Finding 601998 (2022-010)

-
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-08-20
Audit: 23277
Auditor: Bbd LLP

AI Summary

  • Core Issue: Philadelphia Legal Assistance Center, Inc. failed to keep proper documentation in some case files, specifically the required citizen attestation statements.
  • Impacted Requirements: This oversight violates 45 CFR § 1626, which mandates that clients seeking legal representation must provide proof of U.S. citizenship.
  • Recommended Follow-Up: The organization should remind staff to ensure all relevant case files include the necessary citizen attestation statements to maintain compliance.

Finding Text

Finding 2022-01 LSC Corporation - 09.339000 Grant period: 01/01/2022 ? 12/31/2022 Condition: Philadelphia Legal Assistance Center, Inc. is required to establish a recordkeeping system that maintains appropriate documentation to ensure compliance with 45 CFR ? 1626, which relates to restrictions on legal assistance to aliens. Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation in all of its case files. Criteria: Except when the only legal service provided is brief advice and consultation by telephone or other nonin- person means, a citizen seeking representation must attest in writing in an LSC-approved form (citizen attestation statement) to the fact of his or her United States citizenship. Cause: Philadelphia Legal Assistance Center, Inc. has procedures in place to maintain citizen attestation statements to ensure compliance with 45 CFR ? 1626; however, some case files did not include this documentation due to an oversight in the case file review process. Effect: Philadelphia Legal Assistance Center, Inc. did not maintain appropriate documentation to ensure compliance with 45 CFR ? 1626. Context: A sample of 60 case files were examined during the audit from a population of approximately 9,500. Of the 60 case files examined, 3 case files did not include the citizen attestation statement. Recommendation: Philadelphia Legal Assistance Center, Inc. should re-emphasize to its staff that certain case files that must include citizen attestation statements include this document. Views of Responsible Officials and Planned Corrective Action: Philadelphia Legal Assistance Center, Inc. agrees with the finding and will re-emphasize that certain case files that must include citizen attestation statements include this document.

Categories

HUD Housing Programs Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
09.339 Basic Field Grant $4.36M
14.218 Community Development Block Grants/entitlement Grants $400,269
21.019 Coronavirus Relief Fund $303,430
16.575 Crime Victim Assistance $256,851
09.338 Technology Initiative Grant $232,103
16.021 Justice Systems Response to Families $210,253
09.339 Migrant Grant $180,818
21.008 Low Income Taxpayer Clinics $100,000
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $56,500
16.524 Legal Assistance for Victims $56,305
17.225 Unemployment Insurance $40,306