Take Action: Submit a Comment on the AmeriCorps State and National Proposed Rule

The AmeriCorps agency is seeking public comments on proposed reforms to four AmeriCorps State and National regulations (§ 2520.50, § 2521.60, § 2521.70 and § 2522.235). Four “substantive changes” have been proposed, but none meet the goals for regulatory reform that Voices for National Service has been seeking for several years.

Anyone is able to participate in the public comment period, and we need our supporters to submit comments before the comment period closes at 11:59 pm EST on Dec. 5, 2023.

Submit a comment in support of Voices for National Service’s proposed reforms following these steps:

Copy this comment template:

As a supporter of AmeriCorps, I agree that it’s time to modernize the 30-year-old AmeriCorps State and National program and to make AmeriCorps more equitable and effective for people and programs. To that end, I am writing in support of the recommendations proposed by Voices for National Service to AmeriCorps State and National regulations § 2520.50, § 2521.60, § 2521.70 and § 2522.235. Voices worked extensively with the AmeriCorps community to develop these recommendations. It is my view that the agency’s proposed changes – as they currently stand – provide superficial changes and in fact add to the complexity of an already bureaucratic framework, creating more administrative burden and risk without substantially addressing the needs of AmeriCorps members and grantees. Voices for National Service’s recommendations in response to Regulation Identifier Number (RIN) 3045-AA84, “AmeriCorps State and National Updates,” would improve AmeriCorps’ value proposition for AmeriCorps members and ensure programs can access and maximize government resources more efficiently.

I appreciate the opportunity to provide input on the proposed changes, and strongly urge the agency to keep working on the rule to make the AmeriCorps State and National program equitable for all participants and sustainable for current and prospective grantees.

Visit https://www.regulations.gov/document/CNCS-2023-0030-0001 and click on the blue button that says “COMMENT”
Paste the comment text into the box. Optional: feel free to insert a brief opening paragraph explaining your connection to AmeriCorps.
Select that you are commenting as an Individual – you will be asked to provide your name, city, state, and zip code.
Press “SUBMIT COMMENT”

It is incredibly simple to submit a comment, and very important that the AmeriCorps agency hears from you! We have been told repeatedly that the volume of comments submitted makes a difference, and we want to demonstrate broad support for more substantial improvements. Please submit a comment before 11:59 PM EST on Tuesday, December 5th to show your support for meaningful reforms for AmeriCorps members and grantees.

ADDITIONAL DETAILS:

You can read Voices for National Service’s public comment here. Voices for National Service has been advocating for a series of critical improvements to the 30-year-old AmeriCorps program to make service more equitable for participants and those seeking AmeriCorps grants. Informed by on-the-ground experience, Voices continues to push for more substantial changes to the existing regulations to increase benefits for participants and ensure more organizations can access and maximize government resources efficiently and responsibly.

Here is a summary of the four changes in the proposed rule, as well as a summary of Voices original position and our concerns with the proposed rule:

The proposed rule, in effect, would make four substantive changes:

1. Waiver for 20% limit on education and training activities.

- AmeriCorps may grant a waiver to allow up to 50% for education/training if the program:
  - is an apprenticeship program;
  - is a job training/readiness program;
  - includes activities to support member attainment of GED/diploma/credentials; or
  - primarily enrolls economically disadvantaged members and provides soft/life skills development.

Voices Original Position	Concerns with Proposed Rule
Remove the “80/20 Rule” to ensure all members – regardless of type of program or length of service term – have opportunity to complete sufficient hours to both prepare for service and enrich their personal and professional development.	Appreciate the intention, but the proposed rule is too limiting. There are additional rationales to allow all AmeriCorps members to engage in more training, education, and professional development. Current rule creates a meaningless administrative burden and compliance risk for grantees. New rule should be a blanket removal and not restricted to the four different types of programs.

2. Modest change to AmeriCorps State and National graduated match scale:

- Proposes smaller incremental increases from 24% match to 50% at a lower frequency (increases every 3-year grant period, rather than every year).
- Reaches 50% (or $1 for $1 match) later, in year 16 rather than year 10.

Voices Original Position

Concerns with Proposed Rule

Repeal graduated match scale (adopted in 2005) and return to the original congressional vision that the federal share of an AmeriCorps State and National grant should not exceed 75%, regardless of years funded.
No required match for the first 3-year grant cycle.

Does not change match scale, which starts at 24% and increases to 50% match over time.
Provides no relief to grantees who have been in operation >16 years.
Assumes relief is only needed for newer grantees that are in geographic areas without a philanthropic community.
Does not acknowledge that grantees raise a considerable amount to run programs, in excess of the match requirement.
Ignores that match requires grantees to artificially inflate program expenses in order to accept and spend the allowable cost/member.
Disregards that 25% match as proposed by Voices meaningfully supports a public-private partnership, and that programs become more sustainable when they are not challenged by an overly stringent match and can maximize use of AmeriCorps funds.

3. Simplifies criteria for waiving AmeriCorps State and National match (currently 4 mandatory criterion).

- Streamlines match waiver criteria to mirror the AmeriCorps Seniors criteria and adds new criterion to capture small applicants.
- Grantees must demonstrate one of the following:
  - Difficulty securing funding in first 3 years of operations;
  - Economic downturn/disaster restricting local funding;
  - Unexpected discontinuation of local support; or
  - Organizational revenue less than $500K.
- Grantee must still provide description of efforts made to raise match under the proposal.

Voices Original Position	Concerns with Proposed Rule
Provide a transparent and streamlined process for programs to request a match waiver or reduced match during their grant cycle. Centralized process should make match relief easier, faster, more transparent, and accessible to a greater number of grantees.	Waiving match requirements is a patch when the agency should be repealing the match scale and returning to 75% federal share requirement as originally authorized by Congress in the National and Community Service Trust Act of 1993.

4. Removes 4-term limit on service in AmeriCorps State and National programs (regardless of term FT, PT, etc).

- Terms to be limited to number of terms needed to earn the aggregate value of two full-time education awards.

Voices Original Position	Concerns
Expand the number of terms an individual can serve in the three AmeriCorps programs to support member recruitment.	Proposed rule should be reworded to ensure members have the option of serving additional terms in ASN, VISTA and NCCC without accruing an education award.

If you have questions about the proposed rule or how to submit public comments for the record, please contact Ray AlQaisi, Voices for National Service’s Director of Congressional Affairs, at raymond.alqaisi@cityyear.org.