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.
Seniors Serve with Improper Background Checks / Disallowed Grant Costs
A hotline complainant alleged that a Florida Senior Corps grantee (1) inaccurately allocated staff time between the Senior Companion Program (SCP), Foster Grandparent Program (FGP), and Retired and Senior Volunteer Program (RSVP) grants; and (2) improperly used of Senior Corps volunteers (volunteers) assigned to SCP, resulting in inaccurate charges to the Senior Corps grants and noncompliance with program requirements. During the investigation CNCS-OIG investigators determined management staff allowed a majority of their volunteers to serve without a properly completed National Sex Offender Public Website (NSOPW) check.
The investigation revealed that grantee staff were not accurately allocating their time to the proper grant. The investigation also showed that grantee management allowed six SCP volunteers to serve in a fee for service program which charged clients a monthly fee of $300 for services rendered by the SCP volunteers. The grantee used the $21,570 in earned fees as an in-kind match to the grant.
While conducting a random sampling of the 141 FGP and 98 SCP active Senior Corps files, investigators found that more than 80 percent of the NSOPW checks had not been properly conducted. Specifically, the NSOPW checks were not nationwide checks, but were instead confined to the State of Florida or local area.
As a result of the CNCS-OIG investigative findings (1) the grantee revised its accounting procedures and hired an independent employment law agency that revised its policies and procedures as well as provided supervisory training on personnel issues, annual audit requirements, and regulatory compliance; (2) CNCS Management disallowed the $21,570 charged as in-kind match to the grant for in-home services performed by the SCP volunteers; and (3) CNCS Management disallowed $29,500 for failure to conduct appropriate NSOPW checks. Additionally, CNCS Management is continuing to review the volunteer files for additional disallowed costs regarding the NSOPW checks.
Case ID: 2015-010
Review of Information Technology Security Leads to Better Vulnerability Scanning
With the help of CNCS-OIG's information technology professionals, investigators discovered the Corporation's Office of Information Technology Office (OIT) was not conducting periodic vulnerability scans of the desktop computers by which most CNCS employees access the agency's information systems. When linked to the agency's network, the computers could provide a conduit for malicious software and other threats to the overall security and privacy of information.
OIT management advised that it had decided not to undertake desktop scans regularly because of their operational impact. The scans extended the time necessary to boot up desktops, resulting in delays and frustration by Corporation employees. (OIT management did have a system in place to scan its network, but these scans did not include desktop computers.) OIT management has since identified and implemented software that can perform vulnerability scans on a monthly basis without problematic delays.
-Case ID: 2014-025
Failure to Safeguard Personal Identifiable Information / Violated the AmeriCorps VISTA Program Grant Terms and Condition / Displacement:
CNCS-OIG received an anonymous hotline complaint alleging VISTA members (VISTA) serving at a service project in Pennsylvania were displacing employees in violation of 45 U.S.C. § 1216. Nondisplacement of employed workers, which states VISTAs may not perform any services or duties or engage in activities which would otherwise be performed by an employed worker as part of his assigned duties as an employee.
The investigation revealed (1) grant officials violated 45 U.S.C. § 1216 when they placed VISTAs to perform activities or duties that would otherwise be carried out by employed workers, (2) violated the AmeriCorps VISTA Program Grant Terms and Conditions section IV when a policy was created restricting VISTAs from freely contacting CNCS employees, and (3) failed to protect current and former VISTA’s Personal Identifiable Information (PII) when they uploaded the VISTA’s personal information (Social Security Card, Passport, Birth Certificate, and Resume) onto their servers and allowed for anyone with access to their server to view, print, and download these documents.
The grantee discovered that that the VISTA’s policy book contained an incorrect policy which restricted members from contacting CNCS employees. The grantee’s official policy was to allow full access to CNCS employees for its members. The grantee also placed security restrictions in place to limit access to the PII information to authorized individuals. The CNCS Pennsylvania state office staff took immediate action to ensure VISTA’s were not serving in staff positions when employees were absent or on leave.
-Case ID: 2015-019
Whistleblower Complaint Unfounded
CNCS-OIG received a complaint from a former Foster Grandparent Program (FGP), Project Director (PD) who claimed she was retaliated against when she was fired by her supervisor in February 2015 for a fraud she reported to CNCS-OIG in November 2012, involving the misuse of grant funds.
The CNCS-OIG investigation determined there was insufficient evidence to substantiate the complainant’s allegation that she was terminated in retaliation for her previous reports to CNCS-OIG. In addition, there was no evidence to refute the supervisor’s assertions that the complainant was terminated for the following acts of misconduct listed below:
The former PD accidentally started a fire at work and then lied to her supervisor to avoid responsibility for the incident. The PD’s lack of candor resulted in the evacuation of the building and numerous county employees being sent home early while the fire department searched for the origin and cause of the fire.
The former PD repeatedly failed to follow instructions to verbally communicate with her supervisor in-person or via telephone when conducting official business. The PD preferred to use e-mail as her primary method of communication with her supervisor in order to have a record of her communications. The former PD’s action caused the supervisor to miss numerous suspense’s because supervisor did not check her e-mail on a regular basis.
Further investigation determined the supervisor had violated the County personnel policies when she terminated the PD without following the procedural due process and grievance requirements concerning the discipline of employees as outlined in the County Personal Policy Handbook. On May 10, 2015, the Whistleblower voluntarily withdrew her complaint.
-Case ID: 2015-013
Displacement at AmeriCorps Service Site Leads to Changes
CNCS-OIG received an anonymous hotline complaint that the National Direct AmeriCorps members serving at a Pasadena, CA, service site had performed duties commonly associated with a paid employee.
The CNCS-OIG investigation found no evidence to support allegations that members at this site had displaced workers, however the investigation did identify, (1) members had insufficient supervision which resulted in excessive idle time; (2) service site officials directed members to entice local residence to seek their health service needs at the service site clinics.
CNCS-OIG investigators expanded its scope of investigation and interviewed members and their supervisor at several other AmeriCorps service sites for the same grantee. The investigation identified two members in which their assigned service violated 45 § CFR 2540.100, What restrictions govern the use of Corporation assistance, when they performed service that would have normally been performed by paid staff.
The grant Terms and Conditions provided for AmeriCorps members to be assigned to communities to improve healthcare for the medically underserved, increase financial literacy with regard to informed health care decisions and address barriers that affect the economically disadvantaged, older adults, individuals with disabilities and overweight children. Although a majority of the member’s service performed was in accordance to the grant provisions, there were instances where other members engaged in service outside of the scope of the grant.
When CNCS-OIG informed the grantee of our the findings, the grantee took action to ensure members were performing appropriate service and provided additional training to the service sites involved. The corrective actions taken by the grantee were approved by the CNCS program officer.
-Case ID: 2015-012
Allegations of Costs Mischarging (Unfounded)
Corporation management reported that they suspected a Retired Senior Volunteer Program (RSVP) grantee mischarged grant funds when it used funds from one CNCS grant as match to another CNCS grant. Additionally, management reported that it suspected that the RSVP grant staff utilized the wrong grant year funds to pay for staff termination/retirement payments.
CNCS-OIG found no evidence to substantiate the allegation that the grantee used grant funds as match to another CNCS grant. The investigation also determined the grantee staff properly charged the employee’s termination/retirement payments to the proper grant year since the pay period ended in the first week of the new grant year. CNCS Management reported it would review the grantee’s financial expenditure to ensure that it properly charged its grant expenses to the proper grant.
Case ID: 2015-024
AmeriCorps Site Supervisors Failed to Supervise Member’s Activity
Corporation Management informed the CNCS-OIG that a National Direct grantee reported an AmeriCorps member at their Tennessee site was suspected of falsifying his timesheets to earn an education award.
The CNCS-OIG investigation found no evidence to substantiate the allegation the member falsified his timesheets; however, the member did not earn an education award after the grantee claimed the member serviced some of the hours at an unapproved service site. The investigation disclosed that due to staff turnover and lack of oversight the member’s supervisor failed to monitor member’s activity when the member changed service sites without approval. The grantee revised its timesheet policy requiring its members to obtain a signature on their timesheets from the service site supervisor prior to grantee approval.
Case ID: 2015-022
AmeriCorps Members Serve From Their Residence Without Proper Supervision
The CNCS-OIG received a Hotline complaint from an anonymous source who claimed that a National Direct AmeriCorps grantee had AmeriCorps members serve from their residence while their supervisor was located in a different state.
The CNCS-OIG investigation disclosed evidence grantee officials violated the conditions of the AmeriCorps grant when it allowed seven members from grant years 2013 – 2015 to serve from their residence without proper supervision. The investigation also found that members’ timesheet/service hours were recorded and approved based on an honor system. CNCS management took immediate action and removed the current members serving from their residence. CNCS management reported that it would ensure future members would not serve from their residence.
Allegations of Theft of Program Funds - Unfounded
CNCS-OIG received an allegation that AmeriCorps members serving with a Florida based grantee continued to receive their living allowance after they had completed the program. The OIG investigation found that members who had completed their service hour requirement were still serving in that the program as the program was requiring the members to fulfill their full-year of service regardless if they met the service hour requirement early. There was no evidence to corroborate the allegation.
-Case ID: 2015-023
Lack of Oversight Leads to Senior Corps Volunteers Serving with Improper National Sex Offender Public Website (NSOPW) Checks
CNCS-OIG investigators discovered that a Senior Corps grantee improperly conducted NSOPW checks for the majority of their more than 230 Senior Corps volunteers between 2010 and 2014. The Florida based grantee only conducted local or state checks versus the required national checks. CNCS-OIG investigators also discovered that a CNCS State Program Officer’s lack of oversight during the monitoring of the Senior Corps project allowed Senior Corps volunteers to serve with incomplete NSOPW checks. In addition, the State Program Officer failed to timely follow up on findings that grantee staff had improperly documented their hours on the CNCS grants. CNCS-OIG informed CNCS management of the findings.
-Case ID: 2015-011
AmeriCorps Executive Director Misuses Agency Funds and Falsifies Loan Documents
Corporation management reported concerns that an AmeriCorps grantee may have mismanaged program funds. CNCS-OIG found that the Executive Director of the Tennessee based non-profit agency misused agency funds for personal use with the knowledge of some board members. This matter was referred to the local state law enforcement agency and local prosecutor. There was no evidence that CNCS funds were misused or stolen.
The investigation also determined that the Executive Director knowingly directed two AmeriCorps members to falsify Certifications of Completion and Final Inspection documents, which were fraudulently used to secure the release of construction funds from a Federal Home Loan Bank, prior to the completion of the project(s). This information was provided to the Federal Housing Finance Agency – OIG.
-Case ID: 2015-003
Texas OneStar Foundation (State Commission) Monitors AmeriCorps Grantee for Displacement
A Hotline complainant reported that program officials at a Texas grantee were using AmeriCorps members to fill staff positions. CNCS-OIG referred this matter to the Texas State Commission for follow up.
Commission personnel conducted an inquiry into the allegation. Commission personnel reported they conducted a review of the member’s position description and interviewed AmeriCorps and school staff personnel. Based on their review, Commission personnel determined a weakness in the grantee’s policy and procedures regarding AmeriCorps members that members had been placed in staff roles for short periods of time during the momentary absence of the teacher. There was no evidence to quantify the time members served in the staff rolls; however, Commission personnel placed the grantee on a corrective action plan and are monitoring their compliance.
-Case ID: 2015-001
Executive Director Embezzles Federal Program Funds / Improper Criminal History Checks Result in Disallowed Costs / Former Commission Employee Debarred for Collusion, Conflict of Interest
A Hotline complaint alleged that the Executive Director of Luz Community Development Coalition (Luz), Las Vegas, NV, used AmeriCorps program funds to pay for a family vacation trip to Europe. The investigation determined that the executive director used a credit card charged to the AmeriCorps grant to pay $8,451.08 of these personal expenses.
In the course of investigating these expenditures, investigators also discovered that Luz personnel improperly disbursed $169,500 in living allowances and certified education awards totaling $95,804 for individuals who were allowed to serve without the required checks of the National Sex Offender Public Website (NSOPW). Moreover, grantee staff presented investigators with altered NSOPW results to conceal their untimely completion. Luz also paid $13,500 in living allowances to 10 members after they had left the program.
Further, due to a conflict of interest, an employee of the Nevada Volunteer Commission had falsely declared the program to be “in full compliance,” even though he learned during a site visit that the NSOPW checks had not been completed. At the time of the site visit, the Commission employee was in employment discussions with Luz, and he subsequently joined its staff.
In March 2015, CNCS management disallowed $177,232 in grant costs, representing living allowances and education awards for those members who did not undergo NSOPW checks or where Luz personnel altered the date of the results. Notwithstanding its written policy to disallow costs incurred prior to completion of NSOPW checks, CNCS did not disallow the costs related to the late-performed checks and did not address the $13,500 in living allowance overpayment. CNCS debarred the former Executive Director for a period of three years and debarred the former Commission employee for one year. In the interim, Luz had ceased operations.
Recent Activity - On April 24, 2015, CNCS management informed the OIG that it has received additional documentation from the Nevada Volunteer Commission, which showed that five of the former members’ NSOPW checks were properly performed prior to service. The Commission personnel also located one of the missing NSOPW checks. Based on the documentation CNC management reduced the disallowed costs to $130,290.
- Case ID: 2012-012
Education Award Treasury Checks Stolen, Forged and Negotiated
A CNCS manager notified OIG that unknown person(s) had stolen and negotiated 12 U.S. Government Treasury checks, totaling $6,692.47, representing education awards paid by the U.S. Treasury and mailed to a Miami Florida College to pay the education expenses of former AmeriCorps members. An additional 55 checks from the same batch had apparently also been stolen; some of them have since been negotiated. This matter was referred to the United States Secret Service, Miami, FL, for investigation.
– Case ID 2015-016
Agency Employee’s Lack of Oversight of VISTA Project Resulted in Waste of $700,000
Due to the carelessness of a CNCS State Program Specialist, the Corporation disbursed more than $700,000 in Federal funds for unallowable and/or otherwise impermissible service activities. OIG found evidence that the employee provided inaccurate guidance that allowed VISTA members to serve in staff position(s). Additionally, the employee approved 13 VISTA Assignment Descriptions (VADs) that impermissibly allowed the sponsor to assign VISTA members to perform direct service. When members complained about these assignments, she made no meaningful effort to resolve their concerns and instead withheld information about the complaints from her supervisors and from the VISTA project site. The employee was allowed to retire prior to imposition of disciplinary action.
Case ID: 2014-021