Finding 576080 (2024-001)

-
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-09-10

AI Summary

  • Core Issue: Two clients were incorrectly classified as financially eligible for LSC assistance, violating LSC eligibility criteria.
  • Impacted Requirements: LSC § 1611.4 (a) mandates accurate financial eligibility determinations for clients receiving LSC-funded legal assistance.
  • Recommended Follow-Up: Provide ongoing training for staff on financial eligibility to prevent future misclassifications.

Finding Text

2024-001 Financial Eligibility Legal Services Corporation ALN#09.233100 Criteria: Per LSC § 1611.4 (a) Financial Eligibility, a recipient may provide legal assistance supported with LSC funds only to individuals whom the recipient has determined to be financially eligible for such assistance. Nothing in this part, however, prohibits a recipient from providing legal assistance to an individual without regard to that individual's income and assets if the legal assistance is wholly supported by funds from a source other than LSC, and is otherwise permissible under applicable law and regulation. Condition: During the LSC case file testing, we identified two instances, where the program clients were not financially eligible for the LSC program but were reported as LSC eligible. Cause: Certain Legal Service NYC employees mistakenly classified the program clients who were not LSC financial eligible as LSC financial eligible in the case system. Effect: Incorrect financial eligibility documentation may lead to the improper inclusion or exclusion of clients from receiving services under the LSC program. Questioned costs: There are no questioned costs noted. Context: Out of 60 cases selected for testing, two (2) cases were erroneously reported as LSC eligible. Recommendation: We recommend that Legal Services NYC continue to provide relevant training to employees involved in client intake regarding financial eligibility. Views of responsible officials: See corrective action plan.

Corrective Action Plan

The Compliance Officer met with the Grants and Contracts team from Manhattan Legal Services about the income ineligible case and discussed systems for ensuring that supervisors review the monthly compliance cleanup reports and make the identified corrections as instructed. They will reiterate to all staff that the LSC income eligibility category in our case management system, LegalServer, is unrelated to income eligibility criteria for individual contracts and that while LSNYC may represent a client who is not LSC income eligible using funds for which that is permissible, those cases must be marked as LSC income ineligible. The intake paralegal responsible for the erroneous override will get remedial instructions on removing such overrides rather than leaving them in place. Additionally, the Compliance Officer has been meeting with staff in other boroughs who distribute monthly cleanup reports to evaluate their practices for ensuring corrections are made in response to the reports. The Compliance Officer and Citywide Director of Intake Services will continue to train on how the LSC income eligibility criteria are to be applied, and that No should be selected for LSC income eligibility even when a client is income eligible under other funders’ contracts. The Director of Grants and Contracts for Queens Legal Services has spoken to the attorney and supervisor responsible for the incorrect LSC Eligibility Override Note in the asset-ineligible case. The Compliance Officer is working with LSNYC's LegalServer Support IT specialist to see if the platform can be customized so that LSC Eligibility Overrides can only be used to go from Yes to No (as is necessary when we have open a duplicate case for a client, since only one case can be LSC eligible), which is the only acceptable way for LSC Eligibility Overrides to work. The Compliance Officer and the Citywide Director of Intake will continue to train staff on the LSC asset eligibility criteria and stress that although we can accept clients whose assets exceed the LSC asset ceiling, no one should be selected for Asset and LSC eligibility for those cases.

Categories

Eligibility

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
09.233 Legal Services Corporation $16.20M
93.558 Temporary Assistance for Needy Families $9.52M
21.023 Emergency Rental Assistance Program $5.11M
16.575 Crime Victim Assistance $2.06M
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 $640,431
14.418 Private Enforcement Initiatives $387,173
21.008 Low Income Taxpayer Clinics $377,698
93.569 Community Services Block Grant $300,561
64.056 Legal Services for Veterans Grants $241,881
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $138,107
16.588 Violence Against Women Formula Grants $123,222
93.667 Social Services Block Grant $104,342
93.493 Congressional Directives $66,666
64.033 Va Supportive Services for Veteran Families Program $46,102
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $38,664
93.778 Grants to States for Medicaid $35,982
16.524 Legal Assistance for Victims $5,625