EIN: 043330208
UEI: EEJZHJFF12G2
Audited by: AAFCPAs, Inc.
Oversight agency: 09 [Legal Services Corporation]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 15, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by November 15, 2026 (73 days from today).
What is a management decision? →An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient even though SCCLS has had this arrangement for several years and had gone through this review in prior years. During 2025, the Organization continued working with LSC to determine the appropriate separation to satisfy the requirements. With consultation from LSC, the Organization was instructed to wait until the Program Integrity Review was completed before submission of their formal Program Integrity Certification. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however, the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year of review, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Was the finding a repeat of a finding in the immediately prior year?: Yes Was the sampling a statistically valid sample?: No Questioned Costs?: None Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has been working with LSC and has already implemented several recommendations from the review. Management Response: Management prepared and developed a corrective action plan with LSC and has met with LSC on a biweekly basis working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026.
Show full finding ▾Hide full finding ▴Significant Deficiency: Separation of the Justice Center Information on the Federal Program: The significant deficiency relates to Federal funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under Assistance Listing number 09.122087, compliance requirement special tests and provisions. Criteria: Entities that receive funding from Legal Services Corporation (LSC) must employ detailed internal controls to ensure compliance with 45 C.F.R. 1610.8, Program Integrity, of Appendix A: Compliance Supplement for Audits of LSC Recipients from Legal Services Corporation Audit Guide for Recipients and Auditors dated October 2023. Specifically, the Organization must ensure objective integrity and independence from any organization that engages in restricted activities and includes operating in a manner that provides sufficient physical and financial separation from the entity. These requirements are to be followed under the activities allowed or unallowed compliance requirements of the Uniform Guidance. Condition: An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient even though SCCLS has had this arrangement for several years and had gone through this review in prior years. During 2025, the Organization continued working with LSC to determine the appropriate separation to satisfy the requirements. With consultation from LSC, the Organization was instructed to wait until the Program Integrity Review was completed before submission of their formal Program Integrity Certification. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however, the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year of review, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Was the finding a repeat of a finding in the immediately prior year?: Yes Was the sampling a statistically valid sample?: No Questioned Costs?: None Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has been working with LSC and has already implemented several recommendations from the review. Management Response: Management prepared and developed a corrective action plan with LSC and has met with LSC on a biweekly basis working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026.
April 23, 2026 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit Period: January 1, 2025 - December 31, 2025 The findings from April 22,2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Seperation of Justice Center Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are seperately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a correction action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2026. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and developed a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to ensure that compliance with the corective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Mulitple aspects of the plan has been implemented, with full compliance expected in 2026. FINDING - FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY LEGAL SERVICES CORPORATION 2024-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 2023-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 Sincerely yours, Christopher Oldi Executive Director
2024-001
FAC accepted this audit on May 14, 2025 — management decision was due November 14, 2025.
An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient even though SCCLS has had this arrangement for several years and had gone through this review in prior years. During 2024, the Organization continued working with LSC to determine the appropriate separation to satisfy the requirements. With consultation from LSC, the Organization was instructed to wait until the Program Integrity Review was completed before submission of their formal Program Integrity Certification. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however, the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Was the finding a repeat of a finding in the immediately prior year?: Yes Was the sampling a statistically valid sample?: No Questioned Costs?: None Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has been working with LSC and has already implemented several recommendations from the review. Management Response: Management prepared and developed a corrective action plan with LSC and has met with LSC on a biweekly basis working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2025.
Show full finding ▾Hide full finding ▴Significant Deficiency: See Finding 2024-001 Separation of the Justice Center Information on the Federal Program: The significant deficiency relates to Federal funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under Assistance Listing number 09.122087, compliance requirement special tests and provisions. Criteria:Entities that receive funding from Legal Services Corporation (LSC) must employ detailed internal controls to ensure compliance with 45 C.F.R. 1610.8, Program Integrity, of Appendix A: Compliance Supplement for Audits of LSC Recipients from Legal Services Corporation Audit Guide for Recipients and Auditors dated October 2023. Specifically, the Organization must ensure objective integrity and independence from any organization that engages in restricted activities and includes operating in a manner that provides sufficient physical and financial separation from the entity. These requirements are to be followed under the activities allowed or unallowed compliance requirements of the Uniform Guidance. Condition: An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient even though SCCLS has had this arrangement for several years and had gone through this review in prior years. During 2024, the Organization continued working with LSC to determine the appropriate separation to satisfy the requirements. With consultation from LSC, the Organization was instructed to wait until the Program Integrity Review was completed before submission of their formal Program Integrity Certification. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however, the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Was the finding a repeat of a finding in the immediately prior year?: Yes Was the sampling a statistically valid sample?: No Questioned Costs?: None Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has been working with LSC and has already implemented several recommendations from the review. Management Response: Management prepared and developed a corrective action plan with LSC and has met with LSC on a biweekly basis working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2025.
April 22, 2025 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit Period: January 1, 2024 - December 31, 2024 The findings from April 22,2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Seperation of Justice Center Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are sperately accounted for to ensure proper seperation consistent with LSC requirements. We understand management has submitted a correction action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and developed a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to ensure that compliance with the corective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Mulitple aspects of the plan has been implemented, with full compliance expected in 2025. FINDING - FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY LEGAL SERVICES CORPORATION 2023-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably relayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2025. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 Sincerely yours, Christopher Oldi Executive Director
2023-001
FAC accepted this audit on May 29, 2024 — management decision was due November 29, 2024.
An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management is currently reviewing various corrective action plans with LSC to ensure compliance with these requirements. Management Response: SCCLS is preparing a corrective action plan with LSC and is in the process of working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations.
Show full finding ▾Hide full finding ▴Separation of the Justice Center Criteria: Entities that receive funding from Legal Services Corporation (LSC) must employ detailed internal controls to ensure compliance with 45 C.F.R. 1610.8, Program Integrity, of Appendix A: Compliance Supplement for Audits of LSC Recipients from Legal Services Corporation Audit Guide for Recipients and Auditors dated October 2023. Specifically, the Organization must ensure objective integrity and independence from any organization that engages in restricted activities and includes operating in a manner that provides sufficient physical and financial separation from the entity. These requirements are to be followed under the activities allowed or unallowed compliance requirements of the Uniform Guidance. Condition: An affiliate of South Coastal Counties Legal Services, Inc. (SCCLS), the Justice Center of Southeast Massachusetts, LLC (JCSM), engages in restricted activity. During 2023, the Organization underwent a Program Integrity and Cost Standards Review from LSC, and they deemed the current arrangement of accounting for JCSM insufficient. Cause: SCCLS monitored the detailed activity of JCSM to properly track all restricted activities in the general ledger, however the physical and financial separation was not deemed appropriate based on the most recent review, which is open to interpretation. The requirements identify the sufficiency of separation will be determined on a case-by-case basis and will be based on the totality of the facts. Some facts and circumstances changed during the year, which overall changed the sufficiency of compliance. Effect: Non-compliance with program integrity requirements for the LSC grant award. Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management is currently reviewing various corrective action plans with LSC to ensure compliance with these requirements. Management Response: SCCLS is preparing a corrective action plan with LSC and is in the process of working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations.
April 29, 2024 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit period: January 1, 2023 - December 31, 2023 The findings from the April 23, 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDING SIGNIFICANT DEFICIENCY 2023-001 Separation of the Justice Center Recommendation: We recommend management examine their internal processes and policies on how activities for both entities, South Coastal Counties Legal Services, Inc. and the Justice Center of Southeast Massachusetts, LLC are separately accounted for to ensure proper separation consistent with Legal Services Corporation requirements. Action Taken: SCCLS is preparing a detailed corrective action plan with LSC and is in the process of working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. The first draft of the detailed corrective action plan has been submitted to LSC. SIGNIFICANT DEFICIENCY LEGAL SERVICES CORPORATION 2023-001 Separation of the Justice Center The significant deficiency relates to Federal funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.122087. Recommendation: We recommend management examine their internal processes and policies on how activities for both entities, South Coastal Counties Legal Services, Inc. and the Justice Center of Southeast Massachusetts, LLC are separately accounted for to ensure proper separation consistent with Legal Services Corporation requirements. Action Taken: SCCLS is preparing a detailed corrective action plan with LSC and is in the process of working with LSC to ensure that compliance with the corrective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. The first draft of the detailed corrective action plan has been submitted to LSC. If Legal Services Corporation has questions regarding this plan, please call Christpoher Oldi, Executive Director at (774) 488-5950. Christopher Oldi Executive Director
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