Finding 1213596 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-05-04

AI Summary

  • Core Issue: Legal services were provided to clients whose income exceeded the LSC eligibility limit due to a software error in calculating income.
  • Impacted Requirements: Compliance with 45 CFR Part 1611, which mandates that federal assistance only goes to eligible individuals based on accurate income assessments.
  • Recommended Follow-Up: Management should implement checks on eligibility calculations and work with the software vendor to resolve the miscalculation issue.

Finding Text

Finding 2025-001 Material Weakness: Eligibility Compliance And Control Finding ALN 09.526020 – Legal Services Corporation Contract Federal Agency: Legal Services Corporation (LSC) Pass-Through Entities: N/A Criteria Or Specific Requirement: 45 CRF Part 1611 requires that federal assistance be provided only to individuals that meet the financial eligibility requirements. Additionally, proper controls must be in place surrounding the determination of the eligibility of individuals. Condition: During our testing of client eligibility for the LSC program, we identified instances where legal services were provided to clients whose household income exceeded the applicable LSC income limit at the time eligibility was determined. Cause: The software system that the Corporation uses to determine eligibility incorrectly calculated the income limit for three individuals tested. Effect: Management did not detect this instance of noncompliance. Questioned Costs: Not determinable Context: Out of sixty files selected and tested, three files indicated legal services being provided to clients that were ineligible to receive assistance under LSC funding. Identification As A Repeat Finding: Not applicable Recommendation: We recommend that management perform checks over system-generated eligibility calculations. We also recommend that management contact the vendor to determine how miscalculation took place. Views Of Responsible Officials: The Corporation has reviewed the initial poverty calculation for cases opened in 2025 and 2026. It has determined that all cases opened from March 11, 2025 to March 10, 2026 were using a base125% federal poverty level (FPL) table instead of the 100% FPL table, as part of our electronic case management system’s (CMS) automatic determination of household percent of poverty, based upon income information entered into the CMS. Cases opened after March 10, 2026 were calculated using the 100% FPL table and are correct. LSEM is in discussions with its case management system vendor to determine how the error occurred when updating the tables for the 2025 federal poverty rates.

Corrective Action Plan

Personnel Responsible For the Corrective Action: Eric Keith, Director of Finance Anticipated Completion Date September 30, 2026 Corrective Action Plan: The vendor has already updated the financial information page to show the Poverty Scale Base Income and Poverty Scale Increment fields so that a user could see how the automated percentage of poverty is calculated. Corrective actions include that within 60 days, the Corporation will determine the root cause of the error, and will implement procedures to have a back-up person manually check the poverty scales within the system after they are updated each year by the data specialist and the data specialist will randomly sample cases opened each day for the first two weeks after the update to verify the calculations and then again quarterly after that. Within 90 days, the Corporation will review cases that were actually over 125%, or other appropriate poverty level limits, and determine if there is any financial impact and report any adjustments.

Categories

Eligibility Material Weakness

Other Findings in this Audit

  • 1213593 2025-001
    Material Weakness Repeat
  • 1213594 2025-001
    Material Weakness Repeat
  • 1213595 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $371,203
16.524 LEGAL ASSISTANCE FOR VICTIMS $272,805
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $147,446
09.U01 LEGAL SERVICES CONTRACT $80,477
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $67,552
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $35,429
16.024 TRIBAL SEXUAL ASSAULT SERVICES PROGRAM $16,163
16.575 CRIME VICTIM ASSISTANCE $8,510
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $4,954
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $796
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $269