ASC Public Comment Letter to the National Commission on Military, National & Public Service

April 13, 2018

America’s Service Commission National Commission on Military, National, and Public Service Public Comment NCMNPS Docket No. 05-2018-01 America’s Service Commissions appreciates the opportunity to provide input into the work of the National Commission on Military, National, and Public Service (Commission) as requested in the public comment opportunity due April 19, 2018. America’s Service Commissions is the national association of the 52 state service commissions, administering 80% of AmeriCorps funding across the country and promoting an ethic of service in their states. State service commissions represent Governor appointed commissioners that direct the work of each state service commission with the goal of engaging people of all ages in service to address pressing community needs. America’s Service Commissions represents the state service commission network and their role in volunteering and national service programs such as AmeriCorps.

For the purpose of this public comment, it should be noted that the state service network defines AmeriCorps as a “national service” program. The current NDAA definitions of “National Service” and “Public Service” do not capture the important work of the federally administered national service program, AmeriCorps, and other service programs. America’s Service Commissions joins our partner Service Year Alliance in recommending that the Commission reexamine the current NDAA definitions of national and public service.

Specifically, we recommend: • Aligning with the Domestic Volunteer Service Act Definition: The current NDAA definitions of ‘‘National Service’’ and “Public Service” differ from the definition in the Domestic Volunteer Service Act, 42 USC 12511(26). The Domestic Volunteer Service Act sets forth specific definitions and criteria about “national service positions,” term lengths, eligibility, activities, benefits, and other matters which have guided program implementation.

• Reconsidering the Term “Employment”: If “civilian employment” is intended to mean traditional employment for wages according to applicable labor laws and regulations, service in AmeriCorps would not be included because AmeriCorps members earn a subsistence living allowance for national service, not wages for paid employment.

Our public comment primarily focuses on 1) broadening the current definitions of national and public service to include national service programs, such as AmeriCorps; 2) partnering with Governor’s state service commissions as the primary leaders for service in their respective states to develop a state strategy for national and public service and; 3) expanding AmeriCorps and other national service programs to provide more opportunities to serve, while integrating them into existing military infrastructures to create a pipeline of service.

If you have questions regarding this public comment, please contact Rachel Bruns, Deputy Director of America’s Service Commissions at rbruns@statecommissions.org or (515) 255-3791.

Public Comment Answers (1) Is a military draft or draft contingency still a necessary component of U.S. national security?

America’s Service Commissions has no comment or opinion on the necessity of the draft.

(2) Are modifications to the selective service system needed?

America’s Service Commissions has no comment or opinion on the selective service system.

(3) How can the United States increase participation in military, national, and public service by individuals with skills critical to address the national security and other public service needs of the nation?

The United States can increase participation in military, national and public service by making civilian national service opportunities such as AmeriCorps more integrated into existing military structures. For example, the United States military has an extensive recruitment infrastructure, while AmeriCorps is run by the Corporation for National and Community Service (CNCS), has no formal recruitment infrastructure and individual programs must conduct their own recruitment. This has created a situation where almost 25 years into the existence of AmeriCorps there is still a significant lack of awareness of AmeriCorps as an opportunity for Americans of all ages to serve their country. For the first time in history, less than 1 percent of Americans are serving in our nation’s military and approximately 71% of the 34 million 17-to-24-year-olds in the U.S. would not qualify for military service because of reasons related to health, physical appearance and educational background. Yet, polling shows that young adults of all background want to serve. Using the military’s existing recruitment infrastructure to incorporate all civilian national service programs, such as AmeriCorps would help to increase awareness of other non-military service opportunities for young Americans. While each individual AmeriCorps program has its own entry requirements, the vast majority of Americans would be able to serve in an AmeriCorps role regardless of their health, physical appearance or education background.

AmeriCorps programs are already having a significant impact in addressing the needs of the nation. While the priorities of each state service commission vary depending on their state needs and their Governor’s priorities, across the nation the top five priorities of state service commissions include: education, economic opportunity, volunteerism, opioid epidemic, and healthy futures. Other priorities represented include environment, disaster services, public safety and demographic specific engagement (seniors, youth, disability, veterans).

State service commissions are leading the nation in developing AmeriCorps programs addressing critical community needs. Each state service commission receives a formula allocation of funding to support statespecific needs. In addition, state service commissions compete in a competition for national funding. In 2017, 80% of all AmeriCorps funding flowed through state service commissions to programs addressing locally identified needs. These programs are addressing a wide-range of needs, but a few examples include: Education — Developed with support and funding from ServeMinnesota, the state service commission for Minnesota, Reading Corps is a breakthrough program that is changing academic outcomes for thousands of

students. With more than 1,500 tutors serving in twelve states and Washington D.C., Reading Corps is helping more than 36,000 children each year become successful readers. It combines the power of national service with literacy science to deliver proven approaches that help struggling learners transform into confident students – something that translates into all areas of their lives.

Disaster Response — A majority of state service commissions (52%) are formally written into their state’s emergency response plan and many others have roles defined outside of the formal plan. State service commissions are typically charged with managing unaffiliated spontaneous volunteers during times of disaster, coordinating volunteers and donations, and deploying AmeriCorps resources to respond to state disasters. Other roles may include disaster fund management and serving as the public information office. In addition, 53% of state service commissions have a program in their portfolio that respond to disasters including programs like the Washington Conservation Corps. Funded and supported by Serve Washington, the Washington Conservation Corps (WCC) is an AmeriCorps program engaging young adults between the ages of 18-25 and military veterans in the restoration of critical habitat, building trails, and responding to local and national disasters. WCC crews are deployed to disasters throughout the country, most recently including supporting gutting and mucking and other needs related to Hurricanes Harvey, Maria and Irma.

Opioid Epidemic — The opioid epidemic is an emerging and growing issue that AmeriCorps is responding to, especially where the needs are greatest related to recovery. Supported by the Massachusetts Service Alliance, the state service commission in Massachusetts, the Police Assisted Addiction & Recovery Initiative (PAARI) places AmeriCorps members across Massachusetts to address the growing opioid epidemic. With member support, each police department will have the ability to directly refer and place 50 or more people into treatment. Supported from Volunteer New Hampshire, the Community Resource Corps (CRC) program is a new AmeriCorps project in New Hampshire, designed to improve health and health outcomes for individuals affected by substance use and behavioral health disorders. All members support the work of primary care clinics, behavioral health centers and other social service organizations by being part of a health Care Team.

We recommend the Commission partner further with America’s Service Commissions and its network of 52 governor appointed state service commissions to identify opportunities to expand AmeriCorps and integrate AmeriCorps recruitment and awareness into existing military structures (National Guard, etc.) as a way to engage all Americans in service to country. As leaders for service in their states, the state infrastructure already exists through state service commissions and their programs to engage Americans in non-military national service programs.

(4) What are the barriers to participation in military, national, or public service?

The biggest barrier facing AmeriCorps is a lack of awareness regarding the opportunity and its benefits.

According to our partner, Service Year Alliance, only 29% of 14-24 year olds are aware of service year options yet 80 percent of Millennials want to participate in national service. We need to help young people and their parents understand the benefit to them giving a year of service or more to their country. Some of those benefits include gaining skills, getting a better job or getting into a better school, earning money for college or to pay student loans and more.

Due in part to the lack of awareness, AmeriCorps programs are struggling with member recruitment. In 2017, the state service commission network ranked member recruitment as the second biggest challenge facing their work, followed by AmeriCorps member retention. As the economy and unemployment continue to improve, recruitment and retention of AmeriCorps members becomes more and more challenging. The Commission has an opportunity to develop a culture of service that provides an opportunity for all Americans to serve their country, not just the 1% that meet the physical attributes.

Other barriers facing participation in AmeriCorps civilian service includes the inequity of access. Currently, given the financial burdens of AmeriCorps service including housing, food, relocation, etc., a significant number of AmeriCorps members are those that have the support systems to do so. AmeriCorps members earn a modest living allowance to assist them in paying for rent and food, but that living allowance has not increased significantly over the last 10 years. While there are exceptions and many programs and state service commissions develop local strategies to reduce the barriers to service, the structural barriers exist that makes it challenging for someone without a support system to serve.

As the Commissions works to make its final recommendations, it should include recommendations to improve the access and equity of civilian national service program like AmeriCorps, as well as strategies to increase the awareness.

(5) Does service have inherent value, and, if so, what is it?

Yes. Service has an inherent value to our democracy. As noted by Alexis de Tocqueville in Democracy in America, “There is no end which the human will despairs of attaining through the combined power of individuals united into a society.” Service provides at least three benefits. First to the volunteer themselves, as demonstrated by numerous research studies on the benefits of service on the volunteer; second, to the primary beneficiary of the service through direct community impact, which can be measured over time; and third, to the greater society, in the form of creating community connections, social capital and bonds that enable society to function effectively.

State service commissions exist to carry out and promote the inherent value of service in their states.

Congress understood this inherent value when it authorized the Domestic Volunteer Service Act of 1973 and renewed this commitment to service in the National and Community Service Act of 1990, the National and Community Service Trust Act of 1993 and the 2009 Serve America Act. (6) Is a mandatory service requirement for all Americans necessary, valuable, and feasible?

America’s Service Commissions does not have a comment on a mandatory service requirement. We believe service should be a common expectation for all Americans and the recommendations of this Commission should work to expand the infrastructure and resources for organizations to support service opportunities like AmeriCorps. The Serve America Act of 2009, authorized up to 500,000 AmeriCorps positions. At current funding levels, we have not been able to support more than 80,000 AmeriCorps positions. In order to meet the demands to engage all young Americans in service, there needs to be an investment in programs like AmeriCorps to provide enough meaningful opportunities.

Knowing the military does not have the ability to absorb an influx of recruits that may not meet the minimum requirements, programs like AmeriCorps could be integrated into the national service pipeline and recruitment infrastructure to accommodate all young Americans with a desire to serve.

(7) How does the United States increase the propensity for Americans, particularly young Americans, to serve?

There is an estimated $1.5 trillion in student loan debt in this country with an average monthly payment of more than $350/month. One of the benefits at the end of successfully completing a full term of AmeriCorps service is a Segal Education Award, equal to the Pell Grant (for less than full-time positions the Education Award is prorated proportionally based on the length of service). The Education Award can be used to pay o eligible student loans or pay for future postsecondary tuition. There is an economic opportunity to provide educational benefits for service to country. We encourage the Commission to explore recommendations that would expand the educational benefits for service to reduce student debt, improve the economy and increase the propensity for young Americans to serve. Recently, Senators Reed (RI), Coons (DE) and Blumenthal (CT) have proposed legislation that would expand the educational benefit of serving in AmeriCorps. Their legislation proposes that by completing two full terms of service, participants would receive an educational benefit equal to four years of the average in-state tuition at a public, four-year college. In addition, any recommendations should ensure there is no tax penalty for receiving this educational award. Currently, while many states do not tax the AmeriCorps education award, the federal government considers it taxable income and this creates yet another barrier and penalty for Americans that have just completed a year of service to their country.

There needs to be a greater incentive and a support system to increase the propensity for young Americans to serve. As stated earlier, we know that a majority of millennials want to serve, but a variety of factors keep them from serving. We need to expand the infrastructure to support young Americans serving in civilian national service programs like AmeriCorps and increase the benefits or at least increase awareness of the existing benefits.

America’s Service Commissions welcomes the opportunity to work with the Commission to explore these vital questions in order to further national and public service in America.