COMMUNITY LEGAL SERVICES

Finding 2025-101 — Semi-Annual Reports – Significant Deficiency in Internal Controls over Compliance (Compliance - Reporting) Federal program information: Funding agencies: Legal Services Corporation, Titles: Basic Field Grant, Migrant Worker Grant, Technology Initiative Grant, Assistance Listing Number: 09.703030 Award year: 2025 Award numbers: N/A Pass-Through grantors: N/A Compliance Requirements: Reporting Questioned Costs: N/A Criteria: Under the Legal Services Corporation grant terms and conditions the organization is required to submit semi-annual progress reports. Progress reports are to be submitted within 30 days of the end of the reporting period. Condition: 2 of 2 TIG semi-annual progress reports selected for review were not submitted by the due date. Cause and Effect: The organization does not have adequate policies and procedures in place to ensure that all reports are submitted timely. The result is that there is increased chance of non-compliance with the requirements of the grant. Auditors’ Recommendations: The organization should establish policies and procedures to ensure that all reports are submitted at the time due.

Federal program information: Funding agencies: Legal Services Corporation, U.S. Department of Treasury Titles: Basic Field Grant, Migrant Worker Grant, Technology Initiative Grant, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 09.703030, 21.027 Award year: 2024 Award numbers: SLFRP1962, CTR067423, C-22-22-159-X-02, C- 73-22-060-X-00 Pass-Through grantors: Arizona Department of Public Safety, Arizona Foundation for Legal Services and Education, Maricopa County, Arizona Compliance Requirements: Procurement Questioned Costs: N/A Criteria: Under the Legal Services Corporation grant terms and conditions and the Coronavirus State and Local Fiscal Recovery requirements the organization should establish and follow procurement policies and procedures. The procurement policies established by CLS require 2 informal quotes for purchases exceeding $2,000, but less than $10,000. Condition: For 2 of 25 transactions that exceeded $2,000 selected for testwork there was no informal quotes obtained as required by the organization’s policies. Cause and Effect: The organization did not follow its policies for procurement. The organization may not have received the most competitive price for goods and services purchased under the grant. Auditors’ Recommendations: The organization should ensure that it is following it policies and procedures for procurement.

Finding 2023-101 — Semi-Annual Reports – Significant Deficiency in Internal Controls over Compliance (Compliance - Reporting) Federal program information: Funding agencies: Legal Services Corporation Titles: Basic Field Grant, Migrant Worker Grant Assistance Listing Number: 09.703030 Award year: 2023 Award numbers: N/A Pass-Through grantors: N/A Compliance Requirements: Reporting Questioned Costs: N/A Criteria: Under the Legal Services Corporation grant terms and conditions the organization is required to submit all board approved minutes from each each full board and committee meeting that occurred in the prior six months. The reports are to be submitted on February 1st and again on August 1st of each year. Condition: As of the date that audit testwork was performed the organization had not submitted 2 of the 5 approved board meeting minutes. Cause and Effect: The organization does not have adequate policies and procedures in place to ensure that all board meeting minutes are submitted timely. The result is that there is increased chance of non-compliance with the requirements of the grant. Auditors’ Recommendations: The organization should establish policies and procedures to ensure that all board meeting minutes are submitted at the time due.

Significant Deficiency in Internal Controls over Compliance (Compliance - Reporting) Federal program information: Funding agencies: Legal Services Corporation Titles: Basic Field Grant, Migrant Worker Grant Assistance Listing Number: 09.703030 Award year: 2023 Award numbers: N/A Pass-Through grantors: N/A Compliance Requirements: Special Tests and Provisions Questioned Costs: N/A Criteria: All staff who handle cases or matters, or make decisions about case acceptance, must have signed a simple agreement, developed by the recipient, indicating that the signatory: (a) has read and understands the priorities established by the recipient's governing body; (b) has read and understands the definition of an emergency situation and the recipient's procedures for dealing with an emergency that falls outside of the recipient's priorities; and (c) will not undertake any case or matter for the recipient that is not a priority or an emergency. (45 C.F.R. § 1620.6). Condition: 2 of 25 staff selected for testwork did not have a signed simple agreement available for review. Cause and Effect: The organization does not have adequate policies and procedures in place to ensure that all staff has completed the necessary agreement and ensures that the agreements are available for review. The result is that there is increased chance of non-compliance with the requirements of the grant. Auditors’ Recommendations: The organization should establish policies and procedures to ensure that all staff completes the necessary agreement and ensures that the documentation is available for review.