EIN: 231901014
UEI: MNVEJFEMKAJ4
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 1, 2024. 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 May 1, 2025, which was (476 days ago).
What is a management decision? →FINDING: 2024-002 Private Attorney Involvement (PAI) Significant Deficiency U.S. Congress via Legal Services Corporation (ALN 09.U01.339141) Statement of Condition: During our audit, we noted that LASP did not meet the adjusted PAI requirement of $278,524. Criteria: Under the Code of Federal Regulations (45 CFR §§ 1614.1, 1614.3, 1614.4, 1614.5 and 1614.6), LSC recipients are required to devote an amount of LSC and/or non-LSC funds equal to at least 12.5 percent of their annualized LSC basic field award to promoting the involvement of private attorneys, law students, law graduates, or other professionals in the delivery of legal information and legal assistance to eligible clients. The recipient is to demonstrate compliance with this Part by using financial systems and procedures and maintaining supporting documentation to identify and account separately for costs related to the PAI effort. Cause: Although procedures were in place, the procedures did not produce an accurate estimate of the potential shortfall in order to request an adequate wavier. Effect of the Condition: The PAI requirement for 2024 of $278,524, consists of the current year amount of $247,311 calculated by multiplying the base grant by 12.5% plus the prior year shortfall of $81,213. The 2024 PAI actual amount spent was $204,348 resulting in a shortfall of $74,176 and therefore will be added to the 2025 PAI requirement. Recommendation: We recommend LASP review its procedures to ensure compliance with the requirements of 45 CFR § 1614. Views of responsible officials and planned corrective action: Management agrees with the finding, see corrective action plan.
2024-002 Significant Deficiency Identified: During our audit, we noted that LASP did not meet the adjusted PAI requirement of $278,524. Management’s Response to Finding: LASP acknowledges that it did not meet the Private Attorney Involvement (PAI) spending requirement for the fiscal year, with actual expenditures totaling $204,348, resulting in a shortfall of $74,176. This shortfall occurred due to errors in the reporting of the prior year’s PAI waiver request. LASP is committed to compliance with all PAI requirements and has taken immediate corrective actions to improve the accuracy of its reporting processes. While this reporting oversight led to a shortfall, it is important to note that PAI spending increased by 23% over the previous year, rising from $165,785 in fiscal year-end 2023 to $204,348 in fiscal year-end 2024. This improvement continues a positive trend and reflects LASP’s dedication to expanding PAI-related activities and strengthening private attorney involvement. Further, LASP’s recently appointed Pro Bono Director has already made significant improvements in the tracking and reporting of eligible PAI hours, including those contributed by law student interns and management-related projects. These efforts provide a more accurate reflection of actual expenditures and strengthen LASP's compliance with PAI requirements. Corrective Actions Implemented: 1. Improved Tracking and Monitoring: LASP has implemented monthly tracking procedures to monitor actual PAI spending against established requirements. This approach will ensure that any discrepancies are identified promptly, allowing for timely corrective measures to meet PAI targets. 2. Waiver Documentation and Approval: The $74,176 shortfall has been documented for inclusion in next year’s PAI requirement. LASP has received approval from the Legal Services Corporation (LSC) to carry forward the unmet spending requirement to the next fiscal period. 3. Enhanced Training Programs: LASP has implemented training programs for staff involved in PAI reporting, covering the latest PAI requirements and reporting best practices. The Pro Bono Director will oversee the training program to ensure staff are accurately tracking and reporting PAI expenditures. 4. Strengthened Oversight and Internal Controls: Additional layers of review have been integrated into the PAI reporting process to enhance the accuracy and completeness of reports, helping to prevent future errors and fostering a culture of compliance. Commitment to Improvement: LASP Management is committed to addressing the identified significant deficiency and reinforcing internal controls over PAI compliance. The corrective actions are intended to prevent future oversights and ensure the accurate and timely reporting of PAI expenditures. The effectiveness of these initiatives will be closely monitored with further adjustments made as needed to maintain compliance with LSC and auditing standards. LASP is dedicated to fulfilling its mission through the effective use of PAI resources and is confident that these measures will enable the organization to meet and exceed PAI requirements in future reporting periods.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 25, 2024. 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 September 25, 2024, which was (694 days ago).
What is a management decision? →U.S. Congress via Legal Services Corporation (ALN 09.U01.339080) Statement of Condition: During our audit, we noted that LASP did not meet the PAI requirement of $246,992 for the current year and did not spend the carryover from the prior year. A waiver was not requested timely for the shortfall. Criteria: Under the Code of Federal Regulations (45 CFR §§ 1614.1, 1614.3, 1614.4, 1614.5 and 1614.6), LSC recipients are required to devote an amount of LSC and/or non-LSC funds equal to at least 12.5 percent of their annualized LSC basic field award to promoting the involvement of private attorneys, law students, law graduates, or other professionals in the delivery of legal information and legal assistance to eligible clients. The recipient is to demonstrate compliance with this Part by using financial systems and procedures and maintaining supporting documentation to identify and account separately for costs related to the PAI effort. Cause: The procedures in place did not result in a timely request for a waiver. PAI waivers must be requested by the end of the fiscal year June 30. LASP requested a waiver during August of 2023 which was approved by LSC. Effect of the Condition: The PAI expenses were $165,785 which is a shortfall of $81,207 for the current year. This is a repeat finding. Recommendation: We recommend LASP review its procedures to ensure compliance with the requirements of 45 CFR § 1614. Views of responsible officials and planned corrective action: LASP will monitor PAI through quarterly meetings and request a timely waiver if needed.
For the finding regarding LASP's compliance with the Private Attorney Involvement provisions of the Code of Federal Regulations pertaining to LSC field programs, LASP will schedule three meetings by December 31, 2023, March 31, 2024, and May 31, 2024 to ascertain status updates on PAl spending for the LASP fiscal year, to address and develop a strategy if spending is not on track to fully meet the 12.5 percent requirement, and to ensure that a waiver request is submitted by June 30, 2024 in case PAI spending is projected to be less than 12.5 per cent of the annualized LSC basic field award. Attendees at these meetings will include LASP's Executive Director, Chief Counsel, Director of Operations, ProBono Director, and Grants and Compliance Specialist, and any other staff that may assist in addressing the issues. It is anticipated that the convening of these meetings will ensure that a waiver request, if needed in 2024, will be submitted by the June 30 deadline.
2022-002
U.S. Congress via Legal Services Corporation (ALN 09.U01.339080) Statement of Condition: During our audit, we noted that for one of four cases tested involving a non- citizen and sixty cases tested in total, the required supporting documentation necessary to demonstrate allowability was not available for a case involving a non- citizen. The case was charged partially to LSC sources and partially to other funding sources. Criteria: Under the Code of Federal Regulations (45 CFR §§ 1626) recipients may not use any funds to provide legal services for or on behalf of aliens. Alien status and eligibility are defined at 45 CFR 1626.5. Aliens eligible for assistance under anti – abuse laws are set out at 45 CFR 1616.4. Cause: According to LASP, initial contact with the client was online and therefore not all documentation was immediately collected. LASP expected to be able to obtain the appropriate documentation from the client allowing services for anti- abuse cases but was unable to do so. When attempts to collect the data were not successful, case time was not removed from LSC sources. Effect of the Condition: The costs charged to LSC related to the unallowable case are questioned costs in the amount of $154.61. LASP handled 263 noncitizen cases during the fiscal year of which 170 were charged to LSC funding based on LASP records. This is not a repeat finding. Recommendation: LASP should provide training to intake personnel and staff regarding acceptable documentation required for LSC when handling non- citizens cases. If the necessary information cannot be collected, a non- LSC funding stream should be charged. Views of responsible officials and planned corrective action: LASP (Legal Aid of Southeastern Pennsylvania) has a rigorous compliance protocol that includes weekly compliance team meetings, a review of multiple LegalServer reports for compliance issues, and ongoing compliance and regulatory communications with LASP’s staff. The LASP Compliance Team includes John Farrell, Grants Compliance Specialist, Carolyn Johnson, Chief Counsel, Phillip Hammond, Director of Operations, and Erika Becker, Compliance Specialist. The experienced Compliance Team is tasked with knowing and understanding the LSC (Legal Services Corporation) restrictions and the multiple regulatory obligations to all LASP’s funding sources. LASP Compliance Team provides the following compliance functions: Weekly reviews of case file openings, funding code assignments, and time allocation reports. Ongoing training of the Grants Compliance staff on the capabilities of LegalServer to meet LASP obligations to track case files, advocate time entries, and to ensure that the case time is allocated to the proper funding source. Detailed analysis of individual files noted in the weekly reports as not being properly documented. Erika Becker, Compliance Specialist, emails weekly reports to LASP advocates with links to files that need documentation to meet the assigned funding code. Erika noted during the fiscal year that the file that is the subject of this comment needed to be properly documented and contacted the advocate. The advocate appropriately documented the case file for the assigned funding code. Prompts have been added to LegalServer to alert the LASP advocates to compliance issues that need to be addressed, including directing the advocate to upload all intake documentation. LegalServer prompts require LASP advocates to note that compliance obligations have been met for the case file’s assigned funding code. As a direct response to the audit comment, LASP has implemented a monthly review of open and closed noncitizen case files and advocate time entries to ensure that time entries are allocated to an allowable funding source. LASP’s Compliance Team, with the support of the Executive Director, Shawn Boehringer, requires advocates to follow all funding source restrictions, and provides quarterly training to all LASP staff on compliance issues.
For the finding regarding LASP's compliance with 45 CFR § 1626, a detailed plan has been created that will include weekly compliance team meetings, review of LegalServer reports, and ongoing communication with, and training of, LASP staff on the requirements of the regulation. These activities will be supervised by LASP's Chief Counsel, Director of Operations, and Grants and Compliance Specialists. As a direct response to the finding, LASP has implemented a monthly review of open and closed cases involving non-citizens to ensure that files contain the required documentation. Advocate time entries will also be reviewed to ensure that time entries are allocated to an allowable funding source.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on November 28, 2022. 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 May 28, 2023, which was (1180 days ago).
What is a management decision? →FINDING: 2022-002 Private Attorney Involvement (PAI) U.S. Congress via Legal Services Corporation (ALN 09.U01.339080) Statement of Condition: During our audit, we noted that LASP did not meet the adjusted PAI requirement of $203,603. Criteria: Under the Code of Federal Regulations (45 CFR ?? 1614.1, 1614.3, 1614.4, 1614.5 and 1614.6), LSC recipients are required to devote an amount of LSC and/or non-LSC funds equal to at least 12.5 percent of their annualized LSC basic field award to promoting the involvement of private attorneys, law students, law graduates, or other professionals in the delivery of legal information and legal assistance to eligible clients. The recipient is to demonstrate compliance with this Part by using financial systems and procedures and maintaining supporting documentation to identify and account separately for costs related to the PAI effort. Cause: Although procedures were in place, the procedures did not produce an accurate estimate of the potential shortfall in order to request an adequate wavier. LASP encountered challenges recruiting pro bono volunteers during the pandemic. Effect of the Condition: The PAI expenses were $155,663 which is a $47,940 shortfall of the 2022 adjusted PAI requirement. This $47,940 shortfall will be added to the 2023 PAI requirement. Recommendation: We recommend LASP review its procedures to ensure compliance with the requirements of 45 CFR ? 1614. Views of responsible officials and planned corrective action: Management will update the procedures to ensure compliance with the requirements of 45 CFR ? 1614. LASP hired a new Pro Bono Director in December 2021, a newly created position. Her hire will assist in ensuring that LASP will meet LSC PAI requirements going forward.
Finding #2: Finding: Current procedures did not produce an accurate estimate of the potential shortfall of the PAI requirement in order to request an adequate waiver. Person responsible for resolution: Fiscal Department Expected completion date March 2023 Finding response: Management will update the procedures to ensure compliance with the requirements of 45 CFR ? 1614. LASP hired a new Pro Bono Director in December 2021, a newly created position. Her hire will assist in ensuring that LASP will meet LSC PAI requirements going forward.
FINDING: 2022-003 Reporting U.S. Congress via Legal Services Corporation (ALN 09.U01.339080) Statement of Condition: During our audit, we noted that the Annual Report on Emergency Non- Priority Cases was submitted on March 1, 2022 but was due on January 31, 2022. Criteria: Under the Code of Federal Regulations (45 CFR ?? 1620.07) LSC recipients are required to file an annual report to the Legal Services Corporation on all emergency cases or matters undertaken that were not within the recipient?s priorities. Per Program Letter dated December 8, 1997 the report is due on January 31. Cause: Although procedures were in place, the procedures did not produce a timely report. Effect of the Condition: The Annual Report on Emergency Non- Priority Cases was submitted late. Recommendation: We recommend LASP review its procedures to ensure compliance with the due date requirements of 45 CFR ?? 1620.07. Views of responsible officials and planned corrective action: Management will ensure that this report is filed timely.
Finding #3: Finding: The Annual Report on Emergency Non-Priority Cases was not submitted timely. Person responsible for resolution: Deputy Director for Operations Expected completion date: January 2023 Finding response: Management will ensure that this report is filed timely.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 23, 2017. 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 April 23, 2018, which was (3041 days ago).
What is a management decision? →Management decision deadline — for entities that funded this organization
The FAC accepted this audit on October 13, 2016. 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 April 13, 2017, which was (3416 days ago).
What is a management decision? →GSA_MIGRATION
GSA_MIGRATION
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