Finding Text
Finding 2024-001 – Timekeeping Requirements
Information on the federal program: Basic Field, Migrant Farmworkers Project, COVID Response
Grant (CFDA Number: 09.515030) – Legal Services Corporation
Criteria: Time spent by attorneys and paralegals must be documented by time records which record the
amount of time spent on each case, matter, or supporting activity (45 CFR Section 1635.3(b)). Time records
must be created contemporaneously and account for time in increments not greater than one-quarter of an
hour which comprise all of the efforts of the attorneys and paralegals for which compensation is paid (45
CFR Section 1635.3(b)(1)).
Condition: Time recorded by attorneys and paralegals was not entered contemporaneously in accordance
with LSC regulations and ILS’ time keeping policy.
Questioned Cost: None.
Context: A sample of 22 separate selections was made of attorney and paralegal time entries from various
one-week periods during 2024. The test found of the 22 selections, there were 2 selections in which time
posted by attorneys and paralegals fell outside of ILS’s contemporaneous timekeeping policy of 2 business
days
Effect: Noncompliance with timely time reporting requirements set forth under LSC regulations and ILS
policy. We found no indications that during the test ILS participated in any actual case or matter that violated
LSC restrictions or prohibitions.
Cause: Attorneys and paralegals lack of timeliness of entering time into the Legal File system.
Repeat Finding: No
Recommendation: We recommend ILS continue to train employees on the importance of timekeeping to
ensure compliance with ILS policy and LSC regulations.
Views of responsible officials and planned corrective actions: Management agrees with the finding
and has prepared a corrective action plan.