Performance Audit of LSC’s Oversight of its Interest in Grantees’ Real Property

View Report

Date Issued

Monday, November 4, 2024

Submitting OIG

Legal Services Corporation OIG

Other Participating OIGs

Legal Services Corporation OIG

Agencies Reviewed/Investigated

Legal Services Corporation

Report Number

AU25-01

Report Type

Audit

Location

Washington, DC
United States

Number of Recommendations

Questioned Costs

Funds for Better Use

Open Recommendations

This report has 11 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
Review and inventory its own records and work with grantees to develop a definitive and authoritative record of LSC-funded real property and supporting documents that is complete, accurate and consistently updated.
2	No	$0	$0
Compile a comprehensive list of LSC-funded real property for which no property interest agreements can be located and execute property interest agreements if necessary.
3	No	$0	$0
Implement the GrantEase real property module and use it as a tool to reconcile grantees’ LSC-funded real property and supporting documents with OCE’s records on an annual basis as part of the FSRM financial statement review.
4	No	$0	$0
Update its FSRM guidance to identify and clarify the Fiscal Analysts’ roles and responsibilities regarding completion of the FSRM sections related to LSC-funded real property and updates to OCE’s Oversight Chart.
5	No	$0	$0
Develop and implement a plan (with milestones) to provide training to LSC grantees on their responsibilities regarding LSC-funded real property, including retention of records, authorized use of property, and accurate annual reporting.
6	No	$0	$0
Require that grantees with inaccurate annual LSC-funded real property accountings work with their auditors to correct errors and certify to LSC that the errors have been corrected in the next fiscal year.
7	No	$0	$0
Work with Grantee H to determine whether its LSC-funded vacant lot is needed for current operations or, if not, to dispose of the vacant lot in accordance with Subpart E of 45 C.F.R. Part 1631
8	No	$0	$0
Ensure that OCE’s updated Policies and Procedures Manual accurately describes and addresses current regulations, as well as OCE’s responsibilities as they relate to grantees’ LSC-funded real property.
9	No	$0	$0
Review existing property interest agreements for all LSC-funded properties to assess whether the agreement conditions (i) identify the applicable requirements of 45 C.F.R. Part 1631 and (ii) include language to ensure that the parties include the cost of LSC-funded capital improvements when determining LSC’s interest in proceeds from disposition.
10	No	$0	$0
Issue guidance and negotiate with LSC grantees, if necessary, to amend existing property interest agreements, to ensure the agreements include the requirements of 45 C.F.R. Part 1631 and that LSC’s interest in real property related to LSC’s investment in capital improvements is protected.
11	No	$0	$0
Work with grantees without property interest agreements to identify LSC-funded capital improvement costs and assess whether the parties should negotiate agreements to protect LSC’s interest in properties that the grantees did not initially acquire with LSC funds.