Finding 576081 (2024-002)

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

AI Summary

  • Core Issue: Two cases incorrectly included assets that do not meet the LSC definition, affecting financial eligibility determinations.
  • Impacted Requirements: Assets like primary residences should be excluded per LSC Reg.# 1611.2(d), leading to potential misclassification of client eligibility.
  • Recommended Follow-Up: Continue training for staff on proper asset reporting and eligibility criteria to prevent recurrence of this issue.

Finding Text

2024-002 Financial Eligibility – Assets Definition Legal Services Corporation ALN#09.233100 Criteria: Per LSC Reg.# 1611.2(d) Definition of Assets, “Assets” means cash or other resources of the applicant or members of the applicant’s household that are readily convertible to cash, which are currently and actually available to the applicant Condition: The recorded assets considered for client financial eligibility determination for two (2) cases did not meet the asset definition as per the LSC regulation. Cause: Certain assets including a primary residence were inaccurately reported as assets. These assets should be excluded when assessing financial eligibility in accordance with LSC Reg.#1611.2(d). 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 included assets that did not align with the asset definition as specified by LSC Reg. # 1611.2(d). *This is a repeated finding from the prior year. The prior year finding # was 2023-004. Recommendation: We recommend that Legal Services NYC continue to provide relevant training to employees involved in client intake regarding maintenance of asset ceiling waiver approvals. Views of responsible officials: See corrective action plan.

Corrective Action Plan

The Director of Grants and Contracts for Queens Legal Services has spoken to the supervisor for the paralegals responsible for the errors in these cases, who has spoken to the paralegals. 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 will work with the Citywide Director of Intake to develop written materials that (1) remind intake staff to exclude primary residences from Asset totals, which has always been and will continue to be part of financial eligibility training; (2) remind intake staff that an Asset Override may only be made with the written approval of a supervisor (who will review to make sure that the assets legitimately exceed the asset ceiling) documented in the case file; and (3) explain to intake staff the appropriate use of each of the override fields - income overrides, asset overrides, and LSC Eligibility overrides.

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