The Corporation for National and Community Service, Office of Inspector General (CNCS-OIG) issued a Management Alert to express our concerns over the following proposed regulatory changes to the Senior Corps Program, which do not appear to have undergone adequate risk assessment prior to the proposed rule-making: (1) Reducing the minimum number of volunteer service hours per week from 15 to 5; and (2) Eliminating the Direct Benefit Ratio or 80/20 Rule, which requires that at least 80 percent of the Federal grant award be expended for volunteer benefits.
CNCS-OIG’s analysis suggests that these two changes may increase certain per-volunteer costs, and simultaneously decrease significantly the service hours delivered to the served communities. CNCS has not considered these potential financial and programmatic effects, nor has it undertaken a pilot program to identify any other unintended consequences.
We made three recommendations to CNCS, focused on additional analysis and research into potential increased costs and reduction in community service hours. CNCS’s response did not address the concerns substantively, but said that it would do so as part of the rulemaking process.