NAU Center for Service and Volunteerism
AmeriCorps Programs Prohibited Activities Policy

Updated: April 1, 2022

The list of activities below are prohibited for staff and program participants of the Center for Service and Volunteerism (CSV) AmeriCorps and AmeriCorps Seniors Programs. They are based on sections 132A and 174 of the NCSA (42 U.S.C. §§ 12584a and 12634) and section 403 of the DVSA (42 U.S.C. § 5043), and provisions by Congress in annual appropriations acts.

While charging time to an AmeriCorps or AmeriCorps Senior program, accumulating service or training hours, or otherwise performing activities supported by those programs, staff, AmeriCorps Seniors volunteers, and AmeriCorps members may not be engaged in the following activities:

1 – Political Activities
No part of any award shall be used to finance, directly or indirectly, any activity to influence the outcome of any election to public office, or any voter registration activity. No project shall be conducted in a manner involving the use of funds, the provision of services, or the employment or assignment of personnel in a matter supporting or resulting in the identification of such project with:

a. Any partisan or nonpartisan political activity associated with a candidate, or contending faction or group, in an election; or
b. Any activity to provide voters or prospective voters with transportation to the polls or similar assistance in connection with any such election; or
c. Any voter registration activity, except that voter registration applications and nonpartisan voter registration information may be made available to the public at the premises of the sponsor. But, in making registration applications and nonpartisan voter registration information available, employees of the sponsor shall not express preferences or seek to influence decisions concerning any candidate, political party, election issue, or voting decision.

Notwithstanding 42 U.S.C. § 5043(c), and 45 C.F.R. §§ 2551.121(a)(3) and 2552.121(a)(3), anti-lobbying language in AmeriCorps’s current appropriations legislation (like anti-lobbying language in AmeriCorps’s past appropriations legislation) prohibits recipients from using AmeriCorps funds to pay the salary or expenses of any grant or contract recipient, or agent acting for such recipient, related to any activity designed to influence the enactment of legislation, appropriations, regulation, administrative action, or Executive order proposed or pending before the Congress or any State government, State legislature or local legislature or legislative body, other than for normal and recognized executive-legislative relationships or participation by an agency or officer of a State, local or tribal government in policymaking and administrative processes within the executive branch of that government.

2 – Non-Displacement of Employed Workers
An AmeriCorps Seniors volunteer or AmeriCorps state/national or VISTA member shall not perform any service or duty or engage in any activity that would otherwise be performed by an employee of the sponsor or partner agency, or that would supplant the hiring of, or result in the displacement of employees, or impair existing contracts for services.

3 – Compensation for Service
NAU CSV’s Americorp Seniors Programs (Foster Grandparent, RSVP, and Senior Companion) and partner agencies to which AmeriCorps Seniors volunteers are assigned, or which operates or supervises any AmeriCorps Seniors program, shall not request or receive any compensation from AmeriCorps Seniors volunteers or from beneficiaries for services of AmeriCorps Seniors volunteers.

a. The regulations do not prohibit NAU CSV from soliciting and accepting voluntary contributions from the community at large to meet its local support obligations under the grant or from entering into agreements with parties other than beneficiaries to support additional volunteers beyond those supported by the AmeriCorps grant;
b. A partner agency (volunteer station) may contribute to the financial support of the AmeriCorps Seniors Program. However, this support shall not be a required precondition for a potential station to obtain program services;
c. If a partner agency agrees to provide funds to support additional AmeriCorps Seniors volunteers, or pay for other volunteer support costs, the agreement shall be stated in a written Memorandum of Understanding. The sponsor shall withdraw services if the station’s inability to provide monetary or in-kind support to the project under the Memorandum of Understanding diminishes or jeopardizes the project’s financial capabilities to fulfill its obligations;
d. Under no circumstances shall AmeriCorps Seniors volunteers receive fees for service from service recipients, their legal guardians, members of their family, or friends.

4 – Labor and Anti-Labor Activity
No grant funds, including staff, volunteer, or member time can be used directly or indirectly to finance labor or anti-labor organizations or related activities. This includes assisting, promoting, or deterring union organizing and impairing existing contracts for services or collective bargaining agreements. No grant funds can be used for organizing or engaging in protests, petitions, boycotts, or strikes.

5 – Fair Labor Standards
A sponsor that employs laborers and mechanics for construction, alteration, or repair of facilities shall pay wages at prevailing rates as determined by the Secretary of Labor in accordance with the Davis-Bacon Act, as amended, 40 U.S.C. 276a.

6 – Religious Activities
No staff nor AmeriCorps Seniors volunteer or AmeriCorps state/national or VISTA member shall engage in religious instruction, conduct worship services or engage in any form of proselytization as part of his or her duties, provide instruction as part of a program that includes mandatory religious instruction or worship, construct or operate facilities devoted to
religious instruction or worship, or maintain facilities primarily or inherently devoted to religious instruction or worship.
A sponsor or volunteer station may retain its independence and may continue to carry out its mission, including the definition, development, practice, and expression of its religious beliefs, provided that it does not use AmeriCorps funds to support any inherently religious activities, such as worship, religious instruction, or proselytization, as part of the programs or services funded. If an organization conducts such activities, the activities must be offered separately, in time or location, from the programs or services funded under this part.

7 – Nepotism
Persons selected for AmeriCorps or AmeriCorps Seniors programs staff positions shall not be related by blood or marriage to other project/program staff, sponsor staff or officers, or members of the sponsor Board of Directors, unless there is written concurrence from the community group established by the sponsor and upon prior notification and approval by NAU and AmeriCorps.

8 – Beneficiaries
No staff nor AmeriCorps Seniors volunteer or AmeriCorps state/national or VISTA member shall provide a direct benefit to:
a. A business organized for profit;
a. A labor union;
a. A partisan political organization;
a. A nonprofit organization that fails to comply with the restrictions contained in section 501(c)(3) of the Internal Revenue Code of 1986 except that nothing in this section shall be construed to prevent participants from engaging in advocacy activities undertaken at their own initiative.

9 – Abortion Services
AmeriCorps members are prohibited from providing abortion services or referrals for receipt of such services.

Individuals may exercise their rights as private citizens and may participate in the activities listed above on their initiative, on non-AmeriCorps time, and using non-Corporation funds. Individuals should not wear the AmeriCorps logo while doing so.