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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

February 2012: 

Measuring Performance: 

The Corporation for National and Community Service Faces Challenges 
Demonstrating Outcomes: 

GAO-12-310: 

Contents: 

Letter: 

Appendix I: Briefing Slides: 

Appendix II: List of CNCS Grantees Interviewed: 

Appendix III: Reported Legal Constraints on Holding Senior Corps 
Grantees Accountable: 

Appendix IV: Comments from the Corporation for National and Community 
Service: 

Appendix V: GAO Contacts and Staff Acknowledgments: 

Related GAO Products: 

Abbreviations: 

CNCS: Corporation for National and Community Service: 

NCCC: National Civilian Community Corps: 

VISTA: AmeriCorps Volunteers in Service to America: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 17, 2012: 

The Honorable Tom Harkin:
Chairman:
The Honorable Michael B. Enzi:
Ranking Member:
Committee on Health, Education, Labor & Pensions:
United States Senate: 

The Honorable John Kline:
Chairman:
The Honorable George Miller:
Ranking Member:
Committee on Education and the Workforce:
House of Representatives: 

It is important for federal agencies--and their grantees--to 
demonstrate the impact of their work and ensure the efficient use of 
their resources. This becomes even more important during times of 
fiscal stress and tight budget constraints as Congress makes difficult 
funding choices. In fiscal year 2011, Congress appropriated 
approximately $1 billion for the Corporation for National and 
Community Service (CNCS)--the federal agency responsible for 
administering the country's national service programs--to carry out a 
variety of federally funded programs, such as AmeriCorps. Through 
these programs, CNCS provides grants to more than 70,000 volunteer 
organizations to address a range of community challenges through 
service activities such as tutoring children, responding to natural 
disasters, or helping seniors to live independently. In 2009, the 
Serve America Act made substantial changes to CNCS's mission, 
including giving CNCS new areas of emphasis, such as working with 
veterans, and directing it to focus more on performance evaluation and 
cost-effectiveness.[Footnote 1] The Serve America Act also mandated 
that we perform a series of reviews relating to program effectiveness 
with respect to CNCS's performance measures.[Footnote 2] 

In 2010, we reported that the performance measures from CNCS's 
previous strategic plan were poorly aligned with its strategic goals 
and did not demonstrate the results of its work.[Footnote 3] Given 
that CNCS is in the process of implementing its new strategic plan and 
performance measures, we examined the following key questions: (1) To 
what extent does CNCS fund service activities that are covered by its 
performance measures? (2) What key challenges, if any, affect the 
ability of CNCS and its grantees to measure performance? 

To answer the first question, we examined agency strategic planning 
and grant-making documents and budget data to better understand how 
CNCS allocates funding to service activities that are covered by its 
performance measures. We also interviewed CNCS officials to obtain 
information about CNCS's grant-making policies and the service 
activities that it funds. We also made adjustments to the programs' 
budgets to remove certain administrative expenses identified by CNCS 
such as health care stipends and child care assistance for the 
AmeriCorps Volunteers in Service to America (VISTA) program. Many of 
these costs are beyond the control of programs and should not be 
directly linked to the program's performance. We discussed these 
adjustments with agency budget officials and they concurred with our 
approach. To answer the second question, we conducted site visits and 
phone interviews with a total of 20 grantees, including 3 state 
service commissions.[Footnote 4] (For a list of the grantees we 
interviewed, see appendix II.) We selected these grantees because they 
are geographically diverse and cover both urban and rural locations, 
provide representation among CNCS's main programs[Footnote 5] and 
program focus areas, and reflect varying levels of success in 
measuring their performance. We conducted site visits with grantees in 
three states--California, Maryland, and Texas--as well as in the 
District of Columbia. The remaining interviews were conducted by 
phone. During our interviews, we used interview protocols with a 
standard set of questions about grantees' experiences measuring 
performance and any challenges they encountered in the process. The 
results of our site visits and phone interviews with these 20 grantees 
cannot be generalized. Furthermore, we also met with CNCS officials to 
identify performance measurement challenges and reviewed relevant 
federal laws, regulations, and agency documents. 

We conducted this performance audit from April 2011 to February 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

We briefed your staff on the results of our analysis on January 11, 
2012, and this report formally conveys the information provided during 
that briefing. See appendix I for the briefing slides that were 
presented on that date. In summary, we reported the following findings: 

* CNCS officials expect that most grantees from its main programs will 
adopt at least 1 of the agency's 16 agency-wide performance measures. 
Specifically, officials told us that AmeriCorps State and National and 
VISTA grantees will adopt at least 1 of CNCS's performance measures by 
fiscal year 2012, and Senior Corps grantees will adopt at least 1 
measure by fiscal year 2013. However, officials also said that they 
plan to fund some activities that do not fall under the performance 
measures, particularly activities that meet local needs and/or are 
innovative. For example, CNCS has funded grantees in the state of 
Washington to carry out gang violence prevention activities to address 
this community challenge. This could present challenges for CNCS as it 
balances accountability, using its performance measures to assess the 
impact of grantees' service activities, with flexibility, allowing 
grantees to take on projects that meet local needs. CNCS may find it 
difficult to demonstrate the effectiveness of its service activities 
that fall outside its performance measures. Additionally, CNCS faces 
challenges using its performance measures to promote accountability 
among its Senior Corps grantees, as legal restrictions make it 
difficult for CNCS to remove funding from grantees that consistently 
fail to meet their performance targets, and these restrictions include 
some requirements for Senior Corps programs that do not apply to 
CNCS's other programs. These restrictions can make it more difficult 
to hold these grantees accountable for performance. (For additional 
information on these legal restrictions, see app. III.) Specifically, 
officials told us that failure to meet performance targets is not a 
sufficient reason to re-compete a Senior Corps grant, and that it is 
very difficult to terminate a grant for poor performance. At the time 
of our review, CNCS officials told us that they have not yet sought 
statutory changes to address these legal constraints. 

* Grantees we interviewed reported performance measurement challenges 
in four general areas that may hamper CNCS's ability to measure its 
impact: understanding and applying CNCS's performance requirements, 
developing data collection approaches, collecting data, and reporting 
data. For example, one grantee told us that CNCS's guidance was too 
broad, and as a result, it had a difficult time understanding how to 
match its program work to the agency's performance measurement 
requirements. With regard to developing data collection approaches, 
one grantee working with elementary and high school students reported 
difficulties designing an approach that would allow the program to 
collect and measure changes in student behavior and knowledge to 
demonstrate their impact. Grantees with multiple worksites and limited 
staff capacity pointed to challenges collecting performance data 
across worksites. Finally, grantees commented that it was challenging 
to report their performance data through eGrants, CNCS's computer 
system. CNCS has taken some steps to address these challenges; 
however, many of these steps are in the early implementation stages. 

As CNCS looks for better ways to demonstrate its impact to Congress 
and the American public, it will be critical for the agency to hold 
grantees accountable for meeting performance targets. To provide other 
options for CNCS to hold Senior Corps grantees accountable for 
performance, we recommended that the Chief Executive Officer of CNCS 
take action to seek statutory changes, as appropriate, that would 
allow it to re-compete Senior Corps grants if the agency has 
determined current grant recipients do not meet agency performance 
measures, or financial management or other requirements. 

We provided a draft of this report to officials at CNCS for review and 
comment. In response, CNCS provided written comments, which are 
reproduced in appendix IV. Overall, CNCS agreed with our findings, and 
consistent with our recommendation, the agency said it planned to seek 
statutory changes to address the legal constraints on Senior Corps' 
ability to introduce competition into those programs. In CNCS's 
Congressional Budget Justification for fiscal year 2013, released 
February 13, 2012, CNCS set forth the statutory changes it is seeking 
to address these legal constraints on the Senior Corps programs. If 
enacted, these changes would remove most of the constraints that 
currently prevent CNCS from holding Senior Corps grantees accountable 
for meeting performance targets. Improved accountability could enable 
CNCS to more fully demonstrate its impact. 

In addition, CNCS provided us with technical comments, which we 
incorporated as appropriate. Notably, in its technical comments, CNCS 
said it continues to make progress aligning appropriate performance 
measures for its major programs. Specifically, it said that NCCC will 
be reporting on some of CNCS's 16 agency-wide performance measures 
that will capture its service work, including its activities related 
to disaster response. This should enable CNCS to better align NCCC's 
activities to the agency's goals. 

With reference to our findings on CNCS's performance measures, CNCS 
said in its technical comments that it plans to measure performance of 
service activities not aligned to its key strategic goals and will 
require grantees to submit their programs' specific performance data 
in progress reports to the agency. While it is important to measure 
performance and report on performance for all its service activities, 
the diversity of these activities may make gathering, combining, and 
presenting robust and consistent performance information difficult and 
lead to challenges demonstrating the overall impact of CNCS's efforts. 
Thus, as emphasized in this review and our previous work, it will 
remain critical for CNCS to focus its performance measures on the 
vital few that align with its strategic goals.[Footnote 6] 

We are sending this report to CNCS, appropriate congressional 
committees, and other interested parties. In addition, the report will 
be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. If you or your staff have any questions about 
this report, please contact me at (202) 512-7215 or scottg@gao.gov. 
Contact points for our Offices of Congressional Relations and Public 
Affairs may be found on the last page of this report. GAO staff who 
made key contributions to this report are listed in appendix V. 

Signed by: 

George A. Scott: 
Director, Education, Workforce and Income Security Issues: 

[End of section] 

Appendix I: Briefing Slides: 

Measuring Performance: The Corporation for National and Community 
Service Faces Challenges Demonstrating Outcomes: 

Briefing to Congressional Committees: 
January 11, 2012: 

Overview: 

Introduction; 
Research Objectives; 
Scope and Methodology; 
Summary of Findings; 
Background; 
Findings; 
Conclusions. 

[End of section] 

Introduction: 

In constrained budget environments, it is increasingly important for 
federal agencies – and their grantees – to demonstrate the impact of 
their work and ensure the efficient use of their resources. 

In fiscal year 2011, Congress appropriated approximately $1 billion 
for the Corporation for National and Community Service (CNCS) to 
administer a variety of volunteer and national service programs. 

The Serve America Act mandated GAO to perform a series of reviews 
relating to program effectiveness with respect to CNCS’s performance 
measures. This work is our second review.[Footnote 7] 

Our previous work found that CNCS’s performance measures aligned 
poorly with its strategic goals and did not demonstrate the results of 
its work.[Footnote 8] 

At the time of our review, CNCS had developed a new strategic plan for 
fiscal years 2011-2015, which included new areas of responsibility 
identified by the Serve America Act (Pub. L. No. 111-13) and new 
performance measures. 

Research Objectives: 

Objective 1: To what extent does CNCS fund service activities that are 
covered by its performance measures? 

Objective 2: What key challenges, if any, affect the ability of CNCS 
and its grantees to measure performance? 

Scope and Methodology: 

To examine the extent to which CNCS funds service activities that are 
covered by its performance measures, we: 

* Examined agency strategic planning and grant-making documents and 
budget data. 

* Interviewed CNCS officials to obtain information about CNCS’s grant-
making policies and the service activities that it funds. 

To examine the challenges that may affect CNCS’s ability to measure 
performance, we: 

* Conducted site visits and phone interviews with 20 grantees, 
[Footnote 9] including state commissions, that represented CNCS’s main 
programs and focus areas, various geographical locations, and varying 
level of success with measuring performance. The information obtained 
cannot be generalized. 

* Reviewed relevant federal laws, regulations, and agency documents, 
and interviewed CNCS officials to identify performance-related 
challenges. 

We conducted this performance audit from April 2011 to February 2012 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Summary of Findings: 

CNCS officials expect that most grantees from its main programs will 
adopt at least one of the agency’s 16 performance measures. 

* Officials told us that AmeriCorps State and National and AmeriCorps 
VISTA grantees will adopt at least one of CNCS’s performance measures 
by fiscal year 2012, and Senior Corps grantees will adopt at least one 
measure by fiscal year 2013. 

* However, CNCS faces difficulties balancing the need to measure the 
outcomes of its activities with providing flexibility for its programs 
to meet local needs. 

* Further, CNCS is limited in its ability to promote accountability 
among its Senior Corps grantees, as statutory restrictions make it 
difficult to remove funding from grantees that consistently fail to 
meet performance targets. However, officials told us that they have not 
yet sought statutory changes to address these restrictions. 

CNCS may also face challenges reporting its impact due to several 
grantee-related performance measurement challenges, such as collecting 
performance data from partnering worksites. 

* CNCS has taken steps to address grantees’ performance measurement 
concerns; however, many of these efforts are in the early 
implementation stages. 

Background: 

Four Programs Accounted for 90 Percent of CNCS’s Budget for Volunteer 
Service Activities in Fiscal Year 2011: 

Figure: CNCS’s Fiscal Year 2011 Budget for Volunteer Service 
Activities, by Program, in Millions: 

[Refer to PDF for image: illustration] 

AmeriCorps State and National: $341.2 million: 
AmeriCorps State and National provides grants to nonprofit, public, 
and other organizations in part to encourage Americans of all 
backgrounds to volunteer to address community needs. 

AmeriCorps State and National funds are divided into two grant funding 
streams: 

Competitive grants: $215.6 million: 
AmeriCorps Competitive grants are AmeriCorps State formula      
awarded and overseen by CNCS.  

State Formula grants: $125.6 million: 
AmeriCorps State formula grants are awarded and overseen by CNCS-
funded state service commissions. These grants give states flexibility 
to respond to local needs.   

Senior Corps: $205.7 million: 
Senior Corps provides grants to a network of about 1,200 organizations 
sponsoring over 1,300 projects that tap the experience, skills, and 
talents of Americans 55 years of age and older in part to meet 
community needs.  

VISTA: $77.9 million: 
VISTA provides grants and full-time volunteers to community 
organizations to help create and expand antipoverty programs.  

NCCC: $28.8 million: 
NCCC is a residential, team-based program that gives young people 
opportunities for leadership and service while addressing national and 
community needs in all 50 states. NCCC is administered directly by 
CNCS and is not a grant making program. 

Source: GAO analysis of CNCS budget data. 

Note: Excludes administrative costs and education awards to volunteers. 

[End of figure] 

Figure: The 16 Agency-Wide Performance Measures in CNCS’s Fiscal Year 
2011-2015 Strategic Plan Will Gauge Progress Toward Its Four Goals: 

[Refer to PDF for image: illustration] 

CNCS's mission: 
Improve lives, strengthen communities, and foster civic engagement 
through service and volunteering: 

CNCS's four goals: 

CNCS's Goal 1: 
Increase impact of national service on community needs; 
Performance measures: 9. 

Goal 2: Participants consistently find satisfaction, meaning, and 
opportunity; 
Performance measures: 2. 

Goal 3: Maximize the value added to grantees, partners, and 
participants; 
Performance measures: 2. 

Goal 4: Fortify management and sustain a capable, responsive, and
accountable organization; 
Performance measures: 3. 

* Performance measures help agencies gauge their progress toward 
achieving their goals. 

* CNCS officials told us that these 16 agency-wide performance measures 
reflect CNCS’s priorities.[Footnote 10] 

* Officials plan to use them to demonstrate how CNCS uses its 
resources to fund service activities that contribute to its four goals. 

Source: GAO analysis of CNCS’s FY 2011-2015 strategic plan. 

[End of figure] 

Figure: Nine of the 16 Agency-Wide Performance Measures Are in Goal 1, 
Divided into 6 Focus Areas: 

[Refer to PDF for image: illustration] 

CNCS's mission: 
Improve lives, strengthen communities, and foster civic engagement 
through service and volunteering: 

CNCS's four goals: 

CNCS's Goal 1: 
Increase impact of national service on community needs; 
Goal 1 performance measures: 
Goal 1 divided into six focus areas: 
1) Disaster services: 
* Number of people receiving assistance with preparedness, response, 
recovery, and/or mitigation. 
2) Economic Opportunity: 
* Percent of economically disadvantaged people receiving housing-related
assistance that improved their housing situation. 
3) Education: 
* Percent of children demonstrating gains in school readiness; 
* Percent demonstrating improved academic performance; 
* Percent of students in CNCS-supported programs demonstrating 
improved academic engagement; 
4) Environmental Stewardship: 
* Acres of at-risk land and/or water improved by CNCS-supported 
members, participants, and volunteers. 
5) Healthy Futures: 
* Percent of homebound or older adults and individuals with 
disabilities reporting increased social ties and/or perceived social 
support; 
* Number of people gaining access to food resources. 
6) Veterans and Military Families: 
* Number of veterans and their families and military services members 
and their families receiving CNCS-supported assistance. 

Goal 2: Participants consistently find satisfaction, meaning, and 
opportunity; 
Goal 2 performance measures: 
* Number of veterans and military family members engaged in providing 
services through CNCS-supported programs; 
* Percent of service participants in CNCS-supported programs reporting 
experiences that expanded educational, employment, or civic 
opportunities. 

Goal 3: Maximize the value added to grantees, partners, and 
participants; 
Goal 3 performance measures: 
* Percent of organizations implementing evaluations that demonstrate 
stronger evidence of program effectiveness than in prior years; 
* Number of community volunteers recruited and/or managed by CNCS-
supported organizations or National Service Participants. 

Goal 4: Fortify management and sustain a capable, responsive, and
accountable organization. 
Goal 4 performance measures: 
* Complete modernization of information technology structure; 
* Ensure that no material internal control or compliance issues are 
identified in annual financial statement audit; 
* Award and close grants and contracts within prescribed time frames. 

Source: GAO analysis of CNCS’s FY 2011-2015 strategic plan. 

[End of figure] 

Objective 1: Adopting Performance Measures: 

CNCS Expects That Most Grantees Will Adopt at Least One of its 
Performance Measures: 

In fiscal year 2012, CNCS officials said they expect most AmeriCorps 
State and National and VISTA grantees to adopt at least one of CNCS’s 
16 performance measures voluntarily. 

* Officials said that “adopting” CNCS’s performance measures means 
that grantees choose one or more of the 16 measures that relate to 
their work, even if they do not cover all their service activities. 

* Officials told us that grantees will generally be expected to measure 
both the outputs and the final outcomes of their service activities. 
For example, the number of students who complete the program is an 
output, while improved academic performance is an outcome. 

Beginning in fiscal year 2013, CNCS officials also said that they 
expect to require Senior Corps grantees to adopt at least one of the16 
performance measures. They did not estimate a time frame for requiring 
other grantees to adopt them. 

CNCS Will Fund Some Service Activities That Do Not Align With its 
Performance Measures: 

CNCS officials told us that they expect to fund some AmeriCorps State 
and National grantees that do not adopt CNCS’s performance measures, 
but whose work is innovative or meets local needs. 

* Some service activities that may meet local needs, such as 
preventing gang violence or teen pregnancies, do not clearly fit 
within CNCS’s 16 performance measures. 

AmeriCorps state formula grantees are overseen by state service 
commissions,[Footnote 11] which have the authority to decide whether 
to require grantees to use CNCS’s performance measures. 

CNCS officials anticipate that some grantees that adopt CNCS’s 
performance measures will not use them for all the work they do, 
because some of their service activities do not align with the 
measures. 

* For example, officials expect that some Senior Corps grantees will 
use CNCS’s performance measures for about 25 to 50 percent of their 
service activities. 

Additionally, Senior Corps and NCCC officials told us they are legally 
required to fund some service activities that fall outside the 16 
agency-wide performance measures, such as providing respite to 
caregivers of homebound seniors. 

NCCC officials also plan to continue to use more general performance 
measures, rather than specific targets, for some of their work in 
order to retain flexibility for NCCC members to respond to disasters. 

CNCS Faces Challenges Balancing Performance Accountability with 
Flexibility: 

According to CNCS officials, it is difficult to hold grantees 
accountable for measuring their activities’ effectiveness without 
compromising grantees’ flexibility to tailor their program activities 
to local needs. 

* Officials said they seek to promote accountability by using the 16 
performance measures to assess the impact of grantees’ work. 

* However, officials also told us that they wanted to preserve 
grantees’ flexibility to meet local needs, even if those needs fall 
outside the performance measures. 

This is consistent with our previous findings that other federal grant 
making programs face similar challenges, because grant features that 
encourage performance accountability can limit grantee flexibility. 
[Footnote 12] 

CNCS officials told us they are currently exploring ways to measure the 
performance of service activities that are not covered under the 16 
agency-wide performance measures. 

* As previously noted, CNCS plans to focus on its 16 agency-wide 
performance measures. However, the strategic plan contains other 
measures that CNCS may use to assess the activities of individual 
initiatives or programs. For example, among other measures, CNCS plans 
to collect: 

- the percent of economically disadvantaged individuals receiving 
employment-related assistance. 

- the number of uninsured and economically disadvantaged individuals 
connected to or utilizing health care services. 

* However, the diversity of these activities may make gathering, 
combining, and presenting robust and consistent performance 
information difficult, leading to challenges demonstrating the overall 
outcomes of these efforts. 

CNCS Faces Challenges Holding Its Senior Corps Grantees Accountable 
For Performance Targets: 

Senior Corps programs—-Senior Companion, Retired and Senior Volunteer 
Program (RSVP), and Foster Grandparent-—are longstanding programs that 
exist to connect older Americans to service opportunities. 

Officials told us that some of the volunteer organizations they fund 
have been grantees for several decades. 

CNCS faces legal obstacles to reducing funding for Senior Corps 
grantees that persistently do not meet their performance targets. 

* Even though CNCS officials told us that they will require Senior 
Corps grantees to adopt at least one of the 16 agency-wide performance 
measures by 2013, they commented that without a change in statutory 
authority, it can be very difficult to remove a Senior Corps grantee 
for poor performance alone. 

* Specifically, officials told us that performance alone is not 
sufficient reason to re-compete a Senior Corps grant, if the grantee 
is otherwise complying with the terms of the grant contract. 

* CNCS officials said that they have not yet sought statutory changes 
to address these difficulties. 

See appendix III for additional information on the legal obstacles 
that affect competition in the Senior Corps programs. 

CNCS can utilize non-financial means to help grantees meet their 
performance targets, such as providing public recognition or increased 
oversight.[Footnote 13] 

* For example, CNCS increases its on-site compliance reviews of Senior 
Corps grantees that do not meet their performance targets. 

However, if non-financial methods fail to improve grantee performance, 
CNCS’s ability to use its performance measures to promote 
accountability is potentially limited due to difficulties offering 
these grants for re-competition. 

Objective 2: Performance Measurement Challenges: 

Several Grantee-Related Performance Measurement Challenges Could 
Hamper CNCS’s Ability to Measure Its Impact: 

* Grantees we interviewed reported performance measurement challenges 
in four areas (see figure). 

* CNCS has taken steps to address grantees’ challenges; however, many 
of its efforts are in the early implementation stages. 

[Figure: illustration] 

CNCS: 

1) Understanding and applying CNCS requirements: CNCS relays 
performance requirements to grantees. 

2) Developing data collection approaches: Grantees develop approaches 
to obtain performance information from work sites. 

3) Collecting data: Grantees collect performances information from 
work sites. 

4) Reporting data: Grantees compile data from work sites and report 
this information through eGrants. 

Source: GAO analysis. 

[End of figure] 

Objective 2: Understanding and Applying CNCS Performance Requirements: 

Grantees Faced Challenges Understanding and Applying Performance 
Information Communicated by CNCS: 

Grantees we interviewed reported: 

* The information provided by CNCS was too broad and lacked specific 
examples related to their work. 

* Overcoming the learning curve to understanding CNCS’s performance 
requirements was challenging. 

Since we met with these grantees, the AmeriCorps and VISTA programs 
have updated their guidance, and CNCS officials expect to do the same 
for their other key programs. 

[Figure: illustration] 

CNCS: 

1) Understanding and applying CNCS requirements. 

Source: GAO analysis. 

[End of figure] 

Objective 2: Developing Data Collection Approaches: 

Grantees Faced Challenges Developing Approaches to Collect 
Performance Data: 

Grantees we interviewed reported challenges developing data collection 
approaches that: 

* Measure the work performed by volunteers. 

* Link program activities with outcomes to show impact. 

CNCS is developing a performance measurement training curriculum, which 
may include information on developing appropriate data collection 
approaches. (Expected completion Sept. 2012.) 

[Figure: illustration] 

CNCS: 

2) Developing data collection approaches. 

Source: GAO analysis. 

[End of figure] 

Objective 2: Collecting Data: 

Grantees Faced Challenges Collecting Performance Data from 
Worksites: 

Grantees we interviewed reported challenges with the lack of: 

* Staff capacity or resources to collect data from multiple worksites. 

* Technology, such as a computer system, that could help them avoid 
manual entry of data. 

CNCS is revamping its resource center and has plans to examine grantees’
data collection needs and identify possible support the agency can 
provide. 

[Figure: illustration] 

CNCS: 

3) Collecting data. 

Source: GAO analysis. 

[End of figure] 

Objective 2: Reporting Data: 

Grantees Faced Challenges Tracking Participants and Reporting 
Meaningful Outcomes to Show Their Impact: 

Grantees we interviewed reported challenges: 

* Following up with some past program participants, particularly those 
at-risk populations. 

* Identifying outcomes within CNCS’s one-year reporting framework. 

CNCS has provided individualized technical assistance through state 
service commissions and its state offices.[Footnote 14] 

Objective 2: Reporting data: 

Grantees Faced Challenges Reporting Performance Data Through CNCS’s 
eGrants Computer System: 

Grantees we interviewed also reported challenges: 

* Accessing the eGrants system, CNCS’s electronic web-based system 
that grantees use to report performance data. 

* Navigating through eGrants. 

CNCS has updated its eGrants performance measurement module for 
AmeriCorps, and plans to develop a module that can be used across all 
programs by summer 2012. 

[Figure: illustration] 

CNCS: 

4) Reporting data. 

Source: GAO analysis. 

[End of figure] 

Conclusions: 

CNCS faces difficulties in striking a balance between providing 
grantees with the flexibility to meet local needs and holding them 
accountable for performance. 

* Currently, not all of the work CNCS funds can be assessed under its 
performance measures. CNCS will face difficulties demonstrating the 
results of this portion of its work. 

* Additionally, CNCS’s ability to use performance information to 
promote accountability among Senior Corps grantees may be limited, due 
to statutory restrictions that make it difficult to remove funding 
from persistently poor performers. 

* At the time of our review, CNCS had not yet sought statutory changes 
to address these restrictions. 

CNCS has taken some steps to address grantee-related performance 
challenges, but many of its efforts are in the early stages. Thus, it 
is unclear to what extent these efforts will fully address grantees’ 
challenges. 

As CNCS moves forward, it will be critical for the agency to continue 
to monitor its efforts and the experiences of its grantees to ensure 
it is able to obtain meaningful performance information to demonstrate 
its impact to Congress and the American public. 

GAO on the Web: 

Web site: [hyperlink, http://www.gao.gov/]. 

Contact: 

Chuck Young, Managing Director, Public Affairs, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: 

Copyright: 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. The published product may be 
reproduced and distributed in its entirety without further permission 
from GAO. However, because this work may contain copyrighted images or 
other material, permission from the copyright holder may be necessary 
if you wish to reproduce this material separately. 

[End of section] 

Appendix II: List of CNCS Grantees Interviewed: 

CNCS grantee: Amarillo Independent School District; 
State: Texas; 
CNCS program: AmeriCorps State; 
Focus area[A]: Education. 

CNCS grantee: AmeriCorps Red Cross Florida Gulf Coast; 
State: Florida; 
CNCS program: AmeriCorps State; 
Focus area[A]: Healthy Futures; Veterans and Military Families; 
Disaster Services. 

CNCS grantee: Baltimore City Health Department; 
State: Maryland; 
CNCS program: Senior Corps/RSVP; 
Focus area[A]: Disaster Services; Education; Healthy Futures. 

CNCS grantee: California Volunteers; 
State: California; 
CNCS program: State Service Commission; 
Focus area[A]: Disaster Services; Economic Opportunity; Education; 
Environmental Stewardship; Healthy Futures; Veterans and Military 
Families. 

CNCS grantee: City of Oakland Office Department of Human Services; 
State: California; 
CNCS program: Senior Corps/Foster Grandparent and Senior Companion; 
Focus area[A]: Education; Healthy Futures. 

CNCS grantee: Conservation Corps North Bay; 
State: California; 
CNCS program: AmeriCorps State; 
Focus area[A]: Environmental Stewardship. 

CNCS grantee: Council of Churches of the Ozarks; 
State: Missouri; 
CNCS program: Senior Corps/RSVP; 
Focus area[A]: Education; Healthy futures. 

CNCS grantee: Montana Prevention Resource Center; 
State: Montana; 
CNCS program: AmeriCorps VISTA; 
Focus area[A]: Healthy Futures; Veterans and Military Families. 

CNCS grantee: Department of Veterans Affairs; 
State: California; 
CNCS program: AmeriCorps State; 
Focus area[A]: Veterans and Military Families. 

CNCS grantee: Serving America's Farmworkers Everywhere (SAFE) 
AmeriCorps; 
State: District of Columbia; 
CNCS program: AmeriCorps National; 
Focus area[A]: Healthy Futures. 

CNCS grantee: Maryland Conservation Corps; 
State: Maryland; 
CNCS program: AmeriCorps State; 
Focus area[A]: Environmental Stewardship. 

CNCS grantee: Maryland Governor's Office on Service and Volunteerism; 
State: Maryland; 
CNCS program: State Service Commission; 
Focus area[A]: Economic Opportunity; Education; Environmental 
Stewardship; Healthy Futures. 

CNCS grantee: OneStar Foundation; 
State: Texas; 
CNCS program: State Service Commission; 
Focus area[A]: Education; Disaster Services. 

CNCS grantee: Panhandle Community Services; 
State: Texas; 
CNCS program: Senior Corps/RSVP; 
Focus area[A]: Healthy Futures; Disaster Services; Education. 

CNCS grantee: Rural Action, Inc.; 
State: Ohio; 
CNCS program: AmeriCorps State; 
Focus area[A]: Environmental Stewardship. 

CNCS grantee: Texas Department of Aging and Disability Services; 
State: Texas; 
CNCS program: Senior Corps/Foster Grandparent Program; 
Focus area[A]: Education. 

CNCS grantee: Texas Homeless Network; 
State: Texas; 
CNCS program: AmeriCorps VISTA; 
Focus area[A]: Economic Opportunity. 

CNCS grantee: United Planning Organization; 
State: District of Columbia; 
CNCS program: Senior Corps/Foster Grandparent Program; 
Focus area[A]: Education. 

CNCS grantee: United Way of the Bay Area; 
State: California; 
CNCS program: AmeriCorps VISTA; 
Focus area[A]: Economic Opportunity. 

CNCS grantee: Coach Across America-Up2Us; 
State: New York; 
CNCS program: AmeriCorps National; 
Focus area[A]: Healthy Futures. 

Source: GAO analysis of data from 20 CNCS grantees. 

[A] These focus areas were used by grantees at the time of our 
interviews, which were conducted from July 2011 to September 2011. 

[End of table] 

[End of section] 

Appendix III: Reported Legal Constraints on Holding Senior Corps 
Grantees Accountable: 

Statutory section: 42 U.S.C. § 5001(e); 
Programs affected: Retired and Senior Volunteer Program (a Senior 
Corps program); 
Description of legal constraint: Beginning in fiscal year 2013, the 
competitive process to determine Retired and Senior Volunteer Program 
(RSVP) grantees must ensure that the number of volunteers in specific 
geographic areas will remain at least at the previous level, and a 
similar distribution of programs must be maintained. Additionally, 
beginning in 2013 the competitive process must ensure that "every 
effort" is made to minimize the disruption to volunteers. 

Statutory section: 42 U.S.C. § 5001(i); 
Programs affected: Retired and Senior Volunteer Program (a Senior 
Corps program); 
Description of legal constraint: CNCS is required to continue funding 
RSVP programs that fail to meet performance measures for up to 12 
months if a competition does not result in a new grantee. 

Statutory section: 42 U.S.C. § 5027(a)(2); 
Programs affected: All Senior Corps programs; 
Description of legal constraint: Funding reductions resulting from 
insufficient appropriations must be applied pro rata to all Senior 
Corps grants. (This pro rata requirement applies regardless of the 
grantees' performance). 

Statutory section: 42 U.S.C. § 5052(a); 
Programs affected: Programs under the Domestic Volunteer Service Act 
of 1973, which includes Senior Corps programs; 
Description of legal constraint: If CNCS wants to deny an application 
for refunding, the grantee must be given (1) at least 75 days notice 
of the possibility of such denial and the grounds for the denial, and 
(2) an opportunity to show cause why such action should not be taken. 
If the grantee's application is denied for noncompliance with the 
grant or contract terms, the grantee must be given an opportunity for 
an informal hearing before an impartial hearing officer who has been 
agreed to by the grantee and CNCS. If CNCS wants to terminate funding 
for noncompliance with grant or contract terms, the grantee must be 
given reasonable notice and opportunity for a full and fair hearing. 

Statutory section: 42 U.S.C. § 12639(l) and (m); 
Programs affected: All CNCS programs, including Senior Corps programs; 
Description of legal constraint: If a grantee is failing to meet 
performance levels, CNCS must develop a corrective action plan and 
establish a period of correction for the grantee. For these low-
performing grantees, CNCS must require the grantee to submit quarterly 
progress reports. In addition, if such a grantee has been receiving 
funding for less than 3 years, CNCS is required to provide technical 
assistance to address the performance problems. Termination or funding 
reduction of a grantee occurs only if the grantee continues to fail to 
meet performance measures after such a period of correction. 

Source: CNCS officials, as confirmed by GAO review of relevant federal 
laws. 

[End of table] 

[End of section] 

Appendix IV: Comments from the Corporation for National and Community 
Service: 

Corporation for National & Community Service: 
1201 New York Avenue, NW: 
Washington, DC 20525: 
202-606-5000: 
[hyperlink, http://www.nationalservice.org] 
Senior Corps--AmeriCorps--Learn and Serve America: 

February 10, 2012: 

Mr. George A. Scott, Director: 
Education, Workforce, and Income Security Issues: 
Government Accountability Office: 
441 G Street, N.W. 
Washington, D.C. 

Re: Comments and Response to Draft Report (GAO-12-310): 

Dear Mr. Scott, 

Thank you for the opportunity to review and comment on the draft 
report entitled "Measuring Performance: The Corporation for National 
and Community Service Faces Challenges Demonstrating Outcomes" (GAO-12-
310). Overall, the draft report is balanced and the issues you raise 
are representative of the conversations we had with your team, as well 
as conversations we continue to have with our grantees and 
stakeholders. We appreciate the thoughtful analysis contained in the 
report and we are well underway with our efforts to address many of 
the issue outlined. 

You will find below some minor edits to the draft which we felt could 
help add greater clarity to the content, and some comments outlined by 
page number. One issue to specifically note is SeniorCorps plans to 
seek statutory changes to address the legal constraints on their 
ability to introduce competition into their programs by the middle of 
February 2012. Thus, the statement in the draft report (repeated 
throughout) that CNCS officials "have not sought statutory changes" 
will be inaccurate if this report is released after the middle of 
February. We attempted to address this issue by qualifying the 
statement, however without knowledge of the report release date, we 
are unsure of the best language to use. 

Again, we thank you for the opportunity to provide you with comments 
and you should feel free to contact me with any questions or concerns. 

Sincerely, 

Signed by: 

John Kim, 

Director of Strategic initiatives: 
Corporation for National and Community Service: 

[End of section] 

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

George A. Scott, Director, (202) 512-7215, scottg@gao.gov: 

Acknowledgments: 

In addition to the contact listed above, Bill Keller (Assistant 
Director), James Bennett, Susannah Compton, Elizabeth Curda, Alex 
Galuten, Kirsten Lauber, Sheila McCoy, Erin McLaughlin, Brittni Milam, 
and Ashanta Williams made key contributions to this report. 

[End of section] 

Related GAO Products: 

[End of section] 

Performance Measurement: Better Alignment to Strategic Goals and Data 
Verification Needed at the Corporation for National and Community 
Service. [hyperlink, http://www.gao.gov/products/GAO-10-886]. 
Washington, D.C.: July 28, 2010. 

Grants Management: Enhancing Performance Accountability Provisions 
Could Lead to Better Results. [hyperlink, 
http://www.gao.gov/products/GAO-06-1046]. Washington, D.C.: September 
29, 2006. 

Corporation for National and Community Service: Better Internal 
Control and Revised Practices Would Improve the Management of 
AmeriCorps and the National Service Trust. [hyperlink, 
http://www.gao.gov/products/GAO-04-225]. Washington, DC.: January 16, 
2004. 

Corporation for National and Community Service: Preliminary 
Observations on the National Service Trust and AmeriCorps. [hyperlink, 
http://www.gao.gov/products/GAO-03-642T]. Washington, D.C.: April 10, 
2003. 

National Service Programs: Two AmeriCorps Programs' Funding and 
Benefits. [hyperlink, http://www.gao.gov/products/GAO/HEHS-00-33]. 
Washington, D.C.: February 15, 2000. 

Grant Programs: Design Features Shape Flexibility, Accountability, and 
Performance Information. [hyperlink, 
http://www.gao.gov/products/GAO/GGD-98-137]. Washington, D.C.: June 
22, 1998. 

The Results Act: An Evaluator's Guide to Assessing Agency Annual 
Performance Plans. [hyperlink, 
http://www.gao.gov/products/GAO/GGD-10.1.20]. Washington, D.C.: April 
1, 1998. 

National Service Programs: Role of State Commissions in Implementing 
the AmeriCorps Program. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-97-49]. Washington, D.C.: 
February 20, 1997. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-13, §§ 1101(6), 1302, and 1607, 123 Stat. 1460, 
1463, 1485, 1532. 

[2] Id. at § 1712, 123 Stat. 1460, 1551. 

[3] GAO, Performance Measurement: Better Alignment to Strategic Goals 
and Data Verification Needed at the Corporation for National and 
Community Service, [hyperlink, http://www.gao.gov/products/GAO-10-886] 
(Washington, D.C.: July 28, 2010). 

[4] State service commissions are responsible for allocating CNCS's 
funding to AmeriCorps state programs and monitoring program activities. 

[5] These main programs include AmeriCorps State and National, VISTA, 
National Civilian Community Corps (NCCC), and Senior Corps. 

[6] See [hyperlink, http://www.gao.gov/products/GAO-10-243]. 

[7] Pub. L. No. 111-13, §1712, 123 Stat. 1460, 1551 (2009). 

[8] GAO, Performance Measurement: Better Alignment to Strategic Goals 
and Data Verification Needed at the Corporation for National and 
Community Service, [hyperlink, http://www.gao.gov/products/GAO-10-886] 
(Washington, D.C.: July 28, 2010). 

[9] For the purposes of this study, we are using the term “grantee” in 
general to describe both CNCS grantees and sponsors—-those 
organizations that receive AmeriCorps Volunteers in Service to 
America(VISTA) volunteers. We did not include National Civilian 
Community Corps (NCCC) worksites in our interviews. 

[10] CNCS’s strategic plan includes other performance measures, but 
they are not agency-wide. 

[11] State service commissions provide CNCS funding to AmeriCorps 
state formula grantees in their states through annual grant 
competitions. In addition, the Commissions manage, monitor and 
evaluate these grantees. 

[12] GAO, Grants Management: Enhancing Performance Accountability 
Provisions Could Lead to Better Results, [hyperlink, 
http://www.gao.gov/products/GAO-06-1046] (Washington, D.C.: Sept. 29, 
2006). 

[13] For more information about financial and non-financial options 
for holding grantees accountable for performance, see GAO-06-1046. 

[14] CNCS state offices are responsible for overseeing and providing 
assistance to Senior Corps and VISTA grantees. 

[End of section] 

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