Finding 44599 (2022-007)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-05-25
Audit: 46024

AI Summary

  • Core Issue: FRLS is not meeting the requirement to involve private attorneys, as 2 out of 20 cases tested were not eligible under LSC guidelines.
  • Impacted Requirements: Compliance with 45 CFR 1614, which mandates that at least 12.5% of the annual grant be used for eligible private attorney involvement.
  • Recommended Follow-up: Strengthen monitoring policies for PAI compliance and consider implementing a reduced fee program for better attorney participation.

Finding Text

Finding 2022-007 ? Special Test and Provisions ? Private Attorney Involvement PAI (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant Criteria: 45 CFR 1614 requires recipient of LSC funding to use at least 12.5% of their annual basic field grant to promote the involvement of private attorneys to eligible clients. Activities undertaken to meet this requirement include direct delivery of legal assistance to eligible programs. FRLS has elected to meet this requirement with a significant amount of pro bono work. Condition/Context: During our testing, we selected 20 cases that were tracked for PAI compliance. Of the 20 cases, 2 were not LSC-eligible type cases. In addition, FRLS records the donated services based on hours and billable rate provided by the outside attorney. We noted that the value of these donated services was not properly calculated. Cause: FRLS valued the services for some cases at a discounted rate rather than the fair market value of the services provided. Two cases were not types of cases allowable under LSC guidelines. Effect: FRLS is not in compliance with PAI compliance requirements. Questioned Costs: None reported. Recommendation: We recommend FRLS strengthen its policies and procedures surrounding monitoring of PAI compliance to ensure pro bono hours are properly recorded and only allowable 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.

Corrective Action Plan

Finding 2022-007 ? Special Test & Provisions- Private Attorney Involvement PAI (Significant Deficiency and Non-compliance) CORRECTIVE ACTION: FRLS requested and received a waiver from LSC with respect to its 2022 spending on PAI. As part of its request, FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective service partners throughout the pandemic, rebuilding and providing excellent services through our pro bono partners. PAI remains one of our top priorities in expanding our program services. Our program improvements, including pro bono assistance via virtual and courthouse clinics have resulted in more PAI services to our client communities. We have increased attendance at our annual bench and bar events to raise PAI awareness in our service communities and are also planning to introduce other annual bench and bar event in other regional offices in the future, including our first bench bar event in our Lakeland Service area.

Categories

Subrecipient Monitoring Significant Deficiency Special Tests & Provisions

Other Findings in this Audit

  • 44597 2022-005
    Material Weakness
  • 44598 2022-006
    Significant Deficiency
  • 44600 2022-008
    -
  • 621039 2022-005
    Material Weakness
  • 621040 2022-006
    Significant Deficiency
  • 621041 2022-007
    Significant Deficiency
  • 621042 2022-008
    -

Programs in Audit

ALN Program Name Expenditures
09.610 Legal Service Corporation $6.00M
16.575 Crime Victim Assistance $1.46M
21.023 Emergency Rental Assistance Program $249,096
21.008 Low Income Taxpayer Clinics $113,570
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $83,734
93.052 National Family Caregiver Support, Title Iii, Part E $13,799
14.218 Community Development Block Grants/entitlement Grants $10,280
14.231 Emergency Solutions Grant Program $6,928
93.055 Pphf - Applied Leadership for Community Health Improvement $5,963