Open Recommendations

We recommend LAN strengthen controls to ensure invoices are paid timely by routinely reviewing outstanding payables and prioritizing payment of those approaching, or past, their deadline.

We recommend LAN ensure all invoices are clearly marked as “paid” following disbursement.

"We recommend LAN work with their Board to determine whether check request forms should remain a requirement for all disbursements.
• If they are required, ensure all disbursement packages include a completed form.
• If they are no longer required, update the Accounting Manual to establish disbursement procedures that ensure source documentation is modified to prevent duplicate payments."

We recommend LAN ensure all credit card charges are supported by the required documentation, per LAN’s policies and procedures, along with contemporaneous records that clearly state the business purpose and demonstrate compliance with LSC requirements.

We recommend LAN implement controls to ensure that all transactions are assigned a grant code in the accounting system and have supporting documentation that clearly identifies the funding source.

We recommend LAN document and enforce credit card spending limits, ensuring any deviations or temporary increases are approved by the appropriate individual with the reason documented.

We recommend LAN implement controls to ensure that only authorized cardholders can access credit card information. If a non-cardholder must make a purchase, prior written authorization (such as an email or memo) should be required and the transaction documented accordingly.

We recommend LAN update their Accounting Manual to include transaction and account limits and deadlines for submitting supporting documentation, as required by the LSC Financial Guide.

We recommend LAN implement procedures for adequate review of case timekeeping to ensure accurate and proper allocation of attorneys’ fees.

We recommend LAN implement procedures to ensure that the source and allocation of all investment income are adequately documented in sufficient detail and retained in accordance with applicable document retention requirements to support accurate financial reporting and compliance with LSC requirements.

We recommend LAN ensure consistency between their Fee Generating Cases Policy and the LAN Accounting Manual regarding the allocation of attorneys’ fees.

We recommend LAN document all asset movements, regularly replace damaged or missing tags and record inventory discrepancies in both the inventory records and the general ledger.

We recommend LAN promptly decommission outdated equipment and reinforce LAN’s Device Replacement Policy. Devices no longer under warranty or running unsupported systems should be retired or isolated with appropriate risk mitigation. Exceptions should be supported by documented business rationale.

We recommend LAN revise its Accounting Manual to include written procedures for inventory and disposal of IT and other sensitive equipment. The policy should require documentation of disposal method, date, approval, and valuation (if sold), and include controls to ensure protection of sensitive information on retired devices.

We recommend LAN require that complete, funding source budget-to-actual reports are prepared monthly, showing revenue and expenses by funding source. This requirement should be reflected in LAN’s written policies

We recommend LAN review and resolve all outstanding checks older than six months consistent with LSC policy and state escheatment requirements. Unresolved balances from prior periods should be investigated, documented, and cleared where appropriate, including outstanding payments and deposit adjustments.

We recommend LAN update the Accounting Manual to require regular review of stale checks with clearly defined responsibilities and documentation standards.

"We recommend LAN revise their bank reconciliation policy to:
• establish a timeline for completing reconciliations (e.g., within 30 days of month-end.);
• require preparers to sign and date reconciliations; and
• include procedures for voiding checks, including physical retention, reason for voiding, and accounting treatment."

We recommend LAN resolve all client trust checks outstanding for more than six months in accordance with LSC requirements and applicable state escheatment laws.

We recommend LAN implement a verification step to ensure all required approvals for sole source contracts are obtained and documented before execution. Email approvals should be formalized through signatures or verified electronic authorization.

We recommend LAN revise the Accounting Manual to explicitly require prior written approval from LSC before expending more than $25,000 of LSC funds on applicable contracts or purchases. The policy should reference 45 C.F.R. § 1630.6 and Part 1631 and require that evidence of LSC approval be retained in the procurement file.

We recommend the Vice President, Transmission System Projects, continue implementation of lessons learned identified from the Strategic Fiber Initiative program for application on future programs.

We recommend the Vice President, Transmission System Projects, for future programs, ensure estimated program costs are adequately supported, including the identification and evaluation of assumptions used to support the estimate.

We recommend the Vice President, Transmission System Projects, evaluate opportunities for maximizing surplus fiber revenue to help offset program costs.

Update applicable procedures to better align with the Sarbanes-Oxley Act of 2002, Section 408(c), and to clarify expectations for the timeliness of Sarbanes-Oxley Act reviews and reporting.