Policy – TCN: Subgrantee Corrective Action Policy

The Corps Network is committed to providing each member with the opportunity to receive high-quality service opportunities within Corps. By offering ongoing technical assistance and targeted support, The Corps Network will ensure that each Subgrantee effectively manages the financial and programmatic responsibilities outlined in the AmeriCorps Manual, and remains in compliance with the Federal Regulations, Terms & Conditions, Policies and Provisions set forth by the AmeriCorps, the Agency.

The following areas of concern are indicators to The Corps Network that a Subgrantee may be experiencing challenges implementing AmeriCorps programs sponsored by The Corps Network.

A. Programmatic

  • Inability to achieve required program performance measures
  • Late submission of documents required to begin enrolling members
  • Inability of Site Administrator to perform key program responsibilities
  • Late or non-submission of reporting documents
  • Incomplete/Inaccurate program reporting

B. General

  • Inadequate Criminal History Checks including NSOPW
  • Late enrollments and exits in eGrants
  • Unsatisfactory enrollment and retention rate
  • Inaccurate/Incomplete Recordkeeping (member files, timekeeping, eGrants)
  • Lack of responsiveness to The Corps Network on information requests
  • Poor results from Site Visits/Desk Audits and/or inadequate response to feedback
  • Poor participation in meetings or webinars

C. Financial (Not for EAP)

  • Inability to perform financial responsibilities (includes submitting Reimbursement Requests on time)
  • Inability to establish internal controls for financial management of grant award
  • Lack of required financial policies and procedures
  • Incomplete/Inaccurate financial reporting (includes Reimbursement Requests, PERs and FFRs)
  • Inability to provide acceptable documentation to justify expenses (includes match funding)
  • Inappropriate use of program funds

If a Subgrantee displays a pattern of one or more of these areas of concern, The Corps Network staff will work directly with the Subgrantee to develop a Corrective Action Plan to resolve any challenges faced in managing the AmeriCorps program.

STEP 1: NOTIFICATION BY EMAIL FROM THE CORPS NETWORK : The Corps Network’s Director of AmeriCorps Programs will inform the Subgrantee of the issue via email, offering support to prevent future incidents from occurring.

STEP 2: CONFERENCE CALL AND PROBATIONARY PERIOD: Once a pattern of incidents has developed, the Site Administrator and or Corps Director) along with other pertinent TCN staff will meet via phone conference to discuss the identified concerns and recommend corrective action (s) to be adopted during the determined probationary period. The Subgrantee will implement systems and processes necessary to demonstrate the issue has been resolved. Once the concerns are adequately addressed and verified by The Corps Network, the Subgrantee may continue regular program operations.

STEP 3: ANNULMENT OF AWARD: If no agreement can be reached, or if the issue persists, The Corps Network may annul its award to the Subgrantee, resulting in the revocation of all member slots for the current program year. Any Subgrantee having its award annulled by The Corps Network will need to submit a detailed Corrective Action Plan in order to be considered as a Subgrantee to future program years.