Audit 360749

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-001 – Timekeeping Requirements Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response Grant (CFDA Number: 09.515030) – Legal Services Corporation Criteria: Time spent by attorneys and paralegals must be documented by time records which record the amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records must be created contemporaneously and account for time in increments not greater than one-quarter of an hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45 CFR Section 1635.3(b)(1)). Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance with LSC regulations and ILS’ time keeping policy. Questioned Cost: None. Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business days Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS policy. We found no indications that during the test ILS participated in any actual case or matter that violated LSC restrictions or prohibitions. Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system. Repeat Finding: No Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to ensure compliance with ILS policy and LSC regulations. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.

Finding 2024-002 – Matching Requirements Information on the federal program: Special Programs For The Aging – Title III, Part B—Grants For Supportive Services and Senior Centers (ALN: 93.044) – Aging Cluster Criteria: All services, whether provided by the State Agency, an Area Agency, or other service providers (excluding any ombudsman services provided under the authority of 42 USC 3024 (d)(1)(D)) must be funded with a nonfederal match of at least 15 percent. One-third of the required 15 percent match must come from state sources (42 USC 3029 (b)(2)). This percentage must be met on a statewide basis. Funds for ombudsman services provided under the authority of 42 USC 3024 (d)(1)(B) are not required to be matched (42 USC 3024 (d)(1)(D); 45 CFR section 1321.47). Condition: ILS did not maintain a formal tracking system for matching funds related to its various aging grants. As a result, ILS determined that it was not in compliance with the 15% matching requirement as outlined in the applicable 2024 Compliance Supplement. Questioned Cost: None. Context: During our review of ILS’s 2024 summary matching contributions file, it was determined that of the 14 aging grants with activity during the year, 7 did not meet the 15% matching requirement as specified in the applicable Compliance Supplement. Effect: Noncompliance with the matching requirements could lead to a request for the return of nonmatched funds, and impact ILS eligibility for future funding. Cause: The noncompliance resulted from a lack of ongoing, year-round monitoring of matching contributions for each aging grant. Management did not have processes in place to ensure that required match amounts were tracked and met consistently throughout the grant period. Repeat Finding: No Recommendation: We recommend that ILS implement a formal system to monitor matching contributions for all aging grants on an ongoing basis. This should include the development of tracking tools and internal controls to ensure that match requirements are met consistently throughout the grant period. Views of responsible officials and planned corrective actions: Management agrees with the finding and has prepared a corrective action plan.