Legal Service Corporation Technical Assistance Review Visit

Legal Service Corporation – Technical Assistance Review Visit

The purpose of the visit is to help us spot and correct any deficiencies in our compliance with LSC regulations (in a setting other than a visit from the Office of the Inspector General) and to establish an open and ongoing line of communication between us and the Office of Compliance and Enforcement.
In advance of the visit, we briefed all staff on the purpose of the visit, and the procedure to be used. We prepared them for the kinds of questions and issues that might come up, and how to handle any uncertainty they might have in answering.
Activities during the visit:
Presentations by the LSC team on LSC requirements;
Time for staff to ask the LSC team questions about requirements;
Staff open and closed case review exercises;
A limited review and assessment of our fiscal systems and controls;
We received about four months advance notice of the visit and the dates were mutually agreed upon (not dictated by LSC).
We were asked to provide an extensive listing of open and closed cases, handled by both staff and PAI partners. In all, we were asked to generate about four dozen separate listing (by office, by Staff vs. PAI, etc.). There were specific, detailed instructions on how the list was to be sorted and what information was to be included in the lists (advocate, funding code, etc.). The list was required well in advance of the actual visit and was used by the LSC team to instruct us to pull a large number (several hundred) sample cases for evaluation.
The actual case files were held by us for use during the visit and were not requested by or provided to, the LSC team. Of the hundreds of cases pulled, less than half were actually used.
We were asked to provide copies of our eligibility policies, priorities, cost allocation methods, segregation of duties policies, independent contractors, and accounting, and some limited review of payroll, timekeeping, and budget records.
We had the option to dispute LSC’s access to any records we felt qualified as privileged or confidential, and were furnished with a procedure to resolve any such dispute.
The LSC team designed a three-day schedule which included both the fiscal review and group meetings with service delivery staff from all our offices. Our LSC team was composed of five people. One person conducted “private” fiscal review meetings with our accounting staff. Group “case review” meetings were held in four of our six offices, with staff from smaller offices traveling to the nearest larger office. All staff responsible for intake and case handling were included in these meetings.
The group meetings consisted of a short presentation by the LSC team, general questions and answers, then reviews of individual cases. We were instructed to have the cases previously selected by the LSC team for review available in the rooms where the meetings were held. Individual staff selected a case at random from the boxes of cases, but not a case that staff member had handled. They then reviewed the file and completed an LSC Case Review Form (sample attached), noting in various fields the answers to regulatory compliance issues such as: Funding source; Problem code; Intake date; Reason closed, Income verification; Eligibility; Retainers; Citizenship attestations, etc. The LSC team collected and reviewed these forms. Several cases were selected for discussion, and used as examples to illustrate various regulatory requirements. The LSC team never handled or viewed the individual case files, and individual client names were never listed or disclosed.
At the conclusion of the visit, the LSC team leader met with the Executive Director for a brief exit conference to highlight any areas where compliance seemed to be a recurring issue. About a month later, these were committed to writing and sent to the Executive Director for follow-up and correction, but were not documented as areas of non-compliance for OIG purposes.
The items identified in the visit were the subject of a day-long follow-up training for all staff, concentrating on clarifying regulatory requirements, and correcting any erroneous practices going forward.