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.
Allegations of Prohibited Activities (Attempt to Influence Legislation, Displacement and Service Outside the Scope of the Grant (Unfounded)
CNCS-OIG investigators found no evidence to support a Hotline call alleging that AmeriCorps members with the Volunteers in Service to America, Student Veterans of America, Washington, DC, a service site of the American Legion Auxiliary, Indianapolis, IN., engaged in prohibited activities to influence proposed legislation related to the GI Bill or performed service unrelated to their official VISTA duties.
Case ID: 2017-010
Improper National Sex Offender Public Website Checks/Displacement and Improper Use of Members Leads to Disallowed Cost
A CNCS-OIG investigation found that AmeriCorps members with the Virginia Department of Veterans Services (DVS), Virginia Beach, VA, displaced staff and performed activities outside the scope of the grant. The investigation was opened based on a hotline allegation.
The investigation also revealed that the current and former Program Directors (1) improperly disbursed Federal grant funds by assigning three members to perform service outside the scope of the grant; (2) violated 45 CFR § 2540.100(e) and (f) by assigning members to duplicate activity and displace staff positions of service site employees, and (3) violated 45 CFR § 2522.230 when they certified partial Education Awards for three members who did not meet the award requirements. The former director also violated 45 CFR § 2540.204 by failing to conduct timely National Sex Offender Public Website (NSOPW) checks on six members.
During its investigation, CNCS-OIG investigators also discovered the Virginia Office on Volunteerism and Community Service (Commission) failed to identify several instances of noncompliance, because it did not adequately monitor DVS. The Commission also failed to follow the CNCS National Service Criminal History Checks (NSCHC) Interim Disallowance Guide regarding cost disallowance for NSCHCs and expanding the scope of file review.
CNCS management reported they concurred with CNCS-OIG’s findings that DVS tasked members to serve outside the scope of the grant and would disallow living allowances and Education Awards for those three members totaling $24,193.50. DVS also failed to conduct timely and complete NSOPW checks on six members and disallowed $9,000. CNCS also directed the Commission to review all members’ files for NSCHC compliance and the service for some of DVS’s service sites. CNCS already provided on-site training to the Commission and confirmed the Commission recently revised its monitoring policies and procedures.
Case ID: 2016-023
Allegation of Prohibited Activity – Unfounded
A CNCS-OIG investigation found no evidence that two AmeriCorps members assigned to a family planning center in Chicago, IL engaged in prohibited activity when they attended an abortion procedure.
Acting on a hotline allegation prohibited activity, CNCS-OIG found that two AmeriCorps members were offered the opportunity to observe an abortion procedure, because one of the members was a future medical student interested in obstetrics and gynecology. The members attended the procedure on June 14, 2017 after they clocked out from their AmeriCorps service and ensured that their attendance was not affiliated with their AmeriCorps enrollment.
Agency/Administrative Action: None
Case ID: 2017-016
AmeriCorps Members Displace Teachers in Classroom
The OIG received hotline allegations that AmeriCorps members assigned to the Summit Tutoring Corps (Summit), Redwood City, CA, were displacing staff. Members at Summit, a subgrantee of The Match Foundation Incorporated (Match Foundation) in Boston, MA, were assigned to provide intensive small group tutoring in math and reading to students in grades 6 through 12. The caller alleged that the Summit members alone managed Personalized Learning Time (PLT) classes, which a paid teacher previously lead.
CNCS-OIG investigators found Summit staff violated 45 CFR § 2540.100(f) Nondisplacement, when members were placed to manage PLT classes as part of their AmeriCorps service. The PLT classes were independent study periods that occurred several times a day. The classroom size ranged from 20 to 43 students from all grade levels and required one member to independently manage per session. The members were (1) required to maintain discipline in the class, (2) ensure the students were productive, and (3) proctor the Content Assessment Test. The members performed little to no tutoring during the PLT classes compared to their normal tutoring service.
Investigators also discovered that members at one school, as part of their AmeriCorps service, were directed to fill in as a receptionist after the receptionist was terminated. In addition, members were also required to be perform lunch monitor duties; the members were required to maintain control and oversee the students during lunch. Summit also allowed members to count their lunch break as part of their AmeriCorps service hours.
CNCS management informed CNCS-OIG they concurred with the finding of displacement and disallowed service hours for the members that performed receptionist duties. CNCS management also disallowed service hours for the members who claimed hours during lunch in which they were not engaged with students.
CNCS management disagreed with the CNCS-OIG finding that members displaced teachers in the Personalized Learning Time (PLT). CNCS management reported that after reviewing the information provided by Summit, CNCS found that the assignment of a member to a PLT class did not result in staff displacement. The nature of the PLT class had changed to provide students an opportunity to receive direct tutoring from members, rather than being a time for self-directed student activity akin to a study hall when it was supervised by a teacher. They claimed that the Match Foundation program focused on delivering tutoring services to improve students’ academic achievement, but AmeriCorps members were also expected to be fully integrated into school operations, including supporting the school’s student behavioral expectations. Member participation in the PLT class contributes to the overall relationship between AmeriCorps member tutors and the students.
CNCS-OIG disagreed with CNCS management’s conclusion that the members placed in PLT classes did not displace teachers. As stated in 45 CFR § 2540.100(f)(6)(i) “A participant in any program receiving assistance under this chapter may not perform services or duties that have been performed by or were assigned to any (i) Presently employed worker” The investigation discovered that prior to the arrival of the AmeriCorps members, as part of their duties, PLT classes were managed by the teachers. Once the members arrived, the PLT duties were removed from the teachers and given to the members as part of their AmeriCorps service.
Additionally, CNCS management claimed that Summit added direct tutoring from the members to the PLT classes. However, the teachers’ also “tutored” students when they helped them with homework assignments and prepared them for the assessment test during the PLT classes. Members would still be able to “be integrated into school operations, including supporting the school’s student behavioral expectations”, if they were preforming proper service.
Case ID: 2017-007
Corporation Contractor Fired for Violating Agency Policy and Leads to Policy Changes
Corporation management reported that an OIT contractor employee had connected a personal non-government laptop computer to the Corporation’s network without authorization.
A joint investigation with the Federal Bureau of Investigation found no evidence that the contractor compromised the integrity of the Corporation’s network or accessed fiscal data or personal identifiable information (PII). The investigation did disclose that the contractor had violated a Corporation policy when he connected his personal laptop computer to the Corporation’s IT server. The contractor employee’s employment was terminated.
As a result of this investigation we conducted a limited review of a Corporation employee’s computer to determine if the individual used their Government issued computer inappropriately. Based on the results of this limited review, we did not observe any questionable use that would rise above the level of appropriate government computer “de minimis use” as described in OIT policy. Also the risk associated with potential exposure of sensitive Corporation information or PII was determined to be low because of the compensating information security controls that were established and implemented by Office of Information and Technology (OIT). However, we did take exception that the employee stored mission related information on drive that is not backed up as per Corporation policy. Although the files are protected through the use of encryption software that protects access to the local disk drive, the files themselves are placed at risk because they are not appropriately archived and stored on a back-up medium that could allow for file restoration in case the file was lost or deleted. OIT management informed us that to remediate the issue they planned to revise their Rules of Behavior to include the requirement to store all work documents on agency shared drives to ensure proper back up. OIT Senior Management also indicated that they would remind employees about saving mission related to files to shared or personal drives network drives.
Case ID: 2012-013
Allegation of Ineligible Senior Corps Volunteer (Unsubstantiated) / Failure to Complete Background Checks (Founded) Case ID: 2017-008
This investigation was initiated after CNCS program personnel discovered during a compliance monitoring visit that a Senior Companion Program (SCP) volunteer in Delaware may have failed to report his prior sex offense convictions to the State of Delaware making him ineligible to serve.
CNCS management reported that the volunteer enrolled in the SCP on May 19, 2015; however, program officials did not conduct a National Sex Offender Public Website (NSOPW) search until June 12, 2015. Program officials reviewed the NSOPW results and determined that none of the individuals listed was the volunteer. Both FBI and Delaware State Criminal History Checks (CHC) were initiated on March 27, 2015. The state check came back with negative results on April 10, 2015. Before the FBI results were returned in early September 2016, the volunteer resigned from the program on June 30, 2016. The FBI results found that the volunteer had three sexual offense convictions that occurred prior to 1982 in North Carolina.
The investigation found that the volunteer had a legal obligation to report his prior convictions to the State of Delaware to determine if he was required to register with the state’s public sex offender registry. Since there was no evidence to prove or disprove that the volunteer complied with the requirement, CNCS management disallowed the cost.
CNCS program personnel also found that the grantee, First State Community Action Agency, was noncompliant when it failed to conduct timely and/or complete NSOPWs and CHCs for numerous staff and volunteers. CNCS disallowed costs and required improvements to the grantee’s policies and training.
As a result of the compliance visit findings, CNCS management disallowed $3,884.24 for the alleged ineligible volunteer and $15,625 for the late or incomplete background checks. CNCS also required the grantee to update its staff and volunteer files.
Allegations of Unallowable Service Hours and Mileage Reimbursement (Unsubstantiated)
This investigation was initiated based on Hotline allegations from an individual who requested anonymity, who alleged that some members assigned to the California Tribal AmeriCorps Program had inflated their service hours and/or claimed mileage reimbursement from their place of residence to their service sites.
The investigation found insufficient evidence to prove or disprove the allegations that members inflated their service hours and/or claimed mileage reimbursement from their place of residence to their service sites.
The results of the investigation were provided to the CNCS management for additional review during its monitoring reviews to ensure that the grantee adheres to the grant provisions.
Case ID: 2017-002
Allegations of Displacement Leads to Program Review
This investigation was initiated based on Hotline allegations from an anonymous complainant who reported staff displacement, inaccurate timekeeping and lack of supervision at the AmeriCorps program.
Investigators discovered that grantee members at two service sites were assigned duties which would ordinarily be performed by staff employees, a violation of 45 CFR § 2540.100(f) – Nondisplacement.
Investigators found no evidence to support the allegations of lack of supervision or fraudulent timesheets.
CNCS management reported that the New York Commission on National and Community Service (Commission) personnel looked into the CNCS-OIG findings and determined that the service provided by the members was not outside the scope of the grant or the members’ position description. The Commission reviewed the circumstances of the program and found that, in a few cases during the time period immediately following member initiation and while undergoing orientation, some members were not fully engaged in regular service. The Commission does not believe this was widespread or significant.
CNCS management reported that the intermittent performance of inappropriate service did not call into question the members living allowance, nor affect their education awards. Additionally, several of the members exited without an education award or were not eligible to earn a ward. Therefore, no funds were disallowed or education awards reduced.
Case ID: 2016-030
Improper National Sex Offender Public Website Checks Lead to Disallowed Costs/ CNCS Management Follow Up on Internal Control and Use of Volunteers Issues
A Hotline call alleged that Senior Corps management with the Central County United Way (CCUW), Hemet, CA, were inflating volunteer service hours; assigning volunteer service activities outside the scope of the grant and displacing staff.
The CNCS-OIG investigation found evidence that grantee management had some of its volunteers performing service outside the scope of the grant and displaced staff with volunteers. Additionally, CNCS-OIG investigators found that four members served in the Forster Grandparent Program before completing the National Sex Offender Public Website (NSOPW) check requirement. There was insufficient evidence to prove or disprove that volunteer timesheets were inflated due to the lack of adequate documentation.
CNCS management concurred that CCUW failed to conduct timely and complete NSOPW checks and disallowed $5,250 for the late NSOPW checks. Additionally, CNCS management reported it will conduct a site visit to determine if additional cost should be disallowed for the questionable service performed outside the scope of the grant; displacement; and review its internal controls concerning it timekeeping procedures.
Case ID: 2016-007
Improper National Sex Offender Public Website Checks Lead to Disallowed Costs
CNCS-OIG received Hotline allegations that AmeriCorps members assigned to the Detroit Parent Network (DPN) Project Graduation AmeriCorps Program, Detroit, MI, were assigned service activities outside the scope of the grant and had displaced DPN staff as employees.
Our investigation found evidence to support the allegation and found DPN had some Americorps members performing service outside the scope of the grant. Additionally, while on-site, CNCS-OIG investigators found that 19 members served in the AmeriCorps program prior to completing the required National Sex Offender Public Website (NSOPW) check.
CNCS management concurred that some members had performed questionable service and DPN had allowed members to serve before completing the required NSOPW background check and has disallowed $28,000.
Case ID: 2016-001
Former AmeriCorps Grantee Finance Director Embezzled Non-CNCS Funds
The United States District Attorney’s Office, District of Rhode Island (USAO), Providence, RI, found that Mr. Charles Denno, former Finance Director, The Providence Plan (ProvPlan), Providence, RI, an AmeriCorps grantee, embezzled over $500,000, in agency funds, during a check writing and forgery scheme between 2012 and 2016.
The investigation conducted by the USAO and several Federal and state agencies determined no CNCS AmeriCorps grant funds were stolen as a result of Mr. Denno’s fraudulent activity.
Case ID: 2016-029
Prohibited Activities – AmeriCorps Members Directed to Transport Individual for Abortion Services
CNCS management alerted CNCS-OIG of an allegation concerning Prohibited Abortion Activity directed by an AmeriCorps grantee employee with the International Institute of Metropolitan St. Louis (IISTL), St Louis, MO.
CNCS-OIG investigators found that an AmeriCorps supervisor violated 42 USC § 12584a(a)(9), providing abortion services or referral for receipt of such services, and CNCS implementing regulation 45 C.F.R.§ 2520.65(a)(10), when she directed an AmeriCorps member to transport a client to an abortion clinic for an abortion.
In addition, IISTL’s AmeriCorps State Position Description (PD) contemplated that AmeriCorps members will, in addition to their direct service activities, provide administrative support services on an as-needed basis. The PD gave rise to the possibility of violations of 45 CFR 2540.100(f), Nondisplacement. The language would seem to allow the grantee to award service hours for unallowable activities.
CNCS management reported they concurred with CNCS-OIG recommendations and the Missouri Commission immediately directed all IISTL staff to complete the CNCS refresher training eCourse on Prohibited Activities. All staff completed the eCourse and follow up discussion on allowable/unallowable and prohibited activities. IISTL reviewed and redrafted member PDs under the supervision of the Commission to clarify any ambiguous language that might be interpreted to allow a member or IISTL staff to contemplate displacement. Also, any costs associated with the prohibited activity were considered de minimis (less than $10), and that it would not be practical to pursue collection because the administrative costs associated with the collection action would far outweigh any recovery.
Case ID: 2016-021
VISTA Project Ended After Duplication of Service
CNCS-OIG completed its investigation into Hotline allegations that VISTA members (VISTA) assigned to Programa de Apoyo y Enlace Comunitaro (PAEC), Rincon, PR, were directed to perform duties ordinarily performed by a paid employee.
The investigation found that several VISTAs were directed by the executive director to renovate a kitchen, paint offices, and clean the exterior of a building all operated by PAEC. The time used to perform these tasks were counted as service hours. The investigation found that the time counted towards their VISTA service was minimum and did not affect their education awards. Additionally, VISTAs performed direct service as part of their VISTA service when they taught classes.
During the CNCS-OIG site visit it was discovered that two VISTAs and two AmeriCorps members manipulated the time keeping machine with the intent of leaving early and receiving service hours not earned. The members involved admitted to the manipulation of the time keeping machine, but denied submitting fraudulent timesheets or counting hours they had not served.
CNCS management reported that action had been taken against the individuals involved with tampering with the time clock. Additionally, CNCS management issued a Notice of Non-Renewal to PAEC, ending PAEC’s VISTA program, which duplicated some of the AmeriCorps program grant.
Case ID: 2016-008
Duplicate and Improper Enrollments Leads to Changes by National Direct Grantee
CNCS management reported that it discovered anomalies with the National Service Participants (NSP) accounts in the National Service Trust (NST) database in which AmeriCorps members had been enrolled in Teach for America (TFA) Idaho and Chicago AmeriCorps programs between Grant Years (GY) 2013 - 2017 under multiple NSP accounts with different Social Security Numbers.
The CNCS-OIG investigation found that a TFA Regional Operations Manager improperly enrolled TFA members at its Chicago, IL, and Nampa, ID, sites between 2013 and 2017. The investigation also found that in two instances duplicate accounts were included in drawdown calculations for the National Direct enrollment fees, which TFA used to cover its administrative grant costs. This allowed TFA to receive $1,600 ($800 per member) it was not entitled. Further, the TFA Regional Operations Manager improperly certified several members to receive dual education awards for the same grant period based on the duplicate enrollments.
TFA management, working with CNCS management, corrected the members’ accounts and implement internal controls and training to ensure future compliance. TFA management reported that it had terminated the employee involved for failing to follow their internal policies. None of the members who improperly received a second award used their duplicate award.
Case ID: 2017-005
Fraudulent Claims Result in Reimbursement and “High Risk” Oversight
A Hotline complainant reported that Senior Resources of Guilford (SRG), Greensboro, NC, officials fraudulently claimed that the Foster Grandparent Program (FGP) Project Director worked a percentage of her time on the Retired Senior Volunteer Program (RSVP), for which the grantee sought reimbursement.
CNCS-OIG completed its investigation into allegations SRG fraudulently used Federal program funds from the SRG RSVP grant, for the salary of the FGP Project Director. Investigators discovered SRG drew down $4,168 of Federal RSVP salary funds and verbally provided false information about the FGP Project Director’s work to CNCS staff . Investigators also found many individuals listed as current RSVP volunteers were either no longer volunteers, or were not aware their service was related to the RSVP or even SRG.
CNCS management reported SRG repaid the $4,168 in disallowed costs. CNCS coordinated with SRG and updated the RSVP volunteer roster. CNCS also developed a long-term mitigation plan to ensure SRG remained in full compliance of CNCS policies.
Case ID: 2016-010