2015 financial report shows that  CNCS awarded about $300 million in grants to state commissions that  subgrant the funds to organizations in the states to run AmeriCorps  programs. Similarly, the report states that CNCS awarded the entire  portfolio of SIF grants, about $70 million, to intermediaries that are  required to make subawards to other organizations. Subrecipient  oversight also has been identified as a key risk area. For example, in prior  work, GAO has concluded that effective practices for overseeing  subrecipients are a critical element of ensuring grant funds are used for  intended purposes.
OMB’s Uniform Guidance established oversight requirements for pass- through entities, such as CNCS’s state commissions, that provide funds  to other organizations. CNCS conducts monitoring activities to review  grantees’ compliance with these and other requirements. However, an  OIG investigation identified concerns about CNCS subrecipients,  indicating that additional subrecipient oversight may be needed. Among  the selected program and grant officers we interviewed (who were  responsible for monitoring the eight grants in our nongeneralizable  sample of grants with negative outcomes), four identified problems with  grants resulting from issues with subrecipients. For example, one CNCS  officer told us about a grantee that lost nearly half of its subrecipients over  2 years (from 11 subrecipients to 6); another said the grantee could not  implement its program because of problems with subrecipients.
To monitor their grantees’ oversight of subrecipients, CNCS programs  with subrecipients have developed provisions for subrecipient oversight  as part of their programs’ standard protocols. However, we found these  provisions to be limited in certain areas, such as criminal history checks  (see table 3), even though, in fiscal year 2015, CNCS reported that nearly  all of its estimated reportable improper payments stemmed from problems  with conducting or documenting criminal history checks. For example,  the AmeriCorps State and National program monitors a grantee’s  oversight of subrecipient compliance with criminal history checks by  reviewing a total of 25 volunteer and staff files, but there is no  requirement to select the files based on the number of subrecipients, or  size of grant. Officials told us that the largest AmeriCorps State grantee  had five grants with a total of 55 subrecipients. Further, the SIF  program’s protocol requires review of 3 employees from a minimum of 3  different subgrantees or subrecipients to gauge compliance; however, the  SIF program has had one grantee with as many as 47 subgrantees, and  four grantees with 20 or more subgrantees. As a result, the monitoring  approach of these CNCS programs may cover only a small portion of  their grantees’ subrecipients in some cases. In addition, both programs  check that the grantee has a plan for overseeing its subrecipients, but the  AmeriCorps State and National program protocol does not require a  review of the results of these activities, such as subrecipient progress  reports or monitoring findings.
CNCS officials acknowledged that ensuring grantees are overseeing  subrecipients is an ongoing challenge. One officer we interviewed  suggested that it could be helpful for CNCS to obtain more information  from its grantees on how they are managing their subrecipients.  Gathering additional information about subrecipients by improving  monitoring protocols could help CNCS to ensure that its grantees are  overseeing subrecipients appropriately. CNCS officials said they have  some plans to update monitoring protocols to address certain risks, but  did not provide timeframes for doing so, and it is unclear whether all  areas of subrecipient oversight will be addressed.
section_title: CNCS Has Not Systematically Evaluated Its Monitoring Efforts
paragraphs: CNCS has not systematically evaluated the results of its monitoring  activities, as called for by internal controls. Officials said that the  agency’s monitoring workgroup holds an annual discussion of the year’s  monitoring activities, but CNCS does not compile monitoring findings,  such as types of compliance problems or errors identified, systematically  across all programs. Moreover, CNCS has not used data systems for  summarizing monitoring findings to use in trend analyses or to evaluate  opportunities for improving its monitoring efforts.
A senior official said they had not conducted agency-wide analyses of  their monitoring efforts because eGrants does not provide reports that  include both assessment information and monitoring results for each  grant, and because the agency has had limited staff capacity to manually  analyze this data given these limitations in reporting. In addition, officials  said that CNCS does not have standardized reporting or longitudinal data  to facilitate evaluation of the effectiveness of CNCS’s monitoring efforts,  although they acknowledged that both would be helpful. With respect to  assessment information, the “yes” or “no” data captured in eGrants from  the annual assessment process for each of the 19 indicators cannot be  easily analyzed for trends. For example, for the indicator on grantee  volunteer retention, the eGrants system records a “yes” or “no” for each  grant depending on whether the grantee’s retention is above or below the  indicator’s threshold, rather than capturing the actual percentage of  volunteers retained.
With respect to monitoring results, each program office has a monitoring  tool to complete when conducting on-site monitoring, but these tools are  not integrated so that the results can be analyzed within the eGrants  system. As a result, some program officers we spoke with described  manual approaches they sometimes used to assess common findings  from their monitoring activities within their programs. For example, they  have used compliance visit letters—sent to grantees to summarize  compliance visit findings—to determine the effectiveness of monitoring  and track trends. CNCS officials told us that, as of November 2016, the  agency was developing the requirements for the monitoring component of  the agency’s new IT system. In developing these requirements, CNCS  has the opportunity to provide additional functionality to support  evaluation of its assessment and monitoring efforts. However, in the  meantime, a more formal effort to summarize monitoring results across all  programs could help identify trends and areas for improvement.
CNCS officials also said that they have not fully evaluated the  effectiveness of the types of monitoring activities the agency conducts  and whether a different mix of these activities could result in improved  monitoring outcomes, although the monitoring workgroup has discussed  the need to do so. In particular, officials said that because on-site  compliance visits can take up to three days and can be very costly, it  would be helpful to have a lower-cost alternative, such as a desk review.  According to CNCS policy, monitoring may consist of a visit or a desk  review. However, we found that in fiscal year 2015, of the 506 grants that  received a monitoring activity, only 9 received desk reviews. Several  grant and program officers we spoke with commented that greater use of  desk reviews could be helpful for identifying and responding to potential  risks.
section_title: CNCS’s Monitoring Capacity Needs Are Unclear Because It Has Not Conducted Strategic Workforce Planning
paragraphs: CNCS has not conducted the strategic workforce planning necessary to  determine whether it has the capacity—including both people and  resources—to effectively monitor grantees’ compliance with grant  program requirements. CNCS included plans to conduct a strategic  workforce planning process in the agency’s strategic plan for fiscal years  2011 through 2015, but these plans were not implemented. Further,  CNCS does not have a training planning process aligned with agency  goals and competencies to help ensure program officers who have similar  grant monitoring responsibilities receive the same needed training to  perform their jobs effectively.
subsections: section_title: CNCS Does Not Have a Strategic Workforce Planning Process
paragraphs: CNCS has not developed or documented a strategic workforce planning  process as key principles for effective strategic workforce planning  suggest. Without such a planning process, CNCS’s efforts to address  gaps in staffing due to attrition have been ad hoc and reactive. In  addition, CNCS has not established whether differences in workload  among grant and program officers in different programs and locations are  reasonable, or if these differences also result from ad hoc responses to  attrition. Internal controls suggest that agencies demonstrate commitment  to various workforce planning activities, such as succession planning, so  that vacancies in key roles are filled with competent staff and that the  entity can continue achieving its objectives.
CNCS has experienced considerable attrition over the past few years in  positions that affected the agency’s capacity to conduct key monitoring  functions, including staff in the OCRO (previously the Office of  Accountability and Oversight), program and grant officers, and other  officials at high levels within the agency. Specifically:
OCRO: Nine of 13 staff in OCRO separated from CNCS in fiscal year  2015. According to the CNCS OIG, as a result of this attrition, as  well as the departure of key OCRO staff members at the beginning of  fiscal year 2016, this office had few, if any, staff members with  sufficient training or experience in grant monitoring and improper  payment assessments, among other responsibilities. Further, in its  fiscal year 2015 financial report, CNCS reported that insufficient staff  in this office limited its ability to conduct improper payment reviews.  More recently, CNCS officials noted that the only staff person in the  OCRO with the knowledge to interpret reports on aggregated data  from the grant assessment component of CNCS’s eGrants information  system left the agency in August 2016. At this time, CNCS was also  completing fiscal year 2016 monitoring and beginning the fiscal year  2017 process, which officials said was challenging in the absence of  OCRO staff with eGrants expertise. Officials also acknowledged that  due to staffing and leadership changes, reviews of eGrants data had  become infrequent.
Program and grant officers: During fiscal year 2015, vacancies  occurred in 15 program officer and 4 grant officer positions. Officials  said that CNCS’s efforts to refill positions were handled on an ad-hoc  basis, without a strategy for addressing turnover trends throughout the  agency to maintain critical skills for monitoring and oversight. Our  analysis of CNCS data indicate that these vacancies had an impact  on the number of monitoring activities conducted in fiscal year 2015.  Specifically, at least 58 desk reviews, drawdown analyses, and  monitoring visits planned for fiscal year 2015 monitoring were not  completed or were delayed because of staff shortages, in particular  the loss of two grant officers. Several program and grant officers told  us that turnover had also affected their workload, often requiring them  to manage additional grants. For example, one grant officer said that  in addition to his responsibilities for monitoring Senior Corps and  VISTA grants, he took on monitoring responsibilities for 40 to 45  additional grants when a grant officer left the agency.
High-level officials: CNCS has also experienced considerable  turnover of senior officials over the past few years. Between fiscal  years 2012 and 2015, the Director of Accountability and Oversight,  Chief Financial Officer, Chief Information Officer, Chief Human Capital  Officer, and General Counsel departed the agency. In addition, the  Director of the Office of Grants Management and the Director of the  Field Financial Management Center also left during this time.
In a previous report, we examined best practices for workforce planning  based on a review of studies by leading workforce planning organizations  and federal agency workforce planning practices, and concluded that a  strategic workforce plan is essential to addressing two critical needs: (1)  aligning an organization’s human capital program with its current and  emerging mission and programmatic goals; and (2) developing long-term  strategies for acquiring, developing, and retaining staff to achieve  programmatic goals. In that report, we identified five principles that  agencies should follow for effective strategic workforce planning:  leadership involvement; determining critical skills and competencies;  developing strategies to address gaps; building capacity to support  workforce planning; and monitoring and evaluating progress toward  human capital goals and programmatic results.
We found that CNCS’s most recent strategic plan (for 2011-2015) had  called for developing and implementing a strategic workforce plan that  reflects a workforce assessment, identifies new competencies, and  includes an ongoing assessment of CNCS’s key work requirements;  however, as of fall 2016, the agency had not yet taken these actions, and  the agency does not have a strategic plan in place for fiscal year 2016 or  beyond. CNCS officials said that they recognize the importance of  strategic workforce planning—which can help with key agency functions  such as grant monitoring—and that efforts to refill vacancies had been ad  hoc, but that they had not yet had an opportunity to begin such planning  because of limited resources. In October 2016, officials said they would  begin strategic workforce planning soon, but could provide no time frames  or documentation about its planned efforts.
In addition, we found that the planned monitoring workloads and  responsibilities of program and grant officers varied across the agency,  and that CNCS had not evaluated whether these differences reflect an  appropriate deployment of resources to monitor grantees effectively. For  example, data from eGrants showed that, across CNCS’s offices,  program officers’ workloads ranged from 1 to 13 planned monitoring  activities, while grant officers’ workloads ranged from 1 to 44 planned  monitoring activities. Some grant officers and program officers we  interviewed noted that not all grants require the same amount of time to  monitor. For example, certain grantees require more day-to-day  communication, depending on such things as their capacity, experience,  and number of subrecipients. Program and grant officers also described  recent changes to their workloads resulting in part from more  comprehensive grant application reviews. A CNCS program management  official told us that increasing responsibilities for grant application reviews,  resulting from new initiatives and partnerships with other federal  agencies, had reduced the amount of time available for grant  monitoring.
While the program or office where an officer works might explain some  workload differences, CNCS officials told us that they have not evaluated  whether staff have been deployed to the offices where they are most  needed for grant monitoring. As a result, it is unclear if workload  differences are reasonable or if they are affecting the agency’s capacity to  monitor grantees effectively. Senior officials said that the grant monitoring  workload distribution is based on the results of the annual assessment  process, but they do not balance the number of high-value, high priority  grants for monitoring across grant and program officers. Instead, their  reviews of the effectiveness of the agency’s workload distribution to meet  its monitoring objectives have been ad hoc. In the absence of a strategic  workforce planning process that fully incorporates and is consistent with  key principles for effective strategic workforce planning, CNCS’s efforts to  address gaps in staffing and to deploy program and grant officers where  they are most needed may continue to be ad hoc and reactive.
section_title: CNCS Does Not Ensure Program Officers Are Offered or Receive Training in Key Areas
paragraphs: CNCS does not ensure that all program officers with similar grant  monitoring responsibilities are offered or receive the same needed  training to perform their jobs effectively, as suggested by internal  controls. Although program officers have been asked to conduct fiscal  monitoring, not all CNCS offices have planning processes that ensure  their program officers receive training on this topic. In addition, CNCS’s  planning process for training is not aligned with agency goals and critical  competencies, which was identified in GAO’s guide for assessing training  as a way to focus strategically on improving performance.
We reviewed CNCS’s training plans for new staff and lists of training  offered to staff in each office and found that training offerings vary by  office, including training on certain key areas of grant monitoring  responsibility (see table 4). Program officers in the AmeriCorps State and  National program office generally did not receive training on fiscal  monitoring, even though they have been asked to conduct fiscal  monitoring. Similarly, in fiscal year 2015, grant officers did not receive  ongoing training on CNCS’s grant monitoring practices, although officials  said that grant officers received this training in fiscal year 2016. While  officials said that program officers in the Office of Field Liaison received  training on fiscal monitoring, four program officers that we interviewed  said that they needed additional training on fiscal monitoring, in part to  help them better understand fiscal terminology and review financial  documents. One of the four program officers noted that because she is  not as familiar with fiscal monitoring, she sometimes had to contact her  grant officer with fiscal compliance questions while conducting a  monitoring visit. In addition, a grant officer told us that training on CNCS’s  grant monitoring tool, including specific examples of information that  could be provided to respond to questions on the tool, would help grant  and program officers meet their monitoring responsibilities more efficiently  and effectively.
Officials told us that variation in training opportunities occurred because  each program and grant office is responsible for planning training for their  staff at the individual level, and practices varied. At the office level, each  CNCS office meets with the Office of Human Capital to discuss skills  gaps, needs, and priorities of staff. For example, they consider such  issues as training required by law and the number of staff in need of  particular training. The Office of Human Capital administers a training  needs survey to each office at the beginning of each fiscal year. At the  individual level, officials told us that each year, employees work with their  supervisors to develop a workplan that includes training requirements.
However, CNCS’s training planning process is not aligned with agency  goals and critical competencies, as GAO’s guide for assessing training  identified as essential for effective performance. In GAO’s guide for  assessing training, we state that it is essential that agencies ensure  training and development efforts are undertaken as an integral part of,  and are driven by, their strategic performance planning processes. By  taking this approach, agencies can help ensure that their training and  development efforts are not initiated in an uncoordinated manner, but  rather are focused on improving performance toward their goals as laid  out in their strategic plan. Well-designed training and development  programs, linked to agency goals and to the organizational, occupational,  and individual skills and competencies, are needed for the agency to  perform effectively. In our review of the documents outlining CNCS’s  planning process for training, we found no links to agency goals for grant  monitoring and associated competencies for program and grant officers.  CNCS officials said that they have not reviewed competencies or  assessed gaps in critical skills and competencies agency-wide since  2008, and that they have been continuing to operate under a 2011-2015  strategic plan. In September 2016, CNCS officials said that they plan to  build an employee development program, but it is unclear whether this  effort will link training to agency goals and competencies for program and  grant officers. In the absence of a training planning process linked to  current agency goals and competencies, program and grant officers may  continue to receive inconsistent training opportunities, and the  opportunities provided may not fully address important aspects of their  grant monitoring responsibilities.
section_title: Conclusions
paragraphs: CNCS programs support efforts across the country designed to  strengthen communities and foster civic engagement through service and  volunteering. To do this, CNCS awards grants totaling hundreds of  millions of dollars annually and must ensure that those funds are used in  accordance with program rules and federal requirements, such as OMB’s  new Circular A-123. In particular, as CNCS implements these new  requirements, further emphasis on assessing and responding to risks, as  well as taking an agency-wide, strategic approach to its workforce  planning, will be key to strengthening CNCS’s ability to effectively monitor  its grants and to move toward a risk-based approach to these activities.
Although CNCS has an assessment process for prioritizing grants for  monitoring activities, there are limitations in the scoring model that  underpins this assessment process. These limitations result in a process  that does not fully identify potential risks, such as the potential for fraud,  or result in the riskiest grants receiving the highest priority for monitoring.  Further, some grants are not included in this assessment process, but are  monitored regardless and without the benefit of information from the  assessment. In addition, available documentation does not indicate how  CNCS developed its indicators or their scoring, or how the agency has  changed them over time. Taken together, these issues create  vulnerabilities for CNCS in its ability to meet federal standards for internal  control with respect to risk assessment, control activities, and monitoring  principles. CNCS’s efforts to benchmark its assessment criteria and pilot  new risk indicators are positive steps in enhancing its approach to  assessing risk and determining monitoring priorities; however, these  efforts are in their early stages. Going forward, it will be important for  CNCS to complete its benchmarking efforts and ensure that information  from these efforts is used to address the limitations we identified in the  agency’s scoring model and in documenting its decisions about it.
Further, CNCS conducts limited reviews of how its grantees oversee their  subrecipients, although subrecipient performance is critical to grant  success. Reviewing monitoring protocols to ensure that they include  collection of information on grantees’ oversight of subrecipients’ activities  will help to identify and mitigate any risks posed by subrecipients. Also,  CNCS has not evaluated its monitoring activities or gathered data  systematically to enable analysis of how well its current efforts assess  risk. By reviewing the outcomes and findings from its monitoring activities,  CNCS will be better positioned to improve these processes and  determine the effectiveness of these activities.
CNCS has taken some steps in workforce planning to fill vacancies in  monitoring staff and key senior management positions, but the agency  has not developed a strategic workforce planning process, which would  help to address its workforce challenges at a strategic, agency-wide level.  In addition, departures of senior officials and staff with grant monitoring  responsibilities have affected the agency’s capacity to conduct key  monitoring functions; but these departures were handled on an ad-hoc  basis, without efforts designed to maintain critical skills for monitoring and  oversight. Meanwhile, staff workloads and responsibilities have changed  due to staff turnover and other factors, but CNCS has not reviewed its  workload distribution on an agency-wide level. In order to ensure the  agency can effectively monitor its grantees, it will be important for CNCS  to take a strategic approach to workforce planning in order to address  current and future agency needs. Finally, CNCS does not ensure that all  program officers have opportunities for or receive training on their grant  monitoring responsibilities, particularly for fiscal monitoring. Its training  planning process is not aligned with agency goals and competencies, and  the agency has not reassessed these competencies in a number of years.  Updating competencies for grant monitoring and planning training to  address agency goals and critical competencies would help CNCS  ensure that its workforce can meet current and future grant monitoring  needs.
section_title: Recommendations for Executive Action
paragraphs: To improve CNCS’s efforts to move toward a risk-based process for  monitoring grants and to improve its capacity for monitoring grantee  compliance, we are making the following six recommendations to the  Chief Executive Officer of the Corporation for National and Community  Service:  1.  Ensure that CNCS completes its efforts to benchmark its assessment  criteria and scoring process to further develop a risk-based approach  to grant monitoring and that information from this effort is used to (a)  score the indicators so that the riskiest grants get the highest scores;  (b) revise the assessment indicators to meaningfully cover all  identifiable risks, including fraud and improper payments; and (c)  document decisions on how indicators are selected and weighted.  2.  Establish and implement a policy to ensure that all grants expected to  be active in a fiscal year, including those awarded after the annual  assessment, are assessed for potential risk.  3.  Review monitoring protocols, including the level of information  collected for oversight of subrecipients’ activities such as criminal  history checks, and enhance protocols, as appropriate.  4.  Establish activities to systematically evaluate grant monitoring results.  5.  Develop and document a strategic workforce planning process.  6.  As part of CNCS’s efforts to develop an employee development  program, update critical competencies for grant monitoring, and  establish a training planning process linked with agency goals and  these competencies.
section_title: Agency Comments
paragraphs: We provided CNCS a draft of this report for review and comment. CNCS  did not comment on the report’s findings or recommendations, but did  provide technical comments, which we incorporated as appropriate. We  also incorporated technical comments received from CNCS OIG, as  appropriate.
We are sending copies of this report to the appropriate congressional  committees and the Chief Executive Officer of the Corporation for  National and Community Service. In addition, the report is available at no  charge on the GAO website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-7215 or bawdena@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix II.
section_title: Appendix I: State-by-State Data on Corporation for National and Community Service (CNCS) Grants
section_title: Appendix II: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Margie K. Shields, Assistant  Director; Dana Z. Hopings, Analyst-in-Charge; Jason S. Palmer; and  Sarah M. Martin made key contributions to this report. Alexander G.  Galuten, Monica P. Savoy, Ruben Montes de Oca, Kathleen van Gelder,  Michael L. Kniss, Amy Sweet, Nicholas Weeks, and James E. Bennett  also provided assistance.