The Foster Grandparent Program (FGP)

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Program level Payment Integrity results

Sponsoring agency: Corporation for National and Community Service

View on Federal Program Inventory

PROGRAM METRICS

$94 M

in FY 2021 outlays, with a

80.7%

payment accuracy rate

PROGRAM METRICS

$92 M

in FY 2022 outlays, with a

76.3%

payment accuracy rate

PROGRAM METRICS

$77 M

in FY 2023 outlays, with a

90.1%

payment accuracy rate

PROGRAM METRICS

$91 M

in FY 2024 outlays, with a

82.4%

payment accuracy rate

PROGRAM METRICS

$94 M

in FY 2025 outlays, with a

76.4%

payment accuracy rate

  • Improper payment estimates over time
    View as:

    Chart toggle amounts:
    Proper payments
    Overpayment
    Underpayment
    Technically improper
    Unknown

Payment Integrity results

  • FY 2021 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2020 - 03/2021


    Confidence interval:

    >95%


    Margin of error:

    +/-6.4

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0.0 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $0.66 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.66 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.19 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.19 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0.19 M

Unknown Payment Details

These payments are unknown because the documentation that is used to establish eligibility and correct payment amount was either not available during the assessment or was not made available until after the payment was made.

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $17.34 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation

Evaluation of corrective actions

The agency had reductions in improper payments from FY19 to FY20 due to agency-wide corrective action for its largest rate driver, NSCHC. The agency did see an increase in rates from FY20 to FY21. The agency's planned corrective actions are more aggressive and comprehensive than they have been in the past in order to prioritize the reduction of non-NSCHC improper payments and unknown payments. The accountable officials and those that own portions of the corrective action plan will now meet every other month to assess progress.

Future payment integrity outlook

The Foster Grandparent Program (FGP) has established a baseline.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $94.1 M
Current year +1 estimated future improper payments $0.8 M
Current year +1 estimated future unknown payments $16.42 M
Current year +1 estimated future improper payment and unknown payment rate 18.3 %

The program's current year improper payment and unknown payment rate of 19.33 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

AmeriCorps has the internal controls, human capital, information systems and other infrastructure to reduce its improper payments to the level the agency has targeted.

Additional programmatic information

  • FY 2022 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2021 - 03/2022


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-7.3

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0 M

Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $1.56 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $1.56 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0 M

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0 M

Unknown Payment Details

Payments are considered unknown when the grantees fail or are unable to provide complete files to determine if payments are proper or improper. This includes National Service Criminal History Check and timekeeping information. Without National Service Criminal History Check information provided, AmeriCorps is unable to properly determine if a person is eligible to serve or be employed by an AmeriCorps program. Without timekeeping information, AmeriCorps is unable to determine if the charges to the award are correct.

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $20.19 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation

Evaluation of corrective actions

The improper payments reported are made that the grantee level. The improper payments are not made at the agency level and largely do not represent monetary loss to the government. The majority are unknown payments for which the agency’s grantees are unable to provide sufficient support documentation to determine if the payment was proper or improper. Since the agency does not have direct control over the payments, it is implanting updated, comprehensive trainings to ensure the grantees have the requisite knowledge to appropriately support their payments. The agency has elevated the reduction of improper payments to be a key performance indicator in its strategic plan.

Future payment integrity outlook

The Foster Grandparent Program (FGP) has established a baseline.

The reduction target equals the estimated future IP and UP rates. The agency assumes flat funding for the current year +1 estimate, so the reduction target was used to calculate IP and UPs. The corrective actions implemented in FY22 that may reduce the future rates are targeting unknown payments, therefore that is where the reduction can be seen.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $91.63 M
Current year +1 estimated future improper payments $1.56 M
Current year +1 estimated future unknown payments $19.28 M
Current year +1 estimated future improper payment and unknown payment rate 22.74 %
Current year +1 estimated future improper payment and unknown payment reduction target 22.7 %

The program's current year improper payment and unknown payment rate of 23.74 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via five-pronged approach. Via the strategic plan that agency is committing resources – human capital, internal controls, and information systems, to reduce improper payments.

AmeriCorps did not request resources.

Additional programmatic information

  • FY 2023 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2022 - 03/2023


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-5.1

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    AmeriCorps had established a Payment Integrity Corrective Action Plan working group. Using improper and unknown payments information from AmeriCorps’ annual Payment Integrity Assessment, the working group has identified the root cause drivers behind the improper and unknown payments. Based on this information, the group has created resources and delivered training focused on the identified improper payment root cause drivers. Those trainings were available to grantees for FY 2023. The agency also provided resolution packets to grantees at the conclusion of the FY 2022 assessment, linking specific root cause drivers of improper payments to the corresponding applicable statute, regulation, and available training. This will continue for the FY 2023 assessment.
    FY2023 Q4
    Completed
    Training
    AmeriCorps plans to continue to provide training and resources to grantees to ensure proper utilization of grant funds. AmeriCorps has a Payment Integrity Corrective Action Plan working group that includes accountable program officials and key agency stakeholders. The working group has created training and resources targeted at the root cause drivers of improper payments which are available on the agency’s website or grantee training platform (LITMOS). The working group plans to analyze the FY 2023 improper payments root cause drivers and explore opportunities to create new resources or expand on those that currently exist in FY 2024.
    FY2024
    Planned

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0 M

AmeriCorps awards grants only to eligible recipients through the grant pre-award process and due diligence reviews. Once the agency obligates the grant funds, program participants and payment decisions are made at the grantee level. AmeriCorps does not review or approve grant expenses prior to payment. The agency is unable to prevent improper payments from occurring through agency systems or DNP before grantees make payments.
Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $2.07 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $2.07 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Outside Agency Control Financial $2.07 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.08 M

Eligibility element/information needed Eligibility amount
Financial $0.08 M

Mitigation strategies taken Mitigation strategies planned
Training Training

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0.08 M

Unknown Payment Details

• The AmeriCorps Payment Integrity Assessment uses documentation submitted by grantees to support the selected federal expenses charged against the grant. There are situations where the grantee is unable to provide the required documentation to support the payment or the documentation provided is insufficient. In these situations, had the grantee been able to provide the missing documentation or adequately documented information a determination regarding the payment as either proper or improper could have been made.

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $5.49 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation
Other $5.49 M The AmeriCorps Payment Integrity Assessment uses documentation submitted by grantees to support the selected federal expenses charged against the grant. There are situations where the grantee cannot provide the required documentation to support the payment or the documentation provided is insufficient. In these situations, had the grantee been able to provide the missing documentation or adequately documented information a determination regarding the payment as either proper or improper could have been made. The specific documentation that is lacking includes: missing/incomplete National Service Criminal History Check information; missing or incomplete program participants’ income eligibility information, missing program participate timesheets; and missing program policy.

Mitigation strategies taken Mitigation strategies planned
Training Training

Evaluation of corrective actions

The agency is committed to the compliance with the Payment Integrity Information Act of 2019 as demonstrated by the agency elevating the reduction of improper payments to be a key performance indicator in its strategic plan.

The improper payments reported are made at the grantee level. The improper payments are not made at the agency level and largely do not represent a monetary loss to the government. The majority are unknown payments for which the agency’s grantees are unable to provide sufficient support documentation to determine if the payment was proper or improper. Since the agency does not have direct control over the payments, it has implemented updated training to ensure the grantees have the requisite knowledge to appropriately support their payments. The agency also provided resolution packets to grantees at the conclusion of the FY 2022 assessment, linking specific root cause drivers of improper payments to the corresponding applicable statute, regulation, and available training. This will continue for the FY 2023 assessment. In addition, AmeriCorps will assess the current training in the coming months to update as needed.

Future payment integrity outlook

The Foster Grandparent Program (FGP) has established a baseline.

The reduction target equals the estimated future Improper Payment and Unknown Payment rates. The agency assumes flat funding for the current year +1 estimate, so the reduction target was used to calculate Improper Payment and Unknown Payments. The corrective actions developed in FY 2022, including enhanced training, may further reduce the future rates targeting unknown payments. Therefore, that is where the reduction can be seen.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $77.32 M
Current year +1 estimated future improper payments $1.7 M
Current year +1 estimated future unknown payments $4.9 M
Current year +1 estimated future improper payment and unknown payment rate 8.54 %
Current year +1 estimated future improper payment and unknown payment reduction target 1.0 %

The program's current year improper payment and unknown payment rate of 9.87 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via a five-pronged approach. The agency is committing resources to human capital, internal controls, and information systems to reduce improper payments.

The agency did not request additional resources in its most recent budget to reduce improper payments.

Additional programmatic information

  • FY 2024 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2023 - 03/2024


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-6.7

  • Actions taken & planned to mitigate improper payments

    Mitigation strategy Description of the corrective action Completion date Status
    Training
    AmeriCorps had previously established a Payment Integrity Corrective Action Plan working group to address improper payment rates. This group identified the root cause drivers behind the improper and unknown payments. Based on this information, the group has created resources and delivered trainings focused on the identified improper payment root cause drivers. Those trainings are and have been available to grantees. The agency also provided resolution packets to grantees at the conclusion of the FY 2024 assessment linking specific root cause drivers of improper payments to the corresponding applicable statute, regulation, and available trainings. This will continue for the FY 2025 assessment.
    FY2024 Q4
    Completed
    Training
    AmeriCorps had previously established a Payment Integrity Corrective Action Plan working group. This group will be revived in FY 2025 analyzing the latest payment integrity results and determining the best actions to reduce rates. Additionally, AmeriCorps has developed an internal control for grantees trainings that will be required in the FY 2025 terms and conditions. AmeriCorps will develop specific required remediations for grantees with identical year over year findings.
    FY2025
    Planned
    Change Process
    The agency currently has two vendors that provide different required National Service Criminal History Checks. The agency will move to one contracted vendor that can provide compliant National Service Criminal History Checks. This will be a new, streamlined process for grantees.
    FY2025
    Planned

Overpayments

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0.0 M

AmeriCorps awards grants only to eligible recipients through the grant pre-award process and due diligence reviews. Once the agency obligates the grant funds, program participant and payment decisions are made at the grantee level. AmeriCorps does not review or approve grant expenses prior to payment. The agency is unable to prevent improper payments from occurring through agency systems or DNP before grantees make payments.
Overpayment root cause Overpayment amount
Amount of overpayments outside the agency's control $2.71 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $2.71 M

Overpayment type Eligibility element/information needed Eligibility amount
Overpayments Outside Agency Control Financial $2.71 M

Underpayments

Underpayment root cause Underpayment amount
Amount of underpayments $0.12 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.12 M

Eligibility element/information needed Eligibility amount
Financial $0.12 M

Mitigation strategies taken Mitigation strategies planned
Training Training

Technically improper payments

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

Additional information

$0.12 M

Unknown Payment Details

The AmeriCorps Payment Integrity Assessment uses documentation submitted by grantees to support the selected federal expenses charged against the grant. There are situations where the grantee is unable to provide the required documentation to support the payment or the documentation provided is insufficient. In these situations, had the grantee been able to provide the missing documentation or adequately documented information a determination regarding the payment as either proper or improper could have been made.

The amount of payments that could either be proper or improper but the agency is unable to determine whether they were proper or improper as a result of insufficient or lack of documentation is $13.14 M


Cause of insufficient or lack of documentation & why the documentation is needed for determination of payment type
Payment cause Amount Description of the documentation that was not provided and explanation of why the program is unable to conclude whether the payment is proper or improper without that documentation
Other $13.14 M The AmeriCorps Payment Integrity Assessment uses documentation submitted by grantees to support the selected federal expenses charged against the grant. There are situations where the grantee is unable to provide the required documentation to support the payment or the documentation provided is insufficient. In these situations, had the grantee been able to provide the missing documentation or adequately documented information a determination regarding the payment as either proper or improper could have been made. The specific documentation that is lacking includes: missing/incomplete National Service Criminal History Check information; missing or incomplete program participants income eligibility information, missing program participate timesheets; and missing program policy.

Mitigation strategies taken Mitigation strategies planned
Training Change Process,Training

Evaluation of corrective actions

The agency is committed to the compliance with PIIA as demonstrated by the agency elevating the reduction of improper payments to be a key performance indicator in its strategic plan.

The improper payments reported in ASN and FGP are made that the grantee level. The improper payments in ASN and FGP are not made at the agency level and largely do not represent monetary loss to the government. The majority are unknown payments for which the agency’s grantees are unable to provide sufficient support documentation to determine if the payment was proper or improper. Since the agency does not have direct control over the payments, it has implemented updated trainings to ensure the grantees have the requisite knowledge to appropriately support their payments.

Program participant and payment eligibility decisions are made at the grantee level. It is essential that grantees have access to training and resources that provide information on financial grants management. Having effective and readily available resources to guide grantees in program implementation promotes effective stewardship of federal funds and reduce non-compliance. The created resources build upon the agency’s currently available tools and focus specifically on areas of non-compliance. Additional actions will be taken given AmeriCorps still reports rates over $10M and/or 10%.

The internal control training will target root causes in both unknown and overpayment categories to address adequate record keeping and controls to ensure payments are correct and correctly recorded.

Regarding the provision of training as a corrective action, AmeriCorps will reestablish the Payment Integrity Corrective Action Plan working group to identify corrective actions the agency could take to address its improper payment rate. Utilizing improper and unknown payments information from AmeriCorps’ annual Payment Integrity Assessment, the working group will identify the root cause drivers behind the improper and unknown payments. Based on this information, the group will implement additional action steps aimed at reducing these areas of non-compliance. The training and resources focus on the identified improper payment root cause drivers.

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via an agency-wide corrective action plan. The prior establishment of the working group represents a coordinated effort by the agency to develop and implement corrective actions aimed at reducing improper payments. The agency performs root cause analysis to determine why improper payments are occurring at the grantee level. This allows for more targeted actions.

Future payment integrity outlook

The Foster Grandparent Program (FGP) has established a baseline.

The reduction target is less than the estimated future IP and UP rates. The agency assumes flat funding for the current year +1 estimate, so the reduction target was used to calculate IP and UPs. Since the payments that AmeriCorps’ tests are in the prior and only part of the current fiscal year, there is a delay in seeing the effects of any implemented corrective actions. The including enhanced trainings and resolution packets provided to grantees with improper payments may further reduce the future rates.

Out-Year improper payment and unknown payment projections and target
Current year +1 estimated future outlays $90.63 M
Current year +1 estimated future improper payments $2.38 M
Current year +1 estimated future unknown payments $12.68 M
Current year +1 estimated future improper payment and unknown payment rate 16.62 %
Current year +1 estimated future improper payment and unknown payment reduction target 1.0 %

The program's current year improper payment and unknown payment rate of 17.62 % has not been achieved with a balance of payment integrity risk and controls and does not represent the lowest rate that can be achieved without disproportionally increasing another risk, therefore it is not the tolerable rate.

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via five-pronged approach. Via the strategic plan that agency is committing resources – human capital, internal controls, and information systems, to reduce improper payments.

No resources were requested. The agency did not request resources because the payments are generally not made at the agency level and are made by individual grantees. Corrective actions to target grantees, such as trainings, can be developed and performed with resources available.

Additional programmatic information

Accountability for detecting, preventing, and recovering improper payments

The agency implemented an improper payment reduction corrective action plan group to develop actions to reduce the improper payments and this group will be reinstated in FY 2025. This group consisted of representatives from offices across the agency. Through root cause analysis and corrective action plan development, the agency is assessing where additional controls may be necessary to reduce improper payments. The improper payments reported for the agency are made at the grantee level, therefore the agency is developing an internal control training to strengthen the control environment at the grantee level. Executive managers, programs, and other staff contribute to improper payment corrective action planning. Reduction in improper payments may be included in performance conversations for those accountable for the reduction.

  • FY 2025 improper payment estimates

    Chart legend and breakdown

    Payment accuracy rate

    Improper payment rate

    Unknown payment rate


    Sampling & estimation methodology details

    Sampling timeframe:

    04/2024 - 03/2025


    Confidence interval:

    95% to <100%


    Margin of error:

    +/-7.8

Causes

The AmeriCorps Payment Integrity Assessment uses documentation submitted by grantees to support the selected federal expenses charged against the grant. The root cause types that were identified are "failure to access data/information" and "unable to determine whether proper and improper." There are situations where the grantee is unable to provide the required documentation to support the payment or the documentation provided is insufficient. In these situations, had the grantee been able to provide the missing documentation or adequately documented information a determination regarding the payment as either proper or improper could have been made.

The specific documentation that is lacking includes: missing/incomplete National Service Criminal History Check information; missing or incomplete program participants income eligibility information; and missing staff timesheets or timesheets that do not adequately identify time worked on specific grant projects.

Overpayment root cause Overpayment amount
Amount of overpayments within the agency's control $0.0 M
Amount of overpayments outside the agency's control $2.57 M
Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $2.57 M

Underpayment root cause Underpayment amount
Amount of underpayments $0.24 M
The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist $0.0 M
The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment $0.0 M
The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment $0.24 M

The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation $0.0 M

The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation $19.34 M

Prevention

AmeriCorps designated accountable officials for improper payments compliance. In addition to naming the accountable officials, AmeriCorps’ Office of Risk and Monitoring, which administers the payment integrity program at AmeriCorps, keeps the Risk Management Council informed of the status of goals established to address compliance and ensuring success in remediating issues in relation to PIIA. The agency believes its corrective actions have demonstrated progress towards compliance and that reauthorization or statutory changes would not bring the program in compliance. Therefore, the agency’s actions to bring the program into compliance and associated timelines can be found below. It is important to note that AmeriCorps does not directly administer the programs required to report under PIIA and it tests individual transactions that occurred in the past due to a lag between when grantees disburse funds and report to the agency. Therefore, the effects of corrective actions are observed in the years following the implementation.

The corrective actions taken/completed in FY25 to mitigate the root causes for "failure to access data or information" and "unable to determine whether proper or improper" include the following: (1) Continue assessing the resource needs of the AmeriCorps program and operational functions and adjust as needed (complete). AmeriCorps has dramatically reduced its improper payment rates in recent years via grantee accountability mechanisms and compliance tools. (2) Based upon prior assessment and trend analysis of the PIIA root cause, continue improving and providing training and technical assistance to grantees on maintaining the appropriate documents and how to properly calculate necessary expenses (complete). AmeriCorps has implemented additional terms and conditions in FY 2025 AmeriCorps’ General Grant and Cooperative Agreement Terms and Conditions aimed at addressing the root causes of improper payments. (3) Based on the assessment of the effectiveness of changes to support timeliness of NSCHC checks and the changes associated with enforcement structure, develop additional strategies and mitigations as needed. AmeriCorps continues to require at least one active staff person from each grantee to complete an annual training course related to NSCHC compliance and continues to offer additional trainings throughout the year. (4) Implement an internal controls training for grantees to address documentation and calculation issues. AmeriCorps has implemented an internal controls training for grantees. (5) Revisit existing timekeeping training to determine if updates are needed and, if so, implement. The agency required grant financial management training for all grantees which addressed timekeeping issues.

The corrective actions planned to be completed in FY26 to mitigate the root causes for "failure to access data or information" and "unable to determine whether proper or improper" include the following: (1) Continue assessing the resource needs of the AmeriCorps program and operational functions and adjust as needed. (2) Based upon prior assessment and trend analysis of the PIIA root cause, continue improving and providing training and technical assistance to grantees on maintaining the appropriate documents and how to properly calculate necessary expenses. AmeriCorps will require written confirmation from grantees with improper payments that at least one person on their staff responsible for the area of the improper payment finding(s) have reviewed all information/taken all training included in the resolution packet(s) provided to them. (3) Based on the assessment of the effectiveness of changes to support timeliness of NSCHC checks and the changes associated with enforcement structure, develop additional strategies and mitigations as needed. For all grantees who have NSCHC based improper payments, AmeriCorps will require the organization to use the agency approved NSCHC vendor.
The agency is committed to compliance with PIIA as demonstrated by the agency elevating the reduction of improper payments to be a key performance indicator in its strategic plan. The improper payments reported in ASN and FGP are made at the grantee level. The improper payments in ASN and FGP are not made at the agency level and largely do not represent monetary loss to the government. The majority are unknown payments for which the agency’s grantees are unable to provide sufficient support documentation to determine if the payment was proper or improper. Since the agency does not have direct control over the payments, it has implemented updated trainings to ensure the grantees have the requisite knowledge to appropriately support their payments.

The internal control training will target root causes in both unknown and overpayment categories to address adequate record keeping and controls to ensure payments are correct and correctly recorded. Regarding the provision of training as a corrective action, AmeriCorps has reestablished the Payment Integrity Corrective Action Plan working group to identify corrective actions as well as implementing targeted monitoring activities for grantees with improper payments to address its improper payment rate. Utilizing improper and unknown payments information from AmeriCorps’ annual Payment Integrity Assessment, the working group will identify the root cause drivers behind the improper and unknown payments. Based on this information, the group will implement additional action steps aimed at reducing these areas of non-compliance. The training and resources focus on the identified improper payment root cause drivers.

Program participant and payment eligibility decisions are made at the grantee level. It is essential that grantees have access to training and resources that provide information on financial grants management. Having effective and readily available resources to guide grantees in program implementation promotes effective stewardship of federal funds and reduces non-compliance. The resources created build upon the agency’s currently available tools and focus specifically on areas of non-compliance. Additional actions will be taken given AmeriCorps still reports rates over $10M and/or 10%.

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via an agency-wide corrective action plan. The prior establishment of the working group represents a coordinated effort by the agency to develop and implement corrective actions aimed at reducing improper payments. The agency performs root cause analysis to determine why improper payments are occurring at the grantee level. This allows for more targeted actions.

Payment type Mitigation strategies taken Mitigation strategies planned
Overpayments Training Change Process, Training
Underpayments Training Change Process, Training
Unknown payments Training Change Process,Training

Eligibility element/information needed Description of the eligbility element/information
Financial The financial position or status of a beneficiary, recipient, or their family

Additional information

Reduction target

1.0 %

As part of its strategic plan, AmeriCorps is prioritizing effective stewardship of federal resources. This goal includes the objective of reducing the agency’s improper payments via five-pronged approach. Via the strategic plan that agency is committing resources – human capital, internal controls, and information systems, to reduce improper payments.

No resources were requested. The agency did not request resources because the payments are generally not made at the agency level and are made by individual grantees. Corrective actions to target grantees, such as trainings, can be developed and performed with resources available.

The agency implemented an improper payment reduction corrective action plan group to develop actions to reduce the improper payments and this group was reinstated in FY25. This group consisted of representatives from offices across the agency. Through root cause analysis and corrective action plan development, the agency is assessing where additional controls may be necessary to reduce improper payments. The improper payments reported for the agency are made at the grantee level; therefore the agency has developed and requires an internal controls training to strengthen the control environment at the grantee level. Executive managers, programs, and other staff contribute to improper payment corrective action planning.

$0.24 M