Recommendations

The LSC OIG Office of Audit makes recommendations in its reports to help LSC and its grantees improve the efficiency and effectiveness of their programs. These recommendations help identify questioned costs and funds that could be put to better use. The aim is to spur our audited entities to take corrective actions, which allow us to close the recommendations.

This dashboard identifies current open recommendations. A recommendation is considered closed when the OIG confirms that the auditee has successfully implemented corrective action to address the recommendation.

Recommendations Chart by Calendar Year

Recommendation issue date and quantity
Year # Open
2019 3
2021 1
2022 5
2024 27
Recommendation issue date and quantity
Year # Closed
2018 25
2019 119
2020 49
2021 113
2022 30
2023 18
2024 89

Current Open Recommendations


Audit of Selected Internal Controls at Central Virginia Legal Aid Society, Inc

Recommendation #8

Conduct a detailed review of all payroll processed in 2018 and 2019 to identify payroll over and underpayments and complete this review within six months of the issuance of this report.

Recommendation #9

To the extent consistent with the law, reimburse employees that were identified as underpaid and attempt to recover payment from all employees that were identified as overpaid in the above review.

Recommendation #16

Ensure that LSC unallowable costs are charged to funding sources other than LSC and reflected within the financial software to provide an audit trail.


Audit of Selected Internal Controls at Legal Services Vermont

Recommendation #1

Consult with LSC Management to ensure the grantee’s engagement with VLA meets the existence of separate personnel criteria stipulated in LSC Regulation 45 CFR 1610.8.


Audit (AU-22-02) on LSC’s Distribution, Use, and Oversight of CARES Act Funds

Recommendation #1

Develop written procedures to maintain documents for Special Purpose, Disaster, or other similar grants. If the documents for requests and approvals of COVID-19 quarterly report extensions can be retrieved, keep them in a central location.

Recommendation #3

Ensure that OPP and OCE Policies and Procedures Manual are updated and complete, including policies and procedures for the oversight and monitoring of Disaster Program funds, which would include LSC CARES Act Funds.

Recommendation #6

Complete revisions and publish the OFAS Accounting Procedures Manual (LSC is currently working to complete and publish the draft OFAS Accounting Procedures Manual), including bank account verification policies and procedures.


Audit on Selected Internal Controls at Texas RioGrande Legal Aid, Inc

Recommendation #24

Ensure that monthly management reports are reviewed by the Executive Director prior to distribution to the Finance Committee every month and the Board of Directors quarterly. Approvals of each monthly management report should be documented when the monthly management reports are finalized and reviewed by all parties.

Recommendation #26

Ensure that TRLA’s Employee Handbook is updated to reflect the current policies described in the Collective Bargaining Agreement.


Audit on Selected Internal Controls at Legal Action of Wisconsin, Inc.

Recommendation #

We are referring $8,534 in questioned costs for further review and action. The questioned costs consist of
credit card purchases for which LAW did not maintain adequate documentation to support the purposes of
the transactions or explain why they were allowable under LSC regulations and guidance.


Audit on Selected Internal Controls at Northwest Justice Project

Recommendation #1

Develop an allocation methodology that will ensure that all attorneys’ fees are proportionately allocated to the fund in which the LSC grant is recorded in the same proportion that the amount of LSC funds were spent on a case or representation.

Recommendation #2

Update and develop LSLRA written policies and procedures for (1) Non-Union Manager Level Staff and (2) the basis for determination of the attorney’s level of experience.

Recommendation #3

Review all LSLRA reimbursements within the audit period (January 1, 2022 to May 31, 2023) to verify that the employees reimbursed were at the experience level 24 and below, per the CBA. Document the results and any deviations from the policy, including review and approval.

Recommendation #4

Review the loan documentation submitted for LSLRA to ensure the documents included with the student loan statements contain the employees’ names, dates of the loan statements, and loan balances for the tuition reimbursements paid within the audit period (January 1, 2022, to May 31, 2023). Once completed, document the results of the review.

Recommendation #5

Obtain the supporting documentation, containing the loan amount forgiven and loan forgiveness date, from the student loan servicer for the employee with the student loan forgiven in 2023.

Recommendation #6

We recommend that the Executive Director update the written policies and procedures for LSLRA to include the following:• Specific, required loan documentation. For example, monthly loan statements from the student’s loan servicer, complete with name, address, and loan balance for the applicable year the reimbursement is requested.• Specific deadline for submitting the Certification form and loan documentation. • Specific procedures for reviewers and approvers, including documenting the review and approval with a signature and date.

Recommendation #7

We recommend that the Executive Director notify and obtain approval from LSC for the purchase of 50 laptops exceeding $25,000.

Recommendation #8

We recommend that the Executive Director develop and implement a process for tagging capitalized property and equipment.

Recommendation #9

We recommend that the Executive Director conduct a physical inventory of capitalized property and equipment as soon as possible, document the results, and do so at least every two years.

Recommendation #10

Update and implement contracting policies to include the following: • requirements for sole source justification;• discouragement of automatically renewing contracts, when possible and if terms allow. If automatically renewing contracts are unavoidable, consider setting up automated reminders to periodically reevaluate contracts;• requirements for periodic re-competition of contracts, when appropriate; and• requirements for full documentation for each contract action, including the request for proposals, vendor selection and approval.

Recommendation #11

We recommend that the Executive Director implement a control to ensure only authorized cardholders have access to card information. In the event another staff member needs to use a credit card and the cardholder cannot make the purchase for them, adequate documentation should be maintained to show that the cardholder authorized the purchase and access to the card was limited.

Recommendation #12

We recommend that the Executive Director ensure credit card user acknowledgment agreements are signed by all cardholders.

Recommendation #13

We recommend the Executive Director update NJP’s written policies for credit cards to include, at a minimum, the following:• guidelines on personal use and disallowed charges;• guidelines on properly documenting any deviations from policy;• restrictions on cash advances and ATM withdrawals;• deadlines for providing supporting documentation;• procedures for cardholders to review and acknowledge credit and purchase card policies.

Recommendation #14

We recommend that the Executive Director document the complete cost allocation process including the adjustments made to arrive at the final allocations for indirect costs.

Recommendation #15

We recommend that the Executive Director enable distinct user access roles for the NJP accounting staff that are commensurate with their responsibilities to ensure adequate segregation of duties is maintained in the accounting software.

Recommendation #16

We recommend that the Executive Director implement a process requiring dated approvals prior to expenses being incurred.

Recommendation #17

We recommend the Executive Director establish a process to document advance approval for employee travel, and, if appropriate, set a threshold above which such approval must be documented and not only given verbally.

Recommendation #18

We recommend that the Executive Director develop policies to ensure the timely disposition of outstanding checks.

Recommendation #19

We recommend that the Executive Director ensure NJP’s Accounting Manual (and, if applicable, Personnel Manual) is updated to include the grantee’s processes surrounding the referenced criteria. This includes:• payroll procedure details,• roles/responsibilities,• frequency,• documentation requirements, and• review/approval requirements (including changes/adjustments).


Performance Audit Report on SALA’s LSC Grant Oversight and Compliance with LSC Grant Requirements

Recommendation #1

Develop written timekeeping policies and procedures, including timesheet review, and provide training to SALA staff and to new employees on charging leave and holiday time.

Recommendation #2

Provide training to all SALA employees involved in coding costs as direct or indirect. The training should include the definitions of direct and indirect costs and should contain explicit guidance on how to account for each type of expense.

Recommendation #3

Update SALA’s Accounting Manual to include a specific, compliant method for charging support staff salaries directly to sponsored funding sources as well as policies and procedures to account for hours worked in excess of the SALA 35 hours per week requirement.

Recommendation #4

Once the Accounting Manual is updated, provide training to its accounting staff.

Recommendation #5

Update the SALA Accounting Manual with detailed second-party review procedures to ensure that unallowable expenses are not charged to the LSC grants.

Recommendation #6

Once the Accounting Manual is updated with detailed procedures, train applicable SALA staff on the timecard and second-party review procedures.

Recommendation #7

Develop detailed review procedures and/or checklists to be used in oversight reviews of records created to support accounting entries and/or compliance assessments.