Better Oversight Urged for AARP Foundation Grant
The Department of Justice’s (DOJ) Office of Justice Programs (OJP) plans to improve its oversight of a grant awarded to the AARP Foundation to ensure the foundation meets its performance goals and implements policies on funding drawdowns and financial reporting, in response to recommendations in a recent audit by the DOJ Office of Inspector General (OIG).
The Washington, D.C.-based AARP Foundation, the affiliated charity of the American Association of Retired Persons (AARP), is a nonprofit organization that aims to “provide older adults with nutritious food, affordable housing, a steady income and strong sustaining social bonds.” OJP’s Office of Juvenile Justice and Delinquency Prevention (OJJDP) issued a three-year, $2 million grant award in September 2015 — which had a project period from October 2015 to September 2018 — to support the foundation’s Experience Corps Program, a tutoring initiative where volunteers 50 and older help students in kindergarten through third grade become better readers. OIG audited the grant award to determine whether the costs claimed under the grant were allowable and whether the recipient met program goals and objectives.
While OIG found that the foundation took appropriate measures to ensure its program is established in several locations nationwide, the program as of February 2018 was not meeting its goals of “improving attendance” and “reducing students’ disruptive behavior.” OIG concluded that while the percentage of students participating in the program reported by teachers as meeting metrics such as “improvement in class participation” and “improvement in motivation to learn” was about 78 percent, only about 50 percent of students were reported as meeting the “improving attendance” and “reducing disruptive behavior” goals. “AARP Foundation progress reports acknowledged that the results of both the attendance and disruptive behavior metrics were likely lower because many [students] did not start the academic year with attendance or behavior problems, resulting in a smaller number of potential [students] who could demonstrate improvement in these two metrics,” the report stated.
OIG also found discrepancies in the performance data reported to OJJDP and the data in AARP Foundation’s source documentation. For example, from July 2016 to June 2017, the foundation reported to OJJDP that 28 mentors left the program, while it reported only 22 in its source documentation. It also reported to OJJDP that 2,012 new youth were added to the program during the period, while its source documentation showed that 2,343 youth were added. OIG noted that the foundation, before the audit began, had implemented a corrective action plan to reconcile differences prior to submitting data to OJJDP. “However, in our opinion, any future inability to adhere to this corrective action plan would increase the risk of the AARP Foundation not accurately tracking its performance related to the youth mentoring program grant,” OIG stressed.
When OIG evaluated the foundation’s oversight of personnel costs, it found that salary and associated fringe benefits allocated to the grant generally reflected the work performed and were adequately supported. However, after sampling six Experience Corps employees, OIG noted that the foundation allocated to the grant the cost of 24 hours of vacation time associated with one employee, while none of the other employees recorded vacation time to the grant.
In addition, OIG determined that the allowable indirect costs the foundation could charge to the grant as of January 2018 was $62,016, yet the foundation had charged $108,197, resulting in an excess of $46,181. The foundation acknowledged to OIG that it exceeded the amount approved in the budget for indirect costs and planned to take corrective actions. OIG also found that an AARP Foundation subrecipient inappropriately charged $1,826 in rental expenses to the grant.
In other audit findings, OIG determined that the foundation’s total expenditures as of February 2018 exceeded its cumulative drawdowns, and that it lacked written policies and procedures for preparing drawdown funding requests. “Because staffing or other personnel changes may take place, future drawdowns could be compromised if the current undocumented practices for drawing funds are not performed consistently,” OIG added.
Recommendations and Response
OIG recommended that OJP work with the AARP Foundation to:
- evaluate and report measurable goals regarding student attendance and behavior as part of its final grant progress report;
- ensure that data submitted to OJJDP reconciles with source documentation;
- implement internal controls that properly allocate payroll charges for employees who work on DOJ grants;
- remedy $46,181 in unallowable indirect costs that exceeded the approved grant budget and $1,826 in unallowable rent charged to the grant by a subgrantee; and
- develop written policies and procedures to guide the making of drawdown requests and the compiling of accurate financial reports.
In response, OJP concurred with the recommendations. The AARP Foundation told OIG that it has identified specific programs that negatively affected overall disruptive behavior outcomes and is incorporating increased behavior management training for DOJ mentors into the program’s annual targeted technical assistance plans. It also has adjusted the attendance targets for the grant to more appropriately reflect the population of students served.
The foundation also told OIG that it has implemented new processes to ensure data discrepancies would not occur in subsequent grant periods. It also noted that it updated its policy and guidance to specify that only staff who are fully funded by a single federal grant may charge leave to the grant, while all other staff must not charge leave to the grant, and that staff charging time to DOJ grants will complete annual refresher training on grants compliance.
The foundation also told OIG that it would revise how it allocates future indirect costs to ensure the amount recorded in its accounting records does not exceed the amount allowed under grant terms and conditions. However, while OIG said in its audit that the allowable indirect costs for the audit period was $62,016, the foundation noted — but did not provide support to OIG — that it had documentation showing this total should be $73,578. Still, OIG said its recommendation would not be closed until OJP has demonstrated that it remedied the $46,181 in questioned costs.
In addition, the foundation told OIG it has finalized and adopted both a drawdown policy, as well as a financial reporting policy designed to ensure that future Federal Financial Reports are accurate and approved prior to submission.
For More Information
The OIG audit is available at https://oig.justice.gov/reports/2018/g3019001.pdf#page=1.