Finding Text
Finding 2024-006 – 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: During audit procedures, we tested the PAI requirements and activities and
costs calculation in accordance with Section 1614. We determined the Organization did not meet the
minimum PAI requirement for fiscal year 2024.
Cause: The Organization applied for and received a waiver from LSC, but the calculation did not
include the prior year waiver amount that increased the current year requirement.
Effect: The Organization waiver amount did not cover the amount of PAI shortfall for fiscal year 2024.
Questioned costs: None
Recommendation: We recommend the Organization strengthen its policies and procedures
surrounding monitoring of PAI compliance to ensure the current year requirement is correctly
calculated to include cumulative obligations. We also recommend the addition of a reduced fee
program to facilitate outside involvement.
Views of Responsible Officials: Management agrees with this finding. See Management’s View
and Corrective Action Plan included at the end of the report.