Finding 25556 (2022-010)

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Requirement
E
Questioned Costs
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Year
2022
Accepted
2023-08-20
Audit: 23277
Auditor: Bbd LLP

AI Summary

  • Core Issue: Philadelphia Legal Assistance Center, Inc. failed to keep proper documentation in some case files, specifically the required citizen attestation statements.
  • Impacted Requirements: This oversight violates 45 CFR § 1626, which mandates that clients seeking legal representation must provide proof of U.S. citizenship.
  • Recommended Follow-Up: The organization should remind staff to ensure all relevant case files include the necessary citizen attestation statements to maintain compliance.

Finding Text

Finding 2022-01 LSC Corporation - 09.339000 Grant period: 01/01/2022 ? 12/31/2022 Condition: Philadelphia Legal Assistance Center, Inc. is required to establish a recordkeeping system that maintains appropriate documentation to ensure compliance with 45 CFR ? 1626, which relates to restrictions on legal assistance to aliens. Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation in all of its case files. Criteria: Except when the only legal service provided is brief advice and consultation by telephone or other nonin- person means, a citizen seeking representation must attest in writing in an LSC-approved form (citizen attestation statement) to the fact of his or her United States citizenship. Cause: Philadelphia Legal Assistance Center, Inc. has procedures in place to maintain citizen attestation statements to ensure compliance with 45 CFR ? 1626; however, some case files did not include this documentation due to an oversight in the case file review process. Effect: Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation to ensure compliance with 45 CFR ? 1626. Context: A sample of 60 case files were examined during the audit from a population of approximately 9,500. Of the 60 case files examined, 3 case files did not include the citizen attestation statement. Recommendation: Philadelphia Legal Assistance Center, Inc. should re-emphasize to its staff that certain case files that must include citizen attestation statements include this document. Views of Responsible Officials and Planned Corrective Action: Philadelphia Legal Assistance Center, Inc. agrees with the finding and will re-emphasize that certain case files that must include citizen attestation statements include this document.

Corrective Action Plan

Corrective Action Plan Provided from Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. PLA is in the process of developing an enhanced training program for case handlers to ensure that case handlers remember to obtain citizenship attestations and documentation of immigration eligibility whenever the LSC regulations require it. We are also in the process of developing an enhanced system of overseeing case files so that if the documentation is missing in a case, that case is deselected from the annual Case Service Reports.

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
09.339 Basic Field Grant $4.36M
14.218 Community Development Block Grants/entitlement Grants $400,269
21.019 Coronavirus Relief Fund $303,430
16.575 Crime Victim Assistance $256,851
09.338 Technology Initiative Grant $232,103
16.021 Justice Systems Response to Families $210,253
09.339 Migrant Grant $180,818
21.008 Low Income Taxpayer Clinics $100,000
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $56,500
16.524 Legal Assistance for Victims $56,305
17.225 Unemployment Insurance $40,306