Finding Text
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.