Audit 359640

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RC1626 Criteria: The Organization should have effective internal controls in place over review and recordkeeping of citizen attestation forms and other documentation for eligible non-citizens per 45 CFR 1626. Condition: During our audit, we noted that there was not an effective review of case file documentation related to citizenship attestation forms, and that Organization was not in compliance with the related recordkeeping requirement. Cause: The Organization has a documented process that managers should be reviewing case files for required documentation, however this review appears to not occur or is ineffective. Effect: The lack of review process of documentation for cases during/after intake and noncompliance with recordkeeping requirement could lead to cases being reported to LSC that are not allowable under the grant. Questioned Costs: None noted. Context: During our audit, we noted 3 of the 60 cases reviewed did not have proper documentation for citizenship and related review. We noted that two cases did not have a record of a signed citizenship attestation although they were required to based on extended services provided or the client was seen in person. One of these cases had a documented attempt to obtain a citizenship attestation signed, but the attempt was not successful. The other had no documented attempt to obtain a signed citizenship attestation. A third case was noted to have a citizenship attestation but not in the form that LSC requires. Recommendation: We recommend the Organization implements a more formal review process for review of documentation related to allowability of cases under LSC requirements, whereby a second person is required to review and document their review of each case for proper documentation. Views of Responsible Officials: The Organization accepts the recommendation of the auditors to resolve their findings regarding material weaknesses in internal controls to ensure compliance with LSC requirements.

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RC1611 Criteria: The Organization should have effective internal controls in place over identification of cases allowable and reportable to LSC compared to other funding sources. The Organization should only report cases to LSC that are allowable under LSC requirements. Condition: During our audit, we noted there was not a review process over the case listing submitted to LSC prior to submission for allowability and that a case that did not meet LSC requirements was reported. Cause: The Organization should have effective internal controls in place over identification of cases allowable and reportable to LSC compared to other funding sources. Effect: The lack of review process of the case listing submitted to LSC could lead to unallowable cases being submitted. Questioned Costs: None noted. Context: During our audit, we noted 1 of 60 cases reviewed should not have been reported to LSC. This case had assets above the allowable threshold and was accepted under a grant from a non-LSC funding source. Recommendation: We recommend the Organization implements a review process of the case listing, whereby a second person is required to review and document their review of the case listing for allowable parameters. We further recommend there be some type of notation when cases are accepted to classify the case as an LSC or non-LSC case. Views of Responsible Officials: The Organization accepts the recommendation of the auditors to resolve their findings regarding material weaknesses in internal controls to ensure compliance with LSC requirements.

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RCOTCR Criteria: The Organization should have effective internal controls around reporting to LSC, to ensure timely reporting in accordance with 45 CFR 1644. Condition: During our audit, we noted that the semi-annual report from January through June of 2024 was not submitted to LSC timely. Cause: The Organization should have effective internal controls in place over reporting to LSC. Effect: The lack of controls over reporting to LSC could cause required reporting to not be done timely. Questioned Costs: None noted. Context: During our audit, we noted that the semi-annual report from January through June of 2024 was not submitted to LSC timely. Recommendation: We recommend the Organization implement a review process over LSC reporting deadlines to ensure that reports are submitted timely. Views of Responsible Officials: The Organization accepts the recommendations of the auditors to resolve their finding regarding a significant deficiency in internal controls to ensure compliance with LSC requirements.

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RC1626 Criteria: The Organization should have effective internal controls in place over review and recordkeeping of citizen attestation forms and other documentation for eligible non-citizens per 45 CFR 1626. Condition: During our audit, we noted that there was not an effective review of case file documentation related to citizenship attestation forms, and that Organization was not in compliance with the related recordkeeping requirement. Cause: The Organization has a documented process that managers should be reviewing case files for required documentation, however this review appears to not occur or is ineffective. Effect: The lack of review process of documentation for cases during/after intake and noncompliance with recordkeeping requirement could lead to cases being reported to LSC that are not allowable under the grant. Questioned Costs: None noted. Context: During our audit, we noted 3 of the 60 cases reviewed did not have proper documentation for citizenship and related review. We noted that two cases did not have a record of a signed citizenship attestation although they were required to based on extended services provided or the client was seen in person. One of these cases had a documented attempt to obtain a citizenship attestation signed, but the attempt was not successful. The other had no documented attempt to obtain a signed citizenship attestation. A third case was noted to have a citizenship attestation but not in the form that LSC requires. Recommendation: We recommend the Organization implements a more formal review process for review of documentation related to allowability of cases under LSC requirements, whereby a second person is required to review and document their review of each case for proper documentation. Views of Responsible Officials: The Organization accepts the recommendation of the auditors to resolve their findings regarding material weaknesses in internal controls to ensure compliance with LSC requirements.

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RC1611 Criteria: The Organization should have effective internal controls in place over identification of cases allowable and reportable to LSC compared to other funding sources. The Organization should only report cases to LSC that are allowable under LSC requirements. Condition: During our audit, we noted there was not a review process over the case listing submitted to LSC prior to submission for allowability and that a case that did not meet LSC requirements was reported. Cause: The Organization should have effective internal controls in place over identification of cases allowable and reportable to LSC compared to other funding sources. Effect: The lack of review process of the case listing submitted to LSC could lead to unallowable cases being submitted. Questioned Costs: None noted. Context: During our audit, we noted 1 of 60 cases reviewed should not have been reported to LSC. This case had assets above the allowable threshold and was accepted under a grant from a non-LSC funding source. Recommendation: We recommend the Organization implements a review process of the case listing, whereby a second person is required to review and document their review of the case listing for allowable parameters. We further recommend there be some type of notation when cases are accepted to classify the case as an LSC or non-LSC case. Views of Responsible Officials: The Organization accepts the recommendation of the auditors to resolve their findings regarding material weaknesses in internal controls to ensure compliance with LSC requirements.

Allowable Costs – Legal Services Corporation Basic Field and Migrant Grant – Federal Assistance Listing Number 9.447030; Award Period: Year ended December 31, 2024; LSC Finding Code - RCOTCR Criteria: The Organization should have effective internal controls around reporting to LSC, to ensure timely reporting in accordance with 45 CFR 1644. Condition: During our audit, we noted that the semi-annual report from January through June of 2024 was not submitted to LSC timely. Cause: The Organization should have effective internal controls in place over reporting to LSC. Effect: The lack of controls over reporting to LSC could cause required reporting to not be done timely. Questioned Costs: None noted. Context: During our audit, we noted that the semi-annual report from January through June of 2024 was not submitted to LSC timely. Recommendation: We recommend the Organization implement a review process over LSC reporting deadlines to ensure that reports are submitted timely. Views of Responsible Officials: The Organization accepts the recommendations of the auditors to resolve their finding regarding a significant deficiency in internal controls to ensure compliance with LSC requirements.