EIN: 630743038
UEI: WDCTMQ6PJPT5
Audited by: WARREN AVERETT, LLC
Oversight agency: 09 [Legal Services Corporation]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 27, 2023. 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 27, 2023 (1037 days ago).
What is a management decision? →Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, Disaster Project Grant, Disaster Grant Incurred Cost, and Technology Grant Criteria: 45 CFR Section 1626 and 1636 requires additional documentation such as a signed retainer, US citizen statement and statement of fact for cases where extended service is provided. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125% of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In one case the client exceeded the 125% income limit, but no documentation of exceptions met were in the case file and one case was closed under an incorrect problem code. Cause: The assigned attorney did not obtain the required income and exemption documentation for the file and failed to properly close the case resulting in inaccurate case data and outcomes. Effect: LSA is not in compliance with case requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-002 ? Case Requirements (Significant Deficiency and Non-compliance) Corrective Action: LSA will provide training to all attorneys and support staff on the policies and procedures involved, with a particular emphasis on the documentation requirements. LSA will also be conducting periodic internal reviews of case files to ensure compliance with all required documentation requirements. These reviews should include a review of financial eligibility documentation, including exceptions, if any. Finally, LSA will review and update any necessary policies and procedures as needed to ensure compliance. Updates to policies and procedires and training will becompleted by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org
2021-001
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Coronavirus State and Local Fiscal Recovery Funds (ARPA) Assistance Listing No. 21.027 and US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: 2 CFR 200.403 establishes factors affecting allowability of costs. This includes costs being adequately documented. Condition/Context: During our ARPA testing, we selected 25 non-payroll disbursements. Of those 25, 18 disbursements were for client assistance. Of those 18, three disbursement amounts did not agree to the amounts in the supporting documentation. During our ERA testing, we selected 15 payroll disbursements where all or part of the employee?s pay was allocated to the program. Of the 15, two amounts allocated did not agree to the supporting documentation. Cause: The client assistance payments made with ARPA funds are to be calculated based on past due rent plus one additional month of rent. The amounts paid on behalf of the client did not agree to the amounts in the supporting documentation. In one instance the renter was paid more than the supporting documentation indicated they were eligible for and two instances the renter was paid less. Employee time was allocated 100% to the ERA program but the timesheets for these pay periods reflected time for other programs in addition to ERA, so the total pay amount should not have been charged to ERA. In addition, one of the pay periods used to calculate the reimbursement amount was more than the employee was actually paid that period. Effect: LSA is not in compliance with allowable cost documentation requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of calculating assistance payments to ensure accurate amounts are disbursed and LSA is in compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-003 ? Allowable Costs (Significant Deficiency and Non-compliance) Corrective Action: The ARPA?s stated purpose is for housing provision, stabilization services, and eviction prevention. The rental assistance funds may be used for arrearage, forward payments, deposits, late fees, and utilities. The grant provides separate application forms for rental assistance and utilities assistance. The grant does not require maximizing the amount paid on behalf of applicants. Every disbursement involves obtaining documents from the applicant and the landlord. The landlord signs an agreement stating they will allow the client to remain housed by accepting the payment. It is common to negotiate the agreed upon amount because some landlords include fees in their amounts that are not allowable under the grant or ask for more months of assistance that is allowed. The disbursements tested included agreements that were all signed and accepted by the landlords. LSA documented the costs which were reimbursed by the funder. One of the payments included a document that had not been updated. The payment included an additional month?s rent due to the time lag between the start of the application and the completed documents and the revised total amount was included on the signed landlord agreement. In this case, the agreement did not include an additional late fee that would have been expected per the terms of the lease. The landlord accepted the payment less the late fee. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. A second payment did not include a beginning ledger balance. The landlord charges an insurance fee that is not covered by the grant. Rather than attempting to determine if the balance forward was due to eligible charges or ineligible charges, the amount was excluded from the total. The documentation attached did not specifically mention that the amount was excluded, but a handwritten total of the included charges was included. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. The third payment was deemed an exception because the reimbursement did not include the client?s utilities charges. Although the charges are eligible under the grant, the applicant and landlord did not request assistance with utilities. LSA staff will document negotiated amounts that are different from the support and provide explanation and the amount included or excluded. Regarding employee time for the program, LSA staff will look for solutions to help prevent time entry errors, and the Finance Department will conduct a review of every grant report. LSA will review if changes can be made in the timekeeping system to restrict certain fund sources from being applied to programs, to enhance controls over time attributed to particular funding. The grant report review will also include a review of program reports when new staff join the program to ensure the time activity is correct and can be allocated as reported. LSA will complete a review of the timekeeping system and procedures by the end of the second quarter 2023 and implement changes by the third quarter of 2023. The grant report review will commence as of the date of this audit report. Contact Person: David Roberson, Director of Finance; (334) 223-0251; droberson@alsp.org
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program (ERA) Assistance Listing No. 21.023 Criteria: Treasury established requirements for providing housing stability services to enable households to maintain or obtain housing. Services may include, among other things, eviction prevention and eviction diversion programs; mediation between landlords and tenants; fair housing counseling; housing navigators that help households access ERA programs or find housing; case management related to housing stability; housing-related services for survivors of domestic abuse or human trafficking; legal services or attorney?s fees related to eviction proceedings and maintaining housing stability; and specialized services for individuals with disabilities or seniors that support their ability to access or maintain housing. Grantees using ERA funds for housing stability services must maintain records regarding such services and the amount of funds provided to them. Condition/Context: During our testing, we selected 25 cases in which LSA provided legal services under a program funded by ERA. Of those 25, three cases were for legal services that were not apparent to be eligible under ERA?s purpose. Cause: These cases were for divorce, divorce with custody, and collections. In addition, two of the clients were homeowners, not renters. LSA did not provide documentation of determination of eligibility to be for affordable rental housing and eviction prevention purposes. Effect: LSA was not in compliance with eligibility requirements. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of accepting cases under the ERA program. LSA must document their policies and procedures for determining a household?s eligibility to ensure LSA is in compliance with the statute. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-004 ? Eligibility (Significant Deficiency and Non-compliance) Corrective Action: Legal Services Alabama services provided services related to eviction proveedings and other legal services that aided in housing stability. LSA will continue its policies and procedures used for case acceptance and eligility requirements. LSA will review its policies for potential improvements. The review will be conducted by the second quarter of 2023 and any changes will be implemented by the third quarter of 2023. Contact Person: Michael Forton, Director of Advocacy; (256) 551-2671; mforton@alsp.org
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Information on the Federal Program: US Department of Treasury Emergency Rental Assistance Program Assistance Listing No. 21.023 Criteria: 2 CFR 200.303 establishes controls required for non-federal entities over reporting. Non-federal entities are required to establish and maintain effective controls over federal award management in compliance with federal statutes, regulations, terms and conditions of the grant. This requirement includes reviewing and approving grant reports prior to submission. Condition/Context: During our testing, we selected four reports submitted during the year for various ERA programs. None of these reports had documentation they were reviewed and approved prior to being submitted. Cause: Reports were submitted by email to the awarding agency and the Controller was copied on the submission emails when submitted. However, no documentation was available that the Controller or other appropriate member of management reviewed and approved these reports. Effect: LSA is not in compliance with required controls over reporting. Questioned Costs: None reported Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of preparing and reviewing grant reports to ensure LSA is in compliance with all internal controls requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan included at the end of the report.
Finding 2022-005 ? Internal Control over Reporting (Significant Deficiency) Corrective Action: LSA will resume a review and approval of every grant report and document the review as of the date of this audit report. Contact Person: David Roberson, Director of Finance; (334) 223-0251; droberson@alsp.org
FAC accepted this audit on May 30, 2022 — management decision was due November 30, 2022.
Finding 2021-001 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Section 1644 requires disclosure of case information for each case filed in court by its attorneys on behalf of a client of the recipient. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125 percent of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In 2 cases, the client exceeded the 125 percent income limit but no documentation of exceptions met were in the case file. In addition, one case was filed affirmatively in the courts but was not properly disclosed to LSC. Cause: The assigned attorney did not obtain the required documentation for the file and failed to properly report the case. Effect: LSA is not in compliance with case requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2021-001 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Section 1644 requires disclosure of case information for each case filed in court by its attorneys on behalf of a client of the recipient. 45 CFR 1611 establishes financial eligibility guidelines. Recipients adopt guidelines to establish a maximum annual income level for persons to be eligible to receive legal aid, not to exceed 125 percent of the Federal Poverty Income Guidelines. If the applicant?s income exceeds the threshold, there are certain factors that can be considered: current income prospects, unreimbursed medical expenses, fixed debts and obligations, and other expenses such as dependent care, transportation, expenses for employment, etc. Condition/Context: During our testing of controls, we examined 71 case files. In 2 cases, the client exceeded the 125 percent income limit but no documentation of exceptions met were in the case file. In addition, one case was filed affirmatively in the courts but was not properly disclosed to LSC. Cause: The assigned attorney did not obtain the required documentation for the file and failed to properly report the case. Effect: LSA is not in compliance with case requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2021-001 ? Case Requirements (Non-compliance) Corrective Action: In response to the findings that LSA had opened several cases where clients were over 125% of poverty but no exceptions were documented, LSA investigated and talked with staff. Based on the investigation we found several more cases where LSA had failed to document exceptions. As a result, LSA spoke with the staff involved along with the managing attorneys. Staff were reminded of LSA?s obligation to document expenses when a potential client is over 125% of poverty. LSA also reviewed cases opened in 2022 and corrections were made to those cases. Finally, LSA created a computer report which will automatically be generated and emailed weekly to the managing attorney of the Call Center (where all of the cases at issue were opened) to review for compliance. Contact Person: Michael Forton, Director of Advocacy; 256-551-2671; mforton@alsp.org
2020-002
FAC accepted this audit on April 4, 2021 — management decision was due October 4, 2021.
Finding 2020-001 ? Internal Controls over case compliance (Significant Deficiency and Noncompliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Sections 1604 through 1644 establish multiple compliance requirements over case compliance. Grantees must have internal controls in place to ensure each compliance requirement and their policies and procedures must be in place to ensure compliance. Control activities established by LSA require the managing attorney in each office to determine whether a case can be accepted. Condition/Context: During our testing of controls, we examined 71 case files. Of those 71, 27 exceptions were noted for lack of managing attorney approvals. And one case was closed using the wrong code. Cause: The managing attorney is not consistently assigning the cases or otherwise documenting a review of case files for compliance. Effect: LSA?s system of internal controls over LSC case compliance was not properly implemented. Recommendation: We recommend LSA review and implement policies and procedures to ensure that it has properly designed and maintained a strong internal control system to ensure compliance with LSC case compliance. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2020-001 ? Internal Controls over case compliance (Significant Deficiency and Noncompliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Sections 1604 through 1644 establish multiple compliance requirements over case compliance. Grantees must have internal controls in place to ensure each compliance requirement and their policies and procedures must be in place to ensure compliance. Control activities established by LSA require the managing attorney in each office to determine whether a case can be accepted. Condition/Context: During our testing of controls, we examined 71 case files. Of those 71, 27 exceptions were noted for lack of managing attorney approvals. And one case was closed using the wrong code. Cause: The managing attorney is not consistently assigning the cases or otherwise documenting a review of case files for compliance. Effect: LSA?s system of internal controls over LSC case compliance was not properly implemented. Recommendation: We recommend LSA review and implement policies and procedures to ensure that it has properly designed and maintained a strong internal control system to ensure compliance with LSC case compliance. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Corrective Action: LSA believes we have very strong controls regarding case compliance. LSA cases currently undergo a four-part process to ensure they are compliant, and it has led to a level of compliance substantially above the national average. Cases at LSA are first screened and opened by administrative assistants trained to make sure that clients are both LSC compliant and within LSA priorities. Administrative assistants are regularly trained. Second, the cases are reviewed and, when appropriate, accepted by attorneys trained and familiar with LSC guidelines who have executed documentation under 45 CFR ? 1620.6 indicating they will not accept LSA non-priority cases. These attorneys (as all LSA attorneys are) are trained shortly after being hired by the Director of Advocacy on compliance and priorities and retrained on a regular basis. Third, each staff member is also required to review their file indicating that LSC regulations have been complied with before the case is prepared for closure. By completing the checklist included in our Legal Services database the staff member attests that all elements of LSC compliance have been met. Finally, the Managing Attorney or Lead Attorney (when designated the task by the Managing Attorney) review each case to ensure compliance before it is finally closed. Managing Attorneys are also tasked with identifying problem areas or staff who may have compliance issues and ensuring the issues are resolved. Based on the fact that LSA?s intake procedures have largely remained unchanged since the establishment of the Call Center fifteen years again and our practices have been reviewed numerous times by both the Office of Compliance and Enforcement and Office of Program Performance, LSA believes this four step process establishes strong internal controls. Finding 2020-001 states that ?Control activities established by LSA require the managing attorney in each office to determine whether a case can be accepted.? Based on the changes adopted by the LSA Board of Directors in LSA?s Compliance Manual, LSA believes it has addressed this control activity, but does accept the finding. To the extent that LSA?s current practices did lead to a single error out of the 71 cases sampled from 2020, LSA would note that this error rate is substantially lower than the average error rate of all LSC programs which is 4.3 percent. See the March 31, 2004 Housing Subcommittee Hearing on Legal Services. It is also worth noting that since the only error was committed by a Managing Attorney (who is no longer employed by LSA), that the suggested control would not have remedied the issue. Training was completed on March 31, 2021 by the Director of Advocacy with the Managing Attorneys and Lead attorneys regarding the finding and what proper procedure is. The control policies will be further reviewed, and any changes needed, if needed, will be adopted by the June 2021 LSA Board of Director?s meeting. Contact Person: Michael Forton, Director of Advocacy; 256-551-2671; mforton@alsp.org
Finding 2020-002 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Section 1626 establishes restrictions on legal assistance by ensuring recipients provide legal assistance only to citizens of the United States and eligible aliens. Applicants for legal aid should attest in writing unless the only service provided was brief advice and consultation. 45 CFR 1611 establishes eligibility guidelines. Recipients should routinely execute a retainer agreement for each client when extended service representation is required. Condition/Context: During our testing of controls, we examined 71 case files. Of those 71, 37 required proof of citizenship based on the level of service provided. Of those 37, a signed proof of citizenship was not in the file. Of those 71, 30 required a signed retainer based on the level of service provided. Of those 30, a signed retainer agreement was not in one of the case files. Cause: The assigned attorney did not obtain the required documentation for the file. Effect: LSA is not in compliance with case restriction documentation requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2020-002 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant, COVID-19 LSC Response Grant, and COVID-19 Telework Capacity Building Grant Criteria: 45 CFR Section 1626 establishes restrictions on legal assistance by ensuring recipients provide legal assistance only to citizens of the United States and eligible aliens. Applicants for legal aid should attest in writing unless the only service provided was brief advice and consultation. 45 CFR 1611 establishes eligibility guidelines. Recipients should routinely execute a retainer agreement for each client when extended service representation is required. Condition/Context: During our testing of controls, we examined 71 case files. Of those 71, 37 required proof of citizenship based on the level of service provided. Of those 37, a signed proof of citizenship was not in the file. Of those 71, 30 required a signed retainer based on the level of service provided. Of those 30, a signed retainer agreement was not in one of the case files. Cause: The assigned attorney did not obtain the required documentation for the file. Effect: LSA is not in compliance with case restriction documentation requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Corrective Action Plan at the end of the report.
Corrective Action: LSA acknowledges that in the review of 71 cases, one lacked proper citizenship documentation and one lacked a proper retainer. Upon review, the one case lacking proper documentation was handled on an emergency basis, and the LSA attorney appeared in court before paperwork was executed due to an inability to get the client?s signature, due to pandemic protocols. The client thereafter failed to execute the paperwork. This does not, however, relieve LSA of our obligation to comply with regulations. The Director of Advocacy met with the Managing Attorneys and Lead Attorneys to train them on compliance issues on March 31, 2021. The Managing and Lead Attorneys were re-trained regarding our obligation to compliance with both citizenship and retainer agreements. Contact Person: Michael Forton, Director of Advocacy; 256-551-2671; mforton@alsp.org
2019-005
FAC accepted this audit on April 28, 2020 — management decision was due October 28, 2020.
Finding 2019-003 ? Internal Controls over Cost Standards and Procedures (Significant Deficiency) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1630 establishes cost standards and procedures for LSC grant recipients to determine the allowability of costs. Recipients must adopt written policies and procedures that develops and maintains a system of internal control to ensure compliance with LSC standards. Control activities established in the LSA Accounting Manual require proper approvals by the Controller, Director or Operations and Supervisors. Condition/Context: During our testing of controls, we examined 70 disbursements. Of those 70, 12 exceptions were noted for lack of proper approvals. Cause: 10 disbursements were not approved by the Controller for payment. Employee time sheets must be certificated by the employee and their supervisor prior to payment. Out of the 10 payroll disbursements tested, 2 timesheets were missing either the employee or supervisor approval. Effect: LSA?s system of internal controls over LSC Cost standards was not properly implemented. Recommendation: We recommend LSA review and revise its current policies and procedures to ensure that it has properly designed and maintained a strong internal control system to ensure compliance with LSC cost standards. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2019-003 ? Internal Controls over Cost Standards and Procedures (Significant Deficiency) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1630 establishes cost standards and procedures for LSC grant recipients to determine the allowability of costs. Recipients must adopt written policies and procedures that develops and maintains a system of internal control to ensure compliance with LSC standards. Control activities established in the LSA Accounting Manual require proper approvals by the Controller, Director or Operations and Supervisors. Condition/Context: During our testing of controls, we examined 70 disbursements. Of those 70, 12 exceptions were noted for lack of proper approvals. Cause: 10 disbursements were not approved by the Controller for payment. Employee time sheets must be certificated by the employee and their supervisor prior to payment. Out of the 10 payroll disbursements tested, 2 timesheets were missing either the employee or supervisor approval. Effect: LSA?s system of internal controls over LSC Cost standards was not properly implemented. Recommendation: We recommend LSA review and revise its current policies and procedures to ensure that it has properly designed and maintained a strong internal control system to ensure compliance with LSC cost standards. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Management Response: LSA will review its policies regarding disbursements and time certification. In addition, the new cloud-based accounting system Financial Edge NXT requires that the Controller approve all disbursements electronically prior to payment. The Controller approves and posts all disbursement activity. LSA is also implementing a new solution for time certification and approval for better tracking which will help eliminate missing documentation.
2018-002
Finding 2019-004 ? Priorities in Use of Resources (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1620 provides guidance to recipients for setting priorities and adopts written priorities for the types of cases, including emergencies, to which the recipient?s staff will limit its commitment of time and resources. Section 1620.6 requires all staff who handle cases or matters, or are authorized to make decisions about case acceptance, must sign an agreement that indicated they have read and are familiar with the established priorities, what and emergency situation would be, and will not undertake any case or matter that is not a priority or an emergency. Condition/Context: During our testing, we tested 10 payroll disbursements. Of those 10, 2 employees did not have a signed written agreement on file. Cause: LSA could not provide the signed written priority statement as required. Effect: LSA was not in compliance with priorities in use of resources requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of obtaining and retaining signed written priority agreements for all required employees. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2019-004 ? Priorities in Use of Resources (Significant Deficiency and Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1620 provides guidance to recipients for setting priorities and adopts written priorities for the types of cases, including emergencies, to which the recipient?s staff will limit its commitment of time and resources. Section 1620.6 requires all staff who handle cases or matters, or are authorized to make decisions about case acceptance, must sign an agreement that indicated they have read and are familiar with the established priorities, what and emergency situation would be, and will not undertake any case or matter that is not a priority or an emergency. Condition/Context: During our testing, we tested 10 payroll disbursements. Of those 10, 2 employees did not have a signed written agreement on file. Cause: LSA could not provide the signed written priority statement as required. Effect: LSA was not in compliance with priorities in use of resources requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of obtaining and retaining signed written priority agreements for all required employees. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Management Response: All staff are required to sign an agreement to abide by priorities at time of hire. The staff indicated in the office have signed the priority forms and are filed in their personnel file. Operations reviews and explains the form during initial onboarding. The agreement is part of LSA?s onboarding process checklist. Additionally, Operations conducted an audit of the personnel files to ensure that each staff?s form is on file. Employees will be contacted to complete the form if any forms are missing.
Finding 2019-005 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1626 establishes restrictions on legal assistance by ensuring recipients provide legal assistance only to citizens of the United States and eligible aliens. Applicants for legal aid should attest in writing unless the only service provided was brief advice and consultation. 45 CFR Section 1644 ensures that information about cases filed in court by grant recipients is disclosed. Condition/Context: During our testing, we selected 71 case files for review. Two exceptions were noted. Cause: Out of the 71 files tested, 52 required written proof of citizenship. Of these 52, 1 case file did not have documentation of citizenship. Out of the 71 files tested, 7 cases were filed affirmatively and required disclosure to LSC. One of those 7 cases was closed with the incorrect code but should have been disclosed based on the closing code in the system. Effect: LSA was not in compliance with case restriction documentation requirements and disclosure requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Show full finding ▾Hide full finding ▴Finding 2019-005 ? Case Requirements (Non-compliance) Information on the Federal Program: Legal Services Corporation Basic Field Grant and Technology Innovations Grant Criteria: 45 CFR Section 1626 establishes restrictions on legal assistance by ensuring recipients provide legal assistance only to citizens of the United States and eligible aliens. Applicants for legal aid should attest in writing unless the only service provided was brief advice and consultation. 45 CFR Section 1644 ensures that information about cases filed in court by grant recipients is disclosed. Condition/Context: During our testing, we selected 71 case files for review. Two exceptions were noted. Cause: Out of the 71 files tested, 52 required written proof of citizenship. Of these 52, 1 case file did not have documentation of citizenship. Out of the 71 files tested, 7 cases were filed affirmatively and required disclosure to LSC. One of those 7 cases was closed with the incorrect code but should have been disclosed based on the closing code in the system. Effect: LSA was not in compliance with case restriction documentation requirements and disclosure requirements. Recommendation: We recommend LSA strengthen its policies and procedures surrounding the process of opening and closing case files to ensure compliance with all required documentation and disclosure requirements. Views of Responsible Officials: See Management?s View and Corrective Action Plan at the end of the report.
Management Response: LSA acknowledges that errors were found in two of the 71 cases reviewed. One case did not have a citizenship form and the other was closed with the wrong closing code. LSA will address this issue in the upcoming meeting of Managing Attorneys to remind them of LSC regulations and the importance of reviewing files for compliance.
2018-004, 2018-005
FAC accepted this audit on May 28, 2019 — management decision was due November 28, 2019.
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2017-003
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2017-004
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2017-006
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2017-007
FAC accepted this audit on May 29, 2018 — management decision was due November 29, 2018.
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2016-004, 2016-005
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2016-003
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FAC accepted this audit on May 2, 2017 — management decision was due November 2, 2017.
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