type: legislation

text:
 14.4.2012
 NL
 Publicatieblad van de Europese Unie
 L 104/26
 UITVOERINGSVERORDENING (EU) Nr. 321/2012 VAN DE COMMISSIE
 van 13 april 2012
 tot vaststelling van de invoerrechten in de sector granen van toepassing vanaf 16 april 2012
 DE EUROPESE COMMISSIE,
 Gezien het Verdrag betreffende de werking van de Europese Unie,
 Gezien Verordening (EG) nr. 1234/2007 van de Raad van 22 oktober 2007 houdende een gemeenschappelijke ordening van de landbouwmarkten en specifieke bepalingen voor een aantal landbouwproducten („integrale-GMO-verordening”) (1),
 Gezien Verordening (EU) nr. 642/2010 van de Commissie van 20 juli 2010 tot vaststelling van uitvoeringsbepalingen van Verordening (EG) nr. 1234/2007 van de Raad ten aanzien van de invoerrechten in de sector granen (2), en met name artikel 2, lid 1,
 Overwegende hetgeen volgt:
 (1)
 In artikel 136, lid 1, van Verordening (EG) nr. 1234/2007 is bepaald dat het invoerrecht voor de producten van de GN-codes 1001 19 00, 1001 11 00, ex 1001 91 20 (zachte tarwe, zaaigoed), ex 1001 99 00 (zachte tarwe van hoge kwaliteit, andere dan zaaigoed), 1002 10 00, 1002 90 00, 1005 10 90, 1005 90 00, 1007 10 90 en 1007 90 00, gelijk is aan de interventieprijs voor deze producten bij de invoer, verhoogd met 55 % en verminderd met de cif-invoerprijs voor de betrokken zending. Dit invoerrecht mag echter niet hoger zijn dan het recht van het gemeenschappelijk douanetarief.
 (2)
 In artikel 136, lid 2, van Verordening (EG) nr. 1234/2007 is bepaald dat voor de berekening van het in lid 1 van dat artikel bedoelde invoerrecht regelmatig representatieve cif-invoerprijzen voor de betrokken producten worden vastgesteld.
 (3)
 Overeenkomstig artikel 2, lid 2, van Verordening (EG) nr. 642/2010 is de prijs die in aanmerking moet worden genomen voor de berekening van het invoerrecht voor de producten van de GN-codes 1001 19 00, 1001 11 00, ex 1001 91 20 (zachte tarwe, zaaigoed), ex 1001 99 00 (zachte tarwe van hoge kwaliteit, andere dan zaaigoed), 1002 10 00, 1002 90 00, 1005 10 90, 1005 90 00, 1007 10 90 en 1007 90 00, de dagelijkse representatieve cif-invoerprijs die wordt bepaald volgens de methode van artikel 5 van die verordening.
 (4)
 Er dienen invoerrechten te worden vastgesteld voor de periode vanaf 16 april 2012, die van toepassing zullen zijn tot er nogmaals nieuwe invoerrechten worden vastgesteld en in werking treden.
 (5)
 Omdat ervoor moet worden gezorgd dat deze maatregel zo snel mogelijk na de terbeschikkingstelling van de geactualiseerde gegevens van toepassing wordt, moet deze verordening in werking treden op de dag van de bekendmaking ervan,
 HEEFT DE VOLGENDE VERORDENING VASTGESTELD:
 Artikel 1
 De in artikel 136, lid 1, van Verordening (EG) nr. 1234/2007 bedoelde invoerrechten in de sector granen die van toepassing zijn vanaf 16 april 2012, worden in bijlage I bij de onderhavige verordening vastgesteld op basis van de in bijlage II vermelde elementen.
 Artikel 2
 Deze verordening treedt in werking op de dag van de bekendmaking ervan in het Publicatieblad van de Europese Unie.
 Deze verordening is verbindend in al haar onderdelen en is rechtstreeks toepasselijk in elke lidstaat.
 Gedaan te Brussel, 13 april 2012.
 Voor de Commissie, namens de voorzitter,
 José Manuel SILVA RODRÍGUEZ
 Directeur-generaal Landbouw en plattelandsontwikkeling
 (1) PB L 299 van 16.11.2007, blz. 1.
 (2) PB L 187 van 21.7.2010, blz. 5.
 BIJLAGE I
 Vanaf 16 april 2012 geldende invoerrechten voor de in artikel 136, lid 1, van Verordening (EG) nr. 1234/2007 bedoelde producten
 GN-code
 Omschrijving
 Invoerrecht (1)
 (EUR/t)
 1001 19 00
 1001 11 00
 HARDE TARWE van hoge kwaliteit
 0,00
 van gemiddelde kwaliteit
 0,00
 van lage kwaliteit
 0,00
 ex 1001 91 20
 ZACHTE TARWE, zaaigoed
 0,00
 ex 1001 99 00
 ZACHTE TARWE van hoge kwaliteit, andere dan zaaigoed
 0,00
 1002 10 00
 1002 90 00
 ROGGE
 0,00
 1005 10 90
 MAÏS, zaaigoed, ander dan hybriden
 0,00
 1005 90 00
 MAÏS, andere dan zaaigoed (2)
 0,00
 1007 10 90
 1007 90 00
 GRAANSORGHO, andere dan hybriden bestemd voor zaaidoeleinden
 0,00
 (1) Krachtens artikel 2, lid 4, van Verordening (EU) nr. 642/2010 komt de importeur in aanmerking voor een verlaging van de invoerrechten met:
 —
 3 EUR per ton, indien de loshaven aan de Middellandse Zee (voorbij de Straat van Gibraltar) of de Zwarte Zee ligt en het product via de Atlantische Oceaan of het Suezkanaal wordt aangevoerd,
 —
 2 EUR per ton, als de loshaven in Denemarken, Estland, Ierland, Letland, Litouwen, Polen, Finland, Zweden, het Verenigd Koninkrijk of aan de Atlantische kust van het Iberisch Schiereiland ligt en het product via de Atlantische Oceaan wordt aangevoerd.
 (2) De importeur komt in aanmerking voor een forfaitaire verlaging van het invoerrecht met 24 EUR per ton als aan de in artikel 3, van Verordening (EU) nr. 642/2010 vastgestelde voorwaarden is voldaan.
 BIJLAGE II
 Elementen voor de berekening van de in bijlage I vastgestelde rechten
 30.3.2012-12.4.2012
 1.
 Gemiddelden over de in artikel 2, lid 2, van Verordening (EU) nr. 642/2010 bedoelde referentieperiode:
 (EUR/t)
 Zachte tarwe (1)
 Maïs
 Harde tarwe van hoge kwaliteit
 Harde tarwe tarwe van gemiddelde kwaliteit (2)
 Harde tarwe van lage kwaliteit (3)
 Beurs
 Minnéapolis
 Chicago
 —
 —
 —
 Notering
 248,19
 192,23
 —
 —
 —
 Fob-prijs VSA
 —
 —
 260,96
 250,96
 230,96
 Golfpremie
 —
 17,55
 —
 —
 —
 Grote-Merenpremie
 40,65
 —
 —
 —
 —
 2.
 Gemiddelden over de in artikel 2, lid 2, van Verordening (EU) nr. 642/2010 bedoelde referentieperiode:
 Vrachtkosten: Golf van Mexico-Rotterdam:
 16,41 EUR/t
 Vrachtkosten: Grote Meren-Rotterdam:
 51,59 EUR/t
 (1) Premie van 14 EUR per ton inbegrepen (artikel 5, lid 3, van Verordening (EU) nr. 642/2010).
 (2) Korting van 10 EUR per ton (artikel 5, lid 3, van Verordening (EU) nr. 642/2010).
 (3) Korting van 30 EUR per ton (artikel 5, lid 3, van Verordening (EU) nr. 642/2010).


type: wikipedia

text:
Joola – Senegalui priklausęs keleivinis laivas, 2002 metų rugsėjo 26 d. apvirtęs ir nuskendęs ties Gambijos krantais. Katastrofoje žuvo 1863 žmonės, daugiau nei nuskendus „Titanikui“. Tai didžiausia kada nors įvykusi nelaimė visoje laivininkystės istorijoje.
 „Joola“ apvirto labai greitai, todėl dauguma žmonių neturėjo jokios galimybės išsigelbėti. Šis plokščiadugnis laivas netiko plaukioti atvira jūra, kuri katastrofos metu buvo labai audringa. Be to, mažiau nei 600 keleivių statytas laivas buvo neabejotinai perkrautas.
 Įvykis sukėlė didelę politinę krize, turėjo atsistatydinti šalies prezidentas.
 Nuorodos
 Istorijos aptarimas
 Kompanijos svetainė
 Nuskendę laivai


type: other

jurisdiction: US

text: b' Office of Inspector General\n Corporation for National and\n Community Service\n\n\n\n\n AGREED-UPON PROCEDURES REVIEW OF\n CORPORATION FOR NATIONAL AND COMMUNITY\n SERVICE GRANT AWARDED TO\n AMERICAN NATIONAL RED CROSS\n\n OIG REPORT NUMBER 10-12\n\n\n\n\n Prepared by:\n\n Clifton Gunderson LLP\n 11710 Beltsville Drive\n Calverton, MD 20705\n\n\n\n\nThis report was issued to Corporation management on May 14, 2010. Under the\nlaws and regulations governing audit follow-up, the Corporation is to make final\nmanagement decisions on the report\xe2\x80\x99s findings and recommendations no later\nthan November 14, 2010, and complete its corrective actions by May 14, 2011.\nConsequently, the reported findings do not necessarily represent the final\nresolution of the issues presented.\n\x0c OFFICE OF INSPECTOR GENERAL\n\n May 14, 2010\n\n\nTO: Lois Nembhard\n Acting Director, AmeriCorps*State and National\n\n Margaret Rosenberry\n Director, Office of Grants Management\n\nFROM: Stuart Axenfeld /s/\n Assistant Inspector General for Audit\n\nSUBJECT: OIG Report 10-12, Agreed-Upon Procedures Review of Corporation for National\n and Community Service Grant Awarded to American National Red Cross\n\n\nAttached is the final report for the above-noted agreed-upon procedures review. We contracted\nwith the independent certified public accounting firm of Clifton Gunderson LLP (Clifton) to\nperform the procedures. The contract required Clifton to conduct its review in accordance with\ngenerally accepted government auditing standards.\n\nClifton is responsible for the attached report, dated February 24, 2010, and the conclusions\nexpressed therein. We do not express opinions on the Consolidated Schedule of Award and\nClaimed Costs, or the Schedule of Award and Claimed Costs for each subgrantee, conclusions\non the effectiveness of internal controls, or the grantee\xe2\x80\x99s compliance with laws, regulations, and\ngrant provisions.\n\nUnder the Corporation\xe2\x80\x99s audit resolution policy, a final management decision on the findings in\nthis report is due by November 14, 2010. Notice of final action is due by May 14, 2011.\n\nIf you have questions pertaining to this report, please call me at (202) 606-9360, or Ronald\nHuritz, Audit Manager, at (202) 606-9355.\n\nAttachment\n\ncc: Meghan Smith, Senior Program Associate, ANRC\n William Anderson, Acting Chief Financial Officer, CNCS\n Rocco Gaudio, Deputy Chief Financial Officer, Grants & Field Financial\n Management, CNCS\n Bridgette Roy, Administrative Assistant, CNCS\n Claire Moreno, Audit Liaison, Office of Grants Management, CNCS\n Denise Wu, Partner, Clifton Gunderson LLP\n\n\n\n\n 1201 New York Avenue, NW \xef\x82\xab Suite 830 \xef\x82\xab Washington, DC 20525\n 202-606-9390 \xef\x82\xab Hotline: 800-452-8210 \xef\x82\xab www.cncsoig.gov\n\n Senior Corps \xef\x82\xab AmeriCorps \xef\x82\xab Learn and Serve America\n\x0c AGREED-UPON PROCEDURES FOR CORPORATION GRANTS\n AWARDED TO THE AMERICAN NATIONAL RED CROSS\n\n\n\n\n TABLE OF CONTENTS\n\n PAGE\n\nEXECUTIVE SUMMARY 1\n\nINDEPENDENT ACCOUNTANT\xe2\x80\x99S REPORT 4\n\nCONSOLIDATED SCHEDULE OF AWARD AND CLAIMED COSTS 5\n\nNOTES TO CONSOLIDATED SCHEDULE OF AWARD AND CLAIMED COSTS 6\n\nSCHEDULE A \xe2\x80\x93 SCHEDULE OF AWARD AND CLAIMED COSTS BY\n GRANTEE/SUBGRANTEE 7\n\nSCHEDULE B \xe2\x80\x93 SCHEDULE OF AWARD AND CLAIMED COSTS: SAN\n FRANCISCO CHAPTER 8\n\nSCHEDULE C \xe2\x80\x93 SCHEDULE OF AWARD AND CLAIMED COSTS: CHICAGO\n CHAPTER 9\n\nSCHEDULE D \xe2\x80\x93 SCHEDULE OF AWARD AND CLAIMED COSTS: CHARLOTTE\n CHAPTER 11\n\nSCHEDULE E \xe2\x80\x93 SCHEDULE OF FINDINGS ....................................................................... 13\n\n\nAPPENDIX A: AMERICAN NATIONAL RED CROSS RESPONSE TO DRAFT REPORT\n\nAPPENDIX B: CORPORATION FOR NATIONAL AND COMMUNITY SERVICE\n RESPONSE TO DRAFT REPORT\n\n\n\n\n i\n\x0c Executive Summary\n\nThe Office of Inspector General (OIG), Corporation for National and Community Service\n(Corporation), contracted with Clifton Gunderson LLP (auditors) to perform agreed-upon\nprocedures on the grant expenditures, terms and provisions (including compliance with\napplicable laws and regulations) for Corporation-funded Federal assistance provided to the\nAmerican National Red Cross (ANRC).\n\nResults\n\nAs a result of applying the procedures, the auditors questioned claimed Federal-share costs of\n$45,914, match costs of $32,594, education awards of $14,175, and $2,002 in interest\nforbearance. A questioned cost is an alleged violation or non-compliance with grant terms\nand/or provisions of laws and regulations governing the expenditure of funds; or a finding that,\nat the time of testing, adequate documentation supporting a cost item was not readily available.\nThe results of our agreed-upon procedures are summarized in the Consolidated Schedule of\nAward and Claimed Costs.\n\nANRC claimed total Federal costs of $1,559,135 and total match costs of $1,198,477 from July\n28, 2007, through July 27, 2009, for Grant No. 06NDHHDC001. Based on testing a\njudgmentally selected sample of transactions, the auditors questioned claimed costs as detailed\nbelow:\n\n Federal Education Interest Match\n Type of Questioned Costs Share Award Forbearance Share\n Time Sheet Exceptions $2,939 $ 4,725 $ - $ 2,068\n National Sex Offender Search was\n incomplete or missing 42,704 9,450 2,002 30,421\n Members did not receive consistent living\n allowance 271 - - 105\n Totals $45,914 $14,175 $2,002 $32,594\n\nParticipants who successfully complete the term of service for the AmeriCorps grants are\neligible for education awards and, in some cases, accrued interest awards funded by the\nCorporation\xe2\x80\x99s National Service Trust. These award amounts are not funded by the Corporation\ngrants and thus are not included in the claimed grant costs. However, at grant award, these\namounts become immediate obligations of the National Service Trust. Therefore, as part of our\nagreed-upon procedures (AUP), and applying the same criteria used for the grantee\xe2\x80\x99s claimed\ncosts, we determined the effect of our findings on AmeriCorps members\xe2\x80\x99 entitlement to\neducation and accrued interest awards.\n\nThe auditors compared the inception-to-date drawdown amounts with the amounts reported in\nthe last Federal Financial Report (FFR) for the period tested and determined that the\ndrawdowns were reasonable.\n\nWe questioned $14,175 in education awards and $2,002 in interest forbearance because the\nmembers lacked completed National Sex Offender checks or adequate support for certified\nhours of service. We did not verify whether the members used the education awards, as it is\noutside the scope of the AUP. The interest forbearance amount is generated from the National\nService Participant\xe2\x80\x99s Award and Payment Activities report, dated January 28, 2010, that the OIG\nprovided to address those education awards that were questioned.\n\n 1\n\x0cDetails of the questioned costs, grant awards, non-compliance with grant provisions, applicable\nlaws and regulations are presented in the Schedule of Findings that follows the results of our\nagreed-upon procedures, which are summarized below.\n\n \xef\x83\x98 Controls not fully implemented over reporting and recording of Federal share costs;\n\n \xef\x83\x98 Lack of adequate procedures to ensure program compliance, such as late criminal\n background checks, incomplete National Sex Offender searches, unequal payment of\n living allowances, and health benefits not provided to members;\n\n \xef\x83\x98 Timesheets not signed by supervisors or the members; and late submission of Exit/End-\n of-Term-of-Service member form;\n\n \xef\x83\x98 Lack of documentation to support members\xe2\x80\x99 attendance at pre-service orientation; and\n\n \xef\x83\x98 Non-compliance with the travel policy, record retention requirements, and submission\n requirements for the Federal Financial Report.\n\nBackground\n\nThe Corporation, pursuant to the authority of the National Community Service Trust Act of 1993\n(as amended), awards grants and cooperative agreements to State commissions, nonprofit\nentities, and tribes and territories to assist in the creation of full- and part-time national and\ncommunity service programs. Through these grantees, AmeriCorps members perform service\nto meet educational, human, environmental, and public safety needs throughout the nation. In\nreturn, eligible members may receive a living allowance and post-service education benefits.\n\nThe ANRC received its first congressional charter in 1900 and a second in 1905. ANRC is a\nFederally chartered instrumentality of the United States. This charter, which remains in effect\ntoday, sets forth the purpose of the organization that includes giving relief to and serving as a\nmedium of communication between members of the armed forces and their families, and\nproviding national and international disaster relief and mitigation. ANRC works closely with the\nFederal Government in the promotion of the Federal Government\xe2\x80\x99s objectives. However, ANRC\nis an independent, volunteer-led organization that is financially supported by voluntary public\ncontributions and cost-reimbursement charges. The ANRC Board of Governors is comprised of\n50 all-volunteer members. The President of the United States is the honorary chairman of the\nANRC. He appoints eight governors, including the chairman of the board. The chairman\nnominates and the board elects the president of the ANRC, who is responsible for implementing\nand maintaining the policies and programs of the board. The ANRC is subject to the Single\nAudit Act and received unqualified opinions on its financial statements, and no findings were\nidentified relating to AmeriCorps funding.\n\nThe mission of the ANRC\xe2\x80\x99s National Preparedness and Response Corps (NPRC) program is to\nprovide vital emergency assistance to communities affected by disasters and to increase\npreparedness before disaster strikes. This is done by recruiting, training, and supporting young\nadults who will provide integrated community outreach and education through ANRC service\nactivities that focus on Homeland Security and the role of ANRC in supporting the National\nResponse Plan.\n\n\n\n 2\n\x0cANRC awarded funds to 18 subgrantees (ANRC Chapters) in Program Year (PY) 2007-2008\nand 17 subgrantees in PY 2008-2009 covered in our scope. The subgrantees used the funds to\nsupport their operations and provide member support. The subgrantees maintain supporting\ndocumentation for the claimed costs and member files. ANRC submitted its monthly Periodic\nExpense Report (PER) to the Corporation\xe2\x80\x99s Web-Based Reporting System (WBRS) until the\nend of PY 2007 \xe2\x80\x93 2008 (9/30/08). After that, WBRS was no longer used for that purpose.\nANRC prepares the aggregate Federal Financial Report (FFR) for the grant by accumulating the\nexpenses reported on subgrantees\xe2\x80\x99 and ANRC\xe2\x80\x99s PERs. ANRC submits its FFR for its\nAmeriCorps grant through the Corporation\xe2\x80\x99s online eGrants system.\n\nANRC monitors its subgrantees by reviewing member information, reimbursement requests,\nperforming site visits and desk reviews, and through regular communication.\n\nANRC claimed Federal costs, totaling $1,559,135, during the scope of this engagement.\n\nAgreed-Upon-Procedures Scope\n\nThe auditors performed the agreed-upon procedures during the period September 4, 2009,\nthrough January 31, 2010. The agreed-upon procedures covered the allowability, allocability,\nand reasonableness of the financial transactions reported between July 28, 2007, and July 27,\n2009, for grant number 06NDHDC001. The auditors also performed tests to determine\ncompliance with certain grant terms and provisions. The procedures performed were based on\nthe OIG\xe2\x80\x99s \xe2\x80\x9cAgreed Upon Procedures for Corporation Awards to Grantees (including\nSubgrantees) dated May 2009.\xe2\x80\x9d The engagement focused on the ANRC and three of its\nsubgrantees: San Francisco Chapter, Charlotte Chapter, and Chicago Chapter. We tested\nANRC transactions totaling $26,355. We also tested transactions totaling $7,149 for the San\nFrancisco Chapter, $11,464 for the Charlotte Chapter and $8,669 for the Chicago Chapter.\n\nExit Conference\n\nWe provided a draft report and discussed its contents with the Corporation, ANRC, and\napplicable subgrantees at an exit conference on February 24, 2010, at ANRC\xe2\x80\x99s offices in\nWashington, DC.\n\nANRC provided its written response, which is included in Appendix A and summarized after\neach recommendation. The Corporation did not respond to the individual findings and\nrecommendations. Its response is in Appendix B.\n\n\n\n\n 3\n\x0c~Clift.a\n~ Gund~rson LLP\n Certified Public Accountants & Consultants\n\n\n\n\n INDEPENDENT ACCOUNTANT\'S REPORT\n ON APPLYING AGREED-UPON PROCEDURES\n\n\nCorporation for National and Community Service\nOffice of Inspector General\n\nWe have performed the procedures, which are agreed to by the OIG, solely to assist you in\nevaluating certain information reported by ANRC in accordance with its Corporation grant terms\nand provisions, and applicable laws and regulations, for the period from July 28, 2007, through\nJuly 27, 2009. ANRC and its subgrantees are responsible for the accuracy and completeness\nof the reported information. This engagement was conducted in accordance with the attestation\nstandards established by the American Institute of Certified Public Accountants and\nGovernment Auditing Standards, issued by the Comptroller General of the United States. The\nsufficiency of the procedures is solely the responsibility of the OIG. Consequently, we make no\nrepresentation regarding the sufficiency of the procedures either for the purpose(s) enumerated\nor for any other purpose.\n\nThe results of our procedures are described in the Schedule of Findings.\n\nWe were not engaged to, and did not, conduct an examination, the objective of which would be\nthe expression of an opinion on the reported information. Accordingly, we do not express such\nan opinion. Had we performed additional procedures, other matters might have come to our\nattention that would have been reported to you.\n\nThis report is intended solely for the information and use of the OIG, the Corporation, ANRC,\nand the U.S. Congress, and is not intended to be, and should not be used by anyone other than\nthese specified parties.\n\n\n\n\nCalverton, Maryland\nFebruary 24, 2010\n\n\n\n\n11710 Belt.fodie Drin. Suite 300\nCaioerton,MD 20 7 05-3106\ntel: 301-931-2050 4 Me,nb.,r of\n\n\n\nfax: 301-931-1710\n Offices in 19 states and Washi.ngton, DC\n B,nternat;ona,\nwww.cliftoncpa.com\n\x0c Consolidated Schedule of Award and Claimed Costs\n Award Period July 28, 2007, through July 27, 2009\n American National Red Cross \xe2\x80\x93 06NDHDC001\n\n Reference\nAuthorized Budget (Corporation Funds) $1,708,795 Note 1\n\nClaimed Federal Costs $1,559,135 Note 2\n\nAuthorized Match Budget $ 543,454 Note 3\n\nClaimed Match Costs $1,198,477 Note 4\n\nQuestioned Federal Costs:\n Timesheet exceptions $ 2,939 Note 5\n National Sex Offender Search was incomplete or 42,704 Note 6\n Missing\n Unequal payment of member living allowance 271 Note 7\n Total Questioned Federal Costs $ 45,914\n\nQuestioned Match Costs:\n Timesheet exceptions $ 2,068 Note 5\n National Sex Offender Search was incomplete or 30,421 Note 6\n Missing\n Unequal payment of member living allowance 105 Note 7\n Total Questioned Match Costs $ 32,594\n\nQuestioned Education Award:\n Timesheet exceptions $ 4,725 Note 5\n National Sex Offender Search was incomplete or 9,450 Note 6\n Missing\n Total Questioned Education Awards $ 14,175\n\nInterest forbearance on questioned education award $ 2,002 Note 6\n\n\n\n\n 5\n\x0c Notes to Consolidated Schedule of Award and Claimed Costs\n\nNotes\n\n1. The approved budget amount represents the funding to the ANRC in accordance with the\n grant agreement.\n\n2. Claimed costs represent ANRC\xe2\x80\x99s reported Federal expenditures for the period of July 28,\n 2007, through July 27, 2009.\n\n3. The approved match budget amount represents the funding to the ANRC in accordance with\n the grant agreement.\n\n4. Claimed costs represent the ANRC\xe2\x80\x99s reported match expenditures for the period of July 28,\n 2007, through July 27, 2009.\n\n5. The Charlotte Chapter had $2,939 in questioned Federal cost, and $2,068 in questioned\n match cost for member living allowance and health benefits due to a missing supervisor or\n member signature on timesheet(s), and $4,725 in questioned cost for the related education\n award (See Finding 1).\n\n6. The Charlotte and Chicago Chapters had $42,704 in Federal questioned member living\n allowances, $22,421 in match living allowances, $8,000 in match health benefits, and\n $9,450 in questioned education awards due to incomplete or missing National Sex Offender\n Registry searches. In addition, we are also questioning interest forbearance of $2,002\n related to one of the questioned education awards. Total questioned match cost was\n $30,421 (see Finding 1).\n\n7. The Chicago Chapter had $271 in Federal questioned costs for member living allowance\n and $105 in questioned costs for the match living allowance due to unequal payment of\n member living allowances (see Finding 1).\n\n\n\n\n 6\n\x0c Schedule A\n\n Schedule of Award and Claimed Costs By Grantee/Subgrantee\n July 28, 2007, through July 27, 2009\n\n Claimed Costs Questioned Costs Questioned Questioned\n Grantee/ Education Interest\n Subgrantee Federal Match Federal Match Awards Forbearance Reference\n American National\n Red Cross $ 278,257 $ 205,340 $ - $ - $ - $ -\n Greenwich\n Chapter 24,604 27,612 - - - - Note 1\n Atlanta Chapter 74,721 71,905 - - - - Note 1\n Richmond Chapter 71,740 58,375 - - - - Note 1\n New Orleans\n Chapter 41,090 32,005 - - - - Note 1\n San Francisco\n Chapter 118,540 70,084 - - - Schedule B\n Santa Barbara\n Chapter 51,076 41,671 - - - - Note 1\n Seattle Chapter 131,867 104,455 - - - - Note 1\n St. Louis Chapter 29,150 20,558 - - - - Note 1\n Chicago Chapter 83,356 56,918 24,891 16,844 9,450 2,002 Schedule C\n Dallas Chapter 63,425 24,666 - - - - Note 1\n New York Chapter 132,345 128,463 - - - - Note 1\n Peoria Chapter 43,824 29,465 - - - - Note 1\n Tulsa Chapter 38,023 20,337 - - - - Note 1\n Charlotte Chapter 105,283 118,186 21,023 15,750 4,725 - Schedule D\n Baltimore Chapter 60,760 47,065 - - - - Note 1\n Cedar Rapids\n Chapter 34,791 29,548 - - - - Note 1\n Springfield\n Chapter 53,233 29,021 - - - - Note 1\n Philadelphia\n Chapter 123,050 82,803 - - - - Note 1\n Totals $1,559,135 $1,198,477 $45,914 $32,594 $14,175 $2,002\n\n\n1. Transactions at this subgrantee were not tested.\n\n\n\n\n 7\n\x0c Schedule B\n\n Schedule of Award and Claimed Costs\n San Francisco Chapter\n July 28, 2007, through July 27, 2009\n\n Reference\n Authorized Budget (Federal Funds) $118,352 Note 1\n\n Claimed Federal Costs $118,540 Note 2\n\n Authorized Match Budget $ 69,510 Note 3\n\n Claimed Match Costs $ 70,084 Note 4\n\n Questioned Federal Costs:\n Total Questioned Federal Costs $ 0\n\n Questioned Match Costs:\n Total Questioned Match Costs $ 0\n\n Questioned Education Award\n Total Questioned Education Awards $ 0\n\n\nNotes\n\n1. The approved budget amount represents the funding to the San Francisco Chapter\n according to the grant agreement.\n\n2. Claimed costs represent the San Francisco Chapter\xe2\x80\x99s reported Federal expenditures for the\n period of July 28, 2007, through July 27, 2009. The claimed costs were in excess of budget\n due to a living allowance calculation error, but the grantee did not exceed the Federal\n budget overall, therefore, the amount was not questioned (See Finding 5 on page 26 for\n further details).\n\n3. The approved match budget amount represents the funding to the San Francisco Chapter in\n accordance with the grant agreement.\n\n4. Claimed costs represent the San Francisco Chapter\xe2\x80\x99s reported match expenditures for the\n period of July 28, 2007, through July 27, 2009. The match cost exceeded budget, but there\n is no exception because our testing of match costs indicated that they were supported and\n allowable.\n\n\n\n\n 8\n\x0c Schedule C\n\n Schedule of Award and Claimed Costs\n Chicago Chapter\n July 28, 2007, through July 27, 2009\n\n Reference\nAuthorized Budget (Federal Funds) $89,570 Note 1\n\nClaimed Federal Costs $83,356 Note 2\n\nAuthorized Match Budget $57,508 Note 3\n\nClaimed Match Costs $56,918 Note 4\n\nQuestioned Federal Costs:\n National Sex Offender Search was incomplete or\n Missing $24,620 Note 5\n Members did not receive consistent living\n Allowance 271 Note 6\n Total Questioned Federal Costs $24,891\n\nQuestioned Match Costs:\n National Sex Offender Search was incomplete or\n Missing $16,739 Note 5\n Members did not receive consistent living\n Allowance 105 Note 6\n Total Questioned Match Costs $16,844\n\nQuestioned Education Award\n National Sex Offender Search was incomplete or\n Missing $ 9,450 Note 5\n Total Questioned Education Awards $ 9,450\n\n Interest Forbearance on Questioned Education Award $ 2,002 Note 5\n\n\n\n\n 9\n\x0cNotes\n\n1. The approved budget amount represents the funding to the Chicago Chapter in accordance\n with the grant agreement.\n\n2. Claimed costs represent the Chicago Chapter\xe2\x80\x99s reported Federal expenditures for the period\n of July 28, 2007, through July 27, 2009.\n\n3. The approved match budget amount represents the funding to the Chicago Chapter in\n accordance with the grant agreement.\n\n4. Claimed costs represent the Chicago Chapter\xe2\x80\x99s reported match expenditures for the period\n of July 28, 2007, through July 27, 2009.\n\n5. The Chicago Chapter had questioned costs of $24,620 in Federal and $12,684 in match\n costs for living allowances, $4,055 in match health benefit costs, and $9,450 in education\n awards due to an incomplete or missing National Sex Offender Registry search. In addition,\n there is questioned interest forbearance of $2,002 related to one of the questioned\n education awards. Total questioned match cost was $16,739 (see Finding 1).\n\n6. The Chicago Chapter had $271 in Federal questioned costs for member living allowance\n and $105 in living allowance match costs due to unequal payment of member living\n allowances (see Finding 1).\n\n\n\n\n 10\n\x0c Schedule D\n\n Schedule of Award and Claimed Costs\n Charlotte Chapter\n July 28, 2007, through July 27, 2009\n\n Reference\nAuthorized Budget (Federal Funds) $126,163 Note 1\n\nClaimed Federal Costs $105,283 Note 2\n\nAuthorized Match Budget $ 72,630 Note 3\n\nClaimed Match Costs $118,186 Note 4\n\nQuestioned Federal Costs:\n Timesheet exceptions $ 2,939 Note 5\n National Sex Offender Search was incomplete or\n Missing 18,084 Note 6\n Total Questioned Federal Costs $ 21,023\n\nQuestioned Match Costs:\n Timesheet exceptions $ 2,068 Note 5\n National Sex Offender Search was incomplete or\n Missing 13,682 Note 6\n Total Questioned Match Costs $ 15,750\n\nQuestioned Education Award\n Timesheet exceptions $ 4,725 Note 5\n Total Questioned Education Awards $ 4,725\n\n\n\n\n 11\n\x0cNotes\n\n1. The approved budget amount represents the funding to the Charlotte Chapter in accordance\n with the grant agreement.\n\n2. Claimed costs represent the Charlotte Chapter\xe2\x80\x99s reported Federal expenditures for the\n period of July 28, 2007, through July 27, 2009.\n\n3. The approved match budget amount represents the funding to the Charlotte Chapter\n according to the grant agreement.\n\n4. Claimed costs represent the Charlotte Chapter\xe2\x80\x99s reported match expenditures for the period\n of July 28, 2007, through July 27, 2009. The match cost exceeded budget, but there is no\n exception because our testing of match costs indicated that they were supported and\n allowable.\n\n5. The Charlotte Chapter had $2,939 in questioned Federal and $1,583 in match costs for\n member living allowances, $485 in match health benefit costs, and a $4,725 education\n award due to missing supervisor or member signature(s) on the timesheets (see Finding 1).\n\n6. Charlotte had $18,084 in questioned Federal and $9,737 in match costs for member living\n allowances, and $3,945 in match health benefit costs due to incomplete or missing National\n Sex Offender Registry searches (see Finding 1).\n\n\n\n\n 12\n\x0c Schedule E\n\n Schedule of Findings\n\n\nFinding 1 - Lack of adequate procedures or internal controls to ensure that service hours\nwere accounted for, members received health benefits, health benefit expense credits\nwere properly applied to grant expenses, criminal background checks and national sex\noffender searches were performed in a timely manner and documented, and members\nreceived consistent member living allowances.\n\nTimesheet Exceptions\n\nWe tested 851 timesheets, representing 21 members at the three subgrantees, for proper\nsignatures and timely submission. The following table summarizes timesheet exceptions that\nresulted from this testing:\n\n Questioned Questioned\n Federal Match Questioned\n Member Member Match Questioned\n Living Living Health Education\n Chapter Members Notes Allowance Allowance Benefits Award\n San Francisco 2 A - - - -\n Charlotte 2 B&D 2,204 1,187 366 -\n Charlotte 3 C 735 396 119 4,725\n Chicago 1 E - - - -\n Totals 8 $2,939 $1,583 $485 $4,725\n\n A. The member\xe2\x80\x99s timesheet signature was not consistent with the member\xe2\x80\x99s signature on\n the previous timesheets; which indicates that someone else signed on behalf of the\n member. No costs are being questioned, but it is noted as a non-compliance finding.\n\n B. The members\xe2\x80\x99 names were typed-in as their signatures on the timesheets. There is no\n evidence that the members certified that they actually performed service during these\n hours, therefore, the hours recorded are questioned.\n\n C. Timesheets were missing the supervisors\xe2\x80\x99 signature. There is no evidence that the\n supervisor verified that the members actually performed service during these hours,\n therefore, the hours recorded are questioned.\n\n D. The supervisor signed the timesheets, but did not indicate the date signed. No costs are\n questioned, but it is being noted as a non-compliance finding.\n\n E. The member signed the timesheet, but did not indicate the date signed. No costs are\n questioned, but it is being noted as a non-compliance finding.\n\nSupervisors and members were not complying with the NPRC Handbook requirement related to\nthe signing and approval of members\xe2\x80\x99 timesheets. In addition, the NPRC Handbook does not\nrequire a date indicating when the member and supervisor sign the member\xe2\x80\x99s timesheet.\n\n\n\n\n 13\n\x0cCriteria:\n\nThe AmeriCorps Special Provisions (Program Year (PY) 07 \xe2\x80\x93 08, Section IV.C.2., Page 8 and\nPY 08 \xe2\x80\x93 09, Section IV.C.4., Page 9) state that the grantee must keep time and attendance\nrecords on all AmeriCorps members in order to document their eligibility for in-service and post\nservice benefits. Time and attendance records must be signed and dated both by the member\nand by an individual with oversight responsibilities for the member.\n\nThe NPRC Handbook (page 7) states, \xe2\x80\x9cA corps member supervisor verifies an AmeriCorps\nmember\xe2\x80\x99s attendance by certifying that member\xe2\x80\x99s service hour logs on a weekly basis. Certified\nservice hour logs must be signed by both the AmeriCorps member and the member\xe2\x80\x99s\nsupervisor.\xe2\x80\x9d\n\nThe ANRC member agreement (page 5) states that upon successful completion of the term of\nservice, the member may be eligible to receive an education award of $4,725. Successful\ncompletion of the term of service includes completion of at least 1,700 service hours.\n\nRecommendations:\n\nWe recommend that the Corporation:\n\n 1a. Resolve the questioned costs in the amount of $2,939 in Federal and $1,583 in match\n member living allowance, $485 in match health benefits and a $4,725 in education\n award and recover any disallowed costs.\n\n 1b. Ensure ANRC strengthens its procedures related to members\xe2\x80\x99 signatures on their\n timesheets, establishes what steps should be taken when member is not available to\n sign, and strengthens procedures to ensure timely review of all timesheets.\n\n 1c. Ensure ANRC updates the NPRC Handbook to include a requirement that members\n and supervisors enter dates when timesheets are signed.\n\nANRC Response:\n\nANRC agreed with the findings regarding the San Francisco and Chicago members. However,\nANRC disagreed with the finding that there is no evidence that the members in Charlotte\nactually performed service during the weeks in question. In all cases, ANRC indicated that the\nmembers recorded the time, recorded comments, and either the member or the supervisor\nsigned the timesheets. ANRC also stated that both the members and supervisors signed the\ntimesheets for the following time period, which included the cumulative totals. ANRC believed\nthat there was sufficient evidence that both the member and the supervisor ultimately\ndocumented that the member engaged in allowable activities for the number of hours reported\non the timesheets. ANRC also indicated that it has implemented a new electronic timekeeping\nsystem for the 2009-2010 program year that has access controls so only the member can enter\nhis or her own time. The system also contains reminder controls that inform the members when\nthey have not submitted their timesheets and informs the supervisors when they have not\napproved them.\n\n\n\n\n 14\n\x0cAuditors\xe2\x80\x99 Comments:\n\nANRC appeared to presume that the supervisor and member certified to the accuracy of the\ncumulative total of hours that was reported on the timesheets and not just for the hours reported\nfor that time period. The Corporation should determine whether the new electronic timekeeping\nsystem for the grantee and its subgrantees is implemented and effectively addresses the finding\nconditions. The Corporation should consider the corrective actions taken, but continue to\nresolve the questioned costs.\n\nHealth Benefits Not Provided to Members\n\nThe ANRC subgrantees we tested did not provide health benefits to full-time members for PY\n07 \xe2\x80\x93 08 in accordance with the grant provisions. The following exceptions were noted:\n\n \xef\x82\xb7 The San Francisco Chapter did not provide health benefits to any of its members in PY\n 07 \xe2\x80\x93 08 until November 2007, resulting in a three-month period during which members\n were not covered.\n\n \xef\x82\xb7 The Charlotte and Chicago Chapters each did not provide health benefits to one of its\n members for program year 07 \xe2\x80\x93 08, and no waiver was obtained from either member.\n The Chapters did obtain waivers from the members after the auditors completed their\n testing.\n\nThe San Francisco Chapter indicated that there was some uncertainty as to who would be\npaying the health benefits for the members (i.e., Chapter versus ANRC Headquarters). The\nCharlotte and Chicago Chapters indicated that they did not request, or they did not maintain the\nmember\xe2\x80\x99s request, to waive the health benefits.\n\nThere is a potential liability to the subgrantee for medical expenses that the members may have\nincurred during the time when health benefit coverage was not provided.\n\nCriteria:\n\nThe AmeriCorps Special Provisions, PY 07 \xe2\x80\x93 08, Section IV.I.5., Page 16, states, \xe2\x80\x9cThe grantee\nmust provide a health care policy to those full-time members not otherwise covered by a health\ncare policy at the time of enrollment into the AmeriCorps program, or to those members who\nlose coverage during their term of service as a result of participating in the Program or through\nno deliberate act of their own.\xe2\x80\x9d\n\nRecommendation:\n\n 1d. We recommend that the Corporation work with ANRC to have the subgrantees\n determine and document whether their members waived their health benefits. If no\n waiver was obtained, the subgrantees should verify whether their members incurred\n any medical expenses during the period in which health benefits were not provided,\n and take action to reimburse the appropriate expenses to those members.\n\nANRC Response:\n\nANRC agreed with the exceptions noted, but indicated that the subgrantee did provide health\nbenefits to all full-time members who wanted it. ANRC indicated that San Francisco was\n\n 15\n\x0cdelayed in enrolling members in the health insurance plan for PY 07-08, but did reimburse any\nexpenses that were submitted. In addition, San Francisco attempted, after our site visit, to\nverify if any members incurred any additional medical expenses during the time period before\ntheir health insurance was activated.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe exceptions we noted are factually correct. No statement was made that the subgrantee\ndenied a member coverage when it was requested. We noted only that coverage was not\nprovided. The Corporation should confirm that ANRC and the San Francisco Chapter have\ntaken appropriate actions to address the recommendation.\n\nHealth Benefit Credit Not Applied to Grant Expenses\n\nDuring our review of the claimed match costs from the chapter\xe2\x80\x99s accounting records, we noted\nthe Charlotte Chapter had overpaid health benefits for members who did not finish their term or\nwere terminated from the AmeriCorps program from January to February 2009. The insurance\ncompany credited the Charlotte Chapter\xe2\x80\x99s account for the overpayment, which was used to pay\nfor the health benefits for the remaining members for the rest of the PY. However, by the end of\nthe PY, there was still a credit of $128 remaining.\n\nThe Charlotte Chapter did not track the balance of that credit and reduce its reported grant\nhealth benefit expense accordingly in compliance with OMB Circular A-122. The remaining\ncredit of $128 for health benefits has left the Chapter with an overstatement in match costs for\nPY 2008 \xe2\x80\x93 2009 of $128. We noted that the subgrantee met its match cost requirements by a\nsignificant amount; therefore, it is noted as a compliance finding.\n\nCriteria:\n\nOMB Circular No. A-122, Cost Principles for Non-Profit Organizations (General Principles:\nA.5.a.), states, \xe2\x80\x9cThe term applicable credits refers to those receipts, or reduction of expenditures\nwhich operate to offset or reduce expense items that are allocable to awards as direct or indirect\ncosts. Typical examples of such transactions are: purchase discounts, rebates or allowances,\nrecoveries or indemnities on losses, insurance refunds, and adjustments of overpayments or\nerroneous charges. To the extent that such credits accruing or received by the organization\nrelate to allowable cost, they shall be credited to the Federal Government either as a cost\nreduction or cash refund, as appropriate.\xe2\x80\x9d\n\nRecommendation:\n\n 1e. We recommend that the Corporation ensure that ANRC provides guidance to the\n subgrantees on how credits are to be accounted for and reported in accordance with\n OMB Circular A-122.\n\nANRC Response:\n\nANRC concurred with the finding and indicated that it has provided the recommended guidance\nto subgrantees.\n\n\n\n\n 16\n\x0cAuditors\xe2\x80\x99 Comments:\n\nANRC\xe2\x80\x99s proposed action should address the finding condition. The Corporation should follow\nup to confirm that ANRC has provided the appropriate guidance to the subgrantees.\n\nCriminal Background Check Performed After Member Enrollment\n\nTwo ANRC subgrantees we tested did not properly complete the criminal background check\nupon member enrollment. Details are as follows:\n\n \xef\x82\xb7 In five of the seven member files tested, the San Francisco Chapter did not perform the\n criminal background check until after the member was enrolled for PY 07 \xe2\x80\x93 08. In four\n instances, the criminal background check was completed four days after enrollment and\n the last one was completed 26 days after enrollment.\n\n \xef\x82\xb7 In three of the seven member files tested, the Chicago Chapter did not perform the\n criminal background check until five months after the member was enrolled for PY 07 \xe2\x80\x93\n 08.\n\n \xef\x82\xb7 In two of the seven member files tested, the Chicago Chapter did not perform the\n criminal background checks until two to eight days after the members started serving for\n PY 08 \xe2\x80\x93 09.\n\nBoth chapters informed us that not obtaining the background checks before the members began\ntheir service was an oversight.\n\nBy not conducting criminal background checks prior to enrolling its members, the subgrantee\nplaces itself, the grantee, the Corporation, and vulnerable populations being served at risk. No\ncosts were questioned, but it is being noted as a non-compliance finding.\n\nCriteria:\n\nThe subgrantee\xe2\x80\x99s FY 2008 Host Site Agreement (PY 07 \xe2\x80\x93 08), Section IV.3.b., states the Host\nSite\'s obligations within and in addition to the AmeriCorps Grant Provisions that require\nbackground checks prior to enrolling members.\n\n45 C.F.R. 2540.200 states that the award recipient must apply suitability criteria relating to\ncriminal history to an individual applying for, or serving in, a position for which an individual\nreceives a Corporation grant-funded living allowance and which involves recurring access to\nchildren, persons age 60 and older, or individuals with disabilities. 45 C.F.R. 2540.203(a) states\nthe State criminal registry check must be conducted on an individual who enrolls in, or is hired\nby, the NPRC program after November 23, 2007.\n\n\n\n\n 17\n\x0cRecommendation:\n 1f. We recommend that the Corporation work with ANRC to provide training to its\n subgrantees to ensure that a member cannot be enrolled or start earning service hours\n until a criminal background check is completed, and that procedures are implemented\n to ensure full compliance.\nANRC Response:\nANRC concurred with the finding, but stated that guidance from the Corporation indicated that a\nmember may start supervised service before background check results have been received.\nIn its response to the draft report, ANRC included the following excerpt from the FAQ FINAL\nRULE ON NATIONAL SERVICE CRIMINAL HISTORY CHECKS, dated 10/29/07: \xe2\x80\x9cBecause\nstate criminal registry check results can sometimes take weeks or more to complete, the rule\ndoes not prohibit an individual from serving while that check is pending. However, the individual\nmay not have unsupervised access to children, persons age 60 and older, or individuals with\ndisabilities while waiting for the results of the state criminal registry check."\nAuditors\xe2\x80\x99 Comments:\nANRC appears to have acted in good faith based on the guidance provided by the Corporation.\nThat guidance allows a person to serve prior to determining their suitability to serve, which is\ncontrary to the Federal regulation. The Corporation should ensure that its guidance to grantees\nis compliant and consistent with the Federal regulations. In addition, the Corporation should\nconfirm that ANRC has provided appropriate training to the subgrantees and implemented\neffective procedures consistent with the Federal regulation to prevent a recurrence of the same\ncondition.\nIncomplete or Missing National Sex Offender Search\nIn seven of the member files we reviewed, documentation of a National Sex Offender search\nwas either missing at the Charlotte and Chicago chapters, or the searches that were performed\ndid not cover all 50 states. In the latter case, the member file indicated that the database for\ncertain states was not accessible at the time the online searches were conducted. Given the\nincomplete searches, we questioned the following living allowances, health benefits and\neducation award costs, as of November 23, 2007:\n Questioned Questioned\n Federal Match Questioned\n Member Member Match Questioned Questioned\n Sample Living Living Health Education Interest\n Member Allowance Allowance Benefits Award Forbearance Note\n Charlotte #4 $ 3,756 $ 2,022 $ 893 $ - $ - 1\n Charlotte #5 3,674 1,978 1,012 - -\n Charlotte #6 2,939 1,583 765 - - 1\n Charlotte #7 7,715 4,154 1,275 - - 1\n Subtotal $18,084 $9,737 $3,945 $ - $ -\n Chicago #5 7,647 3,940 1,267 - -\n Chicago #6 8,393 4,324 1,394 4,725 2,002\n Chicago #7 8,580 4,420 1,394 4,725 -\n Subtotal $24,620 $12,684 $4,055 $9,450 $2,002\n Totals $42,704 $22,421 $8,000 $9,450 $2,002\n\nNote 1: These costs are net of those questioned under Timesheet Exceptions (see Page 13).\n 18\n\x0cThe Charlotte Chapter indicated that it was an oversight on their part for three members for\nwhom the search was incomplete. For the one member whose search document was missing,\nthe Chapter indicated that the documentation had been misplaced. The Chicago Chapter stated\nthat it was an oversight in the cases of the three incomplete searches. Both Chapters went\nonline and obtained the missing National Sex Offender search information for each member and\nprovided this information to the auditors after testing was completed.\nCriteria:\n45 C.F.R. 2540.203(b) states that the National Sex Offender Public Registry check must be\nconducted on an individual who is serving, or applies to serve, in a covered position on or after\nNovember 23, 2007. 45 C.F.R. 2540.201 states that any individual who is registered, or\nrequired to be registered, on a State sex offender registry is deemed unsuitable for, and may\nnot serve in, a position covered by suitability criteria.\nRecommendations:\nWe recommend that the Corporation:\n 1g. Ensure ANRC enhances its NPRC Handbook to stress that National Sex Offender\n Searches must be complete to include follow-up for non-reporting States.\n 1h. Ensure that ANRC strengthens its monitoring efforts to ascertain subgrantees\xe2\x80\x99\n compliance with grantee\xe2\x80\x99s \xe2\x80\x9cBackground Checks\xe2\x80\x9d procedures requiring certification that:\n 1) State criminal registry checks were conducted and documented in the member files\n or in separate files that protect each member\xe2\x80\x99s privacy; and\n 2) National Sex Offender searches encompassing all 50 states, as well as Guam,\n Puerto Rico, and the District of Columbia, were conducted and documented in the\n member\xe2\x80\x99s file or a privately maintained file.\n 1i. Resolve the questioned costs in the amounts of $42,704 in Federal and $22,421 in\n matched member living allowances, $8,000 in matched health benefits, $9,450 in\n education awards, and $2,002 in interest forbearance, and recover any disallowed\n costs.\nANRC Response:\n\nANRC concurred with the finding, but did not agree with the questioned costs. It indicated that\nadditional information has been discovered since the time of the audit that confirms that ANRC\nimplemented procedures according to the prevailing Corporation guidance as follows:\n\nExcerpt from FAQ FINAL RULE ON NATIONAL SERVICE CRIMINAL HISTORY CHECKS,\n10/29/07, states,"4.12 What steps should I take if I discover that several States\' sex offender\nregistry sites are inoperative when I am conducting the NSOPR check on an applicant? You\nmust document in writing that you conducted the search and further indicate the States whose\nsites were inoperative. If any of these States is either the State in which your program is\noperating or one where the applicant resides, you must continue the search in order to ensure\nthat the applicant is not listed on those States\' registries. If the inoperative sites include other\nStates, merely document the names of these States for the file, as this would satisfy the rule\'s\nrequirement. However, as a best practice, it would be prudent to re-check the NSOPR at a later\ndate in order to rule out the possibility that the applicant may be registered in that State. "\n\n\n 19\n\x0cANRC indicated that it made a good faith effort to follow the guidance from the Corporation.\nANRC also re-ran the checks on all members in question during our testing and in all cases they\nwere cleared and eligible to serve.\nAuditors\xe2\x80\x99 Comments:\nThe Corporation should verify that ANRC has revised its NPRC handbook and strengthened its\nmonitoring efforts to ensure that National Sex Offender Public Registry searches are conducted\nin accordance with Federal regulations. Given the guidance provided by the Corporation to\nANRC, we believe that recommendation 1.i. should be revised to state, \xe2\x80\x9cRevise Corporation\nguidance for grantees on National Service Criminal History Checks to fully comply with the\nFederal regulation for a National Sex Offender Public Registry check.\xe2\x80\x9d A national check does\nnot mean only some states, but all states.\nUnequal Payment of Living Allowance to Members\nTwo of the ANRC subgrantees provided unequal member living allowance payments. The\nfollowing table summarizes the Charlotte and Chicago Chapters questioned member living\nallowances (MLA):\n\n MLA that\n should\n Program MLA have been Overpaid/ Federal Match\n Year Chapter Member Paid paid (Underpaid) Amount Amount\n 07 \xe2\x80\x93 08 Chicago #1 $ 4,622 $ 4,522 $100 $ 72 $28\n 07 \xe2\x80\x93 08 Chicago #4 12,711 12,435 276 199 77\n Total 07-08 $17,333 $16,957 $376 $271 $105\n\n 08 \xe2\x80\x93 09 Charlotte #4 $ 6,910 $ 7,348 ($ 438) ($ 285) ($153)\n 08 \xe2\x80\x93 09 Charlotte #6 7,122 7,348 (226) (147) (79)\n 08 \xe2\x80\x93 09 Chicago #5 11,587 11,870 (283) (187) (96)\n 08 \xe2\x80\x93 09 Chicago #6 12,717 13,000 (283) (187) (96)\n Total 08-09 $38,336 $39,566 ($1,230) ($806) ($424)\n\n Total Difference ($854) ($535) ($319)\n\nCriteria:\nThe AmeriCorps Special Provisions (PY 07 \xe2\x80\x93 08, Section IV.I.1., Page 15 and PY 08 \xe2\x80\x93 09\nSection IV. F.1., Page 11) state,\n A living allowance is not a wage. Programs must not pay a living allowance on\n an hourly basis. Programs should pay the living allowance in regular increments,\n such as weekly or bi-weekly, paying an increased increment only on the basis of\n increased living expenses such as food, housing, or transportation. Payments\n should not fluctuate based on the number of hours served in a particular time\n period, and must cease when a member concludes a term of service.\n If a member serves 1700 hours but is permitted to conclude a term of service\n before the originally agreed upon date, the program may not provide a \xe2\x80\x9clump\n sum\xe2\x80\x9d payment to the member. Similarly, if a member enrolls after the program\xe2\x80\x99s\n start date, the program must provide regular living allowance payments from the\n member\xe2\x80\x99s start date and may not increase the member\xe2\x80\x99s living allowance\n incremental payment or provide a lump sum to \xe2\x80\x9cmake up\xe2\x80\x9d any missed payments.\n\n 20\n\x0cThe ANRC member agreement (Section V B.1 and B.1.c.) states that the member will receive a\nliving allowance of up to $13,000 and this is based on a complete term of service. The living\nallowance will be distributed biweekly. The gross pay period amount will be approximately\n$565.\n\nThe ANRC member agreement (Section VIII.E.) states that if any member discontinues the term\nof service for any reason other than an approved compelling personal circumstance, the\nmember will cease to receive program benefits and will receive no portion of the education\naward.\n\nRecommendations:\n\nWe recommend that the Corporation take the following actions:\n\n 1j. Direct the Charlotte Chapter to make payments to the appropriate members to address\n the underpayments of $432 in Federal and $232 in matched living allowance.\n\n 1k. Direct the Chicago Chapter to make payments to the appropriate members to address\n the underpayments of $374 in Federal and $192 in matched living allowance.\n\n 1l. Resolve questioned costs in the amount of $271 in Federal and $105 in matched\n member living allowance, and recover any disallowed costs.\n\n 1m. Direct the grantee to develop more effective policies and procedures to ensure\n member living allowance payments are consistent with the AmeriCorps grant\n provisions and the ANRC member agreement. In addition, the grantee should\n strengthen its monitoring efforts, including a review of subgrantees\xe2\x80\x99 member living\n allowance payments, to ensure that allowances are paid consistently.\n\nANRC Response:\n\nANRC indicated that the Charlotte Chapter administered the payments according to program\npolicy. The Chicago Chapter indicated that its members were paid the correct amounts, but\noffered no further explanation to dispute the finding or clarify its response.\n\nAuditors\xe2\x80\x99 Comments:\n\nWe believe that the member living allowance should be consistent with grant provisions and the\nmember agreements. The Corporation should ensure that ANRC and the subgrantees address\nthe underpayments made to the members. The Corporation also should resolve the questioned\nFederal and match member living allowance costs and recover any disallowed costs. In\naddition, the Corporation should consider revising the grant provisions related to member living\nallowance to provide clearer guidance to the grantees.\n\n\nFinding 2 \xe2\x80\x93 Late submission of the exit/end-of-term-of-service form.\n\nThe ANRC Charlotte Chapter did not submit the approved Exit/End-of-Term-of-Service form in\nWBRS by the due date. Management at the ANRC headquarters indicated that it was an\noversight. Not entering member exit forms within 30 days (now into the My AmeriCorps Portal)\nmay result in sanctions to the grantee, up to and including suspension or termination.\n\n 21\n\x0cCriteria:\n\nThe AmeriCorps Special Provisions (PY 08 \xe2\x80\x93 09, Section IV.C.1., Page 8) indicate that the\ngrantee must notify the Corporation\xe2\x80\x99s National Service Trust within 30 days of a member\xe2\x80\x99s\nselection for, completion of, suspension from, or release from, a term of service.\n\nRecommendation:\n\n 2 We recommend that the Corporation ensure that ANRC implements effective control\n procedures for its subgrantees so that member forms (i.e., enrollment, change in status,\n or exit) are submitted on time through the My AmeriCorps Portal.\n\nANRC Response:\n\nANRC concurred with the finding. It has added a monitoring step to address the cause of the\nfinding.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe Corporation should verify that ANRC\xe2\x80\x99s monitoring step has been implemented and is\neffective in preventing a recurrence of the finding.\n\n\nFinding 3 \xe2\x80\x93 Lack of documentation of members attending pre-service orientation.\n\nFor all 21 members tested, the ANRC subgrantees did not provide documentation that their\nmembers received a pre-service orientation that addressed specific issues required by the grant\nprovisions. However, there was evidence that the members did receive the member agreement\nand a handbook that covers those requirements.\n\nThe lack of documentation is due to the chapters not realizing that they needed to maintain\ndocumentation to support that specific orientation requirements were addressed and that the\nmembers were present during the sessions. The Chapters plan to implement an orientation\nsign-in sheet to document when the orientation occurs, what it addresses, and who attends.\n\nCriteria:\n\nThe AmeriCorps Special Provisions (PY 07 \xe2\x80\x93 08, Section IV.D.3., Page 10 and PY 08 \xe2\x80\x93 09,\nreferring to the Policy FAQ entitled Orientation) state, "The grantee must conduct an orientation\nfor members and comply with any pre-service orientation or training required by the\nCorporation. This orientation should be designed to enhance member security and sensitivity to\nthe community. Orientation should cover member rights and responsibilities, including the\nprogram\'s code of conduct, prohibited activities (including those specified in the regulations),\nrequirements under the Drug-Free Workplace Act (41 U.S.C. 701 et seq.), suspension and\ntermination from service, grievance procedures, sexual harassment, other non-discrimination\nissues, and other topics as necessary."\n\nRecommendations:\n\nWe recommend that the Corporation:\n\n 22\n\x0c 3a. Ensure that ANRC establishes a pre-service orientation process that specifically\n addresses all requirements noted in the grant provisions, and establishes\n requirements to document when the orientation occurred, what was covered, and to\n verify that members were present.\n\n 3b. Include a requirement for an orientation sign-in sheet that addresses the orientation\n requirements in the grant provisions and in the grantee handbook to provide guidance\n for future grantees.\n\nANRC Response:\n\nANRC agreed with the finding and indicated that it has amended its procedures to incorporate\nthe recommendation.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe Corporation should verify that the proposed procedures have been implemented and are\noperating effectively. In addition, the Corporation should consider updating its grant provisions\nand the grantee handbook to clarify its pre-service orientation requirements.\n\n\nFinding 4 \xe2\x80\x93 Noncompliance with record retention requirements, late submission of\nFinancial Status Report, and noncompliance with travel policy.\n\nNoncompliance with Record Retention Policy\n\nANRC Headquarters\xe2\x80\x99 Records Management Policy indicates that documents related to grants\nare to be maintained for five years from date of the grant. The Chapters comply with the\nCorporation\xe2\x80\x99s grant provisions, which require records to be retained for three years from the\ndate of the submission of the final expenditure report. The difference in policy was due to an\noversight by ANRC management.\n\nThe purpose of the record retention policy is to ensure the grant costs can be supported by the\norganization and are available for review or audit. A policy that is inconsistent with the\nCorporation\xe2\x80\x99s provisions may result in the grantee having difficulties in obtaining documentation\nto support grant costs when required.\n\nCriteria:\n\nThe AmeriCorps General Provisions (PY 07 \xe2\x80\x93 08, Section V.E., Page 26 and PY 08 \xe2\x80\x93 09\nreferring to CFR 45\xc2\xa72543.53 (b.)) indicate that the grantee must retain and make available all\nfinancial records, supporting documentation, statistical records, evaluation and program\nperformance data, member information and personnel records, for three years from the date of\nthe submission of the final expenditure report.\n\nRecommendation:\n\n 4a. We recommend that the Corporation instruct ANRC to revise its Records Management\n Policy to comply with record retention requirements in the grant provisions.\n\n\n 23\n\x0cANRC Response:\n\nANRC concurred with the finding.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe Corporation should verify that ANRC has revised its Records Management Policy to\naddress the finding condition.\n\nLate Submission of Financial Status Report\n\nIn two instances, ANRC did not submit its Financial Status Reports on time (i.e., one and two\ndays late). ANRC indicated that the late submission of the FSRs was due to delays in collecting\ninformation from the chapters, which prevented it from submitting the reports when due.\n\nBy submitting the FSR (now the Federal Financial Report) after the deadline, the grantee may\ndelay the reimbursement of the semi-annual grant costs, which could have an adverse effect on\nthe grantee\xe2\x80\x99s ability to operate its program.\n\nCriteria:\n\nThe AmeriCorps Special Provisions (PY 07 \xe2\x80\x93 08, Section IV.N.1.a., Page 22) states a grantee\nshall submit semi-annual cumulative financial status reports, summarizing expenditures during\nthe reporting period using eGrants. Financial Status Report deadlines are as follows:\n\n Due Date Reporting Period Covered\n April 30 Start of grant through March 31\n October 31 April 1 \xe2\x80\x93 September 30\n\nRecommendation:\n\n 4b. We recommend that the Corporation ensure that ANRC develops effective control\n procedures to ensure that it submits its Federal Financial Report when it is due.\n\nANRC Response:\n\nANRC agreed with the finding, and indicated that it has amended its procedures to address the\nrecommendation.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe Corporation should verify that ANRC has amended its procedures to address the finding\ncondition.\n\nNoncompliance with Travel Policy\n\nIn testing one travel expense, we found that the traveling employee returned a rental car without\nrefueling the vehicle.\n\n\n\n\n 24\n\x0cThe purpose of the ANRC Travel policy is \xe2\x80\x9cto ensure the most appropriate and economical use\nof Red Cross funds when traveling on behalf of Red Cross.\xe2\x80\x9d The refueling service charge was\n$37.84. As a result, ANRC incurred additional cost that could have been avoided.\n\nCriteria:\n\nANRC\xe2\x80\x99s Staff Travel and Reimbursement Policy (II.G.2.b.) states that, \xe2\x80\x9cCar companies charge a\npremium to refill partially or empty gas tanks. To avoid excess fees, travelers are required to\nrefuel at local gas stations prior to returning the rental vehicle.\xe2\x80\x9d\n\nRecommendation:\n\n4c. We recommend that the Corporation work with ANRC to strengthen its controls for\n compliance with its travel policy.\n\nANRC Response:\n\nANRC concurred with the finding, and indicated that it has ensured that current NPRC program\nstaff have reviewed the travel policy.\n\nAuditors\xe2\x80\x99 Comments:\n\nThe Corporation should verify that the corrective actions taken by ANRC are sufficient to\naddress the finding condition.\n\n\nFinding 5 - Lack of controls over reporting of Federal costs.\n\nFederal Cost Claimed In Excess of Award Amount\n\nWe compared the Federal award budget amount to the actual cost claimed for PYs 07 \xe2\x80\x93 08 and\n08 \xe2\x80\x93 09 and found that the San Francisco Chapter exceeded the Federal award budget for\nmember living allowance for PY 07 \xe2\x80\x93 08 by $187, as follows:\n\n Program Year 2007 \xe2\x80\x93 2008\n Federal Award Federal Costs Balance\n Amount Claimed\n $84,053 $84,240 ($187)\n\nNo amendments have been made to the award agreement. ANRC management stated an error\nwas made when the subgrantee\xe2\x80\x99s budget was calculated. Given that the grantee was still well\nbelow its total budget award from the Corporation, we did not question the amount.\n\nCriteria:\n\nThe AmeriCorps National Preparedness & Response Corps FY 2008 Host Site Cooperative\nAgreement (dated August 2, 2007), for the San Francisco Chapter states that the Corporation\nfunding for the chapter will be $84,053.\n\n\n\n\n 25\n\x0cRecommendation:\n\n 5. We recommend that the Corporation instruct ANRC to strengthen its controls and\n monitoring procedures to ensure that its subgrantees do not claim expenses in excess\n of their award amount.\n\nANRC Response:\n\nANRC concurred with the finding. It indicated that it has changed the methodology for creating\nthe budget in the Host Site Agreements, which should eliminate the rounding errors in\ncalculating the host site budget.\n\nAuditors\xe2\x80\x99 Comments:\n\nANRC has taken action to address the budget calculation process that resulted in understating\nthe budget. However, this action does not strengthen the control to ensure that expenses will\nnot exceed the award amount. The Corporation should work with ANRC to ensure that such\ncontrols are in place so that the claimed amount exceeding the award amount will not be paid.\n\n\n\n\n 26\n\x0c APPENDIX A\n_______________________________________________________________\n AMERICAN NATIONAL RED CROSS\xe2\x80\x99\n RESPONSE TO THE DRAFT REPORT\n\x0c American Red Cros s\n\n\n\n\n+\n A meriCorps"Nati onal Preparedne ss and Respons e Corps\n American Chap ter Operations\n Washington, D.C. 20006\n Red Cross (202) 303-5813\n\n\n\n\nTO: Stuart Axenfeld\n Assistant Inspector General for Audit\n Corporation for National and Community Service\n\nDraft Audit Report Review and Comment\nAgreed Upon Procedures Review of Corporation Grants\nAmerican National Red Cross\nSubmitted: April 23, 2010\n\nPrepared By:\n\nJt::;yP~\nDirector Chapter Quality Assurance and NPRC AmeriCorps Program Director\n\n \'171;< (/;1:/ IJ\nMeghJr: McG~d~ic~~h\nNPRC AmeriCorps Senior Associate and Program Manager\n\n\nFinding 1: Lack of adequate procedures or internal controls to ensure service hours\nwere accounted for, members received health benefits, health expense credits were\nproperly applied to grant expenses, criminal background checks and national sex\noffender registry searches were properly performed in a timely manner and\ndocumented and members received consistent living allowances.\n\nResponse to Finding 1:\n\nI. Timesheet Exceptions; We agree with the findings regarding the San Francisco and\n Chicago members and implemented a new electronic timekeeping system in the\n 2009-2010 program year which eliminates these issues. The system has automatic\n controls that only the member has access to record and approve their own time and\n the date of all approvals are automatically time stamped. In light of additional review\n of the timesheets, we respectfully disagree with the finding that there is no evidence\n that the members in Charlotte actually performed service during the weeks in\n question . In all cases the members recorded the time, recorded comments and either\n the member or the supervisor signed the timesheets for the weeks in question , and\n both the members and supervisors signed the time sheets for the following time period\n which included the cumulative totals. While the chapter did not comply with the\n specific instructions provided, there is evidence that both the member and the\n supervi sor ultimately documented agreement that the member engaged in allowable\n activities for the number of hours indicated. Since the time in question we have\n implemented an on-line timekeeping system which addresses the recommendations\n made by the OIG.\n\x0c American Red Cross\n\n\n\n\n+\n AmeriCorps"Nationa l Preparedness and Response Corps\n American Chapl er Operations\n Washington, D.C. 20006\n Red Cross (202) 303-58 13\n\n\n\n\n2. Health Benefits; We disagree with the finding that we did not provide health benefits\n to all full time members who wanted it. We do agree with the exceptions noted. San\n Francisco was delayed in enrolling members in the health insurance plan in 07-08 but\n did reimburse any expenses that were submitted. Per the auditor\'s recommendation,\n San Francisco has attempted to verify if members incurred any additional medical\n expenses during the time period before their health insurance was activated. For the\n other two chapters, the members declined coverage, but the chapter did not have a file\n copy of the signed waiver. We have since obtained and submitted waivers for all\n members in question from Chicago and Charlotte.\n\n3. Health Benefit Not Applied to Grant Expenses; We agree with the finding and have\n provided the recommended guidance to subgrantees.\n\n4. Criminal Background Check Performed After Member Enrollment; We agree with\n the finding but would like to point out that per guidance from the Corporation,\n members may start supervised service before background checks results are received.\n Our policy is that the member\' s service is contingent upon successful completion of\n the Criminal Background Check and we have revised our procedures to further\n emphasize that checks must be initiated before members begin service.\n\n5. Incomplete Or Missing National Sex Offender Search; We agree with the finding but\n do not agree with the questioned costs. We made a good faith effort to follow the\n guidance from the Corporation. Our procedures instruct subgrantees to complete\n these checks before members start and sign off in the enrollment paperwork that the\n checks are clear for each member. Training was also provided when the new rules\n went into effect. These oversights where checks were not rerun when some state\n databases were down were not intentional or due to lack of training but were human\n error. Additional information has come to light since the time of the audit which\n confirms that the Red Cross implemented the procedure at the time according to the\n prevailing guidance for how to handle checks when some state databases are down.\n We reran the checks on all members in question during the audit and in all cases they\n were clear and eligible to serve. We have amended our existing training for "How to\n Conduct NSOPR Checks" to highlight the minimum requirements, best practices\n expectations, and documentation requirements.\n\n6. Unequal Payments of Living Allowance To Members; We do not agree with the\n finding.\n\n Recommendations:\n\n lao Resolve questioned costs\n\n We disagree that there is no evidence of the member having served during the time in\n question. Regarding the member timesheets in Charlotte for which there are\n questioned costs, the time was logged for the time period in question and was signed\n\n\n 2\n\x0c American Red Cross\n AmeriCorps\'Nalional Preparedness and Response Corps\n\n\n\n\n+ American\n Red Cross\n Chapter Operations\n Washington, D.C, 20006\n (202) 303-5813\n\n\n\n\nby either the member or the supervisor. Member comments were included in the\nreflections section as well. In addition, the timesheets for the time period following\nthose periods included a cumulative total and was signed by both the member and the\nsupervisor. In the cases where the education award is questioned , the total cumulative\ntime was also signed off on by both the member and the supervisor on the final time\nlog of the term and equaled sufficient time to qualify for the Education Award. Our\nmember timesheet are set up to automatically roll forward the cumulative total hours\nas well as the cumulative subtotals for service, fund raising and training hours.\n\n A TT l: Sample time sheet\n\nlb. Ensure ARC strengthens its procedures related to members signatures on\ntheir timesheets, establishes steps that should be taken when member not\navailable to sign and strengthens procedures to ensure timely review of all\ntimesheets.\n\n a. Evidence addressed\n\n The Red Cross implemented the OnCorps electronic timekeeping system which\n addresses this finding during the 2009-20 10 program year. The system is Internet\n accessible which eliminates delays due to not being physically present when time\n sheets are due and has controls built in for reminders when time has not been\n approved by either the member or the supervisor. Included is a role for the Host\n Site Manager to oversee the process and ensure timely review. We recently\n amended our OnCorps procedures to include instructions for what to do in the\n event the member or the supervi sor is not available per the auditor\'s\n recommendation ..\n\n b. Procedure/Training\n\n Each chapter was oriented individually to the timekeeping system roles and\n functionality when implementing the system last fall and adding their members\n and supervisors. A training tutorial is also available for users and the system is\n fully operational.\n\n The following procedures were created and distributed as part of the above\n process and are posted for ongoing access. Both have been revised to include the\n instructions on what to do in the unlikely event that the member or supervisor is\n not available.\n\n ATT 2: OnCorps Time Keeping Procedures\n ATT 3: OnCorps Time Log Roles\n\n The revised procedures were distributed and reviewed as part of the "NPRC\n Compliance Review" for Host Site Managers conducted April 21 , 2010.\n\n\n 3\n\x0c American Red Cross\n\n\n\n\n+\n AmeriCorps\xc2\xb7National Prep aredness and Re sponse Corps\n American Chapter Operations\n Washington, D.C. 20006\n Red Cross (202) 303-5813\n\n\n\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Overview"\n A TT 6: "NP RC Compliance Overview" presentation\n\n Ie. Ensure ARC updates the NPRC handbook to include a requirement that\n members and supervisors enter dates when timesheets are signed.\n\n a. Evidence addressed\n\n This recommendation is no longer applicable as the On Corps timekeeping system\n automatically records the date the time log was approved by both the member and\n the supervisor.\n\n b. Training/Procedure - N/A\n\n c. Proof of implementation - See I b\n\n\n Id. Document and determine if waived health care benefit - or verify\n whether member had any outstanding expenses.\n\n a. Evidence addressed\n\n San Francisco has attempted to verify if members incurred any additional medical\n expenses during the time period before their health insurance was activated,\n however the members have not responded. They did however, reimburse one\n member who submitted expenses at the time and we have no reason to believe\n that others would not have done the same. For the other two chapters, the\n members declined coverage and we have since obtained and submitted waivers\n for all members in question from Chicago and Charlotte.\n\n ATT 7: San Francisco follow-up letter\n\n b. Training/Procedure\n\n The existing procedures include thi s requirement and chapters attest to obtaining\n the waiver. However, we modified the start up procedures to include the potential\n consequences of not maintaining this information on file. We also included a\n reminder in our "NPR C Compliance Overview" distributed April 21.\n\n ATT 8: FY IO Stmi Up Procedures\n ATT 6: Slide #8 "NPRC Compliance Review "\n\n\n\n 4\n\x0c American Red Cross\n\n\n\n\n+\n AmeriCorps"National Preparedn ess and Response Corps\n American Chapter Operations\n Wash ington, D.C. 20006\n Red Cross (202) 303-5813\n\n\n\n\n c. Proof of implementation -\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Overview"\n\n Ie. Give guidance to subgrantees on how credits are to be accounted for and\n reported in accordance with OMB circular -133.\n\n a. Evidence addressed - N/A\n\n b. Training/Procedure\n\n We revised our SOP on Financial Monitoring to reference this information\n and included information on the NPRC Compliance Review issued April 21,\n 2010.\n\n ATT 7: Revised SOP Financial Monitoring\n ATT 8: Slide # 13 in NPRC Compliance Overview\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Review "\n\n If. Provide training to subgrantees to ensure member cannot be enrolled or\n start earning service hours until background check complete and procedures\n implemented to ensure full compliance.\n\n a. Evidence addressed\n\n Red Cross program procedures require completion of a State Criminal Hi story\n Background Check and attestation by the host site that the checks were completed\n and cleared. Per guidance from the Corporation, a member may begin service\n while awaiting results of a State Criminal Background Check, however may not\n have unsupervised access to vulnerable populations. Red Cross policy is\n consistent with thi s guidance.\n\n Excerpt from FAQ FINAL RULE ON NATIONAL SERVICE CRIMINAL\n HISTORY CHECKS, 10/29/07\n\n UBecause state criminal registry checks results can sometimes take weeks or more to\n complete, the rule does not prohibit an individual from serving while that check is\n pending However, the individual may not have unsupervised access to children, persons\n age 60 and older, or individuals with disabilities while waitingfor the results of the state\n criminal registry check. "\n\n\n\n 5\n\x0c American Red Cross\n AmeriCorps"National Prepa redness and Response Corps\n\n\n\n\n+ American\n RedCroH\n Chapter Operations\n Washington, D.C. 20006\n (202 ) 303-5813\n\n\n\n\n This was also included in the Corporation\'s initial training materials on the new\n rule and affirmed in the recently updated FAQ\'s.\n\n b. Training/Procedure\n\n The Corporation\'s materials were used in the establishment of the Red Cross\n policy and provision of training to introduce the Criminal Background Check\n requirement when the rule went into effect. Additionally, FYI1 Start Up\n procedures were revi sed to further emphasize the policy, the FY11 Enrollment\n Attestation Form was rearranged to draw greater attention to timing of the check,\n and requirements were reviewed in the "NPRC Compliance Review ", distributed\n April 21, 2010.\n\n ATT 9: Slide #14, Host Chapter Web Conference, November 14, 2007\n ATTIO: FYI1 Start Up Procedures\n ATT 11: FY II Enrollment Attestation form\n ATT 6: Slide #8 "NPRC Compliance Review "\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Review "\n\n\n Ig. Enhance NPRC handbook to stress that Sex Offender Registry Searches\n must be complete to include non reporting states.\n\n a. Evidence addressed\n\n Excerpt from FAQ FINAL RULE ON NATIONAL SERVICE CRIMINAL\n HISTORY CHECKS, 10/29/07\n "4.12 What steps should 1 take if 1 discover that several Sllltes \' sex offender registry\n sites are inoperative when 1 a11l conducting the NSOPR check on an applicant?\n You must document in writing that you conducted the search and further indicate the\n States whose sites were inoperative. If any of these States is either the Slllte in which your\n program is operating or one where the applicant resides, you must continue the search ill\n order to ensure that the applicant is not listed on those States\' registries. If the\n inoperative sites include other States, merely document the names of these States jor the\n jile, as this would satisfy the rule\'s requirement. However, as a best practice, i/ would be\n prudent to re-check the NSOPR at a later date in order to rule out the possibility that the\n applicallt may be registered in that State. "\n\n This was further clarified in recent FAQ update.\n\n\n\n\n 6\n\x0c American Red Cfoss\n\n\n\n\n+\n AmeriCorps"Nauonal Preparedness and Respon se Corps\n American Chapter Opera ti ons\n washington, D.C. 20006\n Red Cross (202) 303-5813\n\n\n\n\n FAQ FINAL RULE ON NATIONAL SERVICE CRIMINAL HISTORY CHECKS,\n April 15, 2010\n\n\n b. Training/Procedure\n\n ATT 6: Slide #8 "NP RC Compliance Review "\n A TT 11: FY 11 Enrollment Attestation form\n ATT 12: How to Conduct a NSOPR Check - presentation\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Overview"\n\n\nIh. Ensure monitoring efforts to ascertain subgrantees compliance with background\nchecks procedures requiring certification that:\n o State Criminal registry checks were conducted and documented in the members\n files\n o Sex Offender Registry Checks encompassing all 50 states, as well as Guam,\n Puerto Rico and the District of Columbia, were conducted and documented in the\n members files\n\n a. Evidence addressed - N/A\n\n b. Training/Procedure\n\n Monitoring is accomplished through the Enrollment Attestation Fonn completed\n for each member and member file checks during site visits. The FY 11 attestation\n form was rearranged to further emphasize timing for completion of both checks\n and was revised to define what a complete NSOPR Check involves.\n\n ATTll: FYl1 Enrollment Attestation Form\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n\nIi. Resolve questioned costs\n\n We disagree that there are questioned costs as we made good faith effort to meet\n the requirements. We have provided evidence that all questioned checks have\n been rerun and all were clear, indicating that all members were eligible (were not\n required to register as a Sex Offender). In addition, we implemented the checks\n\n\n 7\n\x0c American Red Cross\n\n\n\n\n+\n AmeriCorps "Na!ional Preparedness and Response Corps\n American ChClpler Operations\n Washington, D.C , 20006\n Red Cross (202) 303-5813\n\n\n\n\n according to the Corporation guidance that checks need not be rerun to meet the\n rule.\n\n1j. Direct Charlotte Chapter to make payments to members to address\nunderpaymen ts\n\n We disagree with the finding. The chapter administered the payments according\n to program policy. We will revise the member agreement for next program year to\n clarify how living allowance payments will be handled for early exit.\n\n ATT 13: Email fi\'om Corporation\n\n\n\n 1k. Direct Chicago chapter to make payments to address underpayments\n\n We disagree with the finding. Members were paid correct amounts.\n\n ATT 13: Email from Corporation\n\n\n 11. Resolve questioned costs of $271 - Chicago overpayment\n\n We disagree with the finding members were paid correct amounts.\n\n ATT 14: Spreadsheet from Chicago\n\n\n 1m. Develop more effective polices and procedures to ensure payments are\n consistent with grant provisions and the member agreement. Strengthen\n monitoring efforts, including review of member living allowance payments.\n\n a. Evidence addressed\n\n b. Training/Procedure\n\n Procedures were modified this program year to include an initi al review the\n member living allowance increments reflected in the first month \' s Program\n Expense Reports received from chapters. Ifthere were discrepancies in what they\n were expected to be, follow up was done with the chapter. This procedure will be\n continued next year. Member agreements will be modified in the next program\n year to address how the living allowance for the last pay period will be\n administered if the member leaves early.\n\n c. Proof of implementation\n\n\n 8\n\x0c American Red 0055\n Am eriCorps"National Preparedness and Response Corps\n\n\n\n\n+ American\n Red Cross\n Chapter Operation s\n W ashington, D.C. 20006\n (202) 303-5813\n\n\n\n\n ATT 15 FY 10 Living Allowance Distribution Tracking Tool\n\nFinding 2: Late submission of exit/end of term service form\n\n Response to Finding 2 We agree with the finding but would like to note that our\n current procedures and accountabilities resulted in all but one member tested\n being exited on time and require only minor adjustment to reduce the risk of this\n recurring. We have updated our procedures to include an additional monitoring\n step.\n\n\n Recommendation 2: Implement effective control procedures so that member\n forms are properly submitted on time (enrollment, change of status, exit).\n\n a. Evidence addressed\n b. Training/Procedure\n\n We already have start up and exit procedures which were provided during the\n course of the audit. A monitoring step was added to the Closeout Timeline to\n address the cause of the finding. We also included the timely enrollment and exit\n in the "NPRC Compliance Review distributed Apri l 21 , 2010\n\n ATT 16: Closeout Timeline Revised April 21, 2010\n\n c. Proof of implementation\n\n ATT 4: Screen Shot ofNPRC AmeriColps website procedures listing\n\nFinding 3 - Lack of documentation of members attending pre-service orientation\n\n Response to Finding: We agree with the finding and have amended our\n procedures to incorporate the recommendation.\n\n Recommendations:\n\n 3a. Ensure pre-service orientation process that specifically addresses all\n requirements noted in the grant provisions and establishes requirements to\n document when the orientation occurred, what was covered and verify\n members present.\n\n a. Evidence addressed\n\n FY I 0 Start up Procedures include the requirement for the provision of an\n orientation and the Guidelines for Chapter Orientation of Members includes a list\n\n\n 9\n\x0c American Red Cross\n Ame riCorps "Nation al Prep aredness and Response Corps\n\n\n\n\n+ American\n Red Cross\n Chapter Operations\n Washington. D ,C. 20006\n (202) 303-5813\n\n\n\n\n of required topics and a presentation which covered all required topics was added\n in the 2009-2010 program year for use during the orientation process. For the\n years included in the audit as well as the current year, th e member handbook that\n includes the required informati on was also provided as part of the orientation\n process and a signed receipt is required which was in the member files. As part of\n the monitoring plan, chapters attested to the provision of the handbook and the\n collection of the receipt on the Member Enrollment Attestation Form.\n\n ATTl7: Required Information presentation\n ATT 8 : Start up procedures FY 10\n\n b. Training/Procedure\n\n Clarification was included in the "NPR C Compliance Review" as to the\n expectation for documentation that the orientation occurred, what was covered\n and verification that members were present and the FY11 Start Up Procedures\n have been amended to reflect thi s requirement.\n\n c. Proof of implementation\n ATT 4: Screen Shot ofNPRC AmeriCorps website procedures listing\n ATT 5: Email distribution of "NPRC Compliance Review "\n\n\n ATTl7: Required Information presentation\n ATT : Start up procedures FY I 0\n\n\n\nFinding 4-\n \xe2\x80\xa2 Non compliance with record retention requirements,\n \xe2\x80\xa2 Late submission of FSR and\n \xe2\x80\xa2 Non compliance with travel policy.\n\n Response to Finding 4\n I. Non Compliance with Record Retention Requirements; We agree with the\n finding. However the correct date for retention of the grant records for the\n 2009-2010 program year was reflected in the Host Site Agreements signed at\n the beginning of the program year to provide clarity on retention expectations.\n In addition we have implemented the recommendation.\n 2. Late Submission of Financial Status Report; We agree with the finding but\n would like to note that the reports in questions were late by one and two days\n and controls put into place since 2008 have resulted in subsequent FSRs being\n submitted on time. We have updated our procedures per the recommendation.\n 3. Noncompliance with Travel Policy; We agree with the finding and have\n ensured that current NPRC program staff have reviewed the policy.\n\n\n 10\n\x0c Ameri ca n Red 0055\n\n\n\n\n+\n AmeriCorps\' Nation a l Preparedness and Response Corps\n American Chapter Opera tion s\n Wash ington, D.C. 20006\n Red Cross (202) 303-5813\n\n\n\n\n Recommendations:\n\n 4a. Revise Record Management Policy to comply with record retention\n requirements in the grant provisions.\n\n a. Evidence addressed\n b. Training/Procedure\n\n The Supplement to the Records Management Policy has been updated to reflect\n the grant requirements. The infonnation was included in the NPRC Compliance\n Review distributed April 21 , 2010 and posted for future reference.\n\n c. Proof of implementation\n\n ATT 18: Revised Supplement to the Record Retention Policy, Rev 04 21 10\n ATT 6: Slide # 14 "NPRC Compliance Review "\n\n4b. Develop effective internal control procedure to ensure that it submits its Federal\nFinancial Report when it is due.\n\n a. Evidence addressed\n b. Training/Procedure\n\n The timeline and steps for on time submission ofthe FSR are reflected in the\n AmeriCorps FSR Reconciliation Policy promUlgated by the Shared Service\n Center - Restricted Funds Unit (SSC-RF) last updated in July 2008 and provided\n during the audit. The NPRC Financial Monitoring Procedure has since been\n revised to include responsibility for monitoring implementation of the SSC-RF\n policy previously.\n\n c. Proof of implementation\n\n ATT 19: Revised Financial Monitoring Procedure\n\n4c. Strengthen controls for compliance with its travel policy.\n\n a. Evidence addressed\n\n b. Training/Procedure\n\n Current NPRC staff have reviewed the travel policy and are familiar with this\n requirement. The Financial Monitoring Procedure has been amended to require\n inclusion of review of the travel policy as part of the orientation of program staff\n that will be traveling or approving travel expense reports.\n\n\n II\n\x0c American Red Cross\n\n\n\n\n+\n AmeriCorps \' Nati on a l Preparedness and Re sponse Corps\n Chapter Operations\n American Washington, D.C . 20006\n Red Cross (202) 303-581 3\n\n\n\n\n c. Proof of implementation\n\n ATT 20: Attestation that travel polices have been reviewed\n ATT 21: Financial Monitoring procedure, page 2.\n\n\nFinding 5 - Lacks controls over reporting federal costs\n\n Response to Finding: We agree that the San Francisco Chapter exceeded the\n Federal award budget for the member living allowance reflected in their sub\n recipient agreement by $187.00. There was a rounding error in the calculation\n and there was no amendment made to their agreement. .\n\n Recommendation 5: Strengthen controls and monitoring procedures to\n ensure subgrantees do not claim expenses in excess of their award amount.\n\n a. Evidence addressed\n\n In the current program year, we changed the methodology for creating the\n budget in the Host Site Agreements and now reimburse the same flat rate for\n each member. This eliminates rounding errors in calculating the host site\n budget which was the cause of the finding .\n\n b. Training/Procedure\n\n The following monitoring procedure was implemented at the beginning of the\n 2009-20 I 0 program year and addresses the recommendation to strengthen\n monitoring. :\n At the point of final approval and before the PER is submitted for payment,\n the NPRC program director logs monthly PER \'s from chapters on a\n spreadsheet which monitors federal costs claimed and matching funds\n compared to budget. This provides the monitoring necessary to ensure costs\n claimed do not exceed the amount awarded.\n\n ATT22 FY I 0 PER Tracking Worksheet - See FSR Tabs\n\n c. Proof of implementation\n\n\n\n\n 12\n\x0c APPENDIX B\n______________________________________________________________\n CORPORATION FOR NATIONAL AND COMMUNITY SERVICE\xe2\x80\x99S\n RESPONSE TO THE DRAFT REPORT\n\x0c NATIONAL&:\n COMMUNITY\n SERVICBt tt\n\nTo:\n\nFrom: ~lif!:W~.j{liSs ants Management\n\nCc.: WilliL n, Acting C ef Financial cer\n Rocco Gaudio, Deputy CFO, or eld Financial Management\n Lois Nernbhard, Acting Director, AmeriCorps\xc2\xb7State and National\n Frank Trinity, General COWlSe1\n Bridgette Roy. Audit Resolution Coordinator\n\nDate: April 20, 20 I 0\n\nSubj: Response to OIG Draft of Agreed-Upon Procedures of Corporation Grants\n Awarded to the American National Red Cross\n\n\nThank you for the opportunity to review the draft Agreed-Upon Procedures report of the\nCorporation\'s grants awarded to the American National Red Cross. We will work witl!\nthe grantee to develop corrective actions. We will respond to all findings and\nrecommendations in our management decision when the audit workipg papers are\nprovided and the final audit is issued.\n\x0c'