EIN: 381958131
UEI: WFM9K8AYR528
Data as of August 23, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 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 October 28, 2022 (1396 days ago).
What is a management decision? →Finding 2021-002, 2020-002 ? Case File Documentation Finding Type ? Significant Deficiency? Eligibility, Noncompliance Program Information ? AL# 9.423060, Legal Services Corporation, Basic Field Grant ? 2021, 2020, 2019 awards, COVID-19 Response Grant No. CV20037 Criteria ? LSC Recipients should have internal controls designed to ensure compliance with all regulations. Condition ? Several case files were missing the client retainer agreements required by 45 CFR 1611. Questioned Costs ? None. Cause and Effect ? It appears that in several instances, applicable staff did not obtain the retainer agreements, and there was no internal control in place to ensure these were obtained when required. We are aware of certain flexibilities in the regulations clarified by LSC?s issuance of Program Letter 20-02 dated April 2, 2020, however, it appears these flexibilities would not apply to all of the cases we examined. The Organization?s Legal Work Manual adheres to the regulation, however, it appears that the manual was not consistently followed specific to this issue and that there was not a sufficient level of monitoring in place to act as a control to ensure the manual is followed in all cases. Recommendation ? We recommend refresher trainings are given to all attorneys and paralegals regarding LSC requirements, with special emphasis on case documentation. We recommend it is communicated that not only should the documentation be present, but the appropriate timing of when it is obtained as well, and examples of how to proceed with legal assistance in the event the documentation is not obtained. Additionally, we recommend the Organization implements some sort of control to ensure the completeness of case file documentation, possibly by designating the managing attorney, a paralegal, an associate attorney, or the Chief Administrative Officer to review the applicable new cases on a bi-weekly basis to ensure that legal assistance does not continue when documentation is not complete, except as allowed by regulations. We further recommend a checklist is kept within the electronic case management system for extended service cases to both document the presence of the required items and reinforce the importance and timing of obtaining them. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 16.
Show full finding ▾Hide full finding ▴Finding 2021-002, 2020-002 ? Case File Documentation Finding Type ? Significant Deficiency? Eligibility, Noncompliance Program Information ? AL# 9.423060, Legal Services Corporation, Basic Field Grant ? 2021, 2020, 2019 awards, COVID-19 Response Grant No. CV20037 Criteria ? LSC Recipients should have internal controls designed to ensure compliance with all regulations. Condition ? Several case files were missing the client retainer agreements required by 45 CFR 1611. Questioned Costs ? None. Cause and Effect ? It appears that in several instances, applicable staff did not obtain the retainer agreements, and there was no internal control in place to ensure these were obtained when required. We are aware of certain flexibilities in the regulations clarified by LSC?s issuance of Program Letter 20-02 dated April 2, 2020, however, it appears these flexibilities would not apply to all of the cases we examined. The Organization?s Legal Work Manual adheres to the regulation, however, it appears that the manual was not consistently followed specific to this issue and that there was not a sufficient level of monitoring in place to act as a control to ensure the manual is followed in all cases. Recommendation ? We recommend refresher trainings are given to all attorneys and paralegals regarding LSC requirements, with special emphasis on case documentation. We recommend it is communicated that not only should the documentation be present, but the appropriate timing of when it is obtained as well, and examples of how to proceed with legal assistance in the event the documentation is not obtained. Additionally, we recommend the Organization implements some sort of control to ensure the completeness of case file documentation, possibly by designating the managing attorney, a paralegal, an associate attorney, or the Chief Administrative Officer to review the applicable new cases on a bi-weekly basis to ensure that legal assistance does not continue when documentation is not complete, except as allowed by regulations. We further recommend a checklist is kept within the electronic case management system for extended service cases to both document the presence of the required items and reinforce the importance and timing of obtaining them. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 16.
When this deficiency was identified in March 2021, LSEM proposed a multi-layered plan for ensuring organizational success in obtaining retainers and citizenship attestations for appropriate cases while staff continued to work remotely or in a hybrid work context. This plan included: TRAINING: To ensure that a retainer and citizenship attestation is obtained as required by LSC guidelines staff have been re-trained on the regulations and how this translates into daily application at an all staff meeting on March 26, 2021. This training will be included in all new hire onboarding conducted by the ED or Directing/Supervising Attorney and will be included in annual all staff regulatory reviews which will be the responsibility of the management team (specifically the ED and CAO) to coordinate and facilitate. This annual training is being planned for May 2022. PROCESSING: LSEM staff have returned to the office in a hybrid capacity. The majority of client service activity is currently, and will continue for the foreseeable future, to be primarily remote (via phone and/or video conference). Therefore, at the completion of the initial telephone contact, intake staff will send a general investigative e-retainer via Google form. E-forms will be returned to a general holding box that will be checked multiple times daily by Intake Staff and uploaded to and noted in the appropriate case in PIKA. Once the case is accepted by the advocate, staff will send a defined scope retainer via DocuSign when further extended representation is indicated. DocuSign allows for automatic reminders to be sent to clients to sign document(s) and notifications of completed document(s) to staff. Upon the document being signed and returned by all it will be uploaded and noted in PlKA and the citizen attestation box in the electronic file will be checked. The majority of 2022 cases where case documentation was lacking predated the 2021 Corrective Action Plan (CAP). Although every effort was made to secure the documentation post CAP institution, not all efforts were successful. These cases seem to arise primarily in the eviction diversion context where advocates are meeting the client for the first time at a virtual pre-hearing. To re-double efforts in securing the case documentation, designated Housing Intake Staff have been assigned to support case documentation facilitation and compliance review on an ongoing basis. MONITORING: The CAO will run bi-monthly reports to review open cases in the last three weeks to ensure that the appropriate e-retainer is present. For those cases where it is not present, the advocate and their supervisor will be notified that they must (within the next three (3) business days) obtain the retainer from the client or schedule an immediate meeting to confirm a process for informing said individual that we will not be able to continue to assist them on their legal matter absent the retainer being returned.
2020-002
FAC accepted this audit on May 2, 2021 — management decision was due November 2, 2021.
Finding 2020-001 ? Audit Adjustments Finding Type - Material Weakness ? Activities Allowed/Unallowed/Allowable Costs (PAI), Equipment and Real Property Management, Noncompliance Program Information ? CFDA 9.423060, Legal Services Corporation, TIG #19052 and Basic Field Grant ? 2020 award. Criteria ? A sound internal control design should ensure an appropriate segregation of duties to help identify and prevent misstatements and fraud from occurring. Condition ? Material audit adjustments were required in order to fairly state the financial statements. Questioned Costs ? None. Cause and Effect ? Three material adjustments were required to fairly state the financial statements. First, it appeared that both total hours and hours coded for Private Attorney Involvement (PAI) activities reported on the Organization?s calculation did not match actual hours reported in the timekeeping system. Several inconsistencies were noted, which produced a material change in the corresponding PAI allocated expense that was charged. Second, the accrued time off liability did not include all time the employees could accumulate and carry to subsequent fiscal years. Third, a material property and equipment addition was charged to expense instead of being capitalized. The first and third entries affected federal awards. The entries other than the PAI adjustment were for uncommon transactions or events to the organization that are not expected to occur in the future. Recommendation ? We recommend a thorough review of all significant schedules and calculations is done by someone other than the individual preparing them and traced to supporting data. This review will help guard against mistakes due to human error. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 14.
Show full finding ▾Hide full finding ▴Finding 2020-001 ? Audit Adjustments Finding Type - Material Weakness ? Activities Allowed/Unallowed/Allowable Costs (PAI), Equipment and Real Property Management, Noncompliance Program Information ? CFDA 9.423060, Legal Services Corporation, TIG #19052 and Basic Field Grant ? 2020 award. Criteria ? A sound internal control design should ensure an appropriate segregation of duties to help identify and prevent misstatements and fraud from occurring. Condition ? Material audit adjustments were required in order to fairly state the financial statements. Questioned Costs ? None. Cause and Effect ? Three material adjustments were required to fairly state the financial statements. First, it appeared that both total hours and hours coded for Private Attorney Involvement (PAI) activities reported on the Organization?s calculation did not match actual hours reported in the timekeeping system. Several inconsistencies were noted, which produced a material change in the corresponding PAI allocated expense that was charged. Second, the accrued time off liability did not include all time the employees could accumulate and carry to subsequent fiscal years. Third, a material property and equipment addition was charged to expense instead of being capitalized. The first and third entries affected federal awards. The entries other than the PAI adjustment were for uncommon transactions or events to the organization that are not expected to occur in the future. Recommendation ? We recommend a thorough review of all significant schedules and calculations is done by someone other than the individual preparing them and traced to supporting data. This review will help guard against mistakes due to human error. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 14.
In order to ensure these audit adjustments will not need to be proposed again, LSEM will ensure the PAl allocation worksheet is based on actual time worked, both for total hours and specific to PAl activities as documented in our time management system. In the case of the two full time Pro Bono Coordinator positions, since their position's primary purpose is PAl engagement and coordination their time will be fully funded under PAl funding. A memo has been placed in their personnel files indicating such. Also, going forward, we will be sure to include all accruable vacation hours so the calculation is in accordance with Generally Accepted Accounting Principles. Finally, we will do a fixed asset search after year end to ensure all fixed assets purchases over the capitalization threshold are recorded as an asset, rather than an expense. Jody Blackburn, CEO, is responsible for completion of this corrective action plan, which will be put into action immediately. It is also noted that all three adjustments are typically done at year end, therefore, the timeline for enforcing this plan would be January 2022.
Finding 2020-002 ? Case File Documentation Finding Type ? Significant Deficiency? Eligibility, Noncompliance Program Information ? CFDA 9.423060, Legal Services Corporation, Basic Field Grant ? 2020 and 2019 awards, COVID-19 Response Grant No. CV20037. Criteria ? LSC Recipients should have internal controls designed to ensure compliance with all regulations. Condition ? Several case files were missing the client retainer agreements required by 45 CFR 1611. Questioned Costs ? None. Cause and Effect ? It appears that in several instances, applicable staff did not obtain the retainer agreements, and there was no internal control in place to ensure these were obtained when required. We are aware of certain flexibilities in the regulations clarified by LSC?s issuance of Program Letter 20-02 dated April 2, 2020, however, it appears these flexibilities would not apply to all of the cases we examined. The Organization?s Legal Work Manual adheres to the regulation, however, it appears that the manual was not consistently followed specific to this issue and that there was not a sufficient level of monitoring in place to act as a control to ensure the manual is followed in all cases. Recommendation ? We recommend refresher trainings are given to all attorneys and paralegals regarding LSC requirements, with special emphasis on case documentation. We recommend it is communicated that not only should the documentation be present, but the appropriate timing of when it is obtained as well, and examples of how to proceed with legal assistance in the event the documentation is not obtained. Additionally, we recommend the Organization implements some sort of control to ensure the completeness of case file documentation, possibly by designating the managing attorney, a paralegal, an associate attorney, or the Chief Administrative Officer to review the applicable new cases on a bi-weekly basis to ensure that legal assistance does not continue when documentation is not complete, except as allowed by regulations. We further recommend a checklist is kept within the electronic case management system for extended service cases to both document the presence of the required items and reinforce the importance and timing of obtaining them. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 14.
Show full finding ▾Hide full finding ▴Finding 2020-002 ? Case File Documentation Finding Type ? Significant Deficiency? Eligibility, Noncompliance Program Information ? CFDA 9.423060, Legal Services Corporation, Basic Field Grant ? 2020 and 2019 awards, COVID-19 Response Grant No. CV20037. Criteria ? LSC Recipients should have internal controls designed to ensure compliance with all regulations. Condition ? Several case files were missing the client retainer agreements required by 45 CFR 1611. Questioned Costs ? None. Cause and Effect ? It appears that in several instances, applicable staff did not obtain the retainer agreements, and there was no internal control in place to ensure these were obtained when required. We are aware of certain flexibilities in the regulations clarified by LSC?s issuance of Program Letter 20-02 dated April 2, 2020, however, it appears these flexibilities would not apply to all of the cases we examined. The Organization?s Legal Work Manual adheres to the regulation, however, it appears that the manual was not consistently followed specific to this issue and that there was not a sufficient level of monitoring in place to act as a control to ensure the manual is followed in all cases. Recommendation ? We recommend refresher trainings are given to all attorneys and paralegals regarding LSC requirements, with special emphasis on case documentation. We recommend it is communicated that not only should the documentation be present, but the appropriate timing of when it is obtained as well, and examples of how to proceed with legal assistance in the event the documentation is not obtained. Additionally, we recommend the Organization implements some sort of control to ensure the completeness of case file documentation, possibly by designating the managing attorney, a paralegal, an associate attorney, or the Chief Administrative Officer to review the applicable new cases on a bi-weekly basis to ensure that legal assistance does not continue when documentation is not complete, except as allowed by regulations. We further recommend a checklist is kept within the electronic case management system for extended service cases to both document the presence of the required items and reinforce the importance and timing of obtaining them. View of Responsible Officials ? Management agrees with this finding. Corrective Action Plan ? See corrective action plan at page 14.
LSEM proposes a multi-layered plan for ensuring organizational success in obtaining retainers and citizenship attestations for appropriate cases while staff continue to work remotely or in hybrid work context once some general return to the office is viable following the health crisis. This plan includes: TRAINING: To ensure that a retainer and citizenship attestation is obtained as required by LSC guidelines staff have been re-trained on the regulations and how this translates into daily application at an all staff meeting on March 26, 2021. This training will be included in all new hire onboarding and included in bi-annual all staff regulatory reviews. PROCESSING: All client service activity is currently, and will continue for the foreseeable future, to be primarily remote (via phone and/or video conference). Therefore, at the completion of the telephone intake staff will send a general investigative e-retainer via Google form. E-forms will be returned to a general holding box that will be checked multiple times daily and uploaded to and noted in the appropriate case in PIKA. Once the case is accepted by the advocate, staff will send a defined scope retainer via DocuSign when further extended representation is indicated. DocuSign is new technology tool for the organization which allows for automatic reminders to be sent to clients to sign document(s) and notifications of completed document(s) to staff. Upon the document being signed and returned by all it will be uploaded and noted in PIKA and the citizen attestation box in the electronic file will be checked. MONITORING: A designated staff person, will do bi-monthly (every other week) review of open cases to ensure that the appropriate e-retainer is present. For those cases where it is not present, the advocate will be notified that they must (within the next three (3) business days) obtain the retainer from the client or schedule an immediate meeting with their supervisor to confirm a process for informing said individual that we will not be able to continue to assist them on their legal matter absent the retainer being returned.
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