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Testimony: 

Before the Committee on the Judiciary, U.S. Senate: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 2:00 p.m. EDT: 

Thursday, May 22, 2008: 

Legal Services Corporation: 

Improvements Needed in Governance, Accountability, and Grants 
Management and Oversight: 

Statement of Jeanette Franzel, Director: 

Financial Management and Assurance: 

GAO-08-833T: 

Mr. Chairman and Members of the Committee: 

I am pleased to be here today to discuss our recent reviews[Footnote 1] 
of Legal Services Corporation's (LSC) governance, accountability and 
grants management practices. LSC's mission is to make federal funding 
available to provide legal assistance in civil matters to low-income 
people throughout the United States on everyday legal problems. LSC 
pursues this mission by providing financial assistance, mostly through 
grants to legal service providers (grant recipients or grantees) who 
serve low-income members of the community who would otherwise not be 
able to afford legal assistance (clients). Established by a federal 
charter in 1974 as a federally funded, private nonprofit corporation, 
[Footnote 2] LSC is highly dependent on federal appropriations for its 
operations. LSC received $348.6 million in appropriations for fiscal 
year 2007, which made up about 99 percent of its total funding. In 
2007, LSC served clients through 137 grantees with more than 900 
offices serving all 50 states, the District of Columbia, and current 
and former U.S. territories. 

LSC uses the majority of its funding to provide grants to local legal- 
service providers. Funds are distributed based on the number of low- 
income persons living within a service area,[Footnote 3] with some 
grantees maintaining several offices within their service area. LSC 
management is responsible for ensuring that grant funds are used for 
their intended purposes and in accordance with laws and regulations. 
Thus, LSC is accountable for the effectiveness of its own internal 
controls and for providing oversight and monitoring of grantees' 
internal controls, use of grant funds, and compliance with laws and 
regulations. LSC's Board of Directors is responsible for carrying out 
fiduciary responsibilities in overseeing LSC management's operations 
and use of appropriated funds. 

In recent years, governance and accountability processes have received 
increased scrutiny and emphasis in the nonprofit, federal agency, and 
public company sectors as a result of governance and accountability 
breakdowns, most notably in the public company financial scandals that 
led to the enactment of the Sarbanes-Oxley Act of 2002. Public 
companies now operate under strengthened governance and accountability 
standards, including requirements for ethics policies and improved 
internal controls. The federal government and nonprofit sectors have 
followed this lead and established new standards and requirements for 
improved internal control reporting and governance and accountability. 
For nonprofit corporations using funding from taxpayers and donors, 
effective governance, accountability, and internal control are key to 
maintaining trust and credibility. Governance and accountability 
breakdowns result in a lack of trust from donors, grantors, and 
appropriators, which could ultimately put funding and the 
organization's credibility at risk. 

The current period of economic hardship for many workers and their 
families' highlights the importance of LSC's mission and the efficient 
and effective use of taxpayers' dollars to achieve that mission. Today 
I will highlight our key findings on LSC's governance and 
accountability practices, as well as the internal control improvements 
needed in LSC's grants management and oversight to increase assurance 
that federal funds are being properly spent and its operations are 
effectively carried out to meet its mission of providing legal 
assistance to low-income people. 

Our conclusions are based on work performed for our August 2007 report 
on LSC's governance and accountability practices[Footnote 4] as well as 
our December 2007 report on LSC's grants management and 
oversight.[Footnote 5] We conducted that work in accordance with 
Generally Accepted Government Auditing Standards. More detailed 
information on our audit scope and methodologies can be found in these 
two reports. 

Summary: 

Although LSC has stronger federal accountability requirements than many 
nonprofit corporations, it is subject to governance and accountability 
requirements that are weaker than those of independent federal agencies 
and U.S. government corporations. Congress issued LSC's federal charter 
over 30 years ago. We found that LSC has not kept up with evolving 
reforms aimed at strengthening internal control over an organization's 
financial reporting process and systems. As noted in our reports, a 
properly implemented governance and accountability structure may have 
prevented recent incidents of compensation rates in excess of statutory 
caps, questionable expenditures, and potential conflicts of interest. 
In addition, LSC has not kept up with current management practices. Of 
particular importance are key processes in risk assessment, internal 
control, and financial reporting. Also at the time or our review 
management had not formally assessed the risks to the safeguarding of 
its assets and maintaining the effectiveness and efficiency of its 
operations, nor had it implemented internal controls or other risk- 
mitigation policies. 

We also found weaknesses in LSC's internal controls over grants 
management and oversight of grantees that negatively affect LSC's 
ability to provide assurance that grant funds are being used for their 
intended purposes in compliance with applicable laws and regulations. 
Effective internal controls over grants and grantee oversight are 
critical to LSC as its very mission and operations rely extensively on 
grantees to provide legal services to people who otherwise could not 
afford to pay for adequate legal counsel. We also found poor fiscal 
practices and improper and potentially improper expenditures by 
grantees. 

As a result of our two reviews, we made a total of 9 recommendations to 
LSC's Board of Directors and 8 recommendations to LSC management. Those 
recommendations dealt with fundamental management and governance 
practices needed in the current environment in light of LSC's mission. 
Both LSC's Board and management accepted our recommendations and 
expressed a commitment to move diligently to implement the 
recommendations. LSC's most recent progress report indicates that LSC 
is starting to take action to address many of our recommendations and 
is planning to take action on the remaining recommendations with 
responsibility for corrective action already assigned. LSC has 
indicated that it will provide us with a final update by September 1, 
2008 to document completion of its implementation of our 
recommendations. We look forward to receiving LSC's final report and 
reviewing the progress LSC Board and management have made on these 
issues. 

LSC's Governance and Accountability Practices Need to be Modernized and 
Strengthened: 

We found that since its inception over 30 years ago, LSC's governance 
and accountability requirements, including its financial reporting and 
internal control, had not changed significantly. Further, LSC's board 
and management had not kept pace with evolving governance and 
accountability practices. As a result, LSC's current practices have 
fallen behind those of federal agencies, U.S. government corporations, 
and other nonprofit corporations. 

For both governmental and nonprofit entities, governance can be 
described as the process of providing leadership, direction, and 
accountability in fulfilling the organization's mission, meeting 
objectives, and providing stewardship of public resources, while 
establishing clear lines of responsibility for results. Accountability 
represents the processes, mechanisms, and other means--including 
financial reporting and internal controls--by which an entity's 
management carries out its stewardship and responsibility for resources 
and performance. Strengthened governance and accountability structures 
within LSC will increase assurance that federal funds are spent 
properly and effectively in order to meet the needs of the clients 
receiving legal assistance. 

Governance and Accountability Requirements: 

Because LSC is a unique federal entity, we compared its governance and 
accountability requirements to other federal entities. We found that 
although LSC has stronger federal accountability requirements than many 
nonprofit corporations, its governance and accountability requirements 
are weaker than those of independent federal agencies headed by boards 
or commissions and those of U.S. government corporations. The LSC Act 
provides that LSC be treated like a federal agency for purposes of 
specified statutes that existed in the 1970s. LSC's authorizing 
legislation was last comprehensively reviewed and reauthorized in the 
Legal Services Corporation Amendment Act of 1977, and LSC's governing 
statutes have undergone only limited changes since then. 

In 1988, Congress created an Office of Inspector General (OIG) within 
LSC. Therefore, LSC is subject to IG oversight. However, in other 
respects, LSC has not kept up with evolving management reforms aimed at 
strengthening internal control over an organization's financial 
reporting process and systems. For example: 

* LSC's statutory requirements for internal control systems are less 
rigorous than those for independent federal agencies or U.S. government 
corporations. The LSC Act requires LSC to account for federal funds 
separately from nonfederal funds, but otherwise includes no specific 
requirements for the establishment of accounting and internal control 
systems. Although the LSC Act includes program management requirements, 
these are much less rigorous than requirements for systems of internal 
control for other federal entities.[Footnote 6] 

* LSC is not subject to federal funds control laws that generally apply 
to independent federal agencies and many U.S. government corporations. 
Like many independent federal agencies and wholly owned government 
corporations, most of LSC's annual revenues come from federal funds 
made available through annual appropriations; however, LSC is not 
required by law to control its use of those funds as are independent 
federal agencies and wholly owned U.S. government corporations. 
Further, the accountable officers of most federal agencies and some 
wholly owned U.S. government corporations are financially liable for 
improper or illegal payments. However, this is not the case for LSC. 
The LSC Act does contain a number of provisions that restrict the use 
of LSC's appropriated funds for certain purposes, such as an activity 
that would influence the passage or defeat of any legislation at the 
local, state, or federal level or that would support any political 
party or campaign of any candidate for public office. 

* Although the LSC Act requires LSC to submit a budget request to 
Congress, it provides no requirements related to the form and content 
of the budget request. For federal agencies and wholly owned U.S. 
government corporations, OMB prescribes the form and content of budget 
requests, consistent with specified statutory requirements that are 
submitted through the President to Congress. Under the LSC Act, LSC 
submits that budget request directly to Congress, with OMB's role 
limited to submitting comments to Congress if it chooses to review 
LSC's budget. 

Governance Practices: 

During our review, we found that the governance practices of LSC's 
board fell short of the modern practices employed by boards of 
nonprofit corporations and public companies. Although the board members 
have demonstrated active involvement in LSC through their regular board 
meeting attendance and participation, we found several areas where 
LSC's governance practices could be strengthened. Those areas included 
a more comprehensive orientation program for new board members and an 
ongoing training program that enables board members to stay current on 
governance practices, the regulatory environment, and key management 
practices. Keeping current with governance practices is especially 
important for the LSC board because the board composition changes 
significantly with each new presidential administration, and thus the 
board does not generally have the benefit of experienced board members. 
Although the LSC board had four committees, including finance and 
operations and regulations, it did not have audit, ethics, or 
compensation committee, important governance mechanisms commonly used 
in corporate governance structures. Finally, the board has not assessed 
the performance, collectively or individually, of its board members. 

Management Practices: 

LSC's management practices have not kept up with the current practices 
for key processes in the areas of risk assessment, internal control, 
and financial reporting. We found that management has not implemented a 
systematic or formal risk assessment that evaluates the risks the 
corporation faces from both external and internal sources. Such an 
assessment provides a structure for implementing internal control and 
other risk mitigation policies. Without an effective program of risk 
assessment and internal control, LSC management does not have adequate 
assurance that it is using organizational resources effectively and 
efficiently, nor reasonable assurances that LSC's assets and operations 
are protected. In addition, senior management has not established 
comprehensive policies or procedures regarding conflicts of interest or 
other issues of ethical conduct. Without such policies and procedures, 
LSC is at risk of not identifying potential conflicts of interest and 
not taking appropriate actions to avoid potentially improper 
transactions or actions on the part of LSC personnel. Such issues, if 
they occur, could result in loss of credibility to LSC as an 
organization. Also, management has not conducted its own assessment or 
analysis of accounting standards to determine the most appropriate 
standards for LSC to follow. Consequently, it is not clear which 
standards are most relevant to LSC's operations and which would provide 
the best financial information to LSC's management and financial 
statement users. 

Improved Internal Controls Needed Over Grants Management and Oversight: 

In our review of grants management and oversight at LSC, we found 
weaknesses in LSC's controls over grants management and oversight that 
negatively affected LSC's ability to monitor and oversee grants and 
left grant funds vulnerable to misuse. At grantees we visited, we also 
found poor fiscal practices and improper or potentially improper 
expenditures that LSC could have identified with more effective 
oversight. 

Internal control is an integral component of an organization's 
management that provides reasonable assurance that the objectives of 
effectiveness and efficiency of operations, reliability of financial 
reporting, and compliance with applicable laws and regulations are 
being achieved.[Footnote 7] Internal controls also serve as the first 
line of defense in safeguarding assets and preventing and detecting 
errors and fraud. Organizations that award and receive grants need good 
internal control systems to ensure that funds are properly used and 
achieve intended results. Effective internal controls over grants and 
grantee oversight are critical to LSC as its very mission and 
operations rely extensively on grantees to provide legal services to 
people who otherwise could not afford to pay for adequate legal 
counsel. For LSC and other organizations that award grants, ensuring 
effective internal control over grant funds requires a two-prong 
approach. LSC management, in addition to being held responsible for its 
own internal control system, needs to provide oversight to help ensure 
that its grantees' internal control systems provide reasonable 
assurance that grant funds are properly used and achieve intended 
results. 

We found weakness in LSC's control environment regarding the lack of a 
clear definition of the authority and responsibilities between two of 
the three organizational units that oversee the work of grantees. 
Currently, LSC management shares with the OIG fiscal oversight and 
monitoring of grantees. Management's oversight role is conducted 
through two offices ----the Office of Program Performance (OPP) and the 
Office of Compliance and Enforcement (OCE). We found that the roles and 
the division of responsibilities were not clearly communicated between 
the OIG and OCE. The result has been staff confusion about the types 
and scope of grantee fiscal reviews that LSC management can undertake 
on its initiative and strained relations between management and the 
OIG. In addition, communication and coordination between OCE and OPP 
was not sufficient to prevent gaps and unnecessary duplication between 
the offices' respective oversight activities. 

Regarding its oversight of grantees, we found that the scope of LSC's 
control activities for monitoring grantee fiscal compliance was 
limited, and feedback to grantees not timely. In determining the timing 
and scope of grantee oversight visits, LSC does not employ a structured 
or systematic approach for assessing the risk of noncompliance or 
financial control weaknesses across its 137 grantees. Without an 
analytically sound basis for assessing risk and distributing its 
oversight resources, LSC does not have a basis for knowing whether its 
oversight resources are being used effectively to mitigate and reduce 
risk among its grantees. 

LSC's monitoring of grantee internal control systems needs to be 
strengthened. We found that the scope of work in OCE's fiscal reviews 
was not sufficient in assessing grantee internal control and compliance 
for purposes of achieving effective oversight. In the OCE site visits 
we observed, staff did not follow up on questionable transactions and 
relied heavily on information obtained through interviews. LSC also was 
not timely in follow up on an investigation into an alleged instance of 
noncompliance referred to it by the OIG. Feedback to grantees was often 
slow. As of September 2007, LSC had not yet issued reports to grantee 
management for almost 19 percent (10 out of 53) of the 2006 site 
visits. Without timely communications about the results of site visits, 
grantee management does not have information about deficiencies and the 
related corrective actions needed. In a grantee exit conference we 
observed, the LSC review team did not communicate a number of findings 
they had concluded were significant and in need of immediate attention. 
Effective grantee monitoring is especially important for LSC because 
LSC has limited options for sanctioning poorly performing grantees due 
to the recurring nature of many of its grants. 

In the limited reviews we performed at 14 grantees, we identified 
internal control weaknesses at 9 grantees that LSC could have 
identified with more effective oversight reviews. We also found 
improper expenditures at some of the grantees we visited. While control 
deficiencies at the grantees were the immediate cause of the improper 
expenditures we found, weaknesses in LSC's controls over its oversight 
of grantees did not assure effective monitoring of grantee controls and 
compliance or prevent the improper expenditures. We identified the 
following weaknesses and improper expenditures at grantees we visited: 

* Expenditures with insufficient supporting documentation - At 7 out of 
the 14 grantees we visited, we identified systemic issues involving 
payments that lacked sufficient supporting documentation that made it 
impossible to determine whether the expenditures were accurate, 
allowable, and appropriate. 

* Questionable independent contractor - One grantee paid an individual 
approximately $750,000 between 2004 and 2006 for information technology 
services. Several factors including the following caused us to question 
the contractor arrangement: 

- The contractor's office and mailing address were located in the same 
office space as the grantee. 

- The grantee could not locate its contract with the individual for 
2005 and 2006. 

- The contractor's business card was identical to that of other 
employees working at the grantee. 

* Alcohol purchases - We identified three grantees that used LSC funds 
to purchase alcoholic beverages. 

* Employee interest-free loans - One grantee that we visited was using 
grant funds to provide interest-free loans to employees upon request as 
an employee benefit. The loans were used to pay college tuition, make 
down payments on homes, and to purchase computers. 

* Lobbying fees - We identified two instances in which one grantee was 
using LSC funds to pay lobbyist registration fees. 

* Late fees - Three of the grantees that we visited used grant funds to 
pay late fees on overdue accounts for goods and services purchased. 

* Earnest money - We discovered an improper transaction at one grantee 
involving the sale of a grantee building using both LSC and non-LSC 
funds. The grantee transferred the escrow account funds into an 
unrestricted general funds account to avoid the funds being subjected 
to LSC regulations. 

Conclusions and GAO's prior recommendations: 

Effective governance and accountability practices are necessary to 
provide strong board oversight and effective day-to-day management of 
LCS's performance in carrying out its mission of promoting equal access 
to the system of justice in our nation and providing high-quality civil 
legal assistance to low-income persons. Effective internal controls 
over grants and grantee oversight are also critical to LSC, as its very 
mission and operations rely extensively on grantees to provide legal 
services to people who otherwise could not afford to pay for adequate 
legal counsel. Effective grants-oversight procedures and monitoring, 
including a structured, systematic approach based on risk, are 
necessary given LSC's limited resources and the scope of its 
responsibilities for many widely dispersed entities. In addition, the 
shared responsibilities for grantee oversight between LSC management 
and OIG presents risks that can be mitigated with clear lines of 
authority and responsibility and effective communications and 
coordination across oversight offices to avoid unnecessary duplication 
where possible. Finally, given the number of grantees, a sound risk- 
based approach for determining timing and scope of site visits is key 
to prioritizing resource allocations to reflect the varying risks 
presented by the grantees. 

To maximize the effectiveness of each site visit, LSC needs to conduct 
its oversight visits with sufficient scope to target areas of greatest 
risk, follow up on information and results of prior reviews and audits, 
and employ a review scope and approach that is tailored to specific 
risks. With high-quality targeted reviews and management that promptly 
informs grantees about findings and provides them an opportunity to 
correct them, risk can be mitigated. 

In our August 2007 report,[Footnote 8] we made recommendations to LSC's 
board for modernizing and strengthening its governance and oversight, 
including action directed at formalizing a comprehensive orientation 
program and an ongoing training program, conducting a performance 
assessment, creating audit and compensation committees, developing and 
implementing an approach to periodically evaluate certain key 
management processes, and ensuring that LSC's audited financial 
statements are issued more promptly. We also made recommendations to 
LSC management directed at improving its accountability by conducting a 
risk assessment and implementing a corresponding risk management 
program as part of a comprehensive evaluation of internal control, 
including establishing policies for handling conflicts of interest 
(ethics) and evaluating accounting standards. 

In our December 2007 report,[Footnote 9] we made five recommendations 
to LSC to improve its internal control and oversight of grants by 
clarifying organizational roles and responsibilities for overseeing 
grantee internal controls and compliance among LSC units, improving 
information sharing and coordination among LSC oversight organizations, 
using risk-based criteria to select grantees for internal control and 
compliance reviews, improving the effectiveness of the current fiscal 
compliance reviews, and following up on each of the improper or 
potentially improper uses of grant funds that we identified. 

In response to both of our reports, we received written comment letters 
from the Chairman on behalf of LSC's Board of Directors and the 
President on behalf of LSC's management. Both the Chairman and 
President expressed their commitment to achieving strong governance and 
accountability and outlined actions that LSC's board and management 
plan to take in response to the recommendations we made in our August 
2007 report. The Chairman and the President also expressed their full 
commitment to making the improvements in controls over grants 
management and oversight noted in our December 2007 report, accepted 
all of our recommendations, and outlined the actions that LSC's board 
and management plan to take in response to our recommendations. LSC's 
most recent progress report on implementing our recommendations is 
highly encouraging. LSC has indicated that it is taking action to 
address many of our recommendations and is planning to take action on 
the remaining recommendations with responsibility already assigned. LSC 
has indicated that it will provide us with a final update by September 
1, 2008 to document completion of its implementation of our 
recommendations. We look forward to receiving LSC's final report and 
reviewing the progress LSC Board and management have made on these 
issues. 

In our August 2007 report, we also included a matter for congressional 
consideration concerning whether LSC should have additional 
legislatively mandated governance and accountability requirements 
modeled after what has worked successfully at federal agencies or U.S. 
government corporations. These requirements could be established either 
by amending LSC's current governing statutes or by converting LSC to a 
federal entity, such as a U.S. government corporation or an independent 
federal agency. LSC's Chairman and President commented on the matter 
that we presented for congressional consideration and provided their 
views that LSC's governing statutes are appropriate and have worked 
well and stated that many of the governance recommendations could be 
accomplished without changing the statutory framework of LSC. 

[End of section] 

Appendix I: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

For further information about this testimony, please contact Jeanette 
M. Franzel, Director, Financial Management and Assurance at (202) 512- 
9471 or FranzelJ@gao.gov . Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this testimony. 

Acknowledgments: 

In addition to the person named above, Kim McGatlin; Bonnie Derby; F. 
Abe Dymond; Lauren Fassler; Cheryl Clark; Maxine Hattery; and, Matt 
Zaun made key contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, Legal Services Corporation: Governance and Accountability 
Practices Need to Be Modernized and Strengthened, GAO-07-993 
(Washington, D.C.: Aug. 15, 2007) and GAO, Legal Services Corporation: 
Improved Internal Controls Needed in Grants Management and Oversight, 
GAO-08-37 (Washington, D.C.: Dec. 28, 2007). 

[2] Legal Services Corporation Act of 1974, Pub. L. No. 93-355, 88 
Stat. 378 (July 25, 1974), codified, as amended, at 42 U.S.C.  2996 - 
2996l (LSC Act). 

[3] Under 45 C.F.R.  1634.2(c), the service area is the geographic 
area defined by LSC to be served by grants or contracts to be awarded 
on the basis of a competitive bidding process. 

[4] GAO-07-993. 

[5] GAO-08-37. 

[6] The legislative requirements that promote effective internal 
control include Federal Managers' Financial Integrity Act of 1982 (31 
U.S.C.  3512(c), (d)); Chief Financial Officers Act of 1990, as 
amended by the Government Management and Reform Act of 1994 and the 
Accountability of Tax Dollars Act of 2002 (31 U.S.C.  3515); and 
Federal Financial Management Improvement Act of 1996 (Pub. L. No. 104- 
208, div. A.,  101(f), tit. VIII, 110 Stat. 3009, 3009-389 (Sept. 30, 
1996) (reprinted in 31 U.S.C.  3512 note)). 

[7] GAO, Standards for Internal Control in the Federal Government, GAO/ 
AIMD-00-21.3.1 (November 1999). 

[8] GAO-07-993. 

[9] GAO-08-37. 

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