Program & Fiscal Management Reminders and What’s New for 2017-2018

Agenda Systems - Quick Refreshers & Updates Member Human Resources Criminal History Checks & FBI Fingerprinting Member Support Fiscal Prohibited Activities & Accountability Federal Budget Grants Process 2018-2019 Discussion

Member Human Resources Recruitment, Selection, Eligibility & Enrollment, Tracking Member Hours, & Exiting Members

Recruitment BRANDING – From the beginning! Identify/explain AmeriCorps in recruitment materials and process Website Position description Partner sites AmeriCorps logo Essential functions of the position Inviting and inclusive language and materials Accommodations for interviews and service

Recruitment Position Descriptions Detailed; outline specific activities Unique for each member role/function Required to show additional responsibility if providing a higher living allowance Be specific Ensure additional responsibilities do not include staff displacement or member management Amount of additional allowance should be justified by additional responsibilities Address position’s contact with vulnerable populations and required checks for the position

Selection To ensure a fair and equitable member selection process by demonstrating a consistent application process followed for each applicant

What we are looking for … Consistent process Evidence of all steps of the selection process for each member, including returning members Policies on background checks On-time, every time, documented Every program must have at least one person, or whoever is completing background checks, complete an online training Evidence of non-discriminatory and inclusive process Programs cannot discriminate based on race, disability, marital/family status, sexual orientation, gender, religion, national origin, birthplace, or age Massachusetts Commission Against Discrimination: www.mass.gov/mcad/

NSCHC requirements All AmeriCorps members must undergo checks prior to start of service “Covered Staff” must also undergo checks prior to start of employment All staff listed on your AmeriCorps grant budget Includes those funded by match, listed as in-kind Does not include individuals who receive financial benefit who do not otherwise perform any service to implement the program (e.g., trainers) Which checks to complete: No recurring access to vulnerable populations: Access to vulnerable populations: NSPOW NSOPW State Check(s) or FBI Check State Check(s) FBI Check

NSOPW National Sex Offender Public Registry/Website (NSOPW) Only valid sex offender check SORI, the MA check, is neither required nor sufficient Check your language All covered staff and AmeriCorps members must undergo this check Use NSOPW.gov Make sure all states, territories included are reporting Verify and document results, check any results returned

State Criminal History Registry Checks Must use designated state repositories/CNCS-approved alternative or request alternate search protocol MA CORI: http://www.mass.gov/eopss/crime-prev-personal-sfty/bkgd-check/cori/ If State of Residence check is required, and BOTH must be initiated before the start of service/employment State of Residence can be difficult to determine, especially for college students or those living and working in different states. Guidance from CNCS FAQ: “The state where a candidate resides is the location that the person considers his or her place of residence at the moment in time that he or she applies to serve or work.” For college students “A person applying to serve or work who is enrolled full-time in college is deemed to be residing in the state where he or she lives for the purpose of attending the school… Programs may not opt to use any other basis for identifying the student’s residence state, e.g., such as the student’s family home.”

FBI Criminal History Record Check CNCS approved channeler: Fieldprint Fieldprint is only for FBI checks Average completion time is about 3-5 business days (according to CNCS) Very helpful Fieldprint introductory webinar recorded by CNCS on YouTube Programs are not required to use Fieldprint Please let us know if you plan to use the Departmental Orders (DO) process, which is the official name for when fingerprints are sent directly to the FBI

Documented Accompaniment No unaccompanied access to vulnerable populations pending State Check(s) or FBI check A person is accompanied when he or she is in the physical presence of a person cleared for access to a vulnerable population. An employee or representative of a placement site may provide accompaniment if that person’s clearance was established under the placement site’s rules. Accompaniment must be documented contemporaneously or it is not compliant Person accompanying must be noted, as well as dates and times Timesheets are best place to document accompaniment

Criminal History Check – ASPs Alternate Screening Protocol (ASP) Cost to the program is prohibitive Program is not authorized or is otherwise unable under state or federal law to access the FBI’s national criminal history background check system Program cannot comply for “good cause”, determined by CNCS Approval process Submit request to MSA MSA will submit to CNCS

Criminal History Checks NSOPW check completed before service/work begins Criminal history check(s) initiated no later than start of service/work Verify identity with government photo identification Obtain written authorization Document understanding that selection is subject to the checks Determine where the checks must be obtained from Pay for the checks Provide opportunity for review of findings Keep information confidential Accompaniment when checks are pending & in contact with vulnerable populations Maintain the results of the checks Document that you verified identity and conducted the checks Document that you considered the results of the checks in selection

Examples of Policies via CNCS CNCS Statutory Minimums Office of Juvenile Justice Delinquency and Prevention Guidelines NCMEC Child Safety Program Refusing to undergo the process False statements Murder Sex offenses requiring registration Crimes involving children or dependent adults Crimes of violence within 10 years* All other crimes discretionary based on position, circumstances, recency and other factors All felony convictions Lesser crimes of force Lesser crimes of a sexual nature Controlled substances Cruelty to animals * If utilized by a CNCS grantee, murder would render an individual ineligible regardless of the offenses’ age, due to the statutory requirements of 45 USC 12645g.

Other Requirements Consecutive terms or continued employment: no need to re-check if service/employment uninterrupted or if a break is fewer than 120 days All programs must have at least one staff person involved in NCHSC complete an online training annually, anyone who is involved in the process should complete it Best practice: address contact with vulnerable populations in position descriptions for members and staff MSA requires you to track criminal history checks along with member hours, submit to MSA periodically

Member Hours/NSCHC tracking sheet for 2017-18

Member Hours/NSCHC Tracking Sheet for 17-18: General Instructions Your Program Officer will send this with 17-18 PER and other startup documents Required to submit the spreadsheet 30 days after program start date and with every reimbursement request Change from last year: must certify each submission Every member and covered staff-person must be listed with criminal history check dates, including returning members and staff There are two tabs to complete: one for covered staff and one for members The members tab includes hours information Note the date that hours entered are counted through Expected hours is equivalent to service term

Hours/NSCHC tracking sheet for 17-18: Instructions for Entering Information If a criminal history check has not been returned, leave the corresponding cell blank or enter "not in" When a state of residence check or FBI check is not required enter "N/A" For the column labeled "accompaniment," select "not required" if either: The member/staff does not have access to vulnerable populations The NSOPW is complete and either required state criminal history check(s) or FBI check are complete before start of service Otherwise, note whether accompaniment was completed/documented

New Hours/NSCHC tracking sheet for 17-18: Helpful Information Read instructions tab, please FBI Check initiation date: for Fieldprint it is the date fingerprints are taken (if using DO, remains the same) We know this is more stringent than CNCS requires, MSA has concerns about considering a check “initiated” when member/staff may not have shown up for appointment We will use the data you provide to calculate disallowance, so please double check information before submitting Be kind to your PO: please do not put additional characters in cells, use the notes column instead

Risk-based Disallowance Two years ago, CNCS came up with a new system for determining consequences of noncompliance Less impact on members for programs’ mistakes Consequences vary based on severity of noncompliance or “risk” In May this year CNCS released a final set of rules for calculating disallowance with a few adjustments Changed name to “Enforcement Guide” Removed > 50% noncompliance increase Even though financial penalty is really a fine (cannot come from unspent CNCS funds anymore, or from match), they are still calling it “disallowance”

CNCS Mitigation Matrix

Mitigation Levels in Plainer Language Mitigation Rating No recurring access to vulnerable populations Recurring access to vulnerable populations Substantial On-time NSOPW AND at least one of these, even if late: State check FBI check All of these: Performed accompaniment On-time NSOPW On-time State Check or FBI check Moderate Late NSOPW AND at least of one of these, even if late: Either: On-time NSOPW and late state check or late FBI check Performed accompaniment and on-time state check or FBI check Low None of the above

CNCS Disallowance Determination NSCHC Risk-Based Disallowance Overall % of noncompliant individuals: Self-Reporting Standard Disallowance Disallowance for each individual with: Mitigation Level ↓ Substantial $250 $500 Moderate $1000 Low $750 $1500 Note: CNCS considers MSA spreadsheet self-reporting

How are MSA programs doing? Not great, and not improving as a group 2015-16 Disallowance: Totals for All MSA AmeriCorps Programs Compliant Members/Staff Noncompliant Members/Staff Total Members/Staff Overall Noncompliance Rate Disallowance 1615 152 1767 8.60% $64,875.00 2016-17 Disallowance: Totals for All MSA AmeriCorps Programs Compliant Members/Staff Noncompliant Members/Staff Total Members/Staff Overall Noncompliance Rate Disallowance 1483 143 1626 8.79% $55,750.00

Disallowance Update Continued Disallowance Results Only nine programs of 25 (36%) fully compliant Four programs had very significant (15-40%) noncompliance Four had extreme noncompliance (>40%) CNCS will be sending debt notification letters to programs with any disallowance via MSA 2016-17 Disallowance: Totals for All MSA AmeriCorps Programs Compliant Members/Staff Noncompliant Members/Staff Total Members/Staff Overall Noncompliance Rate Disallowance 1483 143 1626 8.79% $55,750.00

What went wrong? New staff or scattered-site member supervisors Initiation date must be before begin employment Staff turnover Not just PD, but other organization staff Issues with organization’s CHC procedures Programs did not follow their written procedures Procedures not in place for staff, not everyone is aware of procedures (e.g. HR department) Lack of communication from sites

100% Compliance for 100% of MSA’s Programs! (For real this time) Next year… 100% Compliance for 100% of MSA’s Programs! (For real this time)

Tools and Resources NSCHC Clearinghouse on Knowledge Network: http://www.nationalservice.gov/resources/criminal-history-check Disallowance Guide: http://www.nationalservice.gov/sites/default/files/resource/Interim_Disallowance_Guide_for_Staff_and_Grantees_Updated_September_9_2015_0.pdf Required NSCHC training: http://cncstraining.articulate-online.com/4240214797 CNCS NSCHC FAQ: http://www.nationalservice.gov/sites/default/files/resource/FAQs_Version_070716_1.pdf Regulations: http://www.ecfr.gov/cgi-bin/text-idx?ID=9e5466ae66b0b60241f448502b41433b&mc=true&tpl=/ecfrbrowse/Title45/45chapterXXV.tpl Instructions on how to request an ASP: http://www.nationalservice.gov/sites/default/files/resource/ASP_and_Exemption_Guidance.pdf

Eligibility and Enrollment To ensure that the program has all necessary paperwork and information for each member in their member files

What we are looking for… Eligibility documentation (age) Contract (signed on or before the enrollment date) Selection documentation (with consistent # of interviews & references) Background check verification With dates initiated and cleared, initialed by staff All timesheets (signed by member and supervisor) Member evaluations Member enrollment/exit forms (if applicable) Documentation of requests for reasonable accommodation Documentation of cause or compelling personal circumstances for members exited early (if applicable)

Enrollment My AmeriCorps portal 30 day enrollment period Member section Program Director section 30 day enrollment period 30 day service location entry period

Tracking Member Hours To ensure that timesheets are kept in a manner that is consistent with AmeriCorps requirements and members are on track to meeting the required number of hours of service

Tracking systems need to… Ensure that paper copies of time sheets in members files are maintained Ensure that electronic timesheet tracking system is in place that adheres to CNCS guidelines (we recommend AmericaLearns or OnCorps) Ensure first time sheet coincides with enrollment date and contract date Ensure a correct percentage of training and fundraising Ensure members are on track to meeting the required number of hours

Exiting Members To ensure a consistent process for exiting members that includes exit forms, documentation for early release if applicable (cause or compelling circumstances) and exiting out of the My AmeriCorps Portal with correct hours within 30 days of the end of the term of service.

What we are looking for… Process My AmeriCorps portal hours reconciliation Member section (Request required for staff portal exits) Final evaluation Documentation Compelling personal circumstances Cause

Enrollment, Member Hours & Exiting 30 day rule Enrollment in portal Service location in portal Timesheets submitted Suspension and return from suspension in portal Exit in portal Exit survey completion rate is low, we can send instructions on how to unlock the survey earlier, prior to end of service Dates coinciding Contract date on or before enrollment Enrollment date on or before the first day of service Last day of service and exit date

Orientation, Training, Supervision, and Evaluation Member Support Orientation, Training, Supervision, and Evaluation

Developing & Implementing Member Training To ensure that members are prepared for service, civic engagement, and personal development through a planned, consistent, and structured method.

Orientation What MSA looks for… Date/time and location Agenda AmeriCorps 101 Contract Prohibited activities Expectations Service specific training Team building Civic engagement training Sign-in sheets Evaluations Plan for orienting members enrolled after initial orientation Reasonable accommodations

Ongoing Training & Development What MSA looks for… Training plan/schedule Supporting members in attaining GED Encouraging members to vote Supporting members in making the transition after end of service – Life After AmeriCorps Structured activities for members to reflect on service Strengthen connection to National Service and identity as AmeriCorps members (reinforced in updated provisions) Agendas and sign-in sheets Plan for involving members in selection of training Participation in National Days of Service

Supervision & Evaluation To ensure members receive appropriate supervision, that reasonable accommodations are made when appropriate, and that supervisors evaluate member performance at the required times during the service year.

Supervision What MSA looks for… Implementation of the supervision plan How and when did supervision take place? What supervision topics were covered? Identification of members and service sites as AmeriCorps service gear signage language & role Ensure prohibited activities do not take place Evaluations

Evaluation What MSA looks for… Mid-term evaluation (full and half time members) End-of-term evaluation (all members) Action steps if member is not meeting performing adequately

End-of-Term Evaluation Requirements Did the member complete the required number of hours; Did the member satisfactorily complete assignments; and Did the member meet other performance criteria that were clearly communicated at the beginning of the term of service. Other program specific requirements Member and Supervisor signoff Exit interview Reflect on member’s service experience Tie service into his/her future plans Request evaluation of his/her host site Request suggestions that would help future members Provide information for letters of recommendation

Tracking, Recording & Reporting Progress, Site Partner Management, Continuous Improvement, Fiscal Systems

Tracking, Recording, Reporting To ensure the program is collecting, documenting, and reviewing necessary data; that it is on track to meet its stated objectives; and that it submits accurate and timely reports of AmeriCorps-related performance measure objectives.

Tracking & Recording Progress Data collection tools Data collection timeline/schedule Data tracking systems Reporting schedule MSA reports Additional stakeholders http://www.nationalservice.gov/resources/performance-measurement/training-resources#collection

Progress Reports 2016-2017 Final Report – October 15, 2017 Will require Program Impact Statement 2017-2018 Mid-Year – April 15 (through March 31) Combines national and applicant-determined measures 2017-2018 Final Report – October 15, 2018 Change: Ongoing vs. episodic volunteers If you can categorize volunteers as episodic or ongoing, there will be an option for that If not, categorize all as episodic Track separately moving forward

Site Partner Management Ensure all site partners are aware of prohibited activities Site partner agreements Site partner orientation agenda Site partner identification as AmeriCorps Site monitoring evaluation tool schedule Program feedback

Continuous Improvement To ensure the program evaluates the quality of its service activities, which includes involving extensive broad-based representation from the following: the community served current and potential members site partners foundations businesses community-based agencies with a demonstrated record in providing services

Fiscal Systems Financial Management Systems Documentation of Matching Funds Reimbursement

Financial Management Systems To ensure that grant-related expenses are properly reported and that the program maintains financial management systems that include written cost allocation procedures and systems that distinguish expenditures attributable and not attributable to this Grant, and that adequate supporting documents for expenditures are maintained.

Documentation of Matching Funds To ensure the program has sufficient matching funds available for upcoming program year and that these funds are properly documented. Cash or in-kind match acceptable Documenting in-kind match – must include: Date service provided and who provided it Description of service provide Value/how calculated Signature of donor/service provider

Reimbursement To ensure the program submits accurate and timely reimbursements including a signed Reimbursement Request Cover Sheet with Program Initials, a PER, a General Ledger, and a clear reconciliation report tying expenses in the PER to the General Ledger.

Fiscal Training MANDATORY for all fiscal staff Review OMB, fiscal management requirements, fiscal site visit procedures Review reimbursement and fiscal reporting processes Program staff welcome to attend if interested Training offered twice August 17, 1:00PM – 3:00PM, at MSA* August 24, 1:00PM – 3:00 PM, webinar * In-person session required for any new fiscal staff and may be required for others at MSA’s discretion

Key Definitions PER/Periodic Expense Report FSR/Financial Status Report (Quarterly PER) Budget Summary Worksheet FFR/Federal Financial Report “Cover Sheet”/Request for Cash Reimbursement Cover Page Backup/Supporting Documentation Hours and criminal history check log

Fiscal Reporting Quarterly Due Dates October 15, 2017 (16-17 and 17-18 through September 30) January 15, 2018 (through December 31) April 15, 2018 (through March 31) July 15, 2018 (through June 30) October 15, 2018 (17-18 and 18-19 through Sept. 30)

Reimbursement Request Process At least quarterly At minimum, request funds 30 days after submission of FSR (except for July 15) Encouraged to request more frequently Payments made via check or electronic fund transfer (EFT) EFT requires small transaction fee deducted from reimbursement Contact July Afable to discuss/choose EFT 617-542-2544, ext. 225 jafable@mass-service.org

Reimbursement Request Process Accurate reimbursement received by 15th processed by 30th; received by 30th processed by 15th Inaccurate reimbursements returned for revision and will be resubmitted for processing in the next reimbursement cycle MSA adheres to 15 day processing timeline to account for staff capacity, time off, etc. MSA does not advance funds MSA will review your request to ensure that adequate progress is being made towards matching percentage

Reimbursement Request Process Complete reimbursement request includes: Cover sheet with original signature PER for current month(s) request Budget summary worksheet General ledger, reconciliation report, other backup documentation Updated hours and background check log must be included Reimbursements will not be processed until all components are received MSA will not take responsibility for ensuring completeness *MSA will ensure that reported estimated unexpended funds are left in the total CNCS balance column

Fiscal Site Visits Set up in spring by MSA’s fiscal staff Programs will have at least one fiscal visit per 3-year grant cycle, longer visits than in the past Common findings will be discussed in fiscal training in August Include but not limited to: Review of organization's internal control structure Review of prior audit reports and management letters Review of progress made from any prior audit and management letter finding(s) Sampling of selected fiscal transactions

Budget Amendments Budget amendment consists of changing or moving CNCS and/or match amounts MSA requests notification for all changes MSA approval required If amending more than 2% of total program budget (CNCS and match total) CNCS approval required If amending 10% or more of total program budget (CNCS and match total)

Budget Amendments Contact your Program Officer before initiating a budget amendment request Include justification with budget amendment request Budget amendments are subject to review and can be rejected Be pro-active in discussing amendments early in the program year! Late spring is often too late for CNCS to be able to approve given how busy they are with grant awards, etc.

New Section III Guidance Revised Formula for CNCS-Fixed Percentage Method Corporation Fixed Amount CNCS Share: ([CNCS Section I] + [CNCS Section II] x 0.0526) x (0.60); Grantee Share [Total Section I] + [Total Section II] x 0.1) Commission Fixed Amount CNCS Share: ([CNCS Section I] + [CNCS Section II] x 0.0526) x (0.40) A. Corporation Fixed Percentage  CNCS  Grantee Corporation Fixed Amount $7,860 $50,500 Commission Fixed Amount $6,187 $0

Monitoring Tools Program Binder Desk Review Monitoring Systems and Objectives Standard Member Documentation File Check Individual Member File Check

Program Calendar Day of Service & Remembrance – September 11 AmeriCorps Opening Day– Friday, November 3rd MEMBERS MUST BE IN GEAR!!!!!! MLK grant application deadline – mid-September FY19 recompete concept paper deadline – September 18 Competitive continuation application deadline – early December MLK Day – January 15

Program Calendar Four Required Program Director meetings – locations TBD October 18th December 13th February 14th April 25th Progress reports – October 15 and April 15 Quarterly FSRs - October 15, January 15, April 15, July 15 Updated Audit – March 31

Binder Materials Program Officer will be in contact about this. Programs will submit: Program Year Calendar Updated systems (if applicable) Updated documents (if applicable) Desk Review Tool is helpful tool for us to assess your program’s binder. Binder is a tool for you when training new staff and for MSA when problem-solving with you.

Prohibited Activities/Accountability Three-pronged Strategy: Prevention Detection Enforcement Prevention: List prohibited activities in NOFO and Provisions Requirement to enter member service location in My AmeriCorps within 30 days of start of service Additional trainings to programs regarding prohibited activities (especially to share with site partners) CNCS will communicate directly with members on this issue

Prohibited Activities/Accountability Detection CNCS Quarterly review of position descriptions Position description Certification from program that members not engaged in prohibited activities Include details of what recruited volunteers will do in member and volunteer positions Members cannot recruit volunteers to do prohibited activities Enforcement Suspension and termination Quick and decisive action

Grants Process 2018-2019 Recompeting Programs RFP released early August Concept papers due mid-September Must be submitted online Notification late October

Grants Process 2018-2019 Continuing Programs Information will be included in CNCS application instructions – released in the late summer/early fall May host optional conference call to review instructions if there are significant changes Competitive continuation applications shared with MSA by early December

IPERIA Improper Payments Evaluation and Recovery Improvement Act (formerly known as IPERA) Continued testing since 2013 based on results of IPERIA process Yearly testing required until improper payments total less than $10 million FY15 focused on NSCHC compliance FY16 IPERIA testing is currently in progress (FFR-GL-Single Transaction)

Discussion AmeriCorps Branding CNCS Updates Other ideas? New grants management system Other ideas?