Oral Testimony of Lori Giblin, Chief Risk Officer Corporation for National and Community Service Before the House Subcommittee on Higher Education and Workforce

Mar 28, 2017

Chairman Guthrie, Ranking Member Davis, and Members of the Subcommittee,  

Thank you for inviting me to testify today.  I share the Committee’s view that our agency has a responsibility to ensure federal funds are well-managed and welcome this opportunity to discuss our commitment to strong risk management and prudent stewardship of taxpayer dollars.

My written testimony details our comprehensive risk management framework and the multiple steps we have taken since the Subcommittee hearing last year.  I will summarize them now.

To properly identify and manage risk, the first step has to be a commitment from the top.  CNCS leadership has made an extraordinary commitment to risk management, and has backed up that commitment with action:

  • We are one of the first independent and small federal agencies to hire a Chief Risk Officer.
  • We are one of the only agencies that has aligned all of our risk assessment functions into one integrated framework.
  • We have been identified as a leader among our peers in implementing the principles of risk management laid out by OMB.
  • Even in an extremely tight budget environment, we have redirected scarce resources to ensure this function is properly staffed and have hired 17 professionals with extensive experience in accounting, auditing, compliance, internal controls, and risk management.

Over many years, CNCS has built a culture of accountability and a strong system for monitoring and oversight.  Now – with the strong commitment from leadership, infusion of resources, and a top-notch team - we are building on that foundation to implement a risk-based program modeled on industry best practices.

Our focus is to identify actual, evidence-based risks, validate and prioritize them, and mitigate them on an ongoing basis.

We follow leading industry practice in organizing risk into four basic categories: programmatic, financial, compliance, and fraud.

  • In the area of programmatic risk, we provide training and technical assistance to our grantees to assist them in successfully implementing their programs.
  • For financial risk, we continually assess our grantees’ financial viability and ability to manage federal funds. If a grantee has challenges, we use a wide range of strategies and corrective actions, including increased monitoring, putting grantees on a reimbursement only status, requiring them to report monthly on expenditures, termination, suspension, and debarment.
  • For compliance and fraud risk, we have taken multiple steps to ensure that grantees comply with the terms and conditions of their award and to ensure that we safeguard the agency against fraud, waste, and abuse.

To ensure our work is effective, coordinated, and delivering results, we have consolidated 5 risk assessment programs under my office:

  • First, we are taking comprehensive action to improve compliance with National Service Criminal History Check requirements.
    • We implemented a solution enabling our grantees to directly obtain FBI checks from a private vendor.
    • We are now seeking another market-based solution to conduct the state criminal history checks that many of our grantees are currently unable to perform.  This solution will include a check of the National Sex Offender Public Website, which will ensure that a required check is complete.
    • We are leaning in.  Going beyond what’s required - to do what is smart by providing resources to our grantees so that they can better detect and prevent misconduct before it happens.
  • My office is implementing a testing process for improper payments that will help us identify root causes of noncompliance and more accurately report the effectiveness of our program to eliminate such payments.
  • The agency is taking multiple steps to strengthen internal controls, including testing enterprise-wide controls, convening a Fraud Risk Assessment Committee; and aligning our internal controls annual testing approach with industry best practices.
  • CNCS is implementing an enterprise risk management program and developing a risk profile that will inform how management invests limited resources in risk mitigation strategies.
  • And last, we are refining the criteria used in the annual grant risk assessment that informs the types of monitoring and technical assistance grantees require.

All these actions – and many others - demonstrate the priority we place on risk management and the commitment we have to accountability and the responsible use of taxpayer dollars. 

Our systems for monitoring and oversight are working.  Misconduct is very rare, and when it happens, we take swift action.  We are always looking for ways to improve and strengthen our systems. We appreciate the guidance from our IG, the GAO, and this Committee.  Enhancing these systems will help us better support the 325,000 dedicated Americans serving through AmeriCorps and Senior Corps at 50,000 locations across our nation. They are tutoring and mentoring at-risk youth... responding to disasters...supporting veterans and their families, and much more – all while recruiting millions of additional volunteers to serve alongside them and multiply their impact.

I hope my testimony today assures the Committee of our commitment to accountability and our interest in doing more and I welcome your questions.

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