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Following up…
Greetings all! I so very much missed being with you at the national conference this year, but of course the arrival of Anderson Rivkin McSwain had to take precedence! I’m happy to report the whole family is doing well. From all reports, the conference was a success and thanks to all who participated.
And congratulations on another successful AmeriCorps Week! Your participation is what makes this event a success, and this year more of you participated than ever. I am happy to announce that AmeriCorps Week will take place again May 9 through 16, 2009. I’m sure we will make it the biggest and best yet.
This issue of the Policy Update is designed to reiterate key messages and collect the resources distributed at the conference in this one place so you will be able to find them easily, including the PowerPoint presentations on policy, the My AmeriCorps portal, and the recruitment system.
~ Kristin McSwain
College Cost Reduction and Access Act of 2007
The College Cost Reduction and Access Act of 2007 (CCRAA) was signed into law in September of 2007. It may offer AmeriCorps members significant benefits.The Act has two provisions with implications for members: the Income-based Repayment Plan (IBR) and the Public Service Loan Forgiveness Program.
The IBR Plan will make it easier for AmeriCorps members to pay back student loans while serving. Members who meet IBR’s debt-to-income ratio threshold specified in the CCRAA will be able to make payments as low as $0 a month while serving in AmeriCorps.
Depending upon the outcome of the Department of Education’s rulemaking, it is possible that AmeriCorps may be considered a public service job for the purposes of this program.If so, then the payments an AmeriCorps member makes on a qualifying loan while serving in AmeriCorps – even payments as low as $0 using IBR - will count towards the 120 qualifying payments required for the loan to be forgiven under the program. We will let you know when the Department of Education’s proposed rule on this Act is published, which should address whether or not AmeriCorps members will be included. We are also in the process of developing a webpage to provide guidance on the impact of the CCRAA on AmeriCorps members.If you have questions in the meantime, please address them to AmeriCorpsLoanForgiveness@cns.gov. In addition, you may find the following web sites helpful in learning more about IBR and Public Service Loan Forgiveness: Department of Education, Equal Justice Works, National Association of Student Financial Aid Administrators, FinAid.org, EdFund.org. Federal Student Aid, IBR Info, Student Loan Borrower Assistance
Correction in 2009 Notice of Federal Funding Opportunity
The estimated amount for states and territories without commissions was incorrect in the Notice of Federal Funding Opportunity distributed at the conference. The Notice has been corrected and can be found here: http://www.americorps.gov/pdf/08_0531_nofa_ac.pdf
Single State EAP FAQs
- Which current grantees are affected by this change?
National Education Award Programs (EAPs) operating in a single state will be affected by this change the next time they recompete. There are eight currently funded programs that will be affected, and none of them are recompleting in 2009. All new EAPs competing in 2009 and beyond will also be affected by the change.
- Will the change in policy affect only brand new applicants, or also recompeting applications?
The new policy affects new and recompleting EAP applicants which operate in a single state.
- Will commissions be prepared to work with National EAPs?
Commissions will receive training and technical assistance in order to ensure they are prepared to work effectively with EAP programs if they do not already do so.
- Will the commissions receive additional funding?
No, commissions will not receive additional funding to work with these single-state national EAPs. However, state and national EAP funding is distinct from national, Tribal, and state competitive funding, so states will access a different funding stream.
- Will the commissions be able to deal with the additional burden? In my state, for example, the commission will have to manage at least 400 additional slots.
We expect that state commissions will find it advantageous to work with EAPs. Many of them support this policy change and have been challenged by a lack of connection with large EAPs in their states in the past. Most already have the capacity to manage additional slots. EAP programs also reduce the commissions overall cost per MSY allowing them greater grant making flexibility.
- How will this work logistically? Will single state EAPs automatically be considered for competitive funds, or will the commissions conduct a separate competition for EAPs?
You will apply through a separate EAP NOFA in eGrants that the state commission will open if they plan to conduct an EAP competition.
- In my state the National EAP and regular state competition is off cycle. Their cycle starts next year for three years, while our program is in Year 1 of a three year grant. How will the commission handle this?
We will address this issue in facilitated discussions with you and your state commission.
- Will the application be the same as it has been?
Although different state commissions have slightly different processes, they typically use the same data collection instrument that you have been using.
- In my state, the commission has a very different application process which is more stringent than the national application process (i.e. it is a two step process and they require three aligned performance measures). Will we have to comply with these new requirements?
This will be one topic for discussions that we will facilitate.
- What about audits and procurement rules? Will we have to comply with the often more stringent state audit requirements and state procurement rules?
As a competitive fixed cost grant, the EAP program may or may not be subject to these standards. We will work with you and the commission to figure out what waivers and adjustments make the most sense for EAPs in their state.
- We currently have a very productive relationship with other EAPs across the country. Will the Corporation continue to offer assistance with this affinity group?
Yes, the higher education and other affinity groups will continue to meet and serve as resources for one another.
- We have developed a productive relationship with our Corporation program officer. How will we be assigned program officers at the commission level?
We will be arranging conference calls to ease the transition in each of the affected states. National program staff will connect with their state counterparts to make sure the transition is effective. National staff will also use the national conference as an opportunity to connect you with their state counterparts.
- What is the timeline for this change to take place?
The change will be reflected in the Notice of Federal Funding Opportunity and the Application Instructions for 2009. We will be conducting conversations on the topic starting this summer, to the January 13 deadline, or until all issues are addressed.
- Additional questions?
Contact your Program Officer and copy aborgstrom@cns.gov.
EAP Member Performance Evaluation FAQs
- What is the requirement for Education Award Programs (EAPs) regarding member evaluations?
In the past, the Provisions were silent as to whether EAPs were required to comply with the regulatory requirement to perform member evaluations. Starting in 2008-2009, EAPs will have to comply with the regulation, which is designed to ensure that members are evaluated sufficiently to determine eligibility for a second term of service. Here is the regulation:
45 CFR §2522.220 What are the required terms of service for AmeriCorps participants, and may they serve for more than one term?
(c) Eligibility for second term. A participant will only be eligible to serve a second or additional term of service if that individual has received satisfactory performance review(s) for any previous term(s) of service in accordance with the requirements of paragraph (d) of this section. Mere eligibility for a second or further term of service in no way guarantees a participant selection or placement.
(d) Participant performance review. For the purposes of determining a participant's eligibility for a second or additional term of service and/or for an AmeriCorps educational award, each AmeriCorps program will evaluate the performance of a participant mid-term and upon completion of a participant's term of service. The end-of-term performance evaluation will assess the following:
(1) Whether the participant has completed the required number of hours described in paragraph (a) of this section;
(2) Whether the participant has satisfactorily completed assignments, tasks or projects; and
(3) Whether the participant has met any other performance criteria which had been clearly communicated both orally and in writing at the beginning of the term of service.
- How do state competitive and national direct programs evaluate their members now? Is there a standard format for mid-term and final evaluations?
The minimum requirements for mid-term and final evaluation are stated in the regulation, above. Grantees may determine the format and contents of their evaluation to meet their needs and the needs of their members as long as these minimum requirements are in place.
- How should we document that the evaluation took place?
The minimum requirement is to have verification that the member received the mid-term and final evaluation as described in the regulation, i.e. whether the participant has completed the required number of hours; satisfactorily completed assignments, tasks or projects; and has met any other performance criteria which had been clearly communicated both orally and in writing at the beginning of the term of service.
- Currently programs are not required to conduct mid-term evaluations for members that serve less than half time. Will that provision continue?
Yes, that provision remains in effect.
- Are we expected to reach out to the program where a member first served to determine the results of these evaluations if he or she is applying for a second term?
It is important to ensure that a member who served previously is eligible to serve in your program, and you should make a reasonable effort to gather that information. If the member received an education award, you may assume the member served satisfactorily in the previous term. If the member was released for cause without receiving an education award, and you do not check with the program with which the member formerly served, you run the risk of enrolling an ineligible member. In this case some or all of the costs associated with that member can be disallowed. We are planning on automating this process in the My AmeriCorps Portal so the member’s past service will be evident in the system.
- Is this policy change retro-active? In other words, will my program be audited on the basis of the regulations or the Provisions that were in effect at the time the program was in operation?
The Corporation management intends to hold programs harmless for non-compliance with the regulation in the past because they have been in compliance with the Grant Provisions issued with their grant. The new requirement applies to grants awarded in 2008 and forward.
- Additional questions?
E-mail aborgstrom@cns.gov and copy your Program Officer.
Dates to Remember
- July 7, 2008: State formula grants due
- September 2008: Estimated date for publication of final rule, Application Instructions released
- September 22-24: State Commission ED Meeting and State Commissioner Institute in Washington, DC
- November 3, 2008: Admin-PDAT-Disability applications , including State Service Plans due
- December 1, 2008: Grantee Progress Reports due
- January 13, 2009: State and National application deadline
- May 9-16, 2009: AmeriCorps Week
What Do You Think?
How can we make this periodic update more useful? What other policy tools would be helpful? Contact aborgstrom@cns.gov with your ideas.
Conference Resources
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