In October, the AmeriCorps agency published in the Federal Register proposed revisions to four AmeriCorps State and National regulations (§ 2520.50, § 2521.60, § 2521.70 and § 2522.235) and launched a public comment period to collect feedback on the updates. Four changes have been proposed, but none meet the goals for regulatory reform that Voices for National Service has been seeking for several years.
The revised regulations would:
- Give the agency the authority to waive the current 20% limit on education and training activities, and allow AmeriCorps members to spend up to 50% of their hours in education and training if they are participating in an AmeriCorps program that is an apprenticeship program; a job training/readiness program; supports member attainment of GED/diploma/credentials; or primarily enrolls economically disadvantaged members and provides soft/life skills development.
- Revise the graduated AmeriCorps State and National match scale so it incrementally increases from a 24% match to 50% at a lower frequency (increasing every 3-year grant period, rather than every year). As a result, grantees would reach a 50% match requirement in year 16 rather than year 10.
- Simplify the criteria for applying for an AmeriCorps State and National match waiver.
- Remove the 4-term limit on service in AmeriCorps State and National programs (regardless of term length).
Voices for National Service is concerned that the proposed AmeriCorps State and National Updates offer superficial changes and lean heavily on the use of waivers, adding complexity to an already bureaucratic framework, and creating more administrative burden and risk. In our comments, Voices for National Service proposes more substantive changes to the 30-year-old AmeriCorps program. Voices’ policy recommendations have been informed by its members and their on-the-ground experience administering AmeriCorps grants. Voices is recommending changes that would both improve the benefits and value proposition for participants and ensure that all organizations can access and maximize government resources efficiently and responsibly.
The public comment period closed out with a total count of 372 submissions. Voices undertook efforts to make the broader field aware of the opportunity to provide the agency with feedback on its proposal. Accessible, short-form comment templates were shared with AmeriCorps State and National stakeholders.
This month, the Administration also proposed a fundamental rewrite of the Office of Management and Budget’s Uniform Grants Guidance, the government-wide framework for grants management and the rules and requirements around federal awards. The proposed changes are lengthy, and the open comment period ultimately garnered over 1,000 unique comments.
Voices appreciates that the Administration seeks to make federal grantmaking more equitable and is trying to eliminate undue complexity that deters impactful and qualified organizations from seeking federal resources. Voices submitted a public comment expressing support for simplifying Notices of Funding Opportunities; eliminating grant reporting that is not necessary for measuring program performance; standardizing the treatment of indirect costs and raising the guaranteed de minimis rate; and lastly, how to improve the federal distribution and utilization of “fixed amount grants.”
Voices for National Service is encouraged to see widespread engagement in both public comment periods. The Administration will now review and analyze all the comments received, and they must decide whether to proceed with the changes proposed, issue a new or modified proposal, or withdraw their proposals. Voices will keep this community informed as there are updates.
Resources – AmeriCorps State and National Updates:
- Comment submitted by Voices for National Service
- Comment submitted by America’s Service Commissions
- All comments are accessible for review on regulations.gov, the federal government’s website for regulatory items.
Resources – Federal Guidance for Grants and Agreements:
- Comment submitted by Voices for National Service
- All comments are accessible for review on regulations.gov.