Accountability and Safeguarding
Corporation Funds
2014 AmeriCorps
State and National Symposium
Purpose
Understand OIG’s mission
Learn to prevent, detect, and remedy problems
commonly found in AmeriCorps programs
Know how and when to contact the OIG
Office of Inspector General
OIG Mission: Oversight
 Improve efficiency and effectiveness of
Corporation programs and operations
 Prevent and detect waste, fraud, and abuse
by:
 Conducting audits and investigations
 Recommending policies
 Keeping the Corporation’s CEO and Congress
informed about deficiencies and the need for/status
of corrective action
Office of Inspector General
OIG Independence
 By law, OIG is independent of CNCS
 We report directly to Congress and
administratively to the Corporation’s CEO.
 Funded by a separate appropriation
 OIG personnel must remain objective at all
times in conducting our work and must be free
of personal or organizational conflicts of
interest with grantees.
Office of Inspector General
What the OIG Does Not Do
Manage or direct CNCS programs
or operations
Office of Inspector General
Key OIG Activities
Two operational units:
Audits
Investigations
Office of Inspector General
AUDITS
Office of Inspector General
Grants Come with Strings
Terms and conditions
Federal law and regulations
Grantees are accountable for
complying with these requirements
and maintaining records to show that
they have done so.
Office of Inspector General
Sound Practices =
Integrity and Accountability
 Have systems, policies, and procedures
in place at grant inception to ensure
that the organization operates within the
rules of its Federal assistance
 Compile and retain full documentation
Office of Inspector General
Ingredients of Accountability
 Strong internal controls
 Written procedures and documented systems
 Active financial management, review
 Accurate, contemporaneous record-keeping
 Following Federal laws, regulations, and grant
terms
 Tone at the top
Office of Inspector General
Common Audit Problems
(and how to avoid them)
 Account separately for each grant.
 Submit Federal Financial Reports (FFRs) on
schedule.
 Best Practice: Make sure that FFRs reconcile
to internal accounting records (general ledger).
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 Staff and member timesheets must be
completed accurately, signed and dated by a
supervisor after completion, and submitted
regularly.
 Timesheets cannot be based on budgeted
amounts—actual work only.
 Best Practice: Periodically conduct your own
timesheet review or audit.
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 National Sex Offender Public Website and
Criminal History Checks—conduct thoroughly,
timely, and document properly, for both staff and
volunteers.
 Best Practice: Conduct your own review, at
beginning of grant.
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
AmeriCorps members cannot replace staff or
perform staff or administrative functions—
“Members are not cheap labor.”
 Grantee, in most cases, may not enroll its
employees as AmeriCorps members. No
double dipping.
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 Record match dollars in general ledger, with
same detail/documentation as for grant
expenditures.
 Document source of match contributions.
 Substantiate market value of in-kind match
contributions.
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 Know what expenses (including personnel) the
grant does/does not cover.
 Confirm that you have receipts for those
expenses.
 Do drawdowns meet your immediate cash
needs?
 Best Practice: Review periodically to be sure
only allowable expenses are charged to the
grant.
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 Fixed Amount Grants
Track enrollment/retention, draw down funds
consistent with it.
 Draw only as much as you need for immediate
program expenses
 Significant share of program expenses must be paid
with non-CNCS funds; plan accordingly
Office of Inspector General
Avoiding Common Audit Problems
(cont’d)
 If you have an indirect cost rate, know what
expenses it includes.
 Check to be sure that you are not charging the
grant directly for expenses covered by the
indirect cost rate.
Office of Inspector General
OMB Grant Reform
 Consolidated grant circulars into a single Omnicircular (combining principles for all grant types)
 2 Code of Federal Regulations (CFR) 200, Uniform
Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
 Raised the Single Audit Act threshold to $750,000
 Many other changes; the proposed rules will became
effective next year
 All audit reports submitted to the Federal Audit
Clearinghouse must be text searchable and in
unencrypted PDF format
Office of Inspector General
INVESTIGATIONS
Office of Inspector General
QUESTION
How important is the AmeriCorps program in your
community?
Office of Inspector General
Common Investigations
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Embezzlement
Misuse of grant funds
Improper use of members
Displacement
Timesheet fraud
Office of Inspector General
Fraud Defined
• An intentional distortion of the truth in an
attempt to obtain something of value. Does not
have to result in monetary loss.
• Layman’s terms:
Lying, cheating, or stealing.
Office of Inspector General
Embezzlement
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Members and staff are not being paid
Payments are made to “ghost members”
Frequent use of white out, changes, or additions
Missing documents or fabricated receipts
Office of Inspector General
Misuse of Grant Funds
Grant funds are fully expended early.
Unauthorized costs are charged to the grant.
Funds are borrowed temporarily to pay for
unauthorized activities.
Funds are drawn down on unfilled member slots.
Funds are drawn down on terminated slots.
Employee salaries not funded under the grant
are charged against the grant.
Office of Inspector General
Improper Use of Members
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Members used as personal assistant
Members assigned as bus and/or hall monitor
Members serving outside the scope of the grant
Team Leaders act in a staff capacity
Office of Inspector General
Displacement
 Members assigned to staff positions
 Staff laid off and replaced by members
 Employee on leave; member assigned the work
 Employee resigns; member assigned the work
Office of Inspector General
Timesheet Fraud
 Recording hours not actually served
 Service hours are not properly documented
 Member hours are not reasonable or allowable
 Hours or service not verified
 Timesheets pre-dated or completed in advance
 Members serving from home
 Staff time inaccurately allocated
Office of Inspector General
The Fraud Triangle
Management Oversight
Strong Internal Controls
Training
Causes
Results
Pressure
Reduced Pressure
Office of Inspector General
Fraud Investigations
 Program officials allowed member(s) to serve without
conducting/completing NSOPW check.
 Members serving outside the scope of the grant.
 Program officials required members to serve as substitute
teachers.
 Program officials assigned members to staff position(s).
 Program officials instructed members to forge documents.
 Executive Director used AmeriCorps funds to go on vacation.
Office of Inspector General
No Reprisals Against Whistleblowers
 By law, you cannot be retaliated against for
reporting waste, fraud, or abuse to OIG.
 You may not retaliate against anyone in your
organization for reporting to OIG.
 Victims of retaliation can make a complaint to
OIG, which will investigate.
Office of Inspector General
QUESTIONS
Office of Inspector General
Contact the OIG
Your identity can be kept
Office of Inspector General
•
•
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Report suspected fraud, waste, or abuse
Information is confidential
You may remain anonymous
1-800-452-8210
or
hotline@cncsoig.gov
#CNCSOIG
Visit us at
www.cncsoig.gov
Office of Inspector General