Finding 479034 (2023-001)

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Requirement
P
Questioned Costs
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Year
2023
Accepted
2024-07-22
Audit: 315557
Organization: 603 Legal Aid (NH)

AI Summary

  • Core Issue: The Board of Directors has only 57.14% attorney members, falling short of the required 60%.
  • Impacted Requirement: Compliance with the Legal Services Corporation Act mandates that at least 60% of the board must be attorney members.
  • Recommended Follow-Up: Implement a procedure for regular internal reviews of board composition and include a calculation of board member percentages in meeting minutes.

Finding Text

Finding 2023-001: Compliance finding – Governing Bodies Legal Services Corporation Basic Field Grant (ALN# 09.130010) Condition: As of December 31, 2023, the Board of Directors was composed of other members representing 7.14%, client members representing 35.72%, and attorney members representing 57.14%. Attorney members were less than the required 60% of the board of directors. Criteria or specific requirement: At least sixty percent (60%) of a governing body shall be attorney members. Cause: Lack of oversight by management. Effect: Governing body may not reasonably reflect the interests of the eligible clients in the area served or consist of members who are supportive of the purposes of the Legal Services Corporation Act and have an interest in, and knowledge of, the delivery of quality legal services to the poor. Questioned costs: No questioned costs were identified. Recommendation: A procedure be implemented to ensure that the Organization remains in compliance and does an internal review to ensure that board composition is maintained. Each set of board meeting minutes could contain a snapshot showing calculation of board composition in response to the requirements of 45 CFR 1607.3.

Corrective Action Plan

2023-001 Planned Corrective Action: The Organization has already taken the necessary corrective action steps to be in compliance with this regulation. In January 2024, 603 Legal Aid communicated with our LSC Program Officer to review the Board of Directors composition requirements and discuss the plan for bringing the Organization into compliance. A new McCollum attorney joined the Board in January 2024, bringing 603 Legal Aid into compliance. Additionally, the Chair of the Board Development Committee has agreed to create and maintain a running list of Board members for ongoing oversight throughout the year to ensure continued compliance. Responsible Person: Ariel Clemmer Date of Completion: Compliant as of January 2024

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
09.U01 Basic Field Grant $868,258
21.027 Coronavirus State and Local Fiscal Recovery Funds $108,196
21.008 Low Income Taxpayer Clinics $100,000
16.588 Violence Against Women Formula Grants $40,000
21.026 Homeowner Assistance Fund $3,333