Finding 974415 (2023-003)

2023-003 – Reports Required by LSC Not Submitted or Submitted Incomplete or Untimely Legal Services Corporation Basic Field Grant Assistance Listing No. – 09.643030 Compliance Requirement – Reporting Condition: During our audit, we noted instances where the following reports required to be submitted to LSC were either not properly submitted in GrantEase system, submitted with incomplete information, or submitted untimely. Certification on Program Integrity – Not submitted in GrantEase. Annual Report on Review of Priorities – Not submitted timely. Legislative and Rulemaking Activity Report – Information was incomplete. Case Disclosure Report – Not submitted timely and information was incomplete. Criteria: The 2023 grant agreement states: “You are also required to annually and semiannually report certain data about your grant activities to LSC. These reports must be submitted through LSC’s GrantEase system.” Additionally, the Legal Services Corporation Regulations (45 C.F.R. Parts 1600- 1644) states the following: 45 C.F.R. 1610.8(b) – Certification on Program Integrity – Report format is contained in a LSC Program Letter 22-3 dated August 26, 2022. Report should be submitted via the GrantEase System by December 31. 45 C.F.R. 1620.7(c) – Annual Report on Review of Priorities – Report should be submitted via the GrantEase system by December 31. 45 C.F.R 1612.10(c) – Legislative and Rulemaking Activity Report – Report should be submitted whether or not there is legislative or rulemaking activity to report. Report should be submitted via the GrantEase system semi-annually by January 31 and July 31. C.F.R. 1644.4(b) – Case Disclosure Report – Report should be submitted via the GrantEase system semi-annually by January 31 and July 31. Cause: There are inadequate procedures and internal controls in place for the submission of reports to grantors. Effect: LSC reporting requirements were not met. Context: The Legal Services Corporation Regulations (45 C.F.R. Parts 1600-1644) were reviewed to ensure compliance requirements were met and the above exceptions were noted during testing. Recommendation: We recommend management review LSC’s reporting requirements and designate the appropriate personnel to be responsible for submitting the required reports. Management’s Response: See management’s corrective action plan.