Finding Text
Finding 2023-007 – Special Test and Provisions- Private Attorney Involvement (PAI)
(Significant Deficiency and Non-compliance)
Information on the Federal Program: Legal Services Corporation Basic Field Grant, Award No.
09.610020
Criteria: 45 CFR 1614 requires a recipient of LSC funding to use at least 12.5% of their annual basic
field grant to promote the involvement of private attorneys, law students, law graduates, or other
professionals to provide legal information and legal assistance to eligible clients. Activities undertaken
to meet this requirement include direct delivery of legal assistance to eligible programs. The
Organization has elected to meet this requirement with a significant amount of pro bono work and
allocating costs associated with facilitating the PAI requirement.
Condition/Context: We tested 25 cases that were tracked for PAI compliance. Of the 25 cases, 3
were non-LSC-eligible cases. In addition, the Organization did not satisfy the 12.5% minimum
requirement for PAI.
Cause: Three cases were not types of cases allowable under LSC guidelines. In addition to the value
of pro bono work, the Organization allocated expenses to PAI but failed to meet the 12.5% minimum.
Effect: The Organization did not comply with PAI compliance requirements.
Questioned costs: None
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding monitoring of PAI compliance to ensure only allowable pro bono cases are accepted. We
also recommend the addition of a reduced fee program to facilitate outside involvement.
Views of Responsible Officials: See Management’s View and Corrective Action Plan included at
the end of the report.