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.
Proactive Vulnerability Assessments at NCCC Campuses Lead to Corrective Action
As part of its fraud prevention efforts, the OIG assessed the vulnerabilities of the Pacific, Southwestern and Southern National Civilian Community Corps (NCCC) campuses in the areas of supply and equipment management, fleet operations, debit card usage and cash management. The OIG found a number of procedures that were inadequate, outdated, or not being followed by NCCC staff and NCCC AmeriCorps members. Examples include:
Neither the campuses nor NCCC headquarters could produce a copy of the specific procedures to be used in conducting and documenting the required quarterly audits of debit cards, resulting in an ad hoc process without program-wide comparability;
Contrary to written procedures, NCCC staff was allowing members to use their NCCC-issued debit cards for food purchases even while not on a deployment (spike);
Investigators noted substantial discrepancies between General Services Administration (GSA) vehicle logs and the vehicles’ mileage, preventing individual accountability and creating a risk of misuse of those vehicles;
Staff at one campus was unable to validate costs and expenditures related to travel and operations, allegedly because external hard drives crashed, without backup;
Investigators advised NCCC program management of these and other findings and observations. NCCC management responded that it was addressing the findings and recommendations by updating its policies and had implemented new procedures.
-Case ID: 2014-006 (Sacramento), 2014-007 (Denver), 2014-008 (Vicksburg)
Allegations of Misuse of Program Funds Referred to State Agency
The President of the Board of Directors of RSVP Colorado West, Inc., Montrose, CO, notified OIG of the discovery that a former executive director diverted $11,000 of agency funds to her personal use. After determining that the organization had not drawn down any Corporation funds during the period in question, OIG investigators referred this matter to the State of Colorado Department of Human Service, Fraud Division. The misused funds appear to have come from the Colorado State Department of Human Service program and/or local donations.
- Case ID: 2014-026
Allegations of Misuse of AmeriCorps Members Result in Administrative Findings
The OIG, along with an AmeriCorps program officer from Volunteer Mississippi, the State service commission (Commission), conducted an investigation of an anonymous complaint that Climb Community Development Corporation (CCDC), Gulfport, MS, officials, (1) credited AmeriCorps members with service hours for non-authorized activities (i.e., attending church, mowing and landscaping), and (2) used AmeriCorps members to operate the grantee’s non-profit café/catering business. While these allegations were not substantiated, OIG and Commission personnel noted administrative discrepancies during their review, ranging from missing documentation to an erroneous education award. Program officials corrected the error, resulting in a cost savings to the government. Commission personnel are resolving the administrative compliance findings with the grantee.
- Case ID: 2014-020
Allegation of Misuse of VISTA Member Results in Removal of VISTAs
The OIG received a Hotline allegation concerning the misuse of an AmeriCorps VISTA member at the Big Brothers Big Sisters of Will and Grundy Counties (BBBS), Joliet, IL. The complainant alleged that the VISTA member was on numerous occasions forced to perform staff duties, as well as fill in for an absent staff member. The OIG referred this matter to Corporation management for review and resolution.
Management reported that BBBS officials did not agree that the VISTA member was directed to perform administrative duties for a majority of her VISTA service, but did confirm the VISTA member was occasionally asked to fill in when a staff member was absent. However, the VISTA member was still expected to fulfill her VISTA service during this period. The VISTA member confirmed she was still required to perform her VISTA duties but the staff position was the receptionist and BBBS officials expected her to perform the clerical duties. Corporation management informed the OIG that all the VISTAs were removed from BBBS.
- Case ID: 2014-010
Corporation State Director Misuses Government Credit Card and Submits False Travel Vouchers
Ms. Rochelle Barry, former Georgia State Director for the Corporation, knowingly defrauded the Federal Government by submitting false and inflated travel claims. She also misused her Government travel card, including making personal purchases on the account.
After being questioned by investigators, Ms. Barry resigned her position to forestall administrative action. The Corporation issued a debt collection letter to Ms. Barry for reimbursement, and she has repaid the outstanding obligation.
- Case ID: 2013-039
Stolen Impounded Government Vehicle Results in Restitution
A CNCS-OIG investigation of a former NCCC AmeriCorps member, Vicksburg, MS. revealed that the member(1) stole and converted to his personal use a General Services Administration (GSA) vehicle valued at $12,300, (2) used without authority a GSA Fleet Service Card to purchase fuel for the stolen GSA vehicle, and (3) shipped personal parcels using the Corporation’s UPS account. His actions resulted in the loss of $12,412.63 in Federal funds.
The OIG investigation disclosed that Mr. Edwards misappropriated an NCCC vehicle, which he drove to the Houston, TX, area to visit with friends. The vehicle was subsequently towed for illegal parking. After unsuccessful attempts to retrieve the vehicle, Mr. Edwards returned to the NCCC campus and failed to notify anyone of the impoundment. As a result, the vehicle went unclaimed and was sold by the towing company. Based on the OIG investigation, Mr. Edwards entered into a settlement agreement with the Corporation. Mr. Edwards will forfeit his two education awards totaling $10,275 and repay the Corporation $2,137.63 to cover the Government’s losses of $12,412.63.
- Case ID: 2013-029
Program Director Debarred for Misuse of AmeriCorps Funds
Mr. Richard Parks, the former Salt Lake County Resource and Development Division’s AmeriCorps Program Director, Salt Lake, UT, pled guilty to Wire Fraud and Theft of Federal Funds in Federal court and was sentenced to 36 months’ probation and required to make restitution in the amount of $13,907. Mr. Parks misused more than $95,000 in Federal program funds when he enrolled ineligible individuals and falsified member time sheets to include fictitious service hours. OIG investigators worked on this matter with the Federal Bureau of Investigation, Salt Lake, UT. Based on the conviction, the Corporation’s Suspension and Debarment Official debarred Mr. Parks from doing business with the Federal Government for a period of three years.
- Case ID: 2011-041
Corporation Ratifies Use of AmeriCorps Members Not Contemplated by Grant Terms
OIG’s Hotline received an anonymous complaint regarding a number of irregularities in the operation of City Year Orlando (CYO), Orlando, FL. The allegations ranged from grantee officials allowing alteration of timesheets to enable members to receive education awards to use of AmeriCorps members to fill staff positions and perform staff duties. The OIG found no evidence that member timesheets were altered or falsified but did find other irregularities in the program’s operations.
CYO’s grant placed AmeriCorps members in six underperforming Orlando schools, to provide interventions targeting at-risk students and to provide general (“whole-school” or “whole-class”) support. Members were assigned 8-12 struggling students to tutor in academics, mentor in behavior management, and encourage in attendance. The grant listed targeted intervention activities in each of these areas, such as greeting assigned students upon arrival, helping them to resolve any barriers to attendance, assisting them with homework, calling families in the event of absences, and the like. In addition to tutoring and mentoring interactions with assigned students, members were to conduct certain activities to improve the overall school climate (e.g., anti-bullying rallies and school beautification projects), as well as supporting classroom behavior and focus. CYO is a subgrantee of Volunteer Florida, the Florida State service commission.
The OIG investigation determined that certain AmeriCorps members were required to provide general supervision of students outside grant parameters. For example, while the attendance interventions in the grant narrative and position descriptions focused on the assigned at-risk students, members were required to devote 45 minutes daily to supervise arrival and dismissal of all students, regulate vehicular traffic, and direct school buses. Multiple members complained that they were required to remain on school premises for an additional one or two hours even if they had no activities to perform and were instructed to count this unproductive time as service hours. At particular schools, members were required to chaperone a school prom, wear the school’s mascot uniform, sit in a dunk tank during a school event, patrol hallways for days at a time during standardized testing, attend sporting events as spectators, provide childcare services to parents attending orientation and regularly substitute for faculty in after-school programs by “watching” the children, so that teachers and staff could attend required meetings. Members at one school were required to attend a Halloween Horror Night sponsored by Universal Studios, a sponsor of CYO’s program at that school, and to greet paying park attendees, receiving service hours in return for this free labor.
Members complained that these extra duties were wasteful, unproductive, and interfered with their attention to individual at-risk students. A majority of the members interviewed by OIG investigators stated that they did not intend to renew their service terms because of their dissatisfaction with these extra duties.
In addition, the investigation determined that, in part because CYO failed to hire all the program managers promised in its grant application, AmeriCorps members were required to assume their professional administrative duties. While Team Leaders at three of the schools were assigned to classrooms and spent the majority of their time tutoring and mentoring, their counterparts at the other three schools were not assigned to classrooms and spent little, if any time, with students. Instead, they devoted the majority of their time to administrative duties in the CYO office and in meetings, functions that the program managers performed at the other schools. The program manager who was made responsible for two schools indicated that constraints on his time meant that his two Team Leaders were often required to perform program management tasks. Investigators also found that, during the previous year, one Team Leader quickly ceased providing services to at-risk students in order to spend all of her time on administrative and management tasks.
The Corporation interpreted the “whole-school” concept liberally, adopting the view of the Florida commission that these activities were “integral” and “consistent with” the program design and overall goals, and therefore allowable. In OIG’s view, even if some of the activities were arguably permissible under a generous reading of the grant, others are not so defensible. The “whole-school” concept is not a wholesale invitation to treat dedicated AmeriCorps members as cheap labor, to be deployed at the school’s convenience, on the theory that their mere presence provides a role model. However heavily the grantee and the Corporation rely on “whole-school” and “role model” concepts to justify the assorted tasks assigned to AmeriCorps members, these were evidently not the basis on which those members were recruited and trained. Members made clear to investigators that they felt misused and taken advantage of.
Moreover, it is difficult to understand why the Corporation condoned a policy that requires AmeriCorps members to remain on school premises with nothing to do and allows this wasted time to be mischaracterized as service hours, at taxpayer expense. The same is true of their required activities for Universal Studios. Neither the Corporation nor the Commission addresses this in its response. Finally, where, as here, the grantee fails to hire the promised number of professional staff, and a staff member acknowledges that his double workload caused him to transfer program management responsibilities to AmeriCorps members, those members were clearly performing staff functions and displacing employees, in violation of applicable regulations.
-Case ID: 2014-011
Corporation Retroactively Expands Grant Scope After OIG Discovers Unauthorized Activities
Following a Hotline complaint, OIG investigators determined that, from 2007 until 2014, officials of YouthBuild USA (YouthBuild), a National Direct grantee, improperly assigned 74 AmeriCorps members to serve as Teacher’s Aides in locations throughout the United States, although assisting in classroom instruction was not authorized service under the terms of the grant. As of June 2014, YouthBuild had disbursed $649,606.96 in living allowance payments for those unauthorized activities and certified $212,815 in related education awards. This figure does not include education awards certified for members serving at the time of our investigation.
YouthBuild’s grant provided in essence that students working towards a high school diploma or GED would participate in AmeriCorps half-time, assisting in their communities with housing construction, renovation, and energy efficiency projects. The grant narrative identifies the primary service activity as the construction and rehabilitation of homes in low-income areas, to include wheel-chair ramp installation and weatherization. Other members might be assigned to refurbish computers or provide technology skills to community non-profit organizations, and a small number of members would provide healthcare services to low-income individuals. The grant identified as secondary service activities removing graffiti from public buildings, offering meals in shelters or reading to school children.
Individuals who had obtained a diploma or GED could serve full-time, either (1) by leading or working on a construction team; or (2) in volunteer generation, i.e., recruiting, training and overseeing community volunteers and developing partnerships with area businesses and non-profits. Although nothing in the grant contemplated that full-time AmeriCorps members would participate in the classroom instruction of the part-time members, YouthBuild repeatedly and throughout the United States assigned full-time members to serve as teaching assistants.
Although teaching assistance forms a part of many AmeriCorps grants, it was not included in YouthBuild’s grant. The applicable standard AmeriCorps grant provisions expressly require prior written approval from the AmeriCorps Program Office for any changes to the program scope, objectives or goals. Nevertheless, YouthBuild officials unilaterally modified the scope of the grant to create a new primary service goal for members to serve as full-time teaching aides, with such duties as tutoring, grading assignments, assisting in applications for financial aid and college admission, and, in some instances, teaching under the supervision of the assigned teacher. Neither the Corporation’s program officer nor its grants officer was aware that YouthBuild was assigning members to such duties. Each of them expressed the view that these activities were outside the scope of the grant.
Corporation management nevertheless ratified the grantee’s actions and declined to disallow the charges, on the ground that having AmeriCorps members serve as teaching aides was “consistent with the program design and overall goals of the YouthBuild AmeriCorps program.” The Corporation disallowed costs for a single AmeriCorps member whose primary service activities involved clerical and administrative functions that should have been performed by grantee staff. Ratifying changes under such an imprecise and subjective standard encourages grantees to seek forgiveness rather than ask permission. The grant provisions require advance approval because that transparency allows the Corporation to make informed choices about the allocation of resources. Moreover, it is far easier to decline to fund an activity in advance than to recover costs expended on unauthorized activities; not only is recovery dependent on the grantee’s ability to repay, but Corporation personnel are reluctant to impose hardship on non-profit grantees, and some of them view disallowance of costs as inherently punitive.
Moreover, OIG has serious concerns about this decision on the merits. In reaching its decision, the Corporation apparently did not obtain information regarding how YouthBuild selected the individuals it assigned as teaching aides, or what training it provided to ensure their effectiveness in an academic setting or in connection with college and financial aid applications. Moreover, we see nothing to demonstrate how the Corporation and the grantee determined that this was a better use of resources than assigning the members to construction teams as originally envisioned, or whether the change had any effect on the performance measures for that construction activity.
- Case ID: 2014-009 and 2014-017
Corporation Retroactively Approved Use of Veterans Initiative Grant for Services to Non-Veterans
Misuse of Federal Grant Funds
The OIG conducted an investigation into allegations received from an anonymous complainant that Ms. Barbara Gilkey, Program Director, Arkansas Home Instruction for Parents of Preschool Youngsters AmeriCorps program (HIPPY), Little Rock, AR, was fraudulently enrolling full-time HIPPY employees in AmeriCorps positions. The investigation established evidence that between 2010 and 2012, Ms. Gilkey caused the improper awarding of $417,167 in Federal grant funds to the HIPPY program and certification of $103,450 in education awards to ineligible members. Investigation further revealed Ms. Mary Bea Gross, Executive Director, Arkansas Service Commission, Little Rock, AR, was negligent in safeguarding Federal funds when she failed to make an adequate inquiry regarding earlier allegations pertaining to Ms. Gilkey. Corporation management reported that Ms. Gross’s employment was terminated as a result of her actions. Corporation management debarred Ms. Gilkey for a period of three years. See www.sam.gov.
Case ID: 2011-038
Executive Director Falsely Certifies AmeriCorps Members’ Education Awards
The OIG received allegations that an Executive Director of an AmeriCorps program at an Arizona Community College, fraudulently created time sheets and falsely certified ineligible AmeriCorps members to receive education awards. The investigation proved that the Executive Director fraudulently certified AmeriCorps members’ time sheets by claiming unallowable service hours. As a result the Executive Director falsely certified the members’ education awards. The Executive Director’s actions induced the Federal Government to wrongfully disburse $2,960,684.05 in Federal funds; $2,036,084.05, in education awards paid to ineligible AmeriCorps members and $924,600 in administrative fees for expenses in implementing the grant. This matter was referred to the United States Attorney’s Office for criminal prosecution. The United States Attorney’s Office declined criminal prosecution citing that the Executive Director did not directly profit from her conduct and that the college was aware of her conduct and took no significant action to remedy the problems. This matter is being pursued civilly with the United States Attorney’s Office under a separate action.
Case ID: 2011-025
FBI Assist in OIG Investigation with Guam AmeriCorps Grantee
The Federal Bureau of Investigation, Guam Resident Agency, in conjunction with the OIG completed an investigation into allegations that a sub-grantee of the Serve Guam! Commission (Commission), enrolled employees as AmeriCorps members and supplemented their salaries with Federal funds. The investigation confirmed that seven grantee employees were also enrolled as part-time AmeriCorps members; however, based on the interviews of members and staff the investigation did not establish evidence that the employees used their employment hours as AmeriCorps service hours. As a result of the investigation, the grantee no longer allows its employees to enroll in the AmeriCorps program.
Case ID: 2013-017
Senior Corps Program Highlights Allowable Service
The OIG received an anonymous Hotline complaint alleging that two Senior Companions assigned to a Senior Companion Program (SCP), in North Carolina charged a fee to transport their clients to the grocery store and keyed vehicles of other residences in retaliation for them provided free transportation to SCP clients.
An inquiry into the allegation by Corporation management and the SCP sponsor determined that clients voluntarily paid the SCP volunteers to reimburse them for their gas. Coordination with the local police department determined that only one vehicle was keyed and the incident was unrelated to SCP and its volunteers.
Subsequently, the grantee reiterated its policies with both the SCP volunteers and the program’s clients.
Case ID: 2014-002
OIG Investigation Uncovers Eligibility Flaw
The OIG, in conjunction with Serve Minnesota, determined that the Corporation’s process for manually verifying the eligibility status of its AmeriCorps members were inadequate, resulting in an undocumented immigrant fraudulently enrolling in a Minnesota Read AmeriCorps program and receiving $6,512.83 in Federal funds. The OIG determined the former member provided both a fraudulent social security number and permanent resident card to enroll in the AmeriCorps program. Grantee officials were alerted to the fraudulent identifications at the conclusion of the member’s service term, when the member declined his education award claiming he was in the country illegally and the documents he provided to enroll were fraudulent.
The OIG verified that the grantee had properly processed the member’s information in the Corporation’s AmeriCorps database. After the member’s personal information was initially rejected the grantee obtained the required documents from the member and faxed them to the Corporation for manual verification, as required. Subsequently, the grantee received approval from the Corporation to allow the member to serve.
The OIG investigation determined that the Corporation Trust does not have the appropriate resources to verify eligibility status. The OIG interviewed Trust personnel and reviewed the process and learned the process was no different than the grantees process with no additional verification. The approval relied on a Corporation employee making a determination based on the authenticity of scanned documents.
The OIG recommended that Corporation management implement a process for manually verifying the eligibility status of AmeriCorps members who were not verified during the Social Security Administration’s initial review such as subscribing to a verification database (Clear, Lexis-Nexis, etc.). The process should encompass a means for Corporation Trust personnel to confirm whether the information submitted matches the individual enrolling in the program. The United States Attorney’s Office declined prosecution citing that the member performed his AmeriCorps service. The Department of Homeland Security declined to interview the former member to verify his immigration status.
Case ID: 2013-043