Finding 381085 (2022-001)

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.