Legal Aid of Wyoming, Inc.

Signed Retainer Agreement (Significant Deficiency) Criteria: Under the requriements 45 CFR 1611.9(a) Financial Eligibility, the Organization is required to execute a retainer agreement with each client when extended service representation commences or as soon thereafter as is practicable. Conditions/Context: In one instance out of sixty files tested it was noted that the signed retainer agreement was not included in the client file as required. Cause: The retainer agreement was not included in the electronic records for the file tested. It appears to be have resulted from limited internal checks to verify document completeness prior to filing and turnover in the administrative assistant position. Effect: The missing document did not have any effect on the eligibility of the client and did not impact services provided to the client. Recommendation: We recommen the Organization review its processes around record retention and the preservation of documnets related to client services. Views of Responsible Officials: The recipient agrees with the audit findings and is implementing procedures to prevent non-compliance in the future.

Part-Time Employee Certification (Significant Deficiency) Criteria: Under the requirements 45 CFR 1635.4(e(1) Timekeeping, any person who works part-time for the recipient and part-time for an organization that engages in restricted activities shall certify in writing that the employee has not engaged in restricted activity during any time for which the employee was compesated by the recipient or has not used recipient resources to carry out restricted activities. Conditions/Context: It was noted that the recipient had multiple part-time employees and none of them had completed the requried certifications. Cause: The omission of the forms appears to be caused by the insufficient internal knowledge of the certification process for part-time employees with dual employment in organizations engaged in restricted activities and an absence of a formal system to identify and monitor such employees for quarterly certification compliance. Effect: Without the signed certifications it is possible that a part-time employee may inadvertently commit potential violations of LSC restrictions, risking improper use of funds. Recommendation: We recommend the Organization review its processes related to part-time employment documentation and include the signed LSC recommended form as part of their employment process. Views of Responsible Officials: The recipient agrees with the audit findings and is implementing procedures to prevent non-compliance in the future.

Criteria: Under the requirements 45 CFR 1630 Cost Standards and Procedures, the Organization is required to accurately distribute costs incurred in each program using a manner that benefits the grant or contract and other work in a reasonable proportion to the benefits received. Conditions/Context: The allocation of indirect costs related to the programs were not reflective of the benefits received by each program. Cause: The accounting manual dictates that the cost be allocated quarterly based on the hours worked on each program. The deficiency was caused by the allocations not being updated during hte year to reflect actual hours worked. Effect: The failure to update the cost allocations resulted in costs being allocated to various programs that was not reflective of the benefits they actually received. Recommendation: We recommend the Organization review it's processes around the cost allocation method and devise a program to ensure the cost allocation is updated quarterly based on actual hours consumed by each program.

Legal Services Corporation CFDA #09.951050 Criteria: Under the requirements 45 CFR 1630 Cost Standards and Procedures, the Organization is required to accurately distribute costs incurred in each program using a manner that benefits the grant or contract and other work in a reasonable proportion to the benefits received. Conditions / Context: The allocation of indirect costs related to the programs were not reflective of the benefits received by each program. Cause: The accounting manual dictates that the cost be allocated quarterly based on the hours worked on each program. The deficiency was caused by the allocations not being updated during the year to reflect actual hours worked. Effect: The failure to update the cost allocations resulted in costs being allocated to various programs that was not reflective of the benefits they actually received. Recommendation: We recommend the Organization review it?s processes around the cost allocation method and devise a program to ensure the cost allocation is updated quarterly based on actual hours consumed by each program.

GSA_MIGRATION