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May 4, 2012 Ms. Wendy Spencer Chief Executive Officer Corporation for National & Co mmunity

May 4, 2012

Ms. Wendy Spencer Chief Executive Officer Corporation for National & Co mmunity Service 1201 New York Avenue, NW Washington, DC 20525

Dear Ms. Spencer:

On behalf of the Board of Direc tors and members of America's Service Commissio ns (ASC), we would like to formally congratu late you on your recent confirmation to become the Chief Executive Officer of the Corpo ration for National and Community Service. We are thrilled that the President has called on a lea der with your knowledge and experience to lead the service movement through these difficu lt times. You have been a leader among commissio ns and understand the important role lo cal investment and leadership play in making natio nal and community service such power ful and effective tools in addressing local needs and our nation’s most pressing issues. We cann ot think of a more appropriate person to lead our cou ntry into a new era of citizen service. Plea se know that state service commissions are apprecia tive of the personal sacrifice you have ma de to answer the President’s call to serve. We know the challenges you face moving forward, and p lease know that the commission network is poised t o support you and the Corporation as partners and friends.

As you begin your tenure at the Corporation, we wanted to share with you a numbe r of priorities that we believe are critical to st ate service commissions for your consideration. Th ese priorities are based on years of state servi ce commission experience managing and administr ating Corporation-funded national se rvice programs. Our goal is to maximize the utilizat ion of these critical resources in a highly eff ective and efficient manner.

As you may be aware, ASC is s oon convening the working group on critical issues established at

our State Service Commission

priorities and to offer solutions to address them. We are including several of those critical issues

in this letter. We plan to addres s all these priorities with new working group, but w e wanted to bring them to your immediate a ttention.

Leadership Summit in March to further identify criti cal issues and

Our first request is that you con sider establishing an office of state service commi ssion liaison, parallel to the office of field lia ison that currently supports the Corporation’s state p rogram offices, due to the diverse role a and partnership the Corporation has with state servic e commissions.

Second, we request that the Cor poration fully implement programs and provision s of the Serve America Act. Our prior ities include the following:

Americ an Association of State Service Commissions 1875 K Street, NW / 5 th Floor / Washington, DC 20006

Combined Competitive - Fulfilling the commitment to devolution that is the central component to the combined competitive competition and the agreement that created it.

Implement Fixed Amount Grants – Implementing fixed amount grants would make oversight and monitoring requirements for state service commissions more effective and improve staff capacity levels necessary to monitor portfolio compliance. However, the current fixed amount grants do not allow less than full-time members even to replace attributed full-time members. This is an unwieldy and ineffective design not allowing a robust use of this vehicle as allowed by the Serve America Act. In addition, the cost per MSY should be the same or more than the cost-reimbursement grants because unlike the cost-reimbursements that often increase the actual MSY over time, the fixed amount grants are not only the budgeted but the actual federal cost per MSY.

Criminal Background Checks – (1) Re-examine the July 2011 proposed changes to the Corporation’s regulations. Both existing and proposed regulations on criminal background checks currently go far beyond the requirements of the Serve America Act. Currently, per an October 2011 issuance to grantees on its web site, the Corporation is attempting without public comment and rule making to impose severe penalties on local nonprofits and the commissions who fund them if criminal history checks are delayed. This ‘policy’ is not directly addressed in the preamble to the regulations and is an expanding issue. (2) A realistic cost benefit analysis should be applied considering the restraints of small and local programming along with the benefit of the FBI check versus the previous requirements and the ease of implementation. The goal of this was to allow and authorize the use of FBI checks for those circumstances that made sense ensuring the safety of everyone who serves and those who are served. The proposed rule does not achieve this standard.

Education Award Program Allocation - One area of immediate concern is the allocation of the set aside for the Education Award Program (EAP) competitive funding, which is taken off the top of the full AmeriCorps appropriation rather than within the competitive allocation where it should be. CNCS selects 63% of the funding and slots by law and commissions select 35.3%. However, if a commission selects an EAP, it is taken out of their formula allocation whereas for CNCS-selected programs it is taken off the top of the allocation before the formula is run. We believe this is a clear violation of the Serve America Act and shortchanges the formula allocation to states by over $3 million each year.

Performance Measurement Reporting - Currently, AmeriCorps programs have only 2 category labels to report accomplishment in performance against established measures under the CNCS system – Met or Unmet as enforced by AmeriCorps program officers. Yet, this is hardly a fair representation of results. If the measure was to recruit 800 volunteers and you only report 799, the measure is Unmet. While AmeriCorps exhorts commissions and programs to set ambitious goals in performance measurements, the end result, once one learns the system, is to set easily attainable goals. AmeriCorps should use the standards established for the Corporation in the OMB Part Performance Measures, which use a 5-part scale: 1. Effective 2. Moderately Effective 3. Adequate for agency programs that are ‘Performing’ 4. Ineffective and 5. Results not demonstrated for programs categorized as ‘Not Performing’.

Third, we request that you allow state service commissions the flexibility to efficiently and effectively administer the grants they oversee. Our priorities include the following:

Commission-determination on administrative costs – The statute authorizes commissions to manage and set policy for allocation of administrative costs of our grants up to 5%. Currently, the Corporation’s policy provides for commissions to use 1% of

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their AmeriCorps grant s for administration. Given the critical need for pro gram accountability, oversig ht, and compliance, we respectfully request that in a ccordance

with the statute, the Co rporation provide the authority to commissions to m ake their own

determination in regard to the administrative costs distribution up to 5%. W this change be in effect immediately.

e request that

Provide member slot

allocations for 1-year no-cost extensions of expiri ng formula

grants under the 6-ye ar master grant – As currently constructed and iden tified as a

problem by CNCS at la st year’s AmeriCorps grantee meeting in Bethesda, grant funds

awarded in 2011 and n ot fully expended will not be able to be used as carry over to continue to conduct Am eriCorps programs and will be returned to the Trea sury. This loss of significant 2011 program funds could be easily rectified by providin g the usual, additional AmeriCorps slots for carryover funds and extending the grant fo r one year while the new 6-year gr ant begins. The grant period end of 6 years is simp y an artificial barrier. If the grant is i n any other year, member slots are provided for carr yover funds

that can be used in the

year funds and maximi ze the use of AmeriCorps funds.

next year. This would provide utilization of the une xpended 6 th

Permit the ability to

move slots/funding within the commission’s compe titive grant

amongst competitive s ub-grants, maximizing the use of AmeriCorps resou rces and

ensuring high-quality

programming and impact.

Fourth, PDAT and Disability r resources need to remain with state service comm issions. These grants provide training and tech nical assistance to improve the programmatic qualit y of national service programs and potential programs. State service commissions use the PDAT funding to convene national service progra m staff and members for trainings, provide high-qu ality, on-site training and technical assistanc e to national service programs, and promote cross-st ream collaboration among all nationa l service programs. It is imperative that these grant s continue to be allocated under a formula ba sis so that every state can meet their individual state training needs.

We appreciate the opportunity t o share this important information with you and tha nk you in advance for your consideration of our requests. We look forward to engaging your staff through the critical issues working grou p and exploring ways to continuously improve the w ork of our collective efforts.

We are thrilled that you have be ecome the CEO and look forward to many years of y our leadership and vision for service. Congrat ulations!


and vision for service. Congrat ulations! Sincerely, Paula Kaiser VanDam Chair Tom Branen Executive Director

Paula Kaiser VanDam Chair

Congrat ulations! Sincerely, Paula Kaiser VanDam Chair Tom Branen Executive Director Americ an Association of State

Tom Branen Executive Director

Americ an Association of State Service Commissions 1875 K Street, NW / 5 th Floor / Washington, DC 20006