Grants Management:

Monitoring Efforts by Corporation for National and Community Service Could Be Improved

GAO-17-90: Published: Mar 21, 2017. Publicly Released: Mar 21, 2017.

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What GAO Found

The Corporation for National and Community Service (CNCS) assesses its grants before the beginning of each fiscal year and prioritizes its grant monitoring based on the scoring of certain indicators, such as potential performance or financial problems and the length of time since the last compliance visit. For fiscal year 2015, CNCS identified about 2,200 grants for assessment and prioritized 16.4 percent for compliance visits and 5.4 percent for other types of visits and financial reviews. In addition, each year CNCS selects a sample of grant records to review for improper payments.

CNCS's process for grant monitoring is not fully aligned with the internal controls for identifying, analyzing, and responding to risks (see fig.). Specifically, because CNCS's assessment process does not include all grants, risks may go unidentified. Further, the assessment process uses a scoring model of 19 indicators to analyze and prioritize grants for monitoring visits rather than to identify the highest-risk grants. For example, multiple financial risks are grouped together under one indicator, including for improper payments, and a grant found to have such risks would not be scored as high priority for monitoring based on this indicator alone. In addition, while nearly half of CNCS grant dollars are passed through to other organizations (referred to as subrecipients) and evidence indicates that subrecipient oversight is a key risk area, CNCS's monitoring of grantees' oversight of subrecipients is limited, leaving the agency's response to risk vulnerable in this area.

Areas for Improvement in CNCS's Grant Monitoring Process

Areas for Improvement in CNCS's Grant Monitoring Process

CNCS has not conducted the strategic workforce planning necessary to determine whether it has the people and resources to effectively monitor grantees' compliance with grant program requirements, as key principles for effective strategic workforce planning suggest. CNCS's workforce management activities to address vacancies have been largely ad-hoc, including vacancies in a key office responsible for grant monitoring, at senior levels across the agency, and among program and grant officers. Some of these vacancies reduced the number of fiscal year 2015 monitoring activities conducted. Further, program and grant officers' workloads varied across the agency, and CNCS has not evaluated whether staff have been deployed where they are most needed. Officials said they had not developed a strategic workforce planning process because of limited resources. Without such a process, CNCS's efforts to address workforce challenges may continue to be ad hoc and reactive.

Why GAO Did This Study

Created in 1993, CNCS distributes about $750 million in grants annually to volunteer and national service programs for needs ranging from disaster recovery to improving education. A 2014 CNCS Office of Inspector General (OIG) report cited problems with grant management. GAO was asked to review CNCS's efforts to improve its grant monitoring.

This report examines (1) CNCS's process for grant monitoring; (2) the extent that this process aligns with relevant internal controls for identifying, analyzing, and responding to risk; and (3) the extent that CNCS has the capacity necessary to monitor grantees' compliance with grant requirements. GAO reviewed agency documents for fiscal years 2015 and 2016; analyzed fiscal year 2015 assessment and monitoring data (the most recent complete year of data available); interviewed agency officials and a nongeneralizable sample of program and grant officers who had experience with grants with negative outcomes, such as greater-than-expected monitoring needs or audit findings; and held discussion groups with a small nongeneralizable number of grantees attending two 2016 training conferences.

What GAO Recommends

GAO is making six recommendations to CNCS, including to ensure that all grants are assessed for risk and that its scoring model prioritizes risk; to review its monitoring protocols; and to develop a strategic workforce planning process. CNCS and CNCS OIG provided technical comments, which were incorporated as appropriate.

For more information, contact Allison Bawden at (202) 512-7215 or bawdena@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: CNCS stated that it would continue to periodically benchmark its assessment criteria to ensure risk assessment. The agency recognizes the need to move from compliance- to risk-based monitoring and will refine its existing approach as part of reviewing and revising risk criteria and scoring. The agency's risk-based approach will begin with FY18 grant awards.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should ensure that CNCS completes its efforts to benchmark its assessment criteria and scoring process to further develop a risk-based approach to grant monitoring and that information from this effort is used to (a) score the indicators so that the riskiest grants get the highest scores; (b) revise the assessment indicators to meaningfully cover all identifiable risks, including fraud and improper payments; and (c) document decisions on how indicators are selected and weighted.

    Agency Affected: Corporation for National and Community Service

  2. Status: Open

    Comments: CNCS agrees with this recommendation and plans to revise its current assessment policy to ensure that all grants are included in the assessment process.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should establish and implement a policy to ensure that all grants expected to be active in a fiscal year, including those awarded after the annual assessment, are assessed for potential risk.

    Agency Affected: Corporation for National and Community Service

  3. Status: Open

    Comments: CNCS reported that they have taken steps to resolve CHC compliance with grantees and sub-recipients. They implemented the use of an FBI channeler and are exploring a contract solution for national and state checks. The agency also reported that it is strictly enforcing compliance and disallowing costs when grantees have failed to comply with grant requirements.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should review monitoring protocols, including the level of information collected for oversight of subrecipients' activities such as criminal history checks, and enhance protocols, as appropriate.

    Agency Affected: Corporation for National and Community Service

  4. Status: Open

    Comments: CNCS reported that it has not only established the Office of the Chief Risk Officer, but resourced it so the agency can continue building on its current risk assessment framework and capture the information and data needed to enhance its approach to risk-based monitoring.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should establish activities to systematically evaluate grant monitoring results.

    Agency Affected: Corporation for National and Community Service

  5. Status: Open

    Comments: CNCS reported that it is launching an enterprise-wide reexamination of the agencies' mission, strategy and structure in order to develop a plan to ensure employee performance is maximized and the agency is operating effectively (per OMB's Memorandum for Heads of Executive Departments and Agencies). The agency also noted its efforts to address workforce needs in the last two years, such as establishing a committee to ensure that all functions within the agency are resourced appropriately, reviewing staffing level requirements and ensuring that appropriate staffing justifications are provided.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should develop and document a strategic workforce planning process.

    Agency Affected: Corporation for National and Community Service

  6. Status: Open

    Comments: CNCS cited its training efforts, such as providing training to grants management staff in FY15 and FY16 related to grants monitoring. The agency is in the process of developing a broader agency-wide employee development program that will link competencies to development needs in various mission-critical roles.

    Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should, as part of CNCS's efforts to develop an employee development program, update critical competencies for grant monitoring, and establish a training planning process linked with agency goals and these competencies.

    Agency Affected: Corporation for National and Community Service

 

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