August 1, 2018


Amy Borgstrom

Docket Manager

Corporation for National and Community Service

250 E Street SW

Washington, D.C. 20525


RE: National Association of Foster Grandparent Program Directors Comments regarding the Transformation and Sustainability Plan


Ms. Borgstrom:


As President of the National Association of Foster Grandparent Program Directors (NAFGPD), I appreciate the opportunity to provide comments regarding the Corporation for National and Community Service’s (CNCS) Transformation and Sustainability Plan. 


NAFGPD shares in CNCS' commitment to national service.  With new leadership at CNCS, we believe it is a good time to examine the way in which the Corporation operates and manages its grant programs.  Below are NAFGPD’s thoughts and comments regarding the six goals laid out in the Plan.


Goal 1: Strengthen core business functions


  • NAFGPD supports CNCS’ goal of reducing the administrative burden to grantees.


  • Consistency is critical in increasing grantee compliance to the Criminal History Check requirements.  As such, we would encourage CNCS to examine internal regulations for consistencies, and to ensure that they lay out clear explanations about how to successfully complete these checks.  We believe this consistency and clarity will help to achieve the goal of increasing grantee compliance and decreasing improper payments.


  • NAFGPD would encourage CNCS to ensure that whatever internal structural changes made are designed to ensure that the agency support the missions of the different programs (AmeriCorps, Senior Corps, and VISTA) equally.


  • To decrease improper payments, NAFGPD would recommend additional training and technical assistance around criminal history checks for grantees and program officers.


Goal 2: Strengthen and align grants management and monitoring to improve efficiencies and maximize effectiveness


  • NAFGPD supports the goal of improved communication and a simplified grants management structure for grantees.   


  • While we agree with the recommendations of the Government Accountability Office’s recommendations, it is important to note that there are specific regulations relating to each of the streams of service (AmeriCorps, Senior Corps, VISTA).  As such, NAFGPD would caution that having one program manager for all the streams of service could result in an increase in improper payments due to the challenges of one individual understanding the differences in regulations for the different streams of service. 


  • Additionally, under the proposed model of one program manager for multiple streams of service, NAFGPD would recommend additional training and education for program officers to better understand the regulatory differences between the streams of service at CNCS.


  • Under the current structure, CNCS state office staff work primarily with Senior Corps programs and VISTA.  As a result, they can provide targeted assistance to struggling programs and be proactive in helping find grantees to apply for relinquished funds in their states.  NAFGPD is concerned that under the proposed model of regional program managers, having multiple streams of service as well as several states in their portfolio, the ability of program managers to be proactive to help struggling programs and find grantees to apply for relinquished funds will be lost, which could result in an increase of programs relinquishing their grants. 


  • Some of our members have great working relationships with their state offices, while other have had challenges and inconsistencies.  As such, NAFGPD would want CNCS to provide opportunities for strong state office staff to have a role under the new CNCS structure; and an enhanced training structure for all program officers.


Goal 3: Prioritize evidence-based interventions


  • Foster Grandparent volunteers serve in evidence-informed environments supervised by professionals in the locations in which they serve (schools, head start programs, etc.).  Additionally, our volunteers must support the curriculum of the schools and programs in which they serve.


  • There is an important distinction between evidence-informed versus evidence-based.  NAFGPD would encourage CNCS to consider an evidence-informed approach.


  • Most evidence-based programs require professional evaluations.  Currently, Foster Grandparent programs have small federal grants that will not cover the cost of these professional evaluations.   Should these evaluations become required, CNCS would need to provide grantees with grant augmentations to cover the additional costs.


Goal 4: Simplify and streamline the application process


  • NAFGPD supports the Corporation’s goal of reducing the administrative burden for grantees.


  • NAFGPD believes that Fixed Based grants would simplify the application and grants management process.  The pilot program implemented for Senior Corps in the past was unsuccessful for some programs; however, the overwhelming reason for that was because the baseline amount per VSY was too low to adequately administer a program.


  • Currently, Senior Corps programs have a statutory requirement to ensure that our programs cover rural areas.  Senior Corps has been and will continue to be poised to serve well in our nation’s rural areas.  As such, NAFGPD would ask for assurances from CNCS that the rural programs would be protected as the agency moves forward. 


  • NAFGPD believes that it is important to ensure that as the Corporation considers the idea of a streamline application process that programs within the agency are not competing against each other for funding.  For example, NAFGPD would be concerned if the Foster Grandparent Program was competing against Reading Corps for CNCS funds. 


Goal 5: Simplify the CNCS brand


  • While NAFGPD supports the idea of simplified branding, it is likely that a rebranding effort will result in additional costs to both CNCS as well as grantees.  As such, we would encourage that CNCS provide grant augmentations to grantees to cover the costs associated with a rebranding effort, as well as allow grantees and CNCS to roll out the new branding simultaneously.


  • At the encouragement of CNCS, grantees have embraced the Senior Corps “S” as the identity of our programs.  The “S” denotes that our programs focus on older volunteers and embrace their valuable contributions to their communities.  NAFGPD would caution that to do away with the senior identity completely could have a negative impact on our programs and affect recruitment of age-eligible volunteers.


  • NAFGPD supports a new name and identity for the Corporation and its programs, so as not to appear that one program is absorbing or becoming another.


Goal 6: Align our workforces and workplaces to better serve our customers, meet evolving needs, and ensure efficient use of taxpayer dollars


  • NAFGPD supports the Corporation’s goal of adapting to meet the changing needs of our volunteers and those we serve.  Just as families have changed over the past 50 years, so have the needs of the children the Foster Grandparents serve.


  • NAFGPD supports that the Foster Grandparent Program and the Senior Companion Program stipends should have a cost of living increase.


NAFGPD wants to continue to be partners with CNCS in working toward the common goal of ensuring that the Corporation, as well as our programs, are on a sustainable path forward.  Thank you for the opportunity to comment on the future of CNCS. 




Jeanine Nemitz


National Association of Foster Grandparent Program Directors