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Introduce new program directors to National Service, AmeriCorps, and MSA, and provide an overview of program systems, compliance, grant management, and partnership expectations.
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Welcome to Kickoff! New Program Director Session
New PD Session Agenda • Introductions • Overview of National Service, AmeriCorps, & MSA • AmeriCorps Systems and Compliance(Systems activity, PD Handbook) • Grants Process and Management • Partnership Expectations
Overview Corporation for National & Community Service (CNCS) Massachusetts Service Alliance AmeriCorps programs AmeriCorps members
Written systems help programs to… • Standardize program operations • Bring new program staff on board • Comply with AmeriCorps Provisions • Share and replicate successful practices
Activity! • Write a system for doing the laundry
Program Binder Requirements • Program Binders must have: • A section for each of the 2017-18 AmeriCorps Systems (Recruitment through Reimbursement). • A completed System Worksheet and supporting documentation for each section • For example: member application, contract, performance measurement instruments, performance evaluation tool, host site monitoring tool • Program Year Calendar (resubmitted annually)
Program Binder Due Dates • All continuing programs must update their systems and documentation annually • Resubmissions due late September (date TBA) • New programs’ binders are due per Program Officer instructions – staggered schedule focusing on start-up systems first • List of the Systems and Objectives and blank system worksheets available on our website: www.mass-service.org
Viewing Your AmeriCorps Grant • eGrants • Program narrative • Performance measures • Aligned measure for primary service activity • Program Budget • Including Budget Narrative • My AmeriCorps portal (to be covered later in Kickoff) • Member enrollment and exiting ( 30 day compliance) • Service site listing • Manage slots • My AmeriCorps tutorials: • http://www.nationalservice.gov/resources/americorps/myamericorps-support-americorps-state-commissions-and-sub-grantees-egrants-0
Progress Reports • Mid-year and end-of-year update with multiple components • Basic program information • Progress toward achieving Performance Measures • Also an opportunity to share accomplishments and challenges • Completed online • October 15, 2017: cumulative for 2016-17 program year • April 15, 2018: data through March 31 for 2017-18 program year • October 15, 2018: cumulative for 2017-18 program year
PER and Reimbursement Requests • Periodic Expense Report (PER) • Minimum quarterly • October, January, April, July • Reimbursement request no later than 30 days after submitting quarterly PER • Must submit with July 15 PER • Able to request more often; MSA recommends monthly • Reimbursement basis; no advances • Fifteen day processing time based on 15th and 30th of each month
Grants Process • Recompete vs. Continuations (review) • FY 2019 MSA RFP released early August 2017 • TA sessions to review instructions • Recompete concept papers due in mid- to late September • Competitive continuation applications due to MSA in Word format by early December • Application instructions will be sent by Program Officer
Partnership • Assume positive intent • Mutually beneficial relationship • Communicate openly and frequently • Lead the service field • Use and refer to provisions to ensure compliance
Communication • Program Officers (primary contact) • Suzana Kantardzic, Senior Program Officer • Maura Hackett, Program Officer • Rachel Lieberman, Program Officer • Elizabeth Way, Program Officer • Other MSA Staff • July Afable, Manager of Accounting and Finance • (Open Position) Commonwealth Corps Program Manager • Steve Gallucci, Chief Financial Officer • Emily Haber, Chief Executive Officer • Lisl Hacker, Manager of Training and Technical Assistance • Shana Lothrop, Program Officer for Volunteer Initiatives • Beth McGuinness, Director of Programs • (Open Position) Administrative Coordinator • Amy Mulvena, Commonwealth Corps Assistant • Lindsay Rooney, Director of External Relations and Development
Branding & Recruitment DO: • AmeriCorps logo (big “A”) on service gear • “Service” in recruitment materials and position descriptions • AmeriCorps signage at service sites • Include AmeriCorps and MSA information at member and site partner orientation • Best practice: giveaway items AVOID: • “Staff” or “Employee” on service gear • “Job” or “Employment” in recruitment materials or position descriptions • Using the term “work” to describe member responsibilities • Referring to or creating culture of members as staff at service sites
Activity: National Service Context • Program Director’s Handbook: Your best friend (2 min.) • Group 1: Skim page 5 (CNCS Mission & Strategic Plan) • Group 2: Skim page 6 through 7 (CNCS Structure and Programs) • Group 3: Skim page 6 and 7 (especially “About MSA”)
National Service Context • Group Activity (7 min.) • On flipchart paper • List five words that summarize most important information about: • Group 1: CNCS • Group 2: National Service Programs • Group 3: Massachusetts Service Alliance • List up to three: • Insights/learning about how this information relates to your role as AmeriCorps program manager, • Questions about this information as it relates to your role.
Program Directors’ Meetings • Four required meetings annually • 2017-2018 meeting dates: • October 18th • December 13th • February 14th • April 25th • Hosted by programs – MSA is looking for volunteers! • Mandatory program representation • Members should not attend
AmeriCorps Opening Day • Full day event on Friday, November 3rd, 2017 • Roxbury Community College • Mandatory program representation • Lindsay or Emily will talk more about this tomorrow morning
Training and Technical Assistance • Contact your Program Officer with questions • Lisl and Gretchen will continue providing support • Online resources • National Service Resource Center • E-newsletters and MSA grantee page • Atlantic Cluster Conference? • We will continue to talk more about T/TA throughout the Kickoff and throughout the year
Welcome to Kickoff! July 25, 2017
Criminal History Checks Compliance, tracking, and enforcement
Agenda • NSCHC Requirements • Tracking criminal history checks with member hours • Enforcement and “disallowance”
Why National Service Criminal History Check (NSCHC)? • Requirements set by Congress and implemented by CNCS • Reasons for criminal history checks: • Responsibility to protect vulnerable populations • Responsibility for taxpayer dollars • Uphold the requirements based in law • Financial penalties • This year, CNCS made consequences more significant, could do the same for the 17-18 program year as well • OIG does not view disallowance as a valid remedy • And other consequences of noncompliance…
What’s the impact? • AmeriCorps is already under threat of elimination, budget cuts • Criminal history check noncompliance increases that threat: • OIG Report on CNCS • Very concerning, poor performance on criminal history checks at forefront of agency issues according to report • IPERIA (formerly known as IPERA) • Of all improper payments, only one(!) file was not criminal history check related • Programs must make checks a top priority! • MSA AmeriCorps programs are not doing well overall, have not improved (more on that later).
The NSCHC requirements • Verify identity against government photo identification • Obtain written authorization from the person to perform the check • Document understanding that selection is subject to the checks • Determine the types of checks required and from where they are to be obtained; • Pay for the checks • Complete and adjudicate the NSOPW check before service/work begins • Initiate the criminal history information check(s) no later than the start of service/work • Provide opportunity for review of findings • Keep the information confidential • Accompany those with pending checks when in contact with vulnerable populations • Maintain the results of the checks • Document that you verified identity and conducted the required checks • Document that you considered the results of the checks.
Disqualifications • An individual is ineligible to serve in an AmeriCorps program if they: • Refuse to consent to a State Criminal Registry and FBI Check Note: this does not include NSOPW check because it is public information, no consent is required. • Make a false statement in connection with a program’s inquiry concerning the individual’s criminal history • Are registered or required to be registered on a State Sex Offender Registry • Convicted of murder
Who must be checked • All AmeriCorps members must undergo checks • “Covered Staff” must also undergo checks • All staff listed on your AmeriCorps grant budget • Includes those funded by match, listed as in-kind, or at sub-sites or national offices • Percentage on grant does not matter • Three types of checks: • NSOPW (National Sex Offender Registry/Website) • State check(s) • FBI check
Defining Recurring Access and Vulnerable Populations • Defined as people: • 17 or younger • 60 and older • Who have a disability • Recurring access: • CNCS defines “recurring access” as “the ability on more than one occasion to approach, observe, or communicate with an individual through physical proximity but not limited to, electronic or telephonic communication.” • And adds that there is an “exemption for access that is episodic in nature or for a [one]-day period. Not regular, scheduled, or anticipated component of activities.” • Accompaniment is required until either required state check(s) or FBI check has been returned
NSOPW • National Sex Offender Public Registry/Website (NSOPW) • Only valid sex offender check • SORI, the MA state sex offender check, is not sufficient (or required part of procedure) • Check your language • All covered staff and AmeriCorps members are required to undergo this check • Extremely easy to complete • Use NSOPW.gov • Make sure all are reporting • Verify and document results, check pictures returned– not considered complete or “adjudicated” until that is done.
State Criminal History Registry Checks • State of Residence and State of Service/Employment check are part of this requirement • Individuals residing in MA when applying only need one (MA) check • Otherwise, two checks are required, and BOTH must be initiated before the start of service, both must be returned before state check is considered complete • CNCS has designated specific registries in each state and most territories • See here for a list of CNCS-designated state repositories and alternatives • Massachusetts Criminal Offender Record Information (MA CORI) is ours • Some states will not provide information or have an extremely onerous procedure • Alternative Search Procedures (ASPs) • Document, document, document!
State of Residence checks • 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.” • It can’t hurt to cover your bases and complete checks for multiple states (especially if the check is easy).
FBI Criminal History Record Check • FBI checks require fingerprints to complete • In some states there is an agency, usually the state police, that serves as a repository for fingerprint-based checks • We do not have that option in Massachusetts • CNCS established an approved FBI check channeler in 2016 • Fieldprint • Channeler is an intermediary between programs and the FBI • Cuts down time for check tremendously
More Information About FBI Checks • Fieldprint is only for FBI checks • Average completion time is 3-5 business days, often even quicker • Programs are not required to use a channeler, but must request permission to use Departmental Orders (DO) process • The 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 the best place to document accompaniment
Reviewing Check Results • Must document that findings have been reviewed or “adjudicated” by program staff and considered in selection/hiring process • No matter what, murder conviction, sex-offense is disqualifying • More info in CNCS regulations and FAQ about what offenses are included • A “not clear” check is not automatically disqualifying • Organizations must have established, documented policies to determine how to deal with other offenses that might be returned on checks
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 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 16-17: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 Disallowance Determination • Note: CNCS considers MSA spreadsheet self-reporting