EIN: 860207220
UEI: H54FSY1P38P3
Audited by: Jaramillo Accounting Group
Oversight agency: 09 [Legal Services Corporation]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 21, 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 21, 2026 (83 days from today).
What is a management decision? →FAC accepted this audit on May 1, 2025 — management decision was due November 1, 2025.
2024-001 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Federal Agency: Legal Services Corporation Federal Program Information & Assistance Listing Number: 09.703068 Award Period: 1/1/2024 to 12/31/2024 Type of Findings: Significant Deficiency, Material Non-compliance Compliance Areas: Allowable Cost and Cost Principles Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. As of April 30, 2025, management has updated most of the policies noted in the OIG report; however, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Criteria 45 CFR Subtitle B - Subtitle B-Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI- LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC's current compliance requirements.
Show full finding ▾Hide full finding ▴2024-001 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Federal Agency: Legal Services Corporation Federal Program Information & Assistance Listing Number: 09.703068 Award Period: 1/1/2024 to 12/31/2024 Type of Findings: Significant Deficiency, Material Non-compliance Compliance Areas: Allowable Cost and Cost Principles Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. As of April 30, 2025, management has updated most of the policies noted in the OIG report; however, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Criteria 45 CFR Subtitle B - Subtitle B-Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI- LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC's current compliance requirements.
Recommendation We recommend DNA formally respond, in detail, to all deficiencies reported in the OIG Report, including Accounting Policies and other Policies such as the Vehicle Use Policy. As the Board needs to formally adopt all revised policies as noted in the OIG Report, we recommend: DNA provide the Board a redline copy of the changes for each revised policy. Correlate each revised policy to each finding in the OIG report and, Provide the Board each related policy section guidance in the LSC Financial Guide. Management Response Corrective Action: As of April 30, 2025, our accounting department is fully staffed and we are supporting accounting staff training needs. As of April 30, 2025, management has drafted updates to many of the policies and procedures referenced in the OIG report. Updated policies, including a revised Accounting Manual and an updated Personnel Manual will be presented to the Board, the Board Budget & Audit Committee, or the Board Executive Committee prior to the June 2, 2025 OIG response deadline. Management acknowledges that during the 2024 audit period the Legal Services Corporation Office of Inspector General (OIG) issued a final report on December 2, 2024 noting inadequate accounting policies, practices, and oversight for the period of January 1, 2022 through April 30, 2023. Also, while many of the policies noted in the OIG report have been updated, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Three primary causes contributed to the deficiencies noted during the period under review by the OIG (January 1, 2022 through April 30, 2023), and before the issuance of the final LSC OIG report in December 2024: Staffing shortages. For most of the January 1, 2022 to April 30, 2023 review period DNA had three vacancies in our five-person accounting operation. Additionally, our Chief Financial Officer was hired during the middle of the period under review, and even though he has extensive legal services accounting experience, he just started learning about DNA's organizational structure and accounting practices, and refamiliarizing himself with LSC accounting policies and financial guidelines. A change in LSC accounting standards applicable to nonprofit LSC funded organizations was implemented during the period under review which made some of our policies and procedures outdated. Management made a strategic decision to wait for the issuance of the final OIG report to ensure that updates to policies and practices would fully align with the OIG's expectations, rather than implementing piecemeal or interim measures that might have required further revision. Due Date of Completion: June 2, 2025 Responsible Person(s): Executive Director and Chief Financial Officer
2024-003 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Funding agency: Legal Services Corporation Title and Assistance Listing Number: Basic Field Grant 09.703068 Type of Finding: Significant Deficiency, Material Non-compliance Compliance Area: Allowable costs/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. DNA was required to update all the policies by June 2, 2025. As of January 15, 2026, management has updated all but one policy noted in the OIG report. Criteria 45 CFR Subtitle B - Subtitle B—Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI—LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect As of December 31, 2024, DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC’s current compliance requirements.
Show full finding ▾Hide full finding ▴2024-003 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Funding agency: Legal Services Corporation Title and Assistance Listing Number: Basic Field Grant 09.703068 Type of Finding: Significant Deficiency, Material Non-compliance Compliance Area: Allowable costs/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. DNA was required to update all the policies by June 2, 2025. As of January 15, 2026, management has updated all but one policy noted in the OIG report. Criteria 45 CFR Subtitle B - Subtitle B—Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI—LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect As of December 31, 2024, DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC’s current compliance requirements.
Recommendation We recommend DNA formally respond, in detail, to all deficiencies reported in the OIG Report, including Accounting Policies and other Policies such as the Vehicle Use Policy. As the Board needs to formally adopt all revised policies as noted in the OIG Report, we recommend: • DNA provide the Board a redline copy of the changes for each revised policy, • correlate each revised policy to each finding in the OIG report and • provide the Board each related policy section guidance in the LSC Financial Guide. Management Response Corrective Action As of January 15, 2026, our accounting department is short one person and we are supporting accounting staff training needs As of January 15, 2026, management has drafted updates and received acceptance by the OIG to all but one of the policies and procedures referenced in the OIG report. Updated policies, including a revised Accounting Manual and an updated Personnel Manual presented to the Board, the Board Budget & Audit Committee and the Board Executive Committee prior to the June 2, 2025 OIG response deadline. Management acknowledges that during the 2024 audit period the Legal Services Corporation Office of Inspector General (OIG) issued a final report on December 2, 2024 noting inadequate accounting policies, practices, and oversight for the period of January 1, 2022 through April 30, 2023. Also, while many of the policies noted in the OIG report have been updated, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Three primary causes contributed to the deficiencies noted during the period under review by the OIG (January 1, 2022 through April 30, 2023), and before the issuance of the final LSC OIG report in December 2024: • Staffing shortages. For most of the January 1, 2022 to April 30, 2023 review period DNA had three vacancies in our five-person accounting operation. Additionally, our Chief Financial Officer was hired during the middle of the period under review, and even though he has extensive legal services accounting experience, he just started learning about DNA’s organizational structure and accounting practices, and refamiliarizing himself with LSC accounting policies and financial guidelines. • A change in LSC accounting standards applicable to nonprofit LSC funded organizations was implemented during the period under review which made some of our policies and procedures outdated. • Management made a strategic decision to wait for the issuance of the final OIG report to ensure that updates to policies and practices would fully align with the OIG's expectations, rather than implementing piecemeal or interim measures that might have required further revision. Due Date of Completion: February 28, 2026. Responsible Person(s) Executive Director and Chief Financial Officer
2024-LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE Title: All included on the Schedule of Expenditures of Federal Awards Agency: All included on the Schedule of Expenditures of Federal Awards Pass Through: All included on the Schedule of Expenditures of Federal Awards Assistance Listings Number: All included on the Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Other - Late Filing of Single Audit Reporting Package Federal Award Year: 2024 Questioned Costs: None Condition DNA did not submit, during the fiscal year ending December 31, 2024, their Single Audit reporting package for the year ended December 31, 2023 (financial statements, data collection form, and corrective action plan) within the required time period. The December 31, 2023 single audit reporting package was due September 30, 2024. However, the report was not submitted until April 30, 2025. Criteria 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period Effect Late reporting could cause additional oversight or restriction by grantors Cause Internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512
Show full finding ▾Hide full finding ▴2024-LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE Title: All included on the Schedule of Expenditures of Federal Awards Agency: All included on the Schedule of Expenditures of Federal Awards Pass Through: All included on the Schedule of Expenditures of Federal Awards Assistance Listings Number: All included on the Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Other - Late Filing of Single Audit Reporting Package Federal Award Year: 2024 Questioned Costs: None Condition DNA did not submit, during the fiscal year ending December 31, 2024, their Single Audit reporting package for the year ended December 31, 2023 (financial statements, data collection form, and corrective action plan) within the required time period. The December 31, 2023 single audit reporting package was due September 30, 2024. However, the report was not submitted until April 30, 2025. Criteria 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period Effect Late reporting could cause additional oversight or restriction by grantors Cause Internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512
Recommendation We recommend that Management enhance its internal control structure, to include milestones for submitting the Single Audit Reporting Package. Management Response Corrective Action Corrective Action: DNA will comply with the recommendation. DNA will ensure processes are in place to comply with the due date of nine months after year end. Due Date of Completion: September 30, 2026. Responsible Party(ies) Chief Financial Officer
FAC accepted this audit on May 28, 2026 — management decision was due November 28, 2026.
2024-001 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Federal Agency: Legal Services Corporation Federal Program Information & Assistance Listing Number: 09.703068 Award Period: 1/1/2024 to 12/31/2024 Type of Findings: Significant Deficiency, Material Non-compliance Compliance Areas: Allowable Cost and Cost Principles Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. As of April 30, 2025, management has updated most of the policies noted in the OIG report; however, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Criteria 45 CFR Subtitle B - Subtitle B-Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI- LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC's current compliance requirements.
Show full finding ▾Hide full finding ▴2024-001 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Federal Agency: Legal Services Corporation Federal Program Information & Assistance Listing Number: 09.703068 Award Period: 1/1/2024 to 12/31/2024 Type of Findings: Significant Deficiency, Material Non-compliance Compliance Areas: Allowable Cost and Cost Principles Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. As of April 30, 2025, management has updated most of the policies noted in the OIG report; however, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Criteria 45 CFR Subtitle B - Subtitle B-Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI- LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC's current compliance requirements.
Recommendation We recommend DNA formally respond, in detail, to all deficiencies reported in the OIG Report, including Accounting Policies and other Policies such as the Vehicle Use Policy. As the Board needs to formally adopt all revised policies as noted in the OIG Report, we recommend: DNA provide the Board a redline copy of the changes for each revised policy. Correlate each revised policy to each finding in the OIG report and, Provide the Board each related policy section guidance in the LSC Financial Guide. Management Response Corrective Action: As of April 30, 2025, our accounting department is fully staffed and we are supporting accounting staff training needs. As of April 30, 2025, management has drafted updates to many of the policies and procedures referenced in the OIG report. Updated policies, including a revised Accounting Manual and an updated Personnel Manual will be presented to the Board, the Board Budget & Audit Committee, or the Board Executive Committee prior to the June 2, 2025 OIG response deadline. Management acknowledges that during the 2024 audit period the Legal Services Corporation Office of Inspector General (OIG) issued a final report on December 2, 2024 noting inadequate accounting policies, practices, and oversight for the period of January 1, 2022 through April 30, 2023. Also, while many of the policies noted in the OIG report have been updated, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Three primary causes contributed to the deficiencies noted during the period under review by the OIG (January 1, 2022 through April 30, 2023), and before the issuance of the final LSC OIG report in December 2024: Staffing shortages. For most of the January 1, 2022 to April 30, 2023 review period DNA had three vacancies in our five-person accounting operation. Additionally, our Chief Financial Officer was hired during the middle of the period under review, and even though he has extensive legal services accounting experience, he just started learning about DNA's organizational structure and accounting practices, and refamiliarizing himself with LSC accounting policies and financial guidelines. A change in LSC accounting standards applicable to nonprofit LSC funded organizations was implemented during the period under review which made some of our policies and procedures outdated. Management made a strategic decision to wait for the issuance of the final OIG report to ensure that updates to policies and practices would fully align with the OIG's expectations, rather than implementing piecemeal or interim measures that might have required further revision. Due Date of Completion: June 2, 2025 Responsible Person(s): Executive Director and Chief Financial Officer
2024-003 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Funding agency: Legal Services Corporation Title and Assistance Listing Number: Basic Field Grant 09.703068 Type of Finding: Significant Deficiency, Material Non-compliance Compliance Area: Allowable costs/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. DNA was required to update all the policies by June 2, 2025. As of January 15, 2026, management has updated all but one policy noted in the OIG report. Criteria 45 CFR Subtitle B - Subtitle B—Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI—LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect As of December 31, 2024, DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC’s current compliance requirements.
Show full finding ▾Hide full finding ▴2024-003 FOLLOW UP ON THE LEGAL SERVICES CORPORATION OFFICE OF THE INSPECTOR GENERAL - AUDIT OF SELECTED INTERNAL CONTROLS Funding agency: Legal Services Corporation Title and Assistance Listing Number: Basic Field Grant 09.703068 Type of Finding: Significant Deficiency, Material Non-compliance Compliance Area: Allowable costs/cost principles Federal Award Year: 2024 Questioned Costs: None Condition The Legal Services Corporation Office of Inspector General issued a final report (OIG Report) on December 2, 2024 for its testing of internal control and operational activities and noted inadequate policies, practices, and oversight over ten of eleven areas (formalize internal controls in writing for fixed assets, cost allocation, credit cards, contracting, derivative income, general ledger and financial control, disbursements, budgeting and management reporting, payroll, and client trust funds for the period of January 1, 2022 through April 30, 2023. Given the timing of the December 2, 2024 OIG Report, certain conditions existed during the annual audit of the year-ended December 31, 2024. DNA was required to update all the policies by June 2, 2025. As of January 15, 2026, management has updated all but one policy noted in the OIG report. Criteria 45 CFR Subtitle B - Subtitle B—Regulations Relating to Public Welfare, Chapter XVI - CHAPTER XVI—LEGAL SERVICES CORPORATION, § 1600.1 - § 1600.1 as further clarified in the LSC Financial Guide. Effect As of December 31, 2024, DNA is not in compliance with Legal Services Corporation federal statutes as further clarified in the LSC Financial Guide. Cause Primarily due to turnover and short staffing in the accounting transaction cycle. Additionally, with the last update of the accounting policies in November 2019, many of the policies have not since been updated as they do not conform to the LSC’s current compliance requirements.
Recommendation We recommend DNA formally respond, in detail, to all deficiencies reported in the OIG Report, including Accounting Policies and other Policies such as the Vehicle Use Policy. As the Board needs to formally adopt all revised policies as noted in the OIG Report, we recommend: • DNA provide the Board a redline copy of the changes for each revised policy, • correlate each revised policy to each finding in the OIG report and • provide the Board each related policy section guidance in the LSC Financial Guide. Management Response Corrective Action As of January 15, 2026, our accounting department is short one person and we are supporting accounting staff training needs As of January 15, 2026, management has drafted updates and received acceptance by the OIG to all but one of the policies and procedures referenced in the OIG report. Updated policies, including a revised Accounting Manual and an updated Personnel Manual presented to the Board, the Board Budget & Audit Committee and the Board Executive Committee prior to the June 2, 2025 OIG response deadline. Management acknowledges that during the 2024 audit period the Legal Services Corporation Office of Inspector General (OIG) issued a final report on December 2, 2024 noting inadequate accounting policies, practices, and oversight for the period of January 1, 2022 through April 30, 2023. Also, while many of the policies noted in the OIG report have been updated, the policies mentioned in the OIG report have not been reviewed or adopted by the Board. Three primary causes contributed to the deficiencies noted during the period under review by the OIG (January 1, 2022 through April 30, 2023), and before the issuance of the final LSC OIG report in December 2024: • Staffing shortages. For most of the January 1, 2022 to April 30, 2023 review period DNA had three vacancies in our five-person accounting operation. Additionally, our Chief Financial Officer was hired during the middle of the period under review, and even though he has extensive legal services accounting experience, he just started learning about DNA’s organizational structure and accounting practices, and refamiliarizing himself with LSC accounting policies and financial guidelines. • A change in LSC accounting standards applicable to nonprofit LSC funded organizations was implemented during the period under review which made some of our policies and procedures outdated. • Management made a strategic decision to wait for the issuance of the final OIG report to ensure that updates to policies and practices would fully align with the OIG's expectations, rather than implementing piecemeal or interim measures that might have required further revision. Due Date of Completion: February 28, 2026. Responsible Person(s) Executive Director and Chief Financial Officer
2024-LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE Title: All included on the Schedule of Expenditures of Federal Awards Agency: All included on the Schedule of Expenditures of Federal Awards Pass Through: All included on the Schedule of Expenditures of Federal Awards Assistance Listings Number: All included on the Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Other - Late Filing of Single Audit Reporting Package Federal Award Year: 2024 Questioned Costs: None Condition DNA did not submit, during the fiscal year ending December 31, 2024, their Single Audit reporting package for the year ended December 31, 2023 (financial statements, data collection form, and corrective action plan) within the required time period. The December 31, 2023 single audit reporting package was due September 30, 2024. However, the report was not submitted until April 30, 2025. Criteria 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period Effect Late reporting could cause additional oversight or restriction by grantors Cause Internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512
Show full finding ▾Hide full finding ▴2024-LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE Title: All included on the Schedule of Expenditures of Federal Awards Agency: All included on the Schedule of Expenditures of Federal Awards Pass Through: All included on the Schedule of Expenditures of Federal Awards Assistance Listings Number: All included on the Schedule of Expenditures of Federal Awards Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Other - Late Filing of Single Audit Reporting Package Federal Award Year: 2024 Questioned Costs: None Condition DNA did not submit, during the fiscal year ending December 31, 2024, their Single Audit reporting package for the year ended December 31, 2023 (financial statements, data collection form, and corrective action plan) within the required time period. The December 31, 2023 single audit reporting package was due September 30, 2024. However, the report was not submitted until April 30, 2025. Criteria 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period Effect Late reporting could cause additional oversight or restriction by grantors Cause Internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512
Recommendation We recommend that Management enhance its internal control structure, to include milestones for submitting the Single Audit Reporting Package. Management Response Corrective Action Corrective Action: DNA will comply with the recommendation. DNA will ensure processes are in place to comply with the due date of nine months after year end. Due Date of Completion: September 30, 2026. Responsible Party(ies) Chief Financial Officer
FAC accepted this audit on May 1, 2025 — management decision was due November 1, 2025.
FAC accepted this audit on September 29, 2023 — management decision was due March 29, 2024.
FAC accepted this audit on September 23, 2022 — management decision was due March 23, 2023.
FAC accepted this audit on August 2, 2021 — management decision was due February 2, 2022.
FAC accepted this audit on September 6, 2021 — management decision was due March 6, 2022.
Finding Number: 2017-002 Repeat Finding: Yes ? Modified Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09.703068 Federal Agency: Legal Services Corporation Federal Award No.: 703068 Pass-Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Cost Standards and Procedures CRITERIA According to 45 CFR 1630.3?-(h) and the Compliance Supplement for Audits of LSC Recipients, a cost is allocable to a particular cost objective, such as a grant, project, service, or other activity, in accordance with the relative benefits received. Costs may be allocated to an LSC grant or contract if it is treated consistently with other costs incurred for the purpose in like circumstances and if it: (1) is incurred specifically for the grant or contract; (2) benefits both the grant or contract and other work and can be distributed in reasonable proportion to the benefits received; or (3) is necessary to the overall operation of the recipient, although a direct relationship to any particular cost objective cannot be shown. Under CFR 1610, a recipient must adopt policies and procedures regarding the restrictions on recipients? activities. The policies must address non-LSC funds and the restrictions on the use of those funds. Additionally, according to CFR 1635.3, the required timekeeping records are to be made available for examination by the auditors and representatives of LSC. CONDITION DNA has not established adequate controls over personnel costs. CAUSE Processes and procedures in place were not followed. EFFECT Improper controls surrounding leave approvals could lead to over payment for hours not worked or completed on the LSC program. CONTEXT During review of personnel costs we noted in 1 of the 50 payroll records reviewed, the employee took leave, but no leave request form was provided. RECOMMENDATION We recommend DNA strengthen controls surrounding the approval and tracking of leave request forms. Documentation should be retained to support all leave taken by employees. Additionally, management along with DNA?s governing body should communicate the importance of the related policies and procedures and ensure all staff are following DNA policy. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Number: 2017-002 Repeat Finding: Yes ? Modified Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09.703068 Federal Agency: Legal Services Corporation Federal Award No.: 703068 Pass-Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Cost Standards and Procedures CRITERIA According to 45 CFR 1630.3?-(h) and the Compliance Supplement for Audits of LSC Recipients, a cost is allocable to a particular cost objective, such as a grant, project, service, or other activity, in accordance with the relative benefits received. Costs may be allocated to an LSC grant or contract if it is treated consistently with other costs incurred for the purpose in like circumstances and if it: (1) is incurred specifically for the grant or contract; (2) benefits both the grant or contract and other work and can be distributed in reasonable proportion to the benefits received; or (3) is necessary to the overall operation of the recipient, although a direct relationship to any particular cost objective cannot be shown. Under CFR 1610, a recipient must adopt policies and procedures regarding the restrictions on recipients? activities. The policies must address non-LSC funds and the restrictions on the use of those funds. Additionally, according to CFR 1635.3, the required timekeeping records are to be made available for examination by the auditors and representatives of LSC. CONDITION DNA has not established adequate controls over personnel costs. CAUSE Processes and procedures in place were not followed. EFFECT Improper controls surrounding leave approvals could lead to over payment for hours not worked or completed on the LSC program. CONTEXT During review of personnel costs we noted in 1 of the 50 payroll records reviewed, the employee took leave, but no leave request form was provided. RECOMMENDATION We recommend DNA strengthen controls surrounding the approval and tracking of leave request forms. Documentation should be retained to support all leave taken by employees. Additionally, management along with DNA?s governing body should communicate the importance of the related policies and procedures and ensure all staff are following DNA policy. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2017-002 Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09-703068 Contact Person: Rodolfo Sanchez, Executive Director Anticipated Completion Date: June 30, 2020 Planned Corrective Action: DNA will offer a written reminder to all staff of the requirement to obtain approval on a leave request form in advance of taking leave. We will also reinforce our existing detective control to confirm leave shown on a timecard is supported by an approved leave request form.
Finding Number: 2019-001 Repeat Finding: No Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09.703068 Federal Agency: Legal Services Corporation Federal Award No.: 703068 Pass-Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Cost Standards and Procedures CRITERIA Section 200.302(b) of the Uniform Guidance requires entities receiving federal awards identify in its records all Federal awards received and expended. CONDITION DNA?s internal controls were not adequate to ensure expenses of federal awards are reported in accordance with federal guidelines. CAUSE Controls in place were not properly followed to ensure federal expenses were recorded in the proper year in accordance with LSC regulations EFFECT Expenses were not allocated in the proper year. Additionally, processes and procedures were not in place or were not followed. CONTEXT During review of non-personnel costs we noted in 1 of the 45 disbursements reviewed, the invoice totaling $1,126.48 was incorrectly recorded in fiscal year 2019, rather than fiscal year 2018. RECOMMENDATION Management?s year end close out procedures should include a review of all account balances to ensure the balances are properly stated in the current fiscal year. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding Number: 2019-001 Repeat Finding: No Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09.703068 Federal Agency: Legal Services Corporation Federal Award No.: 703068 Pass-Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Cost Standards and Procedures CRITERIA Section 200.302(b) of the Uniform Guidance requires entities receiving federal awards identify in its records all Federal awards received and expended. CONDITION DNA?s internal controls were not adequate to ensure expenses of federal awards are reported in accordance with federal guidelines. CAUSE Controls in place were not properly followed to ensure federal expenses were recorded in the proper year in accordance with LSC regulations EFFECT Expenses were not allocated in the proper year. Additionally, processes and procedures were not in place or were not followed. CONTEXT During review of non-personnel costs we noted in 1 of the 45 disbursements reviewed, the invoice totaling $1,126.48 was incorrectly recorded in fiscal year 2019, rather than fiscal year 2018. RECOMMENDATION Management?s year end close out procedures should include a review of all account balances to ensure the balances are properly stated in the current fiscal year. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2019-001 Program Name/CFDA Title: Legal Services Corporation CFDA Number: 09-703068 Contact Person: Rodolfo Sanchez, Executive Director Anticipated Completion Date: June 30, 2020 Planned Corrective Action: DNA will provide additional training to accounting personnel regarding the appropriate period for recording payable invoices.
2018-002
FAC accepted this audit on June 30, 2019 — management decision was due December 30, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-003
FAC accepted this audit on December 27, 2018 — management decision was due June 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-002
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-003
FAC accepted this audit on May 9, 2017 — management decision was due November 9, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-003
GSA_MIGRATION
Show full finding ▾Hide full finding ▴Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Browse other Single Audit organizations in New Mexico →
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
