YouthBuild's Broken Timekeeping Puts $12.65M at Risk
Summary
An AmeriCorps Office of Inspector General audit tested 5 of YouthBuild USA's 82 subgrantees and found $6.69 million in questioned costs and funds put to better use -- most of it tracing to a timekeeping system YouthBuild never required anyone to independently check, and to one subgrantee, San Jose Conservation Corps, that recruited its own employees as AmeriCorps members and let them earn education awards for hours worked on the job they already had. Because every subgrantee ran on the same non-compliant policy, OIG classified $12.65 million in education awards across all 82 subgrantees of YouthBuild's two audited grants -- about 23% of the $55.28 million AmeriCorps awarded YouthBuild since 2018 -- as resting on hours nobody can verify were actually served. AmeriCorps has formally refused to recover any of it.
A regulatory gap AmeriCorps knew about for 15 years
In 2009, the Serve America Act⧉ eliminated an 85% cap on the federal share of AmeriCorps members' living allowances and support costs. AmeriCorps never updated the Federal Regulations that still state the old 85% limit -- and internal correspondence from 2019 shows its own Associate General Counsel acknowledging the regulations were outdated and telling staff to just point grantees to the statute instead. 's own analysis of grant data found only 64% of AmeriCorps State and National grants from 2019 through 2023 were administered consistent with the outdated regulation -- meaning a third of grantees, YouthBuild's national-direct awards among them, effectively got a better deal than others simply by not knowing, or not following, rules AmeriCorps itself had stopped enforcing 15 years earlier.
View data as table
| Timekeeping practices non-compliant | 3,608,618 | $520,827 in education awards already paid plus $3,087,791 classified as funds put to better use |
|---|---|---|
| SJCC employees served as members | 3,025,779 | Federal and match costs questioned after a subgrantee recruited its own employees as AmeriCorps members |
| Inadequate subgrantee monitoring | 57,749 | Federal and match costs questioned for compliance gaps YouthBuild's own monitoring did not catch |
A timekeeping template nobody double-checked
YouthBuild's subgrantees tracked AmeriCorps member hours on a monthly template, hand-copied from daily service logs and school attendance sheets. found that transfer step was never reviewed by a second staff member, and the template's totals were never checked against members' exit evaluations or the hours logged in AmeriCorps' own eGrants system. YouthBuild's policy also never required subgrantees to record time members spent on other funded work -- only their AmeriCorps hours -- leaving no way to verify a member's claimed service time wasn't also being billed to a different federal, state, or private grant.
Employees who were also "members"
The costliest single finding involved San Jose Conservation Corps⧉ (SJCC), a YouthBuild subgrantee that recruited its own prospective and existing employees to serve as AmeriCorps members -- letting them earn education awards for hours they were already being paid to work in their normal jobs. questioned $2,125,096 in federal costs and $900,683 in match costs tied to that practice alone, more than the amount tied to YouthBuild's own timekeeping failures. YouthBuild's inadequate monitoring of its subgrantees -- the mechanism that should have caught this -- added a further $57,749 in questioned costs.
View data as table
| 5 tested subgrantees | 3,608,618 | $520,827 already paid, $3,087,791 still outstanding -- the OIG's audited sample |
|---|---|---|
| 77 untested subgrantees | 9,042,686 | $1,349,717 already paid, $7,692,969 still outstanding -- same timekeeping policy, never independently checked |
AmeriCorps says the policy was fine. Its own regulations disagree.
recommended AmeriCorps recover $520,827 in education awards already paid under the non-compliant timekeeping, require YouthBuild to pay the $3,087,791 still outstanding, and assess whether the remaining $9,042,686 at risk across YouthBuild's other 77 subgrantees has adequate documentation. AmeriCorps refused all three recommendations, arguing YouthBuild's timekeeping was consistent with what the agency "intended" its own Terms and Conditions to mean, even though those Terms and Conditions cite the federal documentation standard verbatim. 's rebuttal: "Federal grants... are not governed by intentions, but rather by Federal Statutes, Regulations, and AmeriCorps' general and specific Terms and Conditions." The stakes reach beyond one grantee -- notes that 30% of all its investigations opened since 2019 involve allegations of false or problematic timekeeping⧉, enough that the office has named it a Top Management Challenge for the agency.
- A five-subgrantee sample found $6.69 million in problems -- and extrapolated the risk to all 82. Because every YouthBuild subgrantee ran on the same non-compliant timekeeping policy, the education awards behind that policy -- $12.65 million system-wide, $10.78 million of it still unpaid as of October 2023 -- carry the same unverified status, whether or not actually tested them.
- AmeriCorps knew its own regulations were outdated for 15 years and didn't fix them. Internal correspondence from 2019 shows the agency's own Associate General Counsel aware the Federal Regulations hadn't caught up to a 2009 statutory change -- and only about 64% of AmeriCorps grants nationwide were administered under the version actually in force.
- One subgrantee recruited its own employees as AmeriCorps members. San Jose Conservation Corps let existing staff earn education awards for hours already covered by their paychecks -- the single largest dollar finding in the audit, at just over $3.9 million across questioned Federal, match, and non-compliant match costs.
- AmeriCorps refused to recover any of the disputed money. The agency rejected 's recommendations to recover paid awards, require repayment of outstanding ones, or even assess whether the remaining $9 million-plus has adequate documentation -- calling YouthBuild's practice consistent with regulatory "intent," a standard says federal grants are not governed by.
Report -AR-24-05 was issued March 29, 2024; this piece reflects the audit's findings and both parties' formal responses as recorded in that report, not any subsequent recovery action. 's testing covered 5 of YouthBuild's 82 subgrantees and two of its AmeriCorps State and National grants (16NDHMA001 and 19NDHMA003); the $12.65 million at-risk figure is 's own extrapolation of the tested findings' underlying cause -- non-compliant timekeeping -- to the full population of subgrantees under those two grants, not a finding that misconduct occurred at all 82. The $1,042,851 in non-compliant match costs tied to COVID-19-era match waivers is excluded from the $6.69 million monetary-impact total by the report's own accounting.
Sources(2) ▾
- AmeriCorps Office of Inspector General, Performance Audit of AmeriCorps Grants Awarded to YouthBuild USA (OIG Report No. AR-24-05) (2024-03-29) — Final performance audit report, 20+ pages including appendices, conducted for AmeriCorps by the independent CPA firm Saggar and Rosenberg, P.C. under Generally Accepted Government Auditing Standards. Fetched directly and read in full (transmittal memorandum, Executive Summary, both narrative findings sections, Table 1 and Table 2 monetary-impact tables, and AmeriCorps' and YouthBuild's written management responses with the 's evaluation of each). The PDF is hosted at oversight.gov, the federal government's cross-agency Inspector General portal -- and is the exact file AmeriCorps 's own report landing page links to as its primary document. oversight.gov · original document
- AmeriCorps Office of Inspector General, Performance Audit of AmeriCorps Grants Awarded to YouthBuild USA -- report landing page (2024-03-29) — AmeriCorps 's own website listing for this audit; its download link points directly at the oversight.gov-hosted PDF used as doc-oig-ar-24-05, confirming the report is the office's own official release and not a third-party mirror. americorpsoig.gov · original document
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AmeriCorps members earn a living allowance and, after completing their term, an education award -- both funded with federal money and both premised on one fact that has to actually be true: that the member served the hours claimed. A performance audit by AmeriCorps' Office of Inspector General⧉ tested just 5 of YouthBuild USA's 82 subgrantees and found $6,692,146 in questioned costs and misclassified funds -- and concluded that the same broken timekeeping system touches $12,651,304 in education awards across all 82 subgrantees of the two grants it reviewed.