Corporation for National and Community Service: Preliminary
Observations on the National Service Trust and AmeriCorps
(10-APR-03, GAO-03-642T).
In November 2002, the Corporation for National and Community
Service suspended enrollments in the AmeriCorps program due to
concern that the National Service Trust may not contain enough
funds to meet the education award obligations resulting from
AmeriCorps enrollments. This testimony reflects GAO's preliminary
review of the factors that contributed to the need to suspend
enrollments and GAO's preliminary assessment of the Corporation's
proposed changes.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-642T
ACCNO: A06629
TITLE: Corporation for National and Community Service:
Preliminary Observations on the National Service Trust and
AmeriCorps
DATE: 04/10/2003
SUBJECT: Locally administered programs
Program management
Volunteer services
Program evaluation
Trust funds
Funds management
National Service Trust
******************************************************************
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GAO-03-642T
Statement for the Record for the Subcommittee on Veteran*s Affairs,
Housing and Urban Development, and Independent Agencies, Committee on
Appropriations, U. S. Senate
United States General Accounting Office
GAO For Release on Delivery Expected at 10: 00 a. m. EDT Thursday, April
10, 2003 CORPORATION FOR
NATIONAL AND COMMUNITY SERVICE
Preliminary Observations on the National Service Trust And AmeriCorps
Statement for the Record by Cornelia M. Ashby, Director, Education,
Workforce and Income Security Issues, and Susan A. Poling, Associate
General Counsel
GAO- 03- 642T
As shown in the figure below, the number of participants enrolled in
AmeriCorps increased by about 20,000 from program year 1998 to program
year 2001. However, the number of AmeriCorps participants was not
reconciled with the number of education awards that the National Service
Trust could support.
GAO identified several factors that led the Corporation to suspend
enrollments. The factors included inappropriate obligation practices,
little or no communication among key Corporation executives, too much
flexibility given to grantees regarding enrollments, and unreliable data
on the number of AmeriCorps participants.
The Corporation has established new policies that may improve the overall
management of the National Service Trust if the policies are fully
implemented. However, the Corporation has not made policy changes to
correct a key factor* how it obligates funds for education awards.
Note: Participants shown are for AmeriCorps* State and National programs
only. Participants for AmeriCorps* National Civilian Community Corps and
its VISTA programs are not included. Data for program years 1998 through
2001 represents actual participants. Program year 2002 data represent
awarded positions. Program year varies by grantee. CORPORATION FOR
NATIONAL AND COMMUNITY SERVICE
Preliminary Observations on the National Service Trust and AmeriCorps
www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 642T. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact Cornelia M. Ashby at (202) 512- 8403 (ashbyc@ gao.
gov) or Susan A. Poling at 202- 512- 2667 Highlights of GAO- 03- 642T,
statement for
the record for the Chairman, Subcommittee on VA, HUD, and Independent
Agencies, Committee on
Appropriations, U. S. Senate
April 10, 2003
In November 2002, the Corporation for National and Community Service
suspended enrollments in the AmeriCorps program due to concern that the
National Service
Trust may not contain enough funds to meet the education award obligations
resulting from AmeriCorps enrollments. This testimony reflects GAO*s
preliminary review of the factors that contributed to the need to suspend
enrollments and GAO*s
preliminary assessment of the Corporation*s proposed changes
Page 1 GAO- 03- 642T
Mr. Chairman and Members of the Subcommittee: We are pleased to have the
opportunity to comment on the preliminary findings from our ongoing study
of the Corporation for National and Community Service*s (the Corporation)
management and oversight of the National Service Trust (the Trust). The
National Service Trust is a dedicated fund within the Corporation that is
to maintain sufficient funds to pay national service educational awards to
participants in the
Corporation*s AmeriCorps program. In November 2002, AmeriCorps suspended
enrollment of program participants. This statement will identify some of
the factors that contributed to this suspension and related policy changes
the Corporation has made since then.
These comments are primarily based on our preliminary analysis of
documents and information obtained through interviews with Corporation
staff. In addition, this statement reflects the April 9, 2003, opinion we
provided the Committee concluding that the Corporation incurs an
obligation for education benefits when it enters into a grant agreement
for the approved number of new participants and therefore it must record
the obligation against the budget authority available in the Trust. See
appendix I for the opinion. In summary, the factors we identified, to
date, that led the Corporation to suspend enrollments include
inappropriate practices for obligating funds, little or no communication
among key Corporation executives, and too much flexibility given to
grantees* they were allowed to adjust authorized positions and were not
required to provide timely information about the number of participants.
While the Corporation has established new policies that may improve the
overall management of AmeriCorps if the policies are fully implemented,
the Corporation has not made policy changes to correct a key factor* how
it obligates funds.
The Corporation for National and Community Service was created to help
meet community needs in education, the environment, and public safety and
to expand educational opportunity by rewarding individuals who participate
in national service 1 . The Corporation is part of USA Freedom Corps, a
White House initiative to foster a culture of citizenship, service, and
responsibility and help all Americans answer the President*s call to
service. The Corporation receives appropriations to fund program
operations and the National Service Trust. The Corporation makes grants
1 The National and Community Service Act of 1990 created the Corporation.
Background
Page 2 GAO- 03- 642T from its program appropriations to help grant
recipients carry out national service programs.
AmeriCorps is one of three national service programs the Corporation
oversees. 2 Most of the grant funding from the Corporation for AmeriCorps
programs goes to state service commissions, which award subgrants to
nonprofit groups and agencies that enroll the AmeriCorps* participants.
Participants in the AmeriCorps program can receive a stipend as well as
health benefits and childcare coverage. For example, about one- half of
AmeriCorps* participants received an annual living allowance of $9,300 and
health benefits. Those participants who successfully complete a required
term of service earn an education award that can be used to pay for
undergraduate school, or graduate school, or to pay back qualified student
loans. In exchange for a term of service, full- time AmeriCorps
participants earned an education award of $4,725 in program year 2002.
Participants have up to 7 years from the date of completion of service to
use the education award. AmeriCorps also enrolls participants on a
parttime basis and as *education awards only* participants. Part- time
participants who serve 900 or fewer hours annually earn education awards
proportional to those earned by full- time participants. Under the
*education awards only* program, AmeriCorps does not pay the participant a
living allowance or other benefits, but provides grant funding for
administrative purposes only, about $400 per full- time participant
annually. However, each participant receives an education award equivalent
to that earned by a paid AmeriCorps participant. The number of AmeriCorps
participants increased by nearly 20, 000 from 1998 to 2001. The program
year 2002 data indicate the number of positions awarded will decrease by
about 8,000. (See figure 1.)
2 The Corporation oversees the Senior Corps, AmeriCorps, and Learn and
Serve America. AmeriCorps consists of three programs: AmeriCorps* State
and National, AmeriCorps* VISTA, and AmeriCorps* National Civilian
Community Corps.
Page 3 GAO- 03- 642T
Figure 1. AmeriCorps Participants from 1998 to 2002
Note: Participants shown are for AmeriCorps* State and National programs
only. Participants for AmeriCorps* National Civilian Community Corps and
its VISTA programs are not included. Data for program years 1998 through
2001 represents actual participants. Program year 2002 data represent
awarded positions. Program year varies by grantee. In November 2002, the
Corporation suspended enrollments in AmeriCorps
because total enrollments were potentially higher than the Corporation had
expected. No new funds had been requested by and appropriated to the Trust
for fiscal year 2002, and under the continuing resolution at the start of
fiscal year 2003, no new funds would be deposited into the Trust until the
Corporation*s fiscal year 2003 appropriations were enacted. The
Corporation concluded that if its grantees and subgrantees were to fully
enroll new participants up to the maximum number of enrollments the
Corporation had approved in its grants, the Trust would not have a
sufficient amount to provide the educational awards to those participants.
Enrollments in AmeriCorps were frozen from November 2002 through March
2003.
Page 4 GAO- 03- 642T
Three factors contributed to the Corporation*s need to suspend enrollments
in AmeriCorps. Although the Corporation specified the maximum number of
new participants in the grants it awarded, the Corporation did not
recognize its obligation to fund participant education awards until it
actually paid the benefits. Had the Corporation properly
tracked and recorded its obligations in the Trust at the time of grant
award when it approved new enrollments, it likely would not have needed to
suspend enrollments. In addition, there was little, if any, communication
among the AmeriCorps program office, the grants management office, and the
Trust about the number of positions that the Trust could support.
Furthermore, by allowing grantees various flexibilities and not requiring
them to provide timely enrollment information, the Corporation and
AmeriCorps managers could not be certain about the number of participants.
The Corporation did not appropriately record or track its obligations for
education awards to program participants. Generally, an agency incurs an
obligation for the amount of the grant award with the execution of a grant
agreement. The Corporation enters into grant agreements with state
service commissions in which it specifies the budget and project period of
the award, the total number of positions approved, the total amount
awarded for program costs for the approved positions, and the terms of
acceptance. The award for the program costs is used to pay participants*
stipends and health and child care coverage. The Corporation incurs an
obligation for these program costs at the time of grant award. 3 While the
costs of education awards for the new participants are not specified in
the grants, in the grant agreements the Corporation commits to funding
education awards for all of the qualified positions initially approved in
a grant if the subgrantee enrolls all of the participants before the
Corporation modifies the terms or conditions of the grant. In other words,
upon award of the grant, the Corporation, at a minimum, has accepted *[ a]
legal duty * which could mature into a legal liability by virtue of
actions on the part of the other party beyond the control of the United
States.* However, the Corporation has concluded that it is not necessary
to obligate funds until an individual actually enrolls in AmeriCorps.
Therefore, the Corporation recorded education award obligations on an
3 We have not examined and accordingly express no opinion on whether the
Corporation is appropriately obligating program costs in the applicable
appropriation account. Three Factors
Contributed to the Need to Suspend AmeriCorps Enrollments
Inappropriate Obligation Practices
Page 5 GAO- 03- 642T
outlay basis. That is, obligations were recorded at the time of the
quarterly drawdown of amounts for education awards from the Trust.
By failing to recognize and record its obligations at the time of grant
award, the Corporation had no assurance that the number of positions
approved in grant awards did not exceed the amount of educational awards
the Trust could support. Proper recording of obligations serves to protect
the government by ensuring that it has adequate budget authority to cover
all of its commitments and prevent agencies from over- obligating its
budget authority.
Corporation executives we interviewed said that there was little if any
coordination between the AmeriCorps program office and officials
responsible for the management of the Trust about the number of positions
that the Trust could support. The AmeriCorps director said that she
considered the grant budget independent from the Trust and she neither
consulted with nor received direction from the Trust director when making
decisions about the grants. In addition, in recent years, AmeriCorps has
tried to increase the number of participants by enrolling them in the
*education awards only* program. Under this program, which was an effort
to lower the per participant program cost, AmeriCorps provides funding to
grantees for administrative purposes only, currently about $400 per full-
time participant annually. Increasing the number of participants in this
way is at a low cost to the AmeriCorps program appropriation, but at full
cost to the Trust, which funds the education awards, because each
participant receives an education award equivalent to that earned by a
paid AmeriCorps participant. Consequently, the number of positions funded
by AmeriCorps grants was not reconciled with the number supportable by the
Trust. According to Corporation officials
we spoke with, the Trust*s funding needs were based on an expected
enrollment of 50,000, while the AmeriCorps program office approved grants
for about 75,000 participants.
Corporation officials also said that prior to suspending enrollments in
AmeriCorps, the Trust was so well funded it did not warrant their
attention. They told us that early in the AmeriCorps program, a goal of
50,000 participants annually was used for Trust budgeting purposes.
However, it was found that fewer than that number of participants
enrolled, and not all of those who participated earned education awards.
Additionally, a Corporation budget official said that in the past those
who earned education awards were not using them as quickly as expected.
Even as the number of AmeriCorps participants grew, the Trust*s Lack of
Communication
Page 6 GAO- 03- 642T
accounting records showed an unobligated balance that was high enough for
Congress to rescind $111 million over fiscal years 2000 and 2001,
resulting in the deobligation of the Trust by this amount. Given this
history, Corporation managers did not see the need to reconcile the number
of positions created by grant funding with the number the Trust could
support. The Trust balance was not viewed as a constraining factor.
Because the number of positions approved in the grants was not reconciled
with the Trust before grants were awarded, there was the potential for
grantees to enroll more participants than the Trust could support.
Two program management policies affected the number and type of
participants and, therefore, the use of Trust funds. One policy permitted
grantees to over enroll participants under certain circumstances with
approval from their AmeriCorps program officer. Specifically, the policy
allowed grantees to over enroll up to 20 percent. The program year 2002-
03 data indicate that while only a few of the grantees increased their
enrollment, some increased theirs by more than 20 percent. Another policy
allowed grantees to convert positions from full- time to part- time as
long as the total number of full- time equivalents supported by the grant
did not change. While this practice did not affect the program funds, it
did affect the Trust. After the enrollments were suspended, Corporation
officials
determined that part- time participants used their education awards at a
higher rate than full- time participants and therefore the number of
parttime participants resulted in a relatively higher level of use for the
education award.
The Corporation did not have reliable data on the number of AmeriCorps
participants during the period leading up to the suspension. Enrollments
are recorded by grantees through the Corporation*s Web- Based Reporting
System (WBRS). While the enrollment information in WBRS was uploaded
into the Corporation*s database and used to track education award
obligations on a weekly basis, Corporation officials said that
discrepancies existed between the number of participants enrolled and the
number the Corporation was aware of, because of the length of time between
when a participant started to serve and when the grantee entered
information into WBRS. A Corporation official said that it was not unheard
of for some grantees to be 60 to 90 days late in entering an enrollment
into WBRS.
By allowing grantees the flexibility to change the number and type of
participants coupled with delays in receiving information on enrollments,
the Corporation and AmeriCorps managers could not be certain about the
Grantees Allowed to
Adjust Authorized Positions and Not Required to Provide Timely Participant
Information
Page 7 GAO- 03- 642T
number of participants. Corporation officials said that this resulting
lack of confidence in the data was a contributing factor to the decision
to suspend enrollments.
In response to concerns that the AmeriCorps program may have enrolled
participants without adequately providing for their education awards, the
Corporation has developed several new policies. While the Corporation is
modifying its practice of when it records obligations, the Corporation
overlooks the legal duty it incurs at the time of grant award. Other
policy changes are directed to improving communication among key
executives, limiting grantees* flexibilities and requiring more timely
information on participants. While these policies were only recently
introduced, they could, if implemented, help the Corporation keep track of
the day- to- day aspects of the AmeriCorps program and provide information
needed to monitor the use of the Trust in order to determine whether the
Corporation should make adjustments, such as deobligating excess funds.
However, data integration problems between WBRS and the program the
Corporation uses to track the education awards earned by AmeriCorps
participants may hamper the effectiveness of the new procedures.
The Corporation is in the process of modifying its practices regarding
when it will record obligations. The Corporation*s General Counsel
explained that the Corporation will record obligations at the time of
enrollment, instead of on a quarterly drawdown basis and that the
obligations will be based on estimates of what these enrolled members will
draw down in the future. The Corporation is of the opinion that it does
not incur an obligation for an education award until the time of
enrollment because it may modify the terms and conditions of a grant,
including a reduction in the number of new participants the grantee may
enroll, prior to the enrollment of all positions initially approved in a
grant, to prevent a shortfall in the Trust. The General Counsel also said
** a binding
agreement between the Government and an AmeriCorps member [participant]
exists only upon the member*s [participant*s] authorized enrollment in the
Trust.*
While it may be true that the Corporation has no binding agreement with a
participant until the participant enrolls in AmeriCorps, this is not the
controlling consideration for fund control purposes. In our opinion, this
view overlooks the legal duty the Corporation incurs at the time of grant
award when it commits to funding a specified number of participants and
the constraint imposed on the Corporation by the National and New Policies
Established, but Additional Changes May be Needed
New Policies for Obligating Funds
Page 8 GAO- 03- 642T
Community Service Act. Specifically, the act says **[ t] he Corporation
may not approve positions as national service positions* for a fiscal year
in excess of the number of positions for which the Corporation has
sufficient available funds in the National Service Trust for that fiscal
year**. The Corporation, by its own admission, may modify the number of
approved participants only if it amends the grant agreement to reduce the
number of enrolled positions prior to enrollment. When a grant is awarded,
the number of new participants approved in the grant establishes a legal
duty that can mature into a legal liability for education awards by virtue
of actions of the grantee, unless the Corporation modifies the grant prior
to participant enrollment. While the Corporation may unilaterally reduce
the number of authorized positions awarded to a grantee prior to
participant enrollment, from the time of grant award until the Corporation
acts to reduce the approved number of positions, the grantee and its
subgrantee, not the Corporation, will control the number of participants
who may enroll, up to the maximum number of participants the Corporation
has approved in the grant agreement. It is also significant to note that
the grantee and subgrantee, by their
actions in enrolling participants, not the Corporation, control the
amount, ultimately, of the Corporation*s liability. If the amount of
liability to the government is under the control of the grantee, not the
Corporation, the government should obligate funds to cover the maximum
amount of the liability. As more information is known, the Corporation
should adjust the obligation* deobligate funds or increase the obligation
level* as needed.
The Corporation also said that at the time a member enrolls it would
record its ** best estimate of the Government*s ultimate liability of
education awards provided to members [participants] enrolled in the
National Service Trust.* According to the Corporation*s General Counsel,
the Corporation*s estimates of the amount that enrolled members
[participants] will draw down is based on historical information, such as
attrition rate and actual usage by participants who complete a term of
service and earn an education award. It appears to us that the Corporation
is confusing its accounting liability* projections booked in its
accounting systems for financial statement purposes, with its legal
liability* amounts to be recorded in its obligational accounting systems
and tracked in order to ensure compliance with fiscal laws. One of the
federal financial accounting standards states that a liability for
proprietary accounting purposes is a probable and measurable future
outflow or other sacrifice of resources as a result of past transactions
or events. Traditionally, projections of accounting liability consider the
same factors, such as historical trends, that are considered in the
Corporation*s model. To track
Page 9 GAO- 03- 642T
its obligations, the Corporation should be recording its unmatured legal
liability for the education awards, which is the total cost associated
with the enrollment of all approved positions. The Corporation*s
obligation should be recorded as it is incurred and should be calculated
by multiplying the number of approved positions in a grant by the total
cost of a national service educational award.
Policy changes at Corporation headquarters are designed to improve
communication between several key offices and officials. A major change is
that the Trust balance is to be a limiting factor on grant awards and,
therefore, enrollment levels. In addition, beginning with the 2003 grant
cycle 4 , one new policy calls for the AmeriCorps director to work with
the grants director, the Chief Financial Officer (CFO), and the Trust
director to compare projections of positions to be approved in grants with
those supported by actual appropriations, and the Chief Executive Officer
(CEO) will only approve the number of positions the Trust can support.
Additionally, the CEO will approve all AmeriCorps grants after
consultation with the CFO on the number of education awards that can be
supported by the Trust. Also, the policy states that the CEO, CFO, the
Trust director, and the AmeriCorps director will meet at least monthly to
review and reconcile enrollment data and Trust data. Through bi- weekly
reports, the AmeriCorps director and the Trust director are to keep the
CEO and CFO informed of the number of approved and filled positions. The
Trust director is to monitor factors relevant to forecasting Trust
liabilities and report regularly to the CFO, highlighting deviations from
assumptions in the model. Each month the CFO is to use actual enrollment
data to re- evaluate the model for forecasting Trust liabilities. If the
revision results in a need to change enrollment targets, the CFO will
notify the CEO and AmeriCorps director immediately. The CEO will take
appropriate action and report any such action to Congress, the
Corporation*s Board, and the Office of Management and Budget.
Regular meetings and attention to the enrollment data should help the
Corporation keep track of the day- to- day aspects of the AmeriCorps
program. Such updated information is an important step in monitoring the
use of the Trust in order to determine whether the Corporation should make
adjustments. For example, if the Corporation obligated the full cost for
each of the positions approved at the time of grant award, and later
4 The Corporation*s 2003 grant review cycle began in the spring of 2003.
More Communication
Planned among Key Corporation Managers
Page 10 GAO- 03- 642T
determined that many of the positions will not be filled, it could reduce
the number of approved positions and deobligate some of the funds. The
policy changes and new procedures were announced in January. We will
continue to monitor the implementation of these policy changes.
The Corporation has changed policies regarding its grantees ability to
over enroll participants, replace participants who leave with new
enrollees and change positions from full- time to part- time. In a January
22, 2003,
memorandum, the director of AmeriCorps cancelled the policy that allowed
grantees to over enroll members by up to 20 percent over the ceiling
established in the grant award in order to take account of attrition.
Furthermore, an official said AmeriCorps now considers a position to be
filled for the term of the grant once the grantee enrolls a participant,
even if the participant later drops out of the program, whether or not an
education award was earned. The official said that in the past, grantees
could enroll a new member to serve out the balance of the term if grant
funds were available. A Corporation official also said that there is a new
policy that restricts grantees from converting full- time positions to
parttime positions. Grantees must now request and receive approval from
the Corporation before such changes can be made.
Since grantees will not be permitted to modify the number and type of
authorized positions, the Corporation*s ability to manage the AmeriCorps
program should improve. Most 2003 grant positions have not yet been
awarded; therefore, it is too early to tell whether these new policies
will be effective. We will monitor these policies and assess the extent to
which they have been implemented as we complete our work.
In January 2003 the Corporation informed all grantees that AmeriCorps will
require timely reporting of participant information to ensure that the
Trust database receives current information on the number of participants
eligible for an education award. Grantees will be required to keep
AmeriCorps informed of the number of participants offered positions and
the number who accept and enroll and to document enrollment through WBRS
no later than 30 days after participants start working. The memorandum
warns grantees that failure to comply with this requirement could result
in reductions in the number of positions or termination of the grant.
Additionally, the memorandum directs state commissions and other
AmeriCorps grantees* the organizations responsible for the oversight of
subgrantees* to implement procedures to ensure that timely notification
Grantees No Longer
Permitted to Change Authorized Positions
Grantees Will Be Required to Report Participant Information within 30
days, but Data Reconciliation Problems May Need To Be Addressed
Page 11 GAO- 03- 642T
of participant commitments and enrollments is part of their review and
oversight functions.
Furthermore, the Corporation has made changes to WBRS, which is used to
track participant, grant, and budget information. First, controls have
been put in place to limit the number of positions listed in WBRS to no
more than the number of approved positions. The Corporation*s Biweekly
Trust Enrollment Summary, as of March 2003, shows that award totals are
being tracked and compared with the data estimates in the Trust. However,
officials told us that there are some data reconciliation problems between
WBRS and the program used by the Corporation to track the education awards
earned by AmeriCorps participants. Corporation staff have had to make
manual adjustments to reconcile the data.
Accurate and timely information about enrollments should help the
Corporation and AmeriCorps manage the program. As grants are awarded, we
will be able to assess whether the policies have been fully implemented.
The Corporation*s new policies, if fully implemented, should help the
Corporation manage the AmeriCorps program by providing better information
on day- to- day operations. However, without obligating the full amount
associated with all of the positions authorized in the grants, the
Corporation remains at risk of having the actual number of enrollments
exceed the estimated number the Trust can support. We will monitor the
implementation of the Corporation*s new policies as we continue our
review.
For further information regarding this statement, please call Cornelia M.
Ashby at (202) 512- 8403 or Susan A. Poling at 202- 512- 5644. Individuals
making key contributions to this testimony included Carolyn M. Taylor, Tom
Armstrong, Anthony DeFrank, Joel Marus, and Hannah Laufe. Conclusion
GAO Contact and Acknowledgments
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 12 GAO- 03- 642T Appendix I: Obligational Practices
of the Corporation for National and Community
Service
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 13 GAO- 03- 642T
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 14 GAO- 03- 642T
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 15 GAO- 03- 642T
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 16 GAO- 03- 642T
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 17 GAO- 03- 642T
Appendix I: Obligational Practices of the Corporation for National and
Community Service Page 18 GAO- 03- 642T
Page 19 GAO- 03- 642T (130265)
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