COVID-19 Guidence Memo: AmeriCorps Staff and Members
This document is subject to change and should be reviewed daily for changes.
We will continue to facilitate weekly PD calls while under this emergency order in order to provide updates, wellness checks and to provide support.
Summary: This memo related to COVID‐19 restates in one place as clearly as possible the Governor’s Office of Volunteer Service’s guidance and policy for AmeriCorps grant management in response to the pandemic. Look for bolded statements on alternative service activities, compelling personal circumstances, and expenditures that empower you to act to support AmeriCorps members and keep serving Alabama. Keep a copy of this memo for your grant records.
HEALTH AND SAFETY
The health of personnel and AmeriCorps members is everyone’s shared priority. The Governor’s Office of Volunteer Services directs subgrantees to comply with evolving guidelines from ADPH and Governor Ivey and to take responsibility for communicating up‐to‐date information on preventing the spread of COVID‐19 to AmeriCorps members, personnel, and the public. The best sources of COVID‐19 information are:
Alabama Department of Public Health (ADPH): http://alabamapublichealth.gov/infectiousdiseases/2019-coronavirus.html
Alabama Voluntary Organizations Active in Disaster (ALVOAD)
If an AmeriCorps member notifies their program that they have a compromised immune system or are high risk to infection, the program should follow their reasonable accommodations procedures and determine an appropriate alternative service for the member.
Discrimination and Confidentiality
The Governor’s Office of Volunteer Services directs all subgrantees to guard against discrimination in our response to COVID-19. To prevent stigma and discrimination during service, do not make a determination to send a member or volunteer home based on race or country of origin. Also, ensure that you maintain confidentiality of any member(s) and volunteer(s) who are confirmed to have COVID‐19 or other illnesses as required by the Americans with Disabilities Act of 1990 (ADA).
LIVING ALLOWANCE AND BENEFITS
As a matter of member safety, the Governor’s Office of Volunteer Services urges subgrantees to continue living allowance and program benefits to members regardless of their activities or hours completed. Those minimal funds support housing and food needs, and it is likely that shift jobs or alternative incomes will be impacted by COVID‐19. Whereas the Governor’s Office of Volunteer Services normally recommends that subgrantees develop a policy to not pay living allowance during a payment period in which a member records zero hours of service, we strongly encourage subgrantees to pay living allowance even in this scenario. Any change in policy should be documented with the effective dates in a Memo to File.
Suspension and Living Allowance
Suspension of service is a tool available to all subgrantees for individual, case by case, member management. Due to the long-term impact on your grant, the Governor’s Office of Volunteer Services would most likely recommend against the suspension of a member at this time, but each situation is unique.
In order to provide subgrantees the maximum flexibility as a result of COVID‐19, CNCS has determined that AmeriCorps State and National members may be paid living allowances and benefits while they are in a Suspended from Service status. This can only be done if the reason for suspension is due to COVID‐19. This is an exception to the regular policy that suspended members are to receive no living allowance. Programs can also elect not to pay living allowances if they suspend their AmeriCorps State and National members. If a subgrantee organization decides to continue to pay members while they are in a suspended status, they must be prepared to obtain additional funding to cover living allowance and benefit expenses once members are reinstated.
If an individual is suspended for any other reason than COVID‐19, the living allowance and other benefits are also to be suspended.
A member suspended due to COVID‐19 activities may continue to receive the childcare benefit (for up to 12 weeks) and health care benefit provided by the grant recipient. To ensure no lapse in childcare coverage, the AmeriCorps State and National subgrantee must notify GAP Solutions in writing within five business days after a member’s status changes. Costs incurred due to the subgrantee’s failure to keep GAP Solutions immediately informed of changes in a member’s status may be charged to the subgrantee’s organization.
ALTERNATIVE SERVICE ACTIVITIES
The Governor’s Office of Volunteer Services asks you to consider the intended purpose of AmeriCorps over and beyond immediate concerns – to Get Things Done for America. Individuals who stay in AmeriCorps have a special character ‐ they want to help, and you can mobilize AmeriCorps members to make a significant difference in this time of national crisis. Your AmeriCorps grant commits to a specific program design and performance measures. In response to COVID‐19, however, AmeriCorps members may be unable to perform planned activities, and you may simply determine that the community has new priorities. The Governor’s Office of Volunteer Services urges subgrantees to plan alternative service for members that allows them to complete their terms, earning a full education award, and supports communities in these uncertain times. Where members are safe and willing to do so, they should be volunteering. The Governor’s Office of Volunteer Services is working with state agencies and partners to support your efforts in identifying alternative service opportunities.
Effective March 2020 through the remainder of this crisis period, the Governor’s Office of Volunteer Services permits subgrantees and their members to perform service activities in response to COVID-19 community needs that are not specifically defined in their approved grant.
For members to receive service credit for activities outside of those approved in the grant award, permission must be obtained from the Governor’s Office of Volunteer Services’ Program Officer. Please note that members and staff may not engage in any activity normally prohibited in AmeriCorps programming.
Subgrantees will describe alternative service and the Governor’s Office of Volunteer Services will monitor activities for noncompliance with AmeriCorps prohibited activities. As with any other alternative service, the program should maintain documentation of staff approval of each member’s alternative service activities.
Alternative Service Opportunities can be found at: https://www.servealabama.gov/covid19
RECORDING COVID-19 SERVICE HOURS
The Governor’s Office of Volunteer Services is requiring all its AmeriCorps programs to have its members who are engaging in activities in response to COVID-19 record service hours in a COVID-19 subcategory in their OnCorps member timesheets. Programs will have to add a COVID-19 subcategory to their member timesheets to accomplish this.
If program staff have any questions about these COVID-19 member timesheet requirements, please contact the Governor’s Office of Volunteer Services’ Compliance Officer.
This is a reminder that AmeriCorps members are permitted to serve remotely, or teleserve, if the published guidance (https://www.nationalservice.gov/sites/default/files/documents/ASN%20006%20Teleservice%20Guidance.pdf) from the Corporation for the National and Community Service is followed:
• Written authorization of teleservice in advance
• Expectations of the communication requirements between supervisors and teleserving members
• Mitigation of the increased risk of time and attendance abuse
• Appropriate supervision including validation of the activities to be performed, and
• Verification of hours claimed
It is a best practice to first investigate the ability (e.g. access to internet) of individual members to serve remotely. Then establish a process to document the procedures above. The Governor’s Office of Volunteer Services will also be asking subgrantees to submit their teleservice policy and procedures for review.
COMPELLING PERSONAL CIRCUMSTANCES (CPC)
COVID-19 will cause extended site closures and sustained disruptions to AmeriCorps members’ service that can reasonably justify a compelling personal circumstance exit under 45 CFR §2522.230 (a) Release for compelling personal circumstances. While the Governor’s Office of Volunteer Services intends that every member shall complete their term of service this year, it is reasonable to expect that will not happen.
To be eligible for CPC, a member must first have completed at least 15% of the hours in their term of service. A CPC exit means that a member is exited for reasons beyond his or her control and can receive a prorated education award and serve in AmeriCorps again if they have completed their term of service satisfactorily. When exiting a member for CPC, follow your CPC policies. Regarding documentation: Do not include medical documentation. The CDC has asked that such paperwork requests be avoided to allow medical professionals to prioritize care. For documentation instead, retain a copy of the relevant statements from Governor Ivey ordering social distancing measures and/or announcement of school closures:
In addition to alternative service, subgrantees may conduct training with members, including online learning. It is important to note, however, that members cannot exceed the maximum 20 percent aggregate training hours.
This is a federal rule that the Governor’s Office of Volunteer Services has no authority to waive – 45 CFR § 2520.50: How much time may AmeriCorps members in my program spend in education and training activities? “No more than 20 percent of the aggregate of all AmeriCorps member service hours in your program, as reflected in the member enrollments in the National Service Trust, may be spent in education and training activities.” Programs are to monitor this closely and provide explicit instruction and definition of what activities are defined as training to members. The Governor’s Office of Volunteer Services reminds its subgrantees that participation in state commission events, are required service activities. Planning time, program meetings, data collection and review, briefings on COVID‐19, program feedback and reflection, as well as team development activities are reasonably tracked as part of members’ community service hours. Please contact the Governor’s Office of Volunteer Services if you need further information on the 20% training threshold.
Remember training for disaster response counts as service. Also, capacity building is not considered training but can count toward service hours. As can program development.
EVENTS AND TRAVEL
All in‐person Governor’s Office of Volunteer Services’ meetings are cancelled throughout the crisis. We do not anticipate that any subgrantee would charge out of state travel in March or April. Please notify the Governor’s Office of Volunteer Services if you are planning travel outside of Alabama for which expenses will be charged to the grant. The ASC regional training conference in Milwaukee has been rescheduled; ASC’s new regional training dates are as follows:
July 27-29 – Pacific/Southwest – Albuquerque, NM
August 24-26 – Central – Milwaukee, WI
Cancelled for 2020 – Atlantic//Southern – Burlington, VT
AMERICORPS GRANT EXPENDITURES
In a dynamic environment, subgrantees may see a need to spend grant funds on safety supplies, training, cellphones/tablet devices for communication, or other AmeriCorps member support costs not currently approved in the submitted budget. Also, additional personnel may be needed to support the AmeriCorps program.
The Governor’s Office of Volunteer Services authorizes all reasonable COVID-19 grant expenditures in support of the AmeriCorps program effective March 2020 through the end of the crisis period.
However, subgrantees are still required to obtain prior approval from GOVS during this time. If a cost-reimbursement subgrantee needs to incur a cost not approved in the budget, please email both the Compliance Officer and the Sr. Accountant – as a budget revision may be required. The Governor’s Office of Volunteer Services does not relinquish authority to disallow costs on the basis that they do not pertain to the AmeriCorps program, demonstrate a lack of fiscal prudence, or disregard prohibited activities.
At this time, the Governor’s Office of Volunteer Services and subgrantees must adhere to the subgrantee match requirements. We recognize that subgrantees face a difficult fundraising environment and will continue to explore flexibility with this AmeriCorps grant structure. If there is a significant change to a source of funds, subgrantees are encouraged to contact the Governor’s Office of Volunteer Services immediately.
Communication is very important. Consider daily check‐ins by phone or video to allow members to ask questions and feel less isolated. Send the Governor’s Office of Volunteer Services unsolicited updates.