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LEO-MCSC AmeriCorps State Grantee Guidance
Last Updated 5.9.2025
Disclaimer: This guidance should not be misconstrued as official AmeriCorps guidance. Programs are encouraged to confer with their legal counsel on any actions. If you have additional questions, please email LEO-grants@michigan.gov and LEO-MIAmeriCorps@michigan.gov.
Summary: As programs were made aware, the Trump-Vance Administration terminated Michigan’s AmeriCorps funding on April 25, 2025, effective immediately. As a result, the LEO-MCSC issued a Stop Work Order to let grantees know that we cannot guarantee reimbursement for expenses incurred after April 25, 2025.
On April 29, 2025, 24 states, including Michigan, filed suit challenging the Trump Administration's termination of AmeriCorps grants to state service commissions. It is our hope that this suit will be successful and grant funding will be restored. In the interim, we will continue to update this guidance as new information becomes available. We understand this is a difficult time and appreciate your patience and understanding as we work to get the most accurate information to you as quickly as possible.
What does a Stop Work Order mean for our program?
A stop work order means LEO-MCSC cannot guarantee reimbursement for expenses incurred after April 25, 2025. At this time LEO-MCSC is not terminating any grants or preventing grantees from continuing grant activity at grantees’ own expense. While LEO is not terminating any grants at this time, programs may initiate termination of their grants. Programs who wish to terminate their grant should contact their Program Officer.
Is there a date when the Stop Work Order will be transitioned to a termination?
At this time, subgrantees remain under a Stop Work Order. More information or updates on the Stop Work status will be shared when available.
Does a Stop Work Order require programs to exit members?
No. Programs can do one of the following options:
Can programs exit members for Compelling Personal Circumstances (CPC)?
Yes, members can be exited for CPC if their exit is a result of the federal termination of grants. The termination of the grant by the AmeriCorps Agency is considered a Compelling Personal Circumstance. (See Termination Notice below) Should your program decide to exit members for CPC, they should be eligible for a prorated education award in egrants. We recommend keeping the Termination Letter as documentation of eligibility for CPC.
Are members at risk of not receiving their prorated Segal Education Award if we do not exit them within 30 days of 4/25/25?
Members must be exited within 30 days of their last day of service (4/25 for those that were enrolled at the time AmeriCorps issued the Termination Notice) unless funding is reinstated. Historically members who were exited after 30 days were still eligible for an education award, but we encourage programs to adhere to the 30 day exit rule in all cases.
Can programs use their own funds to transition members to employees or volunteers to continue services?
If a program wants to do this, they need to end the member’s service. However, you may wait the 30-day exit period before exiting the member in eGrants. In the event AmeriCorps funds are reinstated, the individual could be re-engaged as AmeriCorps member.
The relationship with the individual changes and the organization will need to follow applicable labor laws, etc.
To avoid future issues or concerns around duplication/supplantation, programs are encouraged to create a distinct position description (whether employee or volunteer) that differentiates it from their AmeriCorps position. Position activities could overlap, but there should be a distinct difference to avoid displacement/duplication issues with prohibited/unallowable activities. This is a concern if the program plans to continue as a grantee in the future.
Can members be transferred to another AmeriCorps program that is still operational?
Per the termination notifications, AmeriCorps is encouraging transferring members when possible. Exploring options for having members transfer to a non-impacted program can be a good justification for not immediately ‘exiting’ members and instead allowing them to stay in an ‘active’ status for a period of time.
If you arrange for a member to be transferred to an existing program, please contact your MCSC Program Officer to initiate the process in eGrants.
It is our understanding that programs can transfer members to any other existing program that has available slots. The receiving program will need to conduct a new National Service Criminal History Check.
What guidance can we provide to members at this time?
Members should be made aware of the Stop Work Order and your program’s plan during this time. Please also refer members to Life After AmeriCorps resources:
Can we pro-rate member living stipends if 4/25 fell in the middle of a pay period?
Programs can pro-rate member living allowances based on days, not hours. Programs will need to work internally with their finance team to determine pay schedule and amount.
Can members record hours served after 4/25 in OnCorps?
No.
Can programs provide members with an “end of service incentive”?
Yes, if your program has existing policies on an end of service incentive you could reasonably provide the completed end of service incentive, as per the agency’s termination letter, the member’s early exit is at no fault of the member.
This is not recommended if an existing policy or end of service/retention incentive is not in place, as it could be risky and create perception issues.
We cannot guarantee reimbursement for expenses incurred after April 25, 2025.
Will education awards previously awarded be taken back?
Our understanding is that when the member enters into a term of service, the funds for their Segal Education Award are already in the National Trust that are dedicated for their Segal Education Award. We are not currently aware of any instances in which the Segal Education Award has been rescinded due to the termination of the program.
If a program has host site fees (program income) unspent, what should they do with it?
Programs with unspent host site fees should determine if those funds can be used for a future grant and complete that service at a future date or return the proportional share of the host site fees/program income if the member service will not be completed.
Will AmeriCorps members be eligible for loan forbearance during the Stop Work Order?
AmeriCorps members may be eligible for forbearance during the Stop Work Order, which postpones repayment of qualified student loans while a member is in service.
Most federally guaranteed student loans are eligible for forbearance. If the loan does not qualify for forbearance based on AmeriCorps service, the individual may be eligible for another type of deferment or forbearance. The loan holder should be contacted to determine eligibility and options.
Members may want to consult with their loan holders for more information once they know their official exit date. Members can be directed to this page for information on loan forbearance.
When does a member's health insurance coverage end?
This depends on the provider you use.
The Corps Network, used by many AmeriCorps programs, typically ends coverage on the last day of the month in which the member’s active service terminates. To provide more flexibility, the Corps Network plan is relaxing a couple eligibility provisions. This will allow temporarily maintaining a member’s eligibility in the event of:
Please check with your program’s provider for the most accurate information.
Will AmeriCorps members impacted by grant terminations be eligible for interest accrual?
After successful completion of a term of service and the member earns an education award, the Trust will pay all or a portion of interest accrued on qualified student loans during an AmeriCorps term of service. Interest payments are not subtracted from the education award, they are made in addition to the education award.
AmeriCorps members must complete a term of service and have earned an education award for the Trust to make an interest payment.
The portion of accrued interest that the Trust pays is determined by the type (full or part-time) and length of service. Typically, members who completed full-time terms, completed the term within 12 months, and received education awards will have 100% of the interest paid that accrued on their qualified loans during service. Members completing part-time terms may not be eligible to have all of the accrued interest paid.
Electronic requests to have a payment made for the interest accrued on a qualified student loan during service can be done from MyAmeriCorps.
Note: AmeriCorps does NOT send reminders to request interest accrual payments. Members may be directed to this page for information on interest accrual.
Some members are experiencing challenges accessing the exit survey in the MyAmeriCorps portal. What should we do if they can’t complete the exit survey?
If members are having issues, the helpdesk agent advises to have the members clear their browser cookies and sign in again.
If they still have issues, they should call 1-800-942-2677 and select option #2.
If the above does not work, historically the program director/staff would have access to the member exit form, and could submit the response on behalf of the member. If there are issues with member access to process a timely exit, we recommend documenting this situation, and the program director/staff can assist in completing the exit form in eGrants.
What is the grant close out process?
Information about the 2024-25 Grant Close Out process will be posted in Basecamp. The Michigan Community Service Commission’s annual program closeout includes two sets of procedures: one set of requirements for closing out programmatic activities and one for finalizing fiscal issues.
Programmatic closeout procedures include successfully documenting progress toward stated performance measures, completion of member service terms and related documents, and submission of all MCSC closeout forms within 60 days of the program end date in the grant.
Fiscal closeout procedures include submission of final cash requests, CNCS Closeout Forms, and final AFR within 60 days of the grant end date provided in the grant and/or grant amendment.
At this time your grant agreement with LEO has not been terminated so you do not yet need to start close out procedures.
What are reasonable close-out costs?
Per the CFR, close out costs can include necessary administrative costs of that Federal award (for example, salaries of personnel preparing final reports, publication and printing costs, costs associated with the disposition of equipment and property, and related indirect costs).
At this time your grant agreement with LEO has not been terminated so you do not yet need to start close out procedures.
Are we able to communicate with our Program Officer?
Yes. Please send all questions to LEO-Grants@michigan.gov and LEO-MIAmeriCorps@michigan.gov. You may also cc your Program Officer.
Is my program required to meet match requirements?
Yes, programs are required to meet the regulatory match requirements. If your program is unable to shift funding sources to meet regulatory match, you may submit a match waiver request. However, we cannot confirm if additional match waivers will be approved and/or the length of time it may take to receive an approval from the AmeriCorps agency. If your program already has an approved match waiver the percentage approved in the waiver is still the required match percentage.
If you wish to submit a match waiver request or you are concerned about your organization’s ability to meet the regulatory match requirements, please contact your Program Officer.
If we no longer have an AmeriCorps grant as of 4/25/25, does that mean the remaining match funds are no longer tied to this grant and are therefore unobligated or no longer restricted?
Your grant agreement with LEO has not been terminated. Matching funds you have already secured are tied to your AmeriCorps grant until the closeout is finalized. Unless your program seeks to terminate the grant agreement and submits a final cash request that effectively closes the grant, then match funds are still obligated.
Can programs incur staff costs after the project period as part of closeout costs?
Administrative costs associated with the closeout activities of a Federal award are allowable (2 CFR 200.403(h) and 2 CFR 200.472(b): 2 CFR 200.472(b)). This can include personnel costs associated with closeout activities such as preparing final reports. Programs should clearly document that costs incurred after the termination of the grant were part of necessary closeout procedures and not just continuation of regular service activities.
Is severance pay for program staff allowed?
Yes per § 200.431, but severance pay requires prior approval and can be a matter of negotiation with the government on what their “fair share” would be. Organizations should follow their existing policy surrounding severance pay.
Did LEO submit an appeal to the grant terminations?
The AmeriCorps notice of termination letter issued on 4/28 to LEO-MCSC stated that “This is a final agency action and is not administratively appealable.” However, LEO did object to the legality of the termination in communication to AmeriCorps sent on 4/28. Additionally, Michigan Attorney General Dana Nessel joined a lawsuit with 23 other states challenging the grant terminations and the dismantling of the agency through an 85% reduction of its workforce.
Will you share the official notice of termination received from AmeriCorps on 4/25?
Yes. The notice was shared with all grantees on 5/5 via email and is linked below.
If the subgrant agreements are terminated, will MI AmeriCorps programs receive a formal notice with an effective date?
Yes, if LEO terminates subgrants, all subgrantee programs will receive a formal notice with an effective end date.
Before the Stop Work Order, we submitted a No Cost Extension (NCE) request for our 2024-25 grant. If FY24 funding is reinstated, will LEO-MCSC still process the NCE request?
Yes, we are working internally to process the NCE requests and if FY24 funding is reinstated we will finalize and approve them.
What is the status of the Russ Mawby Signature Service Projects?
We are working to understand the plan in each region. Here is what we know:
Northern MI: unknown
West MI: Moving forward with a service project: https://3.basecamp.com/3624101/buckets/13461928/chats/2024795033
Flint Area: unknown
Mid-MI: unknown
Southeast MI: Moving forward with a service project: https://www.eventbrite.com/e/rouge-park-appreciation-day-tickets-1291842649139?aff=oddtdtcreator