The Investigations Section within the OIG is responsible for the detection and investigation of fraud, waste, and abuse within Corporation for National and Community Service programs and operations. Special Agents conduct various criminal, civil, and administrative investigations. Some of our criminal investigations are conducted in conjunction with other federal, state or local law enforcement agencies. Criminal investigations are presented to the U.S. Attorney and, in some cases, the local prosecutor, for criminal prosecution and/or civil recovery.
The Investigations Section also conducts fraud awareness briefings and provides a pamphlet entitled "OIG Investigations and You" which discusses the Corporation for National and Community Service employees' rights and responsibilities regarding investigations. Also, See;
The Investigations Section also maintains the Fraud Hotline which can be used to report fraud, waste and abuse involving Corporation for National and Community Service programs and operations.
CNCS Employee Denied Leave Under Family Medical Leave Act
The Corporation for National and Community Service (CNCS), Office of Inspector General (CNCSOIG) investigated an allegation that CNCS improperly denied leave under the Family Medical Leave Act (FMLA) to one of its employees. The investigation revealed that CNCS – Office of Human Capital inaccurately informed the employee’s supervisor that the employee was not eligible for FMLA. The investigation found the employee was in fact eligible for leave under the FMLA based on the employee’s prior creditable Federal service.
CNCS management concurred with the CNCS‐OIG’s finding. CNCS‐OHC indicated it has subsequently conducted training regarding approval of FMLA and changed its processes to ensure other employees with prior Federal service are not improperly denied leave under FMLA.
Case ID: 2018‐008
AmeriCorps Grantee Failed to Conduct a Compliant National Service Criminal History Check
CNCS-OIG investigated allegations that AmeriCorps members (members) serving in the Impact America (IA), Birmingham, AL, AmeriCorps program were instructed to alter their service activities on their timesheets, received additional salary payments from IA, and acted as supervisors of other members. The investigation found no evidence to support these allegations. However, investigators determined IA failed to conduct a compliant National Service Criminal History Check (CHC) on one member because the member’s name was misspelled in the National Sex Offender Public Website (NSOPW) search. This violated 45 C.F.R. § 2540.203.
Additional allegations were raised that members were sexually harassed by an IA executive. Consistent with CNCS policy, after an initial site visit, CNCS-OIG referred the sexual harassment allegations to CNCS AmeriCorps State and National (ASN) for resolution.
CNCS management concurred with CNCS-OIG’s findings that IA’s search of the NSOPW was noncompliant due to the misspelling of the member’s name and ultimately disallowed nominal costs pursuant to the sanctions matrix.
Regarding the sexual harassment allegations, CNCS related to us that the individual accused of harassment was no longer employed by IA, a new Human Resources Director was hired, and new policies were implemented. In addition, ASN informed the alleged victim of sexual harassment of their rights to file a case with the CNCS EEO Office or with their state. Therefore, CNCS considers the matter closed.
Case ID 2018-029
AmeriCorps VISTA Members Tasked with Service Outside the Scope of the Grant
CNCS-OIG investigated allegations that AmeriCorps VISTA members (VISTA) serving at Community Students Learning Center (CSLC), Lexington, MS, performed service outside the scope of the grant.
The investigation found CSLC directed VISTAs to conduct various activities outside the scope of the grant, such as tutoring and setting up for CSLC fundraisers, and CSLC staff did not fully understand what types of service activities VISTAs could and could not perform.
CNCS responded that it prioritizes training for grantees on allowable VISTA service, but since CSLC ended its VISTA project, CNCS did not agree to take any action in this case.
Case ID 2018-019
AmeriCorps Member Performing Prohibited Religious Activities Leads to Removal of Service Site
CNCS-OIG investigated allegations that AmeriCorps members (member) serving in the Teach for America (TFA), New York, NY, AmeriCorps program at the El Centro Incorporated, Academy for Children (El Centro), Kansas City, MO, service site were directed to perform prohibited religious activities.
The investigation confirmed that one member regularly performed a prohibited religious activity by leading a religious prayer to the students in the classroom three times a day during service hours, a violation of 42 U.S.C. § 12584a(a)(7).
CNCS management concurred with CNCS-OIG’s finding that a TFA member performed a prohibited activity by leading a religious prayer with students and took the following actions: (1) TFA removed El Centro as a service site for the 2018 grant year; (2) TFA senior staff provided additional training on prohibited activities to regional staff; (3) TFA issued guidance to regional staff on their responsibilities to train site supervisors on prohibited activities; and (4) TFA senior staff decided to review any member placements at religious schools in the future to ensure that prohibited activities would not be assigned.
Case ID 2018-018
AmeriCorps Grantee Failed to Conduct a Compliant National Service Criminal History Check
CNCS-OIG investigated allegations that AmeriCorps members serving in the St. Bernard Project (SBP), New York, NY, AmeriCorps program displaced the work of paid staff, served outside the scope of the grant, and were not reimbursed for travel expenses.
The investigation found no evidence to support the allegations but did find that SBP failed to conduct a compliant National Service Criminal History Check (CHC) on one former member, a violation of 45 C.F.R. § 2540.203. The check was noncompliant because the search of the National Sex Offender Public Website (NSOPW) misspelled the former member’s first name.
CNCS management concurred with CNCS-OIG’s finding that SBP failed to conduct a compliant CHC on the former member; however, CNCS initially determined not to impose a financial consequence, asserting that, as long as the last name is correct, and the first name is similar to the actual name, the search is generally sufficient to ascertain whether the person is a registered sex offender.
On January 11, 2019, CNCS revised its decision and elected to impose a financial consequence on SBP for the noncompliant CHC.
Case ID 2018-012
Foster Grandparent Program (FGP) and Senior Companion Program (SCP) Grantee Required to Repay $92,000 for Insufficient and Falsified National Service Criminal History Checks for Individuals in Covered Positions
CNCS-OIG investigated allegations that a senior official at Council on Aging of West Florida (COAWF), Pensacola, FL, altered the National Sex Offender Public Website (NSOPW) checks of FGP and SCP volunteers.
Investigation found that after receiving notification of a site monitoring visit from the CNCS Florida State Office, the COAWF senior official intentionally mislead CNCS employees by altering 36 NSOPW checks of FGP and SCP volunteers assigned to COAWF. The senior official altered the names or completion dates of the NSOPW checks in an attempt to conceal the fact the checks were not conducted in a timely manner.
CNCS concurred with our findings and recommendations, and required COAWF to repay $92,000. CNCS debarred the senior official from conducting business with the Federal
Government for a period of three years.
Case ID: 2017-001
Senior Companion Program (SCP) Grantee and a Senior Official Debarred for a Period of Three Years for Willful Violation of a Statutory and Regulatory Provision and Engaging in Inappropriate Activities
CNCS-OIG investigated allegations that a senior official at the Senior Community Outreach Services, Inc. (SCOS) Alamo, TX improperly managed aspects of its Senior Corps grant. An investigation by CNCS-OIG found that the SCOS senior official directed employees to falsify documents with the intent to double bill multiple grants (CNCS and HUD) and deceive grantors during compliance inspections and monitoring visits. Due to the poor state of SCOS’s financial records, CNCS-OIG, the CNCS Texas State Office, and the Department of Housing and Urban Development Office of Inspector General (HUD-OIG) were unable to determine if CNCS or HUD funds were expended appropriately. In addition, CNCS-OIG determined SCOS:
- Failed to Maintain Adequate Financial Records a violation of 2 CFR § 200.302 (a) and (b)(3), when it comingled various grant funds (public and private) without establishing an adequate accounting system to distinguish the sources of funding or explain how the funds were expended;
- Violated 45 CFR § 2551.25, Perform Work Outside the Scope of the Grant when a SCOS senior official performed work on other grants but charged 100 percent of his time to the SCP grant; and
- A senior official improperly charged portions of his salary to other grants, even though the salary was fully funded by the CNCS SCP grant, a violation of 45 CFR § 2551.25.
CNCS management concurred with our findings and issued a proposed termination of the SCP and FGP grants awarded to SCOS; however, SCOS voluntarily relinquished its SCP and FGP grants in lieu of termination. SCOS’s falsification of documents and poor financial records prevented any reliable analysis of its financial records. As a result, CNCS did not disallow any costs from the SCOS grants as it was unable to distinguish legitimate from improper expenditures.
AmeriCorps Member Exited from Program for Falsification of Timesheets and Violating Agency Policies
The Kentucky Commission on Community Volunteerism and Service (Commission), Frankfort, KY, reported to the Corporation for National and Community Service (CNCS), Office of Inspector General (OIG) that an AmeriCorps member (member) submitted fraudulent timesheets to the Kentucky Coalition Against Domestic Violence (KCADV).
CNCS-OIG recommended that CNCS direct the Commission to conduct a review of KCADV’s AmeriCorps program to determine if the member’s action was an isolated incident or part of a systemic problem.
The Commission found no evidence of a systemic problem and determined the level of supervision and oversight of the AmeriCorps program by KCADV was adequate. The member was exited from the program for falsification of time sheets and violating KCADV policies.
Case ID 2018-014
Foster Grandparent Program (FGP) Grantee Required to Repay $143,278.47 for Cost Improperly Charged to the FGP Grant.
CNCS-OIG investigated an allegation that volunteers and staff from Kansas Neurological Institute (KNI), Topeka, KS, Foster Grandparent Program (FGP) falsified timesheets and performed duties outside the scope of the FGP grant.
The investigation revealed the following findings:
KNI allowed KNI’s FGP official to spend up to 70 percent of her time performing non- FGP duties associated with her former KNI position, even though the grant required her to spend 100 percent of her time on KNI's FGP matters;
KNI violated 45 C.F.R. § 2552.25 What are a sponsor's administrative responsibilities?, subsection (c), when it allowed KNI’s FGP former project director (PD) to concurrently serve as the volunteer treasurer for the National Association of Foster Grandparent Program Directors (NAFGPD) while working as full-time director for KNI's FGP. This was contrary to FGP regulations and KNI's FGP grant agreement, which required the sponsor to employ a project director full-time and dedicate 100 percent of their time managing KNI’s FGP grant;
KNI’s former PD submitted timesheets for the last five years that falsely claimed she spent 100 percent of her time working on FGP matters when in fact she spent approximately 75 percent of her time performing non-FGP duties; and
The former PD improperly authorized FGP volunteers to claim five hours of stipend payments during in-service training and/or recognition events even though the FGP volunteers were usually at the events for no more than three hours.
CNCS management concurred with CNCS-OIG’s findings and recommendations and required KNI to repay $143,278.47 for costs improperly charged to the FGP grant.
Case ID 2016-032
AmeriCorps Subgrantee Submitted False Claims and Directed AmeriCorps Members to Displace Staff
CNCS-OIG investigated an allegation that a senior official at Ashby House, Salina, KS, improperly managed the AmeriCorps program. An investigation by CNCS-OIG and the Kansas Volunteer Commission (Commission), Topeka, KS, determined the senior official improperly utilized members to perform various duties outside the scope of the grant and improperly charged a printer to the grant. In addition, the grantee violated:
45 C.F.R. § 2540.100 – Displacement, when the grantee improperly utilized AmeriCorps members (members) to perform various duties normally performed by Ashby House employees.
CNCS management and the Commission concurred with the CNCS-OIG findings and recommendations. The Commission immediately suspended Ashby House’s AmeriCorps grant and subsequently conducted a comprehensive review of the program. The Commission disallowed $7,656.66 for (1) expenses improperly charged to the grant, (2) displacement, (3) member service performed outside the scope of the grant, and (4) timesheet non-compliance.
Ashby House was allowed to complete its 2016-2017 grant under close supervision by the Commission. However, due to management concerns, the Commission elected not to renew Ashby House’s AmeriCorps grant application for 2017-2018.
Case ID: 2017-004
Retired Senior Volunteer Service Grantee Failed to Complete National Service Criminal History Check, Accurately Report the Number of Volunteers, Failed to Conduct Volunteer Station Assessments and Update the Volunteer Station Memorandum of Understanding
CNCS-OIG investigated allegations that employees from the Retired Senior Volunteer Program (RSVP) of Tulsa, Tulsa, OK, intentionally submitted inaccurate time and attendance records and inflated the number of RSVPs enrolled on a Progress Report to CNCS.
The investigation found no evidence to support the allegation that employees falsified or submitted inaccurate time and attendance records. However, the investigation concluded RSVP of Tulsa demonstrated a lack of due diligence in ensuring the RSVP grant was properly administered. RSVP of Tulsa violated:
- 45 C.F.R. § 2540.204 when it failed to complete the National Service Criminal History Check (CHC) on a covered employee. Additionally, RSVP of Tulsa did not use the approved repository (Oklahoma State Bureau of Investigation) or received approval to use alternative search procedures to conduct the former employee’s background check;
- 45 C.F.R. § 2553.25(g) when it intentionally did not accurately report the number of RSVP volunteers in the program. The executive director for RSVP Tulsa admitted to utilizing the number of participants for a Tai Chi class to be counted as RSVP volunteers. The seniors enrolled in the Tai Chi class were only participants and did not perform any service related activities; and
- 45 C.F.R. § 2553.23 when it failed to update the Memorandums of Understanding (MOU) and conduct the required annual assessments of the volunteer stations. The executive director admitted RSVP of Tulsa did not perform reliable verification of the volunteer service hours. In addition, 20 percent of the MOU’s were expired.
CNCS management concurred with CNCS-OIG findings and took the following actions: (1) disallowed $1,500, in accordance with the CNCS disallowance matrix, for the period the former employee worked without a completed CHC; (2) instructed the RSVP of Tulsa on MOU requirements. Five MOUs were updated and the remaining expired MOUs were transitioned to inactive status; and (3) provided technical assistance related to enrollment of RSVP volunteers and appropriate service activities. RSVP of Tulsa was directed to revise the affected annual progress report (PPR) and exclude participants of the Tai Chi class from its volunteer counts throughout the report.
Case ID 2017-011
Grantee Submitted False Claims, Improperly Charged for Unallowable Match, and Directed AmeriCorps Members to Displace Staff.
CNCS-OIG investigated an allegation that a senior official at the Center for People in Need (CFPIN), Lincoln, NE, improperly managed various aspects of its AmeriCorps program. An investigation by the CNCS-OIG and Nebraska Volunteer Service Commission (Commission) found that the subgrantee improperly charged the AmeriCorps grant for salaries of program staff who could not quantify time spent on the AmeriCorps program versus time spent on other programs. CFPIN also improperly charged the AmeriCorps grant for staff who were not assigned to the AmeriCorps program. In addition, CNCS-OIG determined that CFPIN violated:
45 C.F.R. § 2540.100 – Non-displacement, when AmeriCorps members (members) were directed to perform work ordinarily performed by a paid employee. CFPIN operated an English as a Second Language (ESL) program with a grant from the U.S. Citizenship and Immigration Service (USCIS), that included funding for paid instructors. When the paid instructors resigned, the grantee improperly utilized AmeriCorps members to teach ESL. CFPIN never hired replacement ESL instructors nor did it notify the Commission or USCIS about the use of members to teach ESL; and,
2 C.F.R. § 200.306 (b) - Billing for Unallowable Match, when CFPIN provided AmeriCorps members with donated items (food, clothing, merchandise) and then improperly claimed the value of those items as part of the non-Federal match charged to the AmeriCorps grant.
CNCS management and the Commission concurred with the CNCS-OIG findings and recommendations. The Commission disallowed $47,063.25 in education awards for AmeriCorps members who improperly received a full or partial education award. After disallowing the match, the Commission found CFPIN still met the minimum match requirements for the AmeriCorps grant. The Commission declined to renew CFPIN’s AmeriCorps grants for subsequent grant years and reported the senior official was terminated.
Case ID: 2016-027
AmeriCorps Subgrantee Improperly Used Head Start Funds as Cost Match, Directed AmeriCorps Members to Displace Staff and Perform Service Outside the Scope of the Grant. In Addition, Two Members Admit to Submitting Fraudulent Timesheets.
CNCS-OIG investigated allegations that the Center for Family Services (CFS), Camden, NJ, directed AmeriCorps members (members) to displace paid staff and that members were submitting fraudulent timesheets. In addition, we reviewed CFS financial records to determine whether the federal funds it used as mandatory cost-match were authorized for that purpose.
The CNCS-OIG investigation found that CFS violated (1) the CFS AmeriCorps grant when it assigned members to perform services outside the scope of the grant, (2) 45 C.F.R. § 2540.100 (e) when it required members as part of their service to perform activities substantially similar to those already performed by an employee (teacher/assistant teacher), and (3) 45 C.F.R. § 2521.45 when it failed to comply with match requirements. In addition, two former members knowingly submitted fraudulent timesheets.
Interviews of members and staff revealed that CFS violated 45 C.F.R. § 2540.100 and AmeriCorps grant terms and conditions when they (1) routinely assigned members duties duplicated the role of a paid staff in the classroom and (2) performed service outside the scope of the grant. Based on the grant terms, members were to provide academic and social support to individual or small groups of children and thereby foster early literacy and social skills. However, the investigation found there was no clear distinction between staff or the members. CFS management and the site supervisors confirmed there was little to no difference between the assistant teacher duties and member’s service. In fact, the roles were so similar, members were frequently assigned to cover as the assistant teacher when staff were late or absent.
To meet the match requirements of the AmeriCorps grant, CFS used Head Start Program grant funds as the source of match. However, Health and Human Services personnel revealed this was an unallowable use of Head Start grant funds.
Two members admitted to CNSC-OIG investigators that they inflated their services hours on their timesheets. The members claimed to have performed their service, but overstated on their timesheets the number of hours they actually served.
CNCS management concurred with CNCS-OIG recommendation and took the following actions: (1) disallowed $140,885 in match funds, (2) directed the New Jersey Commission to take appropriate corrective actions to prevent members from performing activities inconsistent with and outside the scope of the grant agreement, and (3) both members who inflated their timesheets were exited from the program without an Education Award. In addition, the CFS’ 2017 grant was placed on hold until CFS presented evidence of adequate match funding.
Case ID 2016-026
Failure to Follow Proper Procedures Leads to Changes for Agency Personnel
CNCS-OIG received an allegation that a CNCS State Program Officer may have falsified documents when she awarded a VISTA grant.
The investigation found no evidence that the employee falsified documents pertaining to the awarding of the VISTA grant; however, the employee failed to follow the VISTA Desk Reference guidelines when she failed to obtain the proper documents and verify the 501(c) (3) nonprofit status before awarding the VISTA grant.
The employee also did not exercise due diligence when she failed to verify that an executive director of the joint venture VISTA program was authorized to sign the VISTA grant application(s) on behalf of the legal entity.
Based on the investigation findings, CNCS-OIG recommended CNCS management add a certification block or a checklist showing that the required documents were obtained and/or verified in the grant management system prior to awarding or funding a grant.
The employee resigned her position. CNCS management concurred with CNCS-OIG recommendations and implemented changes requiring employees to document the verification of the required documents prior to grant award.
Case ID: 2017-013
AmeriCorps Members Displaced Staff While Earning Education Award Leads to Disallowed Costs
A Hotline caller alleged that staff at the YMCA of Cass and Clay County (YMCA), Fargo, ND, were using AmeriCorps members (members) to fill staff positions and perform duties unrelated to their AmeriCorps position descriptions.
The CNCS-OIG investigation disclosed that the YMCA staff violated 45 CFR § 2540.100(f) Nondisplacement, when they knowingly allowed 13 members to fill vacant staff positions (daycare teachers/assistant teachers) with the YMCA’s School Age Learning Center (SLC) program for up to three months until the YMCA could hire suitable employees.
Additionally, the YMCA staff violated 42 U.S.C. § 12602 when they improperly awarded Segal Education Awards to eight members whose portion of service hours consisted of staff displacement.
The YMCA staff violated the terms and conditions of the AmeriCorps grant when a YMCA staff employee performed the duties of both the AmeriCorps program coordinator and AmeriCorps volunteer coordinator even though the grant application stated the YMCA would have separate employees performing the duties. Additionally, both positions were charged to the grant as matching funds.
The YMCA also violated the terms and conditions of the AmeriCorps grant when they assigned members to the YMCA’s XERZONE so they could watch the children of patrons who utilized the YMCA’s facilities (exercise room, gym, pool, classes). Members assigned to the YMCA’s XERZONE experienced a significant amount of idle time when children were not present. During those idle times, the YMCA did not assign any productive service for the members.
CNCS management concurred with CNCS-OIG recommendations and took the following action: (1) disallowed and recouped $22,312 in stipend payments disbursed to thirteen members placed in staff positions; (2) disallowed and recouped $22, 237.86 in Segal Education Awards awarded to eight members whose hours included staff displacement; and (3) elevate the risk level of the North Dakota Commission due to the poor program management of the YMCA grant. CNCS management declined to disallow any staff salary used as non-Federal match because the YMCA’s match contribution (50 percent of total project) exceeded the legally required match amount (38 percent of the total project).
In addition to the aforementioned action by CNCS management, the North Dakota Commission implemented a corrective action plan to ensure the YMCA provided better training to the members and utilized the members more effectively.
Case D: 2016-006