Public Comments

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July 6, 2026
AmeriCorps Agency Colleagues,
This comment is in response to the public comment opportunity related to Agency
Information Collection Activities; Comment Request; AmeriCorps VISTA Application and
Reporting Forms.
This comment is submitted on behalf of America’s Service Commissions (ASC), the national
association of the 52 governor-designated state and territorial service commissions. Service
commissions are responsible for administering AmeriCorps State funding and promoting
service in their respective states and territories. Additionally, there are more than a dozen
commissions that act as AmeriCorps VISTA project sponsors, and many other who collaborate
with and support local VISTA projects.
We appreciate the agency reviewing these documents and processes with the goal of
streamlining and updating for clarity and understanding. With this in mind, we encourage the
agency to take a deeper look at the documents and accompanying systems, materials, and
processes for further streamlining.
For example, we encourage the agency to consider consolidating the VISTA Progress Report
Supplement (VPRS) with the Project Process Report (PPR). Having a singular reporting period
to manage, rather than two distinct and different reporting periods, would reduce the
reporting and data collection/management burden on projects. (PPR is on the individual
project’s grant cycle, while VPRS is on the federal fiscal year for all projects).
Additionally, we noted in our review of the documents that the documents seem to be written
from the view point of a project that is operated by a singular organization placing member’s
at only that agency (single-site or multi-service site projects) and intermediary projects find it
difficult to fit the requested information into the page limits/section limits. Additionally, we
suggest revising the various instructions documents for intermediary projects to make it
more clear on what is required of, helpful for, and reasonable for intermediary projects to
provide, and to balance the additional burden of sections where intermediaries have
additional prompts or lengthier responses, like the PPR’s Intermediary Project Model section
which has 6 additional prompts for intermediaries. Additional examples of areas we believe
further streamlining could take place:
•

Within the PPR, the Sustainability narrative section is difficult to fully address for
intermediary projects. We recommend making this section N/A for intermediary

projects, and instead have intermediary projects address how they ensure service
locations are building sustainability in the Intermediary Project Model narrative.
•

Within the PPR, the Partnership Collaboration Development narrative section can
become very lengthy and burdensome for intermediary projects. We recommend this
section be N/A for intermediary sponsors or to specify in the instructions that
intermediaries should discuss what partnership development looks like as the
sponsor organization, not for each individual service locations that are part of the
project.

The following sections will address comments for each of the documents included in the
public comment opportunity.
Concept Paper and Project Application Instructions
Streamlining the application instructions to include both the concept paper and the
subsequent application instructions does not raise issue for our network. We again encourage
the agency to continue to explore avenues that balances streamlining processes to fit their
capacity, takes the burden on grantees into considerations, and collects necessary and
impactful data.
Continuation Application Instructions
We highly recommend revising these instructions for intermediary projects to provide clear
instructions on what is required of, helpful for, and reasonable for intermediary projects to
provide. There are numerous sections where intermediary project’s responses — especially
projects with a large number of VISTA Volunteers, a large number of service sites, or large
service-area (statewide, regional, or perhaps a national program) — would have a great
burden to collect, condense, and collate the requested information in the current form. We
encourage the agency to further review for areas of the Continuation Application Instructions
that would reduce the burden on all parties involved in writing, reviewing, and approving the
submission. Additional comments the Performance Measure module is provided below in the
Project Progress Report Instructions section of this comment.
Project Progress Report Instructions
We have a number of recommendations and requests in response to the PPR instructions:
• Seeing the PPR turn into an annual submission — rather than semi-annual — is great.
•

Having a due date of 30 days after the project end date is challenging for intermediary
projects to collect all the data from service sites, then review, clarify, aggregate, and
compile to submit by the deadline. We recommend and highly encourage the agency
to implement a due date of 60 days after project period end date for the PPR.

•

For the Member Development section, we appreciate the agency streamlining the
question, however, we encourage the agency to take another look at the importance
of the section as a whole. The information provided does not feel impactful and it is
unclear how the agency uses this information. If the objective is to ensure that VISTA
Volunteers are receiving training, perhaps simply have the sponsor certify to this fact.

•

The Demographics section heading itself is confusing. If possible, we recommend
changing the name of the section all together.
o We see the addition of lines 5-7, which appear to have come over from the
VPRS report. Projects should not have to report the same data, from differing
time periods, on two different reports. This is evidence that the agency should
consider condensing the VPRS and the PPR into one report submission for
projects.
o Additionally, lines 5-6 are data points that are rather abstract and are not
clearly linked to VISTA Volunteer service since it asks about youth and
veteran/military family members receiving services provided by VISTAsupported partners and service sites in all focus areas. These services may or
may not have direct impacts from the VISTA Volunteers or their service
activities, thus making the question broader than the scope of the VISTA
project. We recommend removing these questions, or at the very least, revising
the question to be clearer to collect youth and veteran/military family
members receiving services provided by VISTA-supported efforts and
initiatives.

•

The Resource Development section is cumbersome to submit in narrative form. Is this
necessary information for VISTA to collect?

•

Within the Performance Measures module there is a field about the number of VISTA
serving under each performance measure. Is this necessary to collect? This can get
confusing to enter when a VISTA serves consecutive terms — is this 1 VISTA or 2
VISTAs; when a VISTA serves only a very short time within the reporting period; when 1
VISTA serves the second half of their term in a reporting period and a new VISTA serves
the first half — this is listed as 2 VISTAs but there’s only been the equivalent of 1 VISTA
serving in the reporting period. If this is necessary for the agency to collect, we
encourage the agency provides additional clarity on how to appropriately calculate
the number to input. However, if there is opportunity to remove this field from the
report, we recommend the agency move forward with removing this field.

Support Grant Budget Instructions

In the Allowable Expenses section, the language was changed to include the bolded phrase
“in their second year and beyond”. Does this mean the second year with the same project, the
same site, in general? Additionally, this distinction creates an imbalance between VISTA
Volunteers that may be serving at the same site. It is unclear what the reasoning behind
adding this phrase is. Perhaps this language should be removed, and the agency can further
lean into the sponsor’s requirement to be a non-first year sponsor to utilize support funds for
these purposes, as later noted in the Allowable Expenses section.

Thank you for the opportunity to provide comment. We welcome the opportunity to further
discuss this comment. Please contact me at [email protected], if there are any
questions or opportunities for discussion.

Sincerely,
Alli Zuel, CVA
Network & Volunteer Engagement Manager
America’s Service Commissions (ASC)