Audit 369802

Major program: LSC Corporation – 09.399000 Grant period: 1/1/2024 – 12/31/2024 Finding Type: Noncompliance with the following direct and material compliance requirement: • Eligibility Criteria: Except when the only legal service provided is brief advice and consultation by telephone or other non-in-person means, a citizen seeking representation must attest in writing in an LSC-approved form (citizen attestation statement) to the fact of his or her United States citizenship. Condition and Context: Philadelphia Legal Assistance Center, Inc. is required to establish a recordkeeping system that maintains appropriate documentation to ensure compliance with 45 CFR § 1626, which relates to restrictions on legal assistance to aliens. Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation in all of its case files. A sample of 60 case files were examined during the audit from a population of approximately 8,300. Of the 60 case files examined, 2 case files did not include the citizen attestation statement. Cause: Philadelphia Legal Assistance Center, Inc. has procedures in place to maintain citizen attestation statements to ensure compliance with 45 CFR § 1626; however, some case files did not include this documentation due to an oversight in the case file review process. Effect or Potential Effect: Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation to ensure compliance with 45 CFR § 1626. Recommendation: We recommend that management implement procedures make sure that applicable case files include the citizen attestation statements. Management’s Response: Management is in the process of creating new controls that will allow them to properly track that applicable case files include the citizen attestation statements.