May 4, 2012 Ms.

Wendy Spencer Chief Executive Officer Corporation for National & Community Service 1201 New York Avenue, NW Washington, DC 20525 Dear Ms. Spencer: On behalf of the Board of Directors and members of America's Service Commissions (ASC), we would like to formally congratulate you on your recent confirmation to become the Chief Executive Officer of the Corporation for National and Community Service. We are thrilled that the President has called on a leader with your knowledge and e experience xperience to lead the service movement through these difficult times. You have been a leader among commissions and understand the important role local investment and leadership play in making national and community service such powerful and effective tool tools s in addressing local needs and our nation’s most pressing issues. We cannot think of a more appropriate person to lead our country into a new era of citizen service. Please know that state service commissions are appreciative of the personal sacrifice you ou have made to answer the President’s call to serve. We know the challenges challenge you face moving forward, and please know that the commission network is poised to support you and the Corporation as partners and friends. As you begin your tenure at the Corp Corporation, we wanted to share with you a number of priorities that we believe are critical to state service commissions for your consideration consideration. These hese priorities are based on years of state service commission experience managing and administrating Corporation-funded funded national service programs. Our goal is to maximize the utilization of these critical resources in a highly effective and efficient manner. As you may be aware, ASC is soon convening the working group on critical issues established at our State Service Commission Leadership Summit in March to further identify critical issues and priorities and to offer solutions to address them. We are including several of those critical issues in this letter. We plan to address all these priorities with new w working group, but we wanted to bring them to your immediate attention. Our first request is that you consider establishing an office of state service commission liaison, parallel to the office of field liaison that currently supports the Corporation’s state program offices, due to the diverse role and partnership the Corporation has with state service commissions. Second, we request that the Corporation fully implement programs rograms and provisions of the Serve America Act. Our priorities include the following:
American Association of State Service Commissions 1875 K Street, NW / 5th Floor / Washington, DC 20006

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

their AmeriCorps grants for administration. Given the critical need for program accountability, oversight, and compliance, we respectfully request that in a accordance ccordance with the statute, the Corporation provide the authority to commissions to make their own determination in regard to the administrative costs distribution up to 5%. We request that this change be in effect immediately. • Provide member slot allocat allocations for 1-year no-cost extensions of expiring ring formula grants under the 6-year year master grant – As currently constructed and identified as a problem by CNCS at last year’s AmeriCorps grantee meeting in Bethesda, grant funds awarded in 2011 and not fully expe expended nded will not be able to be used as carryover to continue to conduct AmeriCorps programs and will be returned to the Treasury. This loss of significant 2011 program funds could be easily rectified by providing the usual, usual additional AmeriCorps slots for ca carryover funds and extending the grant nt for one year while the new 6-year year grant begins. The grant period end of 6 years is simply an artificial barrier. If the grant is in any other year, member slots are provided for carryover funds that can be used in the e next year. This would provide utilization of the unexpended 6th year funds and maximize the use of AmeriCorps funds. • Permit the ability bility to move slots/funding within the commission’s competitive competitiv grant amongst competitive sub sub-grants, maximizing the use of AmeriCorps resources rces and ensuring high-quality quality programming and impact. Fourth, PDAT and Disability resources need to remain with state service commissions. These grants provide training and technical assistance to improve the programmatic qual quality ity of national service programs and potential programs. State service commissions use the PDAT funding to convene national service program staff and members for trainings, provide high high-quality, quality, on-site on training and technical assistance to national service programs, and promote cross-stream stream collaboration among all national service programs. It is imperative that these grants continue to be allocated under a formula basis so that every state can meet their individual state training needs. We appreciate the opportunity to share this important information with you and thank you in advance for your consideration of our requests. We look forward to engaging your staff through the critical issues working group and exploring ways to continuously improve the work of our collective efforts. We are thrilled that you have become the CEO and look forward to many years of your leadership and vision for service. Congratulations! Sincerely,

Paula Kaiser VanDam Chair

Tom Branen Executive Director

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

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