December 21, 2011 Robert Velasco II Acting Chief Executive Officer Corporation for National and Community Service

1201 New York Avenue, NW Washington, DC 20525 Dear Mr. Velasco: Americas Service Commissions writes on behalf of the nations 53 state service commissions. As we have previously stated, we are disappointed and surprised with Congress's decision on the dramatic fiscal year 2012 cuts to state service commissions. These funding cuts have the potential to severely jeopardize the critical oversight and compliance obligation commissions have over approximately $240 million dollars in federal funds and AmeriCorps programs. Commissions have been on the front lines of program and fiscal management and oversight since the inception of the Corporation for National and Community Service and have a long track record of success. The Corporation for National and Community Service has always made rigorous oversight of its programs by commissions a priority. You reinforced that earlier this year at a Congressional hearing where you detailed the agency's commitment to accountability, oversight, and monitoring practices. You included that commissions are responsible for subgrantee compliance and ensuring that each AmeriCorps member supported under each commission grant receives proper training on prohibited activities, monitoring, and supervision. Further, you stated that all of the steps included in the action plan to prevent prohibited activities detailed to Congress involve the commissions and that the Corporation relies on principles of local control and the agency recognizes that many of the best solutions come from outside Washington. State service commissions have been and will continue to be the Corporations statutebased partner in fulfilling the Corporations commitment to the American people of providing accountability and oversight of these vital national service resources. However, we believe it is necessary that we will require restoration of some funds to fulfill that commitment. As you know, the statute states that commissions are authorized to use not more than five percent of the amount of their AmeriCorps grants to pay for administrative costs. The
American Association of State Service Commissions 1875 K Street, NW / 5th Floor / Washington, DC 20006

regulations state that the distribution of administrative costs between the grant and any subgrant will be subject to the approval of the Corporation. Currently, the Corporation allows for commissions to use one percent of their AmeriCorps grants for administration. Given the critical need for program accountability, oversight, and compliance and the unfortunate cuts to commissions federal resources, we respectfully request that in accordance with the statute the Corporation provide the authority to commissions to make their own determination in regard to the administrative costs distribution. We request that this be in effect immediately for current grants and those going forward. State service commissions have been quite prudent in their use of their grants administrative costs and that would remain the case if the requested authority for local determination was in effect. As you know, any additional administrative funds acquired by Commissions will not come close to replacing the loss suffered in the current appropriation. . Thank you for your consideration. Sincerely,

Paula Kaiser VanDam Chair

Tom Branen Executive Director

American Association of State Service Commissions 1875 K Street, NW / 5th Floor / Washington, DC 20006