Finding 500266 (2023-006)

Significant Deficiency
Requirement
P
Questioned Costs
$1
Year
2023
Accepted
2024-09-30

AI Summary

  • Core Issue: A capital improvement purchase of $31,350 was made without the required prior approval from LSC, violating LSC Reg. 1630.6.
  • Impacted Requirements: Any expenditure of $25,000 or more on personal property, services, or capital improvements must receive LSC's prior written approval.
  • Recommended Follow-Up: Legal Services NYC should ensure LSC approval is obtained before any future purchases of $25,000 or more using LSC funds.

Finding Text

2023-006 Costs requiring LSC prior approval Legal Services Corporation ALN#09.233100 Criteria: Per LSC Reg. 1630.6 Prior Approval: a recipient may not expend $25,000 or more of LSC funds on any of the following without LSC's prior written approval, (i) A single purchase or single lease of personal property; (ii) A single contract for services; (iii) A single combined purchase or lease of personal property and contract for services; and (iv) Capital improvements. Condition: One capital improvement purchase, amounting to $31,350, charged to the LSC funding did not receive the required prior approval as stipulated by LSC Reg. 1630.6. Cause: The expense was charged to the LSC program when the finance team performed the program cost allocation during their year-end closing process. However, the necessary LSC approval should have been obtained prior to charging this cost to the program. Effect: LSC could determine this to be an unallowed cost and could initiate a request for the return of funding. Context: We identified one capital improvement purchase that costs $25,000 or more out of the entire purchase population. Questioned costs: $31,350. Recommendation: We recommend that Legal Services NYC obtain LSC approval prior to making a purchase of $25,000 or more with the LSC funds in accordance with the LSC Reg. 1630. Views of responsible officials: See corrective action plan.

Corrective Action Plan

This expense was reallocated to LSC in accordance with LSNYC's Cost Allocation Plan, which was developed to comply with LSC regulations on cost allocations and situations where funders will not cover certain costs. In this situation, the initial funder did not allow capital expenses, which is why the expense was then allocated to LSC. In the future, we will get advance approval for expenses that we know will get allocated to LSC before they are purchased.

Categories

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 500263 2023-003
    Significant Deficiency Repeat
  • 500264 2023-004
    Significant Deficiency Repeat
  • 500265 2023-005
    Significant Deficiency
  • 500267 2023-007
    Significant Deficiency
  • 1076705 2023-003
    Significant Deficiency Repeat
  • 1076706 2023-004
    Significant Deficiency Repeat
  • 1076707 2023-005
    Significant Deficiency
  • 1076708 2023-006
    Significant Deficiency
  • 1076709 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
09.223 Legal Services Corporation $16.06M
93.558 Temporary Assistance for Needy Families $8.46M
21.027 Coronavirus State and Local Fiscal Recovery Funds $5.01M
16.575 Crime Victim Assistance $2.02M
93.914 Hiv Emergency Relief Project Grants $1.10M
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $564,516
14.418 Private Enforcement Initiatives $400,702
93.569 Community Services Block Grant $313,351
21.008 Low Income Taxpayer Clinics $265,388
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $238,716
16.588 Violence Against Women Formula Grants $149,999
64.033 Va Supportive Services for Veteran Families Program $137,500
93.667 Social Services Block Grant $100,468
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $60,999
93.778 Medical Assistance Program $56,769
14.408 Fair Housing Initiatives Program $14,491
16.524 Legal Assistance for Victims $1,516