Finding Text
Federal Agency: Legal Services Corporation (LSC) Federal Program Name: LSC Grants Assistance Listing Number: 09.706060 Federal Award Identification Number and Year: 09.706060 - 2025 Award Period: January 1, 2025 – December 31, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Federal regulations (45 CFR 1620.6) specify that all staff who handle cases or matters, or are authorized to make decisions about case acceptance, must sign a simple agreement developed by the recipient which indicates that the signatory: a) Has read and is familiar with the priorities of the recipient; b) Has read and is familiar with the definition of an emergency situation and the procedures for dealing with an emergency that have been adopted by the recipient; and c) Will not undertake any case or matter for the recipient that is not a priority or an emergency. Condition: During our testing, we noted one instance where the Organization was not able to provide evidence of a signed simple agreement for a staff member who handle cases or matters, or is authorized to make decisions about case acceptance. Questioned Costs: None. Context: This instance was noted during testing of sixteen signed simple agreements for staff members who handle cases or matters, or are authorized to make decisions about case acceptance. Cause: The Organization does not have a control process in place to ensure that the required signed simple agreements are obtained for all staff members who handle cases or matters or are authorized to make decisions about case acceptance. Effect: The Organization may not be in compliance with federal regulations related to the required signed written simple agreements for all staff members who handle cases or matters or are authorized to make decisions about case acceptance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the Organization implement a control process to ensure that it obtains signed written simple agreements for all staff members who handle cases or matters or are authorized to make decisions about case acceptance where required in accordance with 45 CFR 1620.6. Views of responsible officials: CLS implemented an onboarding process in 2025 through its HR system, BambooHR, which includes verification of this and other required elements. While this process has been applied to new hires, CLS will extend and enforce the verification of these requirements for employees who joined the organization prior to 2025. CLS believes that this matter would be more appropriately communicated in the management letter rather than presented as part of the overall audit report. Auditor’s Concluding Remarks: Management’s response did not persuade the auditor to revise the finding. Federal regulations reference above specify that signed written simple agreements must be obtained all staff members who handle cases or matters, or is authorized to make decisions about case acceptance.