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. To close this recommendation, CNCS will need to show documentation for how it selected and weighted revised indicators to cover identifiable risks, and how the revised scoring system identifies the riskiest grants.

    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: Although CNCS said that by regulation, grantees are primarily responsible for subgrantee monitoring, the agency acknowledged that more needs to be done to address risk at the sub-recipient level, particularly regarding criminal history check compliance, and noted that it is taking several actions to improve criminal history check compliance. However, the agency's comments did not specifically address reviewing monitoring protocols. We continue to believe that it is important to determine whether monitoring protocols are designed to gather sufficient and appropriate information on subrecipient oversight, to help ensure that grantees are monitoring subgrantees as required.

    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 said that its Office of the Chief Risk Officer has been building on the agency's current risk assessment framework and capturing the information and data necessary to enhance its approach to risk-based monitoring. However, CNCS's comments did not specifically address any planned activities to systematically evaluate grant monitoring results. We continue to believe that reviewing the outcomes and findings from its monitoring activities would help the agency analyze how well its CNCS's current efforts assess risk, and help guide improvements.

    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 its senior level executive committee reviews all staffing requests and ensures that appropriate staffing justifications are provided, and ensures that all functions in the agency are provided appropriate resources. The agency also noted that, in accordance with direction received from OMB following the release of OMB Memorandum M-17-22 ("Memorandum for Heads of Executive Departments and Agencies"), it is launching an enterprise-wide re-examination of its mission, strategy and structure in order to develop a plan to ensure employee performance is maximized and the agency is operating effectively. To help close this recommendation, CNCS will need to document and develop a strategic workforce planning process that addresses key principles for effective strategic workforce planning, such as to develop strategies tailored to address gaps in number, deployment, and alignment of human capital approaches for enabling and sustaining the contributions of all critical skills and competencies, and to monitor and evaluate process toward human capital goals and programmatic results.

    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. To close this recommendation, CNCS will need to determine which competencies are critical for grant monitoring, and show how the competencies are linked with the agency's training planning processes and agency goals.

    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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