Audit 399843

Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.742018 Federal Award Identification Number and Year: 09.742018 2025 Award Period: 1/1/2025-12/31/2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Federal regulations require allowable costs under federal awards to be incurred during the federal award grant period. Condition: During our testing, we noted the Organization incurred expenses in one transaction totaling $348 in our testing sample of 15 transactions outside of the period of performance for the 2025 award. Context: The instance was noted during our testing of transactions at the beginning and end of the 2025 grant period of performance. Questioned costs: $348 Cause: Based on the dollar amount of the transaction and timing of receipt of the invoice for the expenses, the Organization recorded the immaterial transaction in 2025 rather than in 2024 when the expense was incurred. Effect: Expenditures for federal awards are incurred outside of the period of performance and may not be allowable expenses if outside of that period. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement a review process for proper cutoff of federal expenditures incurred during a grant’s period of performance to ensure only expenses incurred during current periods are included. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.742018 Federal Award Identification Number and Year: 09.742018 2025 Award Period: 1/1/2025-12/31/2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Reporting Condition: During our testing of reporting requirements under Uniform Guidance and the LSC Audit Guides, we noted the Organization did not have key internal control around a documented review and approval of the required reports by an informed member of management. Context: The instance was noted during our testing of internal controls over reporting compliance for 9 required report submissions in 2025. Cause: We noted no evidence from management that all reports had been reviewed and approved by someone other than the preparer for those submitted in 2025. We noted timely submissions of all reports, however, no key control was in place over reporting. Effect: Reporting submitted to the funder may contain errors without a documented review process in place to review the completeness and accuracy of the report submissions. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should implement a review process for all financial and performance reports required for submission during each year to ensure completeness and accuracy of the report submissions. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.742018 Federal Award Identification Number and Year: 09.742018 2025 Award Period: 1/1/2025-12/31/2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Requirements under 45 CFR 1610 detail LSC regulation around the use of non-LSC sourced funds by LSC recipients. The Organization is required to adopt certain policies in accordance with the provisions of this requirement. Condition: We noted in our review of the Dakota Plains Legal Services Policy Manual, there were no organizational policies adopted specific to 45 CFR 1610 requirements, including those specifically under 45 CFR 1610.7 and procedures for written notifications of the prohibitions and conditions on the use of non-LSC sourced funds. Context: During our required staff interviews under LSC special reporting compliance requirements, we noted an overall awareness of the provisions of 45 CFR 1610, however, we noted no policies specific to these requirements in the DPLS policy manual. We also noted Dakota Plains Legal Services completed its 2025 Certification of Program Integrity under 45 CFR 1610 as required. Cause: Per discussions with management, the Organization has not adopted a specific policy related to the requirements of 45 CFR 1610. Effect: The Organization may not meet the requirements on the use of non-LSC sourced funds and staff may not be knowledgeable of these requirements without policies and procedures in place. Repeat Finding: This is not a repeat finding. Recommendation: The Organization should review its policy manual and ensure that required provisions of 45 CFR 1610 are fully incorporated to ensure compliance with LSC requirements. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.742018 Federal Award Identification Number and Year: 09.742018 2025 Award Period: 1/1/2025-12/31/2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. Non-federal entities are prohibited from contracting with or making subawards under covered transactions that are suspended or debarred. Before entering into a covered transaction, the entity must verify that the contractor is not suspended, debarred, or otherwise excluded from participating in the transaction. Condition: During our testing, we noted the Organization did not have adequate internal controls designed to ensure vendors were not suspended or debarred. The Organization did not retain documentation that the suspension and debarment status of contractors were verified prior to entering into the contract. Context: During our testing, we noted no established procedures were in place during the year to review that vendors were not suspended or debarred. Cause: Per discussions with management, the Organization adopted a new procurement policy that includes procedures for a review of vendors for suspension or debarment, however, procedures were not yet implemented in 2025. Effect: The Organization could have entered into an agreement with a contractor that was suspended or debarred. The absence of documentation performed prior to contract execution presents a risk of noncompliance with applicable procurement regulations. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place to review potential contractors to determine they are not suspended or debarred prior to entering into transactions with contractors. Views of responsible officials: There is no disagreement with the audit finding.