2022-003 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Procurement Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1631 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law. Condition: Our testing detected five instances in which the transaction exceeded the DPLS?s micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing DPLS?s considerations over the procurement process. Effect: Without completing a written evaluation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 60 disbursements. Out of the 60 disbursements, five items exceeded DPLS? micro-purchase threshold. Repeat Finding from Prior Year: Yes. 2021-003 reported a similar finding over procurement. Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Views of Responsible Officials: Management is in agreement.
2022-004 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1630 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: One instance identified in which hours worked by an employee did not agree to hours paid. Cause: There was a lapse in oversight of the internal control process ensuring hours worked reconciled to hours paid. Effect: DPLS? controls did not detect or correct the errors identified, which results in a reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported. The error was corrected in a subsequent pay period. Context/Sampling: A nonstatistical sample of 60 payroll transactions that had time charged to the LSC grants were reviewed. Total LSC direct payroll accounted for $539,572 out of $876,222 direct payroll expenditures. Repeat Finding from Prior Year: Yes. 2021-004 reported a similar finding over payroll. Recommendation: We recommend DPLS review payroll policies and procedures with applicable employees to ensure compliance with documented procedures. Views of Responsible Officials: Management is in agreement.
2022-005 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1644.4 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. For each case filed in court by the auditee?s attorneys on behalf of a client, case disclosure information is required to be reported to Legal Services Corporation. Condition: One instance identified in which the Grant Compliance Checklist wasn?t completed as required by DPLS policy. Additionally, one instance identified in which Form 1644 Disclosure of Case Information was not completed timely, resulting in the case information not being reported to the Corporation. Cause: There was a lapse in oversight of the internal control process ensuring case files include the required documentation to ensure cases are in compliance with the applicable federal standards. Effect: Lack of compliance with designed internal controls over case files could result in DPLS using funds for cases that are not eligible for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 62 case files. Repeat Finding from Prior Year: Yes. 2021-005 reported a similar finding over eligibility. Recommendation: We recommend DPLS review policies and procedures with applicable employees and remind them of the importance of established review and monitoring processes. Views of Responsible Officials: Management is in agreement.
2022-006 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Reporting Significant Deficiency in Internal Control over Compliance Criteria: Grant Terms and Conditions No. 6 establishes various reporting requirements for the auditee. Condition: DPLS entered a lease of personal property exceeding $25,000 requiring the completion of an application of approval, however, this was not completed. Additionally, DPLS entered a lease to relocate office space for an existing branch office requiring an update to DPLS? Grantee Profile on GrantEase within 15 calendar days, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring LSC approval was received prior to entering a personal property lease exceeding $25,000. Additionally, there was a lapse in oversight of the internal control process ensuring the Grantee Profile was updated in GrantEase after relocating office space for an existing branch office. Effect: Failure to notify LSC prior to certain events could result in the reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 4 out of 8 annual and semi-annual reports were selected for testing. Additionally, as documented within LSC Reporting Requirements, Prior Approval Requirements Applying to Certain Events, Waivers of Requirements Applying to Certain Events and Reports Contingent on the Occurrence of Certain Events were tested in total. Repeat Finding from Prior Year: Yes. 2021-008 reported a similar finding over reporting. Recommendation: We recommend DPLS review LSC reporting requirements with applicable employees. Views of Responsible Officials: Management is in agreement.
2022-003 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Procurement Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1631 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law. Condition: Our testing detected five instances in which the transaction exceeded the DPLS?s micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing DPLS?s considerations over the procurement process. Effect: Without completing a written evaluation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 60 disbursements. Out of the 60 disbursements, five items exceeded DPLS? micro-purchase threshold. Repeat Finding from Prior Year: Yes. 2021-003 reported a similar finding over procurement. Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Views of Responsible Officials: Management is in agreement.
2022-004 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1630 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: One instance identified in which hours worked by an employee did not agree to hours paid. Cause: There was a lapse in oversight of the internal control process ensuring hours worked reconciled to hours paid. Effect: DPLS? controls did not detect or correct the errors identified, which results in a reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported. The error was corrected in a subsequent pay period. Context/Sampling: A nonstatistical sample of 60 payroll transactions that had time charged to the LSC grants were reviewed. Total LSC direct payroll accounted for $539,572 out of $876,222 direct payroll expenditures. Repeat Finding from Prior Year: Yes. 2021-004 reported a similar finding over payroll. Recommendation: We recommend DPLS review payroll policies and procedures with applicable employees to ensure compliance with documented procedures. Views of Responsible Officials: Management is in agreement.
2022-005 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1644.4 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. For each case filed in court by the auditee?s attorneys on behalf of a client, case disclosure information is required to be reported to Legal Services Corporation. Condition: One instance identified in which the Grant Compliance Checklist wasn?t completed as required by DPLS policy. Additionally, one instance identified in which Form 1644 Disclosure of Case Information was not completed timely, resulting in the case information not being reported to the Corporation. Cause: There was a lapse in oversight of the internal control process ensuring case files include the required documentation to ensure cases are in compliance with the applicable federal standards. Effect: Lack of compliance with designed internal controls over case files could result in DPLS using funds for cases that are not eligible for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 62 case files. Repeat Finding from Prior Year: Yes. 2021-005 reported a similar finding over eligibility. Recommendation: We recommend DPLS review policies and procedures with applicable employees and remind them of the importance of established review and monitoring processes. Views of Responsible Officials: Management is in agreement.
2022-006 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Reporting Significant Deficiency in Internal Control over Compliance Criteria: Grant Terms and Conditions No. 6 establishes various reporting requirements for the auditee. Condition: DPLS entered a lease of personal property exceeding $25,000 requiring the completion of an application of approval, however, this was not completed. Additionally, DPLS entered a lease to relocate office space for an existing branch office requiring an update to DPLS? Grantee Profile on GrantEase within 15 calendar days, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring LSC approval was received prior to entering a personal property lease exceeding $25,000. Additionally, there was a lapse in oversight of the internal control process ensuring the Grantee Profile was updated in GrantEase after relocating office space for an existing branch office. Effect: Failure to notify LSC prior to certain events could result in the reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 4 out of 8 annual and semi-annual reports were selected for testing. Additionally, as documented within LSC Reporting Requirements, Prior Approval Requirements Applying to Certain Events, Waivers of Requirements Applying to Certain Events and Reports Contingent on the Occurrence of Certain Events were tested in total. Repeat Finding from Prior Year: Yes. 2021-008 reported a similar finding over reporting. Recommendation: We recommend DPLS review LSC reporting requirements with applicable employees. Views of Responsible Officials: Management is in agreement.
2022-003 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Procurement Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1631 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law. Condition: Our testing detected five instances in which the transaction exceeded the DPLS?s micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing DPLS?s considerations over the procurement process. Effect: Without completing a written evaluation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 60 disbursements. Out of the 60 disbursements, five items exceeded DPLS? micro-purchase threshold. Repeat Finding from Prior Year: Yes. 2021-003 reported a similar finding over procurement. Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Views of Responsible Officials: Management is in agreement.
2022-004 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1630 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: One instance identified in which hours worked by an employee did not agree to hours paid. Cause: There was a lapse in oversight of the internal control process ensuring hours worked reconciled to hours paid. Effect: DPLS? controls did not detect or correct the errors identified, which results in a reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported. The error was corrected in a subsequent pay period. Context/Sampling: A nonstatistical sample of 60 payroll transactions that had time charged to the LSC grants were reviewed. Total LSC direct payroll accounted for $539,572 out of $876,222 direct payroll expenditures. Repeat Finding from Prior Year: Yes. 2021-004 reported a similar finding over payroll. Recommendation: We recommend DPLS review payroll policies and procedures with applicable employees to ensure compliance with documented procedures. Views of Responsible Officials: Management is in agreement.
2022-005 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1644.4 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. For each case filed in court by the auditee?s attorneys on behalf of a client, case disclosure information is required to be reported to Legal Services Corporation. Condition: One instance identified in which the Grant Compliance Checklist wasn?t completed as required by DPLS policy. Additionally, one instance identified in which Form 1644 Disclosure of Case Information was not completed timely, resulting in the case information not being reported to the Corporation. Cause: There was a lapse in oversight of the internal control process ensuring case files include the required documentation to ensure cases are in compliance with the applicable federal standards. Effect: Lack of compliance with designed internal controls over case files could result in DPLS using funds for cases that are not eligible for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 62 case files. Repeat Finding from Prior Year: Yes. 2021-005 reported a similar finding over eligibility. Recommendation: We recommend DPLS review policies and procedures with applicable employees and remind them of the importance of established review and monitoring processes. Views of Responsible Officials: Management is in agreement.
2022-006 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Reporting Significant Deficiency in Internal Control over Compliance Criteria: Grant Terms and Conditions No. 6 establishes various reporting requirements for the auditee. Condition: DPLS entered a lease of personal property exceeding $25,000 requiring the completion of an application of approval, however, this was not completed. Additionally, DPLS entered a lease to relocate office space for an existing branch office requiring an update to DPLS? Grantee Profile on GrantEase within 15 calendar days, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring LSC approval was received prior to entering a personal property lease exceeding $25,000. Additionally, there was a lapse in oversight of the internal control process ensuring the Grantee Profile was updated in GrantEase after relocating office space for an existing branch office. Effect: Failure to notify LSC prior to certain events could result in the reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 4 out of 8 annual and semi-annual reports were selected for testing. Additionally, as documented within LSC Reporting Requirements, Prior Approval Requirements Applying to Certain Events, Waivers of Requirements Applying to Certain Events and Reports Contingent on the Occurrence of Certain Events were tested in total. Repeat Finding from Prior Year: Yes. 2021-008 reported a similar finding over reporting. Recommendation: We recommend DPLS review LSC reporting requirements with applicable employees. Views of Responsible Officials: Management is in agreement.
2022-003 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Procurement Material Weakness in Internal Control over Compliance Criteria: 45 CFR 1631 requires that a non-Federal entity must use its own documented procurement procedures which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal law. Condition: Our testing detected five instances in which the transaction exceeded the DPLS?s micro-purchase threshold, requiring rate quotes and a written evaluation why the vendor was chosen, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring a written evaluation was completed, detailing DPLS?s considerations over the procurement process. Effect: Without completing a written evaluation detailing the history of procurement, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported based on assessment of comparative pricing readily available. Context/Sampling: A nonstatistical sample of 60 disbursements. Out of the 60 disbursements, five items exceeded DPLS? micro-purchase threshold. Repeat Finding from Prior Year: Yes. 2021-003 reported a similar finding over procurement. Recommendation: We recommend management review the internal control process to ensure procurement considerations are documented and retained. Views of Responsible Officials: Management is in agreement.
2022-004 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1630 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: One instance identified in which hours worked by an employee did not agree to hours paid. Cause: There was a lapse in oversight of the internal control process ensuring hours worked reconciled to hours paid. Effect: DPLS? controls did not detect or correct the errors identified, which results in a reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported. The error was corrected in a subsequent pay period. Context/Sampling: A nonstatistical sample of 60 payroll transactions that had time charged to the LSC grants were reviewed. Total LSC direct payroll accounted for $539,572 out of $876,222 direct payroll expenditures. Repeat Finding from Prior Year: Yes. 2021-004 reported a similar finding over payroll. Recommendation: We recommend DPLS review payroll policies and procedures with applicable employees to ensure compliance with documented procedures. Views of Responsible Officials: Management is in agreement.
2022-005 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Eligibility Significant Deficiency in Internal Control over Compliance Criteria: 45 CFR 1644.4 establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. For each case filed in court by the auditee?s attorneys on behalf of a client, case disclosure information is required to be reported to Legal Services Corporation. Condition: One instance identified in which the Grant Compliance Checklist wasn?t completed as required by DPLS policy. Additionally, one instance identified in which Form 1644 Disclosure of Case Information was not completed timely, resulting in the case information not being reported to the Corporation. Cause: There was a lapse in oversight of the internal control process ensuring case files include the required documentation to ensure cases are in compliance with the applicable federal standards. Effect: Lack of compliance with designed internal controls over case files could result in DPLS using funds for cases that are not eligible for reimbursement. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 62 case files. Repeat Finding from Prior Year: Yes. 2021-005 reported a similar finding over eligibility. Recommendation: We recommend DPLS review policies and procedures with applicable employees and remind them of the importance of established review and monitoring processes. Views of Responsible Officials: Management is in agreement.
2022-006 Legal Services Corporation CFDA #09-742018 Legal Services Corporation ? Basic Field ? General CFDA #09-742018 Legal Services Corporation ? Basic Field ? Native American Reporting Significant Deficiency in Internal Control over Compliance Criteria: Grant Terms and Conditions No. 6 establishes various reporting requirements for the auditee. Condition: DPLS entered a lease of personal property exceeding $25,000 requiring the completion of an application of approval, however, this was not completed. Additionally, DPLS entered a lease to relocate office space for an existing branch office requiring an update to DPLS? Grantee Profile on GrantEase within 15 calendar days, however, this was not completed. Cause: There was a lapse in oversight of the internal control process ensuring LSC approval was received prior to entering a personal property lease exceeding $25,000. Additionally, there was a lapse in oversight of the internal control process ensuring the Grantee Profile was updated in GrantEase after relocating office space for an existing branch office. Effect: Failure to notify LSC prior to certain events could result in the reasonable possibility that DPLS could submit disallowed costs under the federal award. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of 4 out of 8 annual and semi-annual reports were selected for testing. Additionally, as documented within LSC Reporting Requirements, Prior Approval Requirements Applying to Certain Events, Waivers of Requirements Applying to Certain Events and Reports Contingent on the Occurrence of Certain Events were tested in total. Repeat Finding from Prior Year: Yes. 2021-008 reported a similar finding over reporting. Recommendation: We recommend DPLS review LSC reporting requirements with applicable employees. Views of Responsible Officials: Management is in agreement.