Finding Text
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.