Finding 395035 (2023-009)

- Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-04-29
Audit: 304969

AI Summary

  • Core Issue: Five out of 25 employees tested lacked signed priority statements, violating compliance with LSC funding requirements.
  • Impacted Requirements: 45 CFR 1620 mandates that all staff involved in case decisions must acknowledge understanding of priorities and emergencies.
  • Recommended Follow-Up: Enhance onboarding procedures to ensure new hires sign priority statements and implement regular file reviews for compliance documentation.

Finding Text

Finding 2023-009 – Special Test & Provisions- Priorities in Use of Resources (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Award No. 09.610020 Criteria: 45 CFR 1620 requires a recipient of LSC funding to adopt a written statement of priorities that determines the cases and matters that can be undertaken. All staff who handle cases or matters, or make decisions about case acceptance must sign an agreement acknowledging they have read and understand the priorities and read and understand an emergency situation, and will not undertake any case or matter that is not a priority or emergency. Condition/Context: We selected 25 payroll allocations charged to the LSC grant. Of those 25 employees tested, 5 did not have the required signed priority statement on file. Cause: The Organization did not obtain or retain the required priority statements for employees involved with cases or other matters. Effect: The Organization did not document compliance with priorities in use of resources compliance requirements.Questioned costs: None Recommendation: We recommend the Organization strengthen its policies and procedures surrounding employee onboarding to ensure the required statement is signed when a new employee is hired. In addition, the policy should include periodic review of employee files to ensure all required documentation is present and up to date. Views of Responsible Officials: See Management’s View and Corrective Action Plan included at the end of the report.

Corrective Action Plan

This finding is related to activities on our Legal Services Corporation Basic Field Grant. For each new employee added to our organization, our onboarding process includes a requirement of a signed priority statement be placed in our employee’s personnel file. FRLS has also implemented a checklist of required documentation before every case closure to be reviewed by the Regional Managing Attorneys and Advocacy Director. This includes the required priority statement Upon closure of a case file, the assigned advocate and Regional Managing Attorney will then attest that a case file contains all necessary documentation for compliance. A review of the checklist and case files will be done by the Advocacy Director on a regular basis to ensure compliance. FRLS will undertake a review of this process to ensure that we are in compliance with priority statements for employees involved with cases or other matters. This review will be completed within the next 90 days.

Categories

Allowable Costs / Cost Principles Special Tests & Provisions

Other Findings in this Audit

  • 395030 2023-004
    Material Weakness Repeat
  • 395031 2023-005
    Material Weakness
  • 395032 2023-006
    Significant Deficiency Repeat
  • 395033 2023-007
    Significant Deficiency Repeat
  • 395034 2023-008
    Significant Deficiency
  • 971472 2023-004
    Material Weakness Repeat
  • 971473 2023-005
    Material Weakness
  • 971474 2023-006
    Significant Deficiency Repeat
  • 971475 2023-007
    Significant Deficiency Repeat
  • 971476 2023-008
    Significant Deficiency
  • 971477 2023-009
    - Repeat

Programs in Audit

ALN Program Name Expenditures
09.020 Legal Services Corporation $7.18M
16.575 Crime Victim Assistance $1.52M
21.008 Low Income Taxpayer Clinics $142,805
21.023 Emergency Rental Assistance Program $85,587
12.599 Congressionally Directed Assistance $62,378
14.231 Emergency Solutions Grant Program $47,405
14.218 Community Development Block Grants/entitlement Grants $13,052
93.052 National Family Caregiver Support, Title Iii, Part E $5,859
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $1,473