Office of Inspector General Working with CNCS and

Office of Inspector General Working with CNCS and Grantees to Ensure Oversight and Safeguarding of Federal Funds Office of Inspector General

Purpose • Understand the Mission of the OIG • Learn From Common Audit and Investigative Findings • Preventing Fraud in Your Organization • Walk-Through the Audit Process • Know How to Contact the OIG Office of Inspector General

What the OIG Does • Promotes Economy, Efficiency and Effectiveness in Agency Programs and Operations • Prevent and Detect Fraud, Waste, and Abuse • Two Operational Units: Audits & Investigations Office of Inspector General

What the OIG Does Not Do Manage or Direct Agency Programs or Operations Office of Inspector General

OIG Mission • Improve efficiency and effectiveness of Corporation (CNCS) programs and operations • Prevent and detect waste, fraud, and abuse by: 1. Conducting audits and investigations; 2. Recommending policies; and 3. Keeping the CNCS CEO and Congress informed about deficiencies, recommendations, and corrective actions Office of Inspector General

OIG Independence • By law, OIG is independent of CNCS • We report directly to Congress and are funded by a separate appropriation • OIG personnel must remain objective at all times in conducting our work and must be free of personal or organizational conflicts of interest with grantees and sub-grantees Office of Inspector General

INVESTIGATIONS Office of Inspector General

Fraud Defined An intentional distortion of the truth in an attempt to obtain something of value. Does not have to result in monetary loss. Layman’s terms: Lying, cheating, or stealing Office of Inspector General

Investigative Process • • Hotline or Direct Reporting Review Information – Personnel, Program or Fraud Determine Who Handles – OIG, CNCS, or Grantee Coordinate with Complainant (If known) Conduct Preliminary Inquiry or Investigation Site Visit Coordinate with U. S. Attorney Office, CNCS (Program/Grants), Commission, or Grantee • Report of Findings • Resolution Office of Inspector General

Site Visit • In Brief • Review Member/Volunteer and Fiscal Documents • Interview Staff (individually) • Interview Members/Volunteers (individually) • Visit Service Site • Interview Recipient of Services • Out Brief (at discretion of Investigator) Office of Inspector General

Question What should you do if you are being investigated? Office of Inspector General

Question How important is your program in your community? Office of Inspector General

Headlines Ameri. Corps Shuts Down Program After Volunteers Broke the Law Working at Abortion Clinics Grant Lost Because Grantee Failed to Perform Criminal History Checks, Altered Documents, and Made False Certifications Registered Sex Offender Terminated from Ameri. Corps Service After Background Check Ex-Senior Corps Program Director Gets Stiff Sentence VISTA Project Ended After Duplication of Service Senior Corps Grantee Debarred After Scamming CNCS Grant Funds Office of Inspector General

Year in Review Project Director falsely certified CHC Assessment Sex Offender allowed to serve Program Director falsified Timesheet - not working hours claimed Program Staff forged NSOPW checks Program improperly paid member who did not serve Unallowable Match Funds Members performed unallowable service Member/Volunteers displaced staff Members engaged in prohibited activities Lack of supervision/oversight Site charged fee for Volunteers’ service Office of Inspector General Grantee Debarred for Misuse of VISTAs & Displacing Staff Program staff altered Senior Corps Timesheets

Common Crimes • • Office of Inspector General Misuse of Grant Funds Timesheet Fraud Embezzlement, Theft Improper use of Members/Volunteers

Misuse of Grant Funds • Grant funds are fully expended before grant ends • Unauthorized costs are charged to the grant • Funds are drawn down on unfilled member slots • Funds are drawn down on terminated slots • Employee salaries not funded under the grant are charged against the grant • Partial Education Awards certified for ineligible members – (Review 45 CFR 2522. 230 for allowable Compelling Personal Circumstances) Office of Inspector General

Timesheet Fraud • Service hours are not properly documented • Hours are not reasonable or allowable (Ex: 20+ hours in one day) • Program officials are not verifying the hours or type of service claimed • Multiple documents prepared at the same time • Staff employee’s time inaccurately allocated • Program staff added hours to timesheets not served by member/volunteer Office of Inspector General

Embezzlement • • Members, volunteers and staff are not being paid Payments are made to “ghost members” Documents altered Documents are missing, copies used instead of originals, fabricated receipts • Grant funds transferred to personal account or program staff’s for-profit business Office of Inspector General

Improper Use of Members/Volunteers • Members/Volunteers are not properly enrolled • Members/Volunteers are not properly serving, performing other service activities not authorized under the grant • Members/Volunteers are serving in staff positions • Members/Volunteers are not properly supervised • Members/Volunteers are not available for service/not at their assigned service site Office of Inspector General

Office of Inspector General

The Fraud Triangle ity tun ppo r por tu er O Few Results n atio aliz Op tion Office of Inspector General Ra Pressure s Les Causes tion a aliz tion Ra nity Management Oversight Strong Internal Controls Training Reduce Pressure

Prevention • You are the 1 st line of defense in protecting the government’s money • Periodic file review of member/volunteer files and timesheets • Unannounced visits to service sites • Talk to members/volunteers individually about their service/experience • Add additional layer of review/oversight (CHCs, Timesheets, Expenses, Position Descriptions) • Create Transition Plan/SOPs for future program staff • Thorough member/site supervisor training (handouts with requirements) • Telework policy Office of Inspector General

Monitoring Visits/Oversight • Meet with members/volunteers/site supervisors (individually) – compare service to PD • Review CPCs (is there an approval requirement? ) • Review Budget-compare to staff positions (how much time they spend on the program) • CHCs (documentation to show CHCs in compliance and/or on-site corrections made) • Require follow-up with deadline to correct any findings (can corrections be done on site? ) • Document all findings (include in monitoring report), keep log of issues and how/when they were resolved • Document all issues or complaints about members/volunteers • Do you have a policy on handling member complaints? Office of Inspector General

Enhanced Whistleblower Protection Whistleblower protection now extends to employees of contractors, sub-contractors, grantees and subgrantees who disclose information related to: • • • Gross mismanagement of a Federal contract or grant Waste of Federal funds Abuse of authority relating to a Federal contract or grant Substantial and specific danger to public health and safety Violations of any law, rule or regulation related to a Federal contract or grant Office of Inspector General

Section 828 Public Law 112 -239 41 U. S. C § 4712 Contractor, Sub-contractor, Grantee, or Subgrantee Employee’s Protected Disclosure Discharge, Demotion or Discrimination Within 180 days and up to an additional 180 days if complainant agrees 3 year time limitation Reprisal complaint to IG IG determines that complaint is frivolous, fails to allege a violation of the prohibition against reprisal under subsection (a) or was addressed in a prior proceeding initiated by complainant IG investigates and submits report of findings to complainant, contractor/grantee, and head of the agency Within 30 days Head of agency fails to issue order within 210 days of complaint submission Head of agency issues order denying relief Within 60 days From date of order U. S. District Court Office of Inspector General Head of agency issues order of remedy Failure of compliance with order of remedy

Contact the OIG Your identity can be kept Office of Inspector General

AUDITS Office of Inspector General

What is an OIG Audit? • An OIG audit is a comprehensive review of any organization • It measures the organization’s compliance with the grant terms and conditions according to laws, regulations, and grant provisions • OIG personnel also reviews financial management standards Office of Inspector General

OIG Audit Plan • • Publicly Available OIG Risk Assessment Legislation Materiality Single Audit Report Results New Program Extent of Prior CNCS OIG Audits OIG Hotline Tips Office of Inspector General

The Audit Process • In-House OIG Auditors and Contracted Auditors • Audit Process: § § § § § Notification Planning (include sub-grantee selections) Entrance Conference Fieldwork/Testing (include sub-grantee site visits) Exit Conference Draft Report CNCS and Grantee Response Final Report Resolution of Findings, Recommendations, and Question Cost Office of Inspector General

Audit Resolution • CNCS and Grantee management agree or disagree on proposed corrective actions • The OIG is given an opportunity to review the proposed corrective actions. However, final decisions are made by CNCS and Grantee management take action to improve operations or correct deficiencies identified in the final audit report Sub-grantees should work closely with Grantee management to resolve audit findings Debts, if applicable, are established: • • • ‣ ‣ Office of Inspector General Collected Payment Schedule

Common Accountability Problems Criminal History Checks National Sex Offender Public Website and Criminal History Checks—conduct thoroughly, timely and document properly, for both staff and members/volunteers. Office of Inspector General

Common Accountability Problems • Timesheets cannot be based on budgeted amounts—actual work only • Suggestion - periodically, conduct your own timesheet review or audit • System of internal controls should exist on timekeeping under Uniform Grant Guidance Office of Inspector General

Common Accountability Problems • Organizations do not separate accounting records for each Federal grant • Submit Federal Financial Reports (FFRs) / Periodic Expenditure Reports (PERs) on schedule • Make sure that the FFRs / PERs reconcile to internal accounting records (general ledger) Office of Inspector General

Common Accountability Problems • Record match dollars in general ledger, with same detail/documentation as for grant expenditures • Document source of match contributions • Substantiate market value of in-kind match contributions Office of Inspector General

Common Accountability Problems • Ineligible member or lack of supporting documents on member eligibility • Members issued partial education awards for Compelling Personal Circumstances (CPC) are not eligible or not properly supported • Members Teleworking Office of Inspector General

Fixed Amount Grants • Grantees receive a grant award for a specific amount ($800) per MSY, with grant amount subject to adjustment per MSY based on: – Education Award Programs (EAP): member enrollment – Full-Time and Professional Corps Fixed Amount Grants: partially completed terms of service • Significantly fewer documentation/reporting requirements under fixed amount grants • Grantees should ensure accuracy of member enrollment or member term of service • Grantee should reconcile member enrollment and MSY data between My. Ameri. Corps Portal and grantee’s member records – Auditors will perform compliance/eligibility testing, including member service hours and that the hours are consistent with the grant terms – Auditors will not test for allowability of grant costs Office of Inspector General

Resources • • Your Commission Staff (for sub-grantees) Your CNCS Program Officer and Grant Officer CNCS National Service Knowledge Network Website http: //www. nationalservice. gov/resources New Learning Management System: Litmos Office of Inspector General

You feel like this after your organization addressed all audit recommendations and resolved all corrective actions… Office of Inspector General

Uniform Grant Guidance 2 CFR 200: Uniform Grant Guidance • • • Indirect Rates Single Audit Threshold Procurement Timekeeping Sub-grantee Monitoring Resources: • US Chief Financial Officers Council – Federal Grants (https: //cfo. gov/grants/) • e. CFR (http: //www. ecfr. gov) • FAQs updated as of July 2017: https: //cfo. gov//wpcontent/uploads/2017/08/July 2017 -Uniform. Guidance. Frequently. Asked. Questions. pdf Office of Inspector General

Timekeeping/Personal Services Compensation (Section 200. 430) Emphasis on internal controls over personnelrelated costs. Records on time and effort must: • Be supported by a system of internal control that charges are accurate, allowable, and properly allocated • Reasonably reflect total activity for which the employee is compensated • Support the distribution of employee’s salary/ wages among specific activities/cost objectives Office of Inspector General

Timekeeping/Personal Services Compensation • Support for payroll costs cannot be based on budget estimates made before services are performed • Federal agencies may require personnel activity reports, including prescribed certifications, or equivalent documentation that support the records Office of Inspector General

Sub-grantee Monitoring (Sections 200. 330 -332) • Include Pass-Through entities audit responsibilities that were in Single Audit • Include specific information in the sub-award, including the indirect cost rate • Evaluate each sub-grantee’s risk of noncompliance with Federal statutes/regulations, and terms and conditions • Consider if specific sub-award conditions are needed • Make any necessary adjustment to the pass-through entity’s records based on reviews and audits of sub-grantee Office of Inspector General

Reminders! KEEP CALM AND Office of Inspector General May the Compliance Be With You

QUESTIONS Office of Inspector General

• Report suspected fraud, waste, or abuse • Information is confidential • You may remain anonymous 1 -800 -452 -8210 or hotline@cncsoig. gov cncsoig #CNCSOIG Office of Inspector General Visit us at www. cncsoig. gov