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Corporation For National And Community Service: Better Internal Control and Revised Practices Would Improve the Management of AmeriCorps and the National Service Trust

GAO-04-225 Published: Jan 16, 2004. Publicly Released: Feb 20, 2004.
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Highlights

The Corporation for National and Community Service (the Corporation) was created to help meet community needs and expand educational opportunity by providing education awards to participants. The Corporation oversees and funds the AmeriCorps program as well as the National Service Trust (the Trust), which pays the education awards. From November 2002 to March 2003 the Corporation suspended AmeriCorps enrollments because there would not have been sufficient funds in the Trust to pay education awards. GAO was asked to determine (1) if all AmeriCorps enrollments were accurately recorded, (2) how the Corporation estimated its funding needs, and (3) if the Corporation made changes to prevent another enrollment suspension and to address requirements established in the Strengthen AmeriCorps Program Act. GAO analyzed laws, reviewed documents, interviewed officials, assessed the reliability of the Trust database, examined the model used to estimate funding needs, and surveyed Americorps grantees.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Corporation for National and Community Service To ensure the National Service Trust receives accurate data for use in its model estimates and Trust database, the chief executive officer of the Corporation for National and Community Service should implement a strategy to correct discrepancies between the Trust database and the enrollment and exit forms.
Closed – Not Implemented
The Corporation agreed with this recommendation. Data supporting member enrollment and exit status is maintained by the Corporation's grantees, which are primarily nonprofit organizations and state governments. Grantees are required to obtain an audit under OMB Circular A-133. For the AmeriCorps program, OMB Circular A-133 requires testing of enrollment and exit data submitted by grantees to the National Service. In December 2004, officials reported that the Corporation had reemphasized with its grantees, state offices and sponsors the importance of timely processing of member exit information. The Corporation also noted that it would regularly review performance in this area to ensure...
Corporation for National and Community Service To ensure the National Service Trust receives accurate data for use in its model estimates and Trust database, the chief executive officer of the Corporation for National and Community Service should review and document the effectiveness of its data assurance processes.
Closed – Implemented
In 2008, the Corporation began phasing out its primary reporting system--WBRS--and moving its functions to a new system--the My AmeriCorps portal. All transactions that have implications for the Trust will be performed in this portal once it is fully functional. The Corporation opted to make this conversion because WBRS would require a number of updates to reflect policy changes in the AmeriCorps programs and the portal is designed in a manner that allows consolidating data from multiple systems. In January 2008, the Corporation's OIG reported that the Corporation had adequate controls to: (1) allow only the refilling of slots vacated by members who served less than 30 percent of their...
Corporation for National and Community Service To ensure the National Service Trust receives accurate data for use in its model estimates and Trust database, the chief executive officer of the Corporation for National and Community Service should regularly verify the accuracy of the SSNs of its participants.
Closed – Implemented
The Corporation reported that it submitted nearly 85,000 SSNs (45,605 for FY 2002 and 38,967 for FY 2003) to the Social Security Administration (SSA) for verification in April 2004. The results of the verification were received back from SSA in May 2004 and more than 96% of the SSNs matched without any errors. The files containing the errors were sorted and distributed to the field offices to research and verify the information by comparing to original documents, such as the social security cards of the members, and checking for typographical or data entry errors. The Corporation completed several requests for documents and received approximately an 85% response rate. In December 2004,...
Corporation for National and Community Service To better ensure that the Corporation for National and Community Service has data that are readily available and is positioned to continue operations in the event of a disaster, emergency, or employee turnover, the chief executive officer of the Corporation should update the users' manual for the National Service Trust database and develop an inventory of edit and data checks used for the database.
Closed – Implemented
According to Corporation officials, the Corporation has strengthened the documentation within Oracle Designer by implementing more rigorous style guidelines and adding additional details to the current data dictionary to enable it to be more user-friendly. Several projects have further enhanced the documentation of all aspects of the entire eSPAN system. These include: (1) a documentation style guide; (2) the incorporation of RoboHelp for all online help documentation; and (3) a Report Library, which will serve as repository for all system report requests. To further increase the accuracy of the system documentation, a Business Intelligence project was undertaken to scrutinize the data...
Corporation for National and Community Service To provide additional assurance over internal control and to minimize the related risks, the chief executive officer of the Corporation for National and Community Service should obtain an auditor's opinion on the adequacy of the internal control over financial reporting as part of the annual financial statement audit.
Closed – Not Implemented
The Corporation's Office of Inspector General (OIG) contracts with an independent public accounting firm to perform the annual audit of the Corporation's financial statements and testing of internal controls. As of September 2004, the Corporation provided this recommendation to the OIG for its consideration and the Corporation agreed to institute an A-123 internal control review. Upon completion of this review, the Corporation would make an assertion that its internal controls were adequate and the financial statement auditors would be able to audit and opine on their adequacy. The Corporation completed the review during 2006 but has not made the necessary assertions on adequacy. The...
Corporation for National and Community Service To enhance the accuracy of National Service Trust budget estimates and ensure the Trust does not accumulate large balances, the chief executive officer of the Corporation for National and Community Service should create a means to take into account the possible impact that external factors may have on participant behavior in its funding estimates and budget requests.
Closed – Implemented
The Corporation contracted with Econometrica, Inc. to assess the trust model. Econometrica issued a report in June 2005 documenting testing it performed for six external factors. It recommended incorporating one into the model--undergraduate enrollment. In August 2006, Econometrica issued a second report describing changes it made to the model for the Corporation such as including anticipated trends in undergraduate enrollment.
Corporation for National and Community Service To enhance the accuracy of National Service Trust budget estimates and ensure the Trust does not accumulate large balances, the chief executive officer of the Corporation for National and Community Service should establish and execute a periodic deobligation schedule for unused Trust obligations.
Closed – Implemented
The Corporation revised its procedures and included steps to monitor Trust activity and deobligate funds for AmeriCorps positions not utilized by grantees. As of September 2004, Corporation officials used an eSPAN query to analyze Trust obligations and determine whether funds could be deobligated. In FY 2006, the Trust reserve had a balance of $40 million and the Corporation requested an additional $7 million for FY 2007. As part of GAO's annual budget justification review of the Corporation's FY 2007 budget request, we advised Congress not to provide the requested $7 million. However, the Corporation responded that the additional $7 million for the reserve would be offset by $9.7...
Corporation for National and Community Service To enhance the accuracy of National Service Trust budget estimates and ensure the Trust does not accumulate large balances, the chief executive officer of the Corporation for National and Community Service should review the assumptions being used in the new funding model after the Corporation gains more experience with the new model and current participant behavior.
Closed – Implemented
The Corporation reported that it regularly monitors Trust activity. Per Congressional direction, the Corporation prepares monthly Trust financial reports, which include updated enrollment, earning, and usage data. As of October 2004, the Corporation continued to use conservative assumptions for enrollments to calculate Trust obligations and budgetary needs. In April 2005 and in early 2006, Corporation officials said that its estimating process has a short history and the National Service Trust provides a buffer in the event its estimates are incorrect. The Corporation added that it lacks sufficient data to justify a change to its policy of growing the National Service Trust and when more...
Corporation for National and Community Service To ensure its policies support its mission and grantees' efforts to deliver services while also providing adequate management controls, the chief executive officer of the Corporation for National and Community Service should evaluate the enrollment policies regarding refilling and converting positions.
Closed – Implemented
After evaluating the impact of the refill policy on grantees, Corporation officials revised the policy for program year 2004-2005. The revised policy allows programs that have fully enrolled their member slots to replace any member who terminates service before completing 15 percent of his or her term. The policy includes a fail-safe mechanism--refilling will be suspended if total enrollment reaches 97 percent of awarded slots or the number of refills reaches 5 percent of awarded slots. According to the policy announcement, the Corporation planned to modify its data systems to ensure that only eligible programs were able to refill slots and to track refill activity. The Corporation...

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