2020 LSC Visits Webinar
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2020 LSC Visits Webinar


Good afternoon and welcome to the 2020 LSE visits webinar. My name is Dr. Dina Shafey Scott, I’m the training and technical assistance manager at Legal Services Corporation and I’m with the office of compliance and enforcement and the office of program performance. I’m joined today by Roxanne Caruso the assistant inspector general for audit in the Office of Inspector General. Daniel O’Rourke the assistant inspector general for Investigations Office of Inspector General and Laura M. Roth the director of the office of compliance and enforcement and finally Joyce McGee the director of the office of program before performance. We have a couple of objectives today that we hope we can fulfill in this webinar. The first is to explain the reasons form and protocols of visits conducted by LSC, including visits conducted by office of inspector general the office of compliance and enforcement and the office of program. performance We hope this webinar will provide you with an opportunity to ask questions about the purposes of visits including what you can expect with pre visit requests on-site logistics and post visits recording. Before we get started a couple of reminders. You can find a copy of today’s webinar at LSC.gov under grantee guidance. Additionally, if we get questions that we are not able to get to today we will follow up soon with an FAQ question response. Additionally, as we will not cover all visits today, we will be following up with a more robust and more specific guidance document that will help you understand all LSC visits. Let’s get started. At the LSC OIG we have two major units the odd division as well as the Investigative Division and I am part of the investigative side the house. Now for the OIG and that the director of the LSC Board and the inspector general, of course we have incorporated robust fraud prevention program. Our goal is to be proactive in this area to provide information to the grantees about past and ongoing fraud schemes so you can get out ahead get out ahead of the fraud issues and set up the proper internal controls and safeguards to prevent fraud from occurring. Hey, Dan, what are you doing as a proactive nature in terms of prevention of fraud? Tell me a little more about that. Well, okay, I will thank you very much for the opportunity. So we do about three different well, two areas really is fraud prevention or three. I’ll begin with some of the board but it’s fraud awareness briefings and a fraud awareness briefing is conducted on-site or by a webinar and we can provide we’d be happy to set up any type of fabric suite for your program. Just give us a call. We can do it by webinar. It lasts about an hour and we recommend this type of fraud awareness briefing to any newly EDs or CFOs to obtain a better understanding of fraud risks that may occur within LLC the LLC grant program. So from a prevention perspective we do feas fraud vulnerability assessments and we schedule of these visits about sixty to ninety days in advance and depending on the size of the program. We sent between two and five investigators and usually spend that four days one site. Usually Monday through Thursday afternoon to conduct the FAA. So an FAA is a preview to assess a grantees risk to fraud. Again, we want to get ahead and get out and make sure we you have the information to prevent fraud. So what do we do during that period? We review your policies and related materials prior to the visit. We complete an entrance conference, provide feedback to the ED during the visit and conduct an exit briefing on that last day on Thursday afternoon. We examine how you apply those policies during an on-site review including removing your financial related documentation and allocation methods. Based upon previous fraud schemes investigated by the OIG we test internal trolls to determine if any weaknesses exist at your program that could possibly lead to fraud occurring at your program. During the exit briefing we offer suggestions, keywords suggestions for any needed enhancements to your policies or procedures to reduce your risk to fraud. During the FPA we don’t issue a formal report. We provide recommendations and our focus is on preventing fraud. Give you the information you need to tackle that problem and not be the gotcha guys best weekend. We want to focus on prevention and not do the formal reporting process. We want to be your assistant be your agent or resource to prevent fraud as best we can. Now on occasion there are issues that may come up then we may identify through an FA that may require additional review or followed by my office which could lead to further discussion with OCE. In terms of the regs or the issues they be uncovered. Possibly a question cost, but that doesn’t happen to very often, but it can occur. So there are some issues that may develop from that FVA on occasion. So that’s the FVA the fraud vulnerability assessment. We really use your financial area on the work, working with the accounting staff and the ED for the most part during that four days were on site and then go into an RVA. So an RVA or regulat ory vulnerability assessment is usually conducted and scheduled with an FVA. So we call this a two-for-one sale. So more or less, we’re going to schedule the FVA with it accompanying our RVA review. The same people one site will complete those two areas of concern and as you know ensuring regulatory compliance is very important to Congress and the LSC board. in Fact a violation of the LSE regulations could cause more harm to a grantee than an actual financial fraud that may occur in the program Most importantly we complete approximately 8 to 12 piays RBA’s visits per year 8 to 12 per year and Try to court a as best we can these visits with OC OPP and the office of audit within the OIG as well So in our VA is intended to assess a grantees financial risk based on regulations of search with the LLC act Related guidelines and grant assurances and we collect that type of information or materials as you can see on the board and the through with with an RBA we focus on the regulatory issues such as outside practice of law prohibited political activity restrictions on lobbying private attorney involvement program integrity sub-grants diversion of clients to the intake process outside employment Bonding of grantees client trust and attorney fee issue. That’s a lot at work but we do a lot of planning prior to and we do your best to Get the information we need and talk to you within those four day period but it is a pretty comprehensive comprehensive review So that’s Effie ace Arby’s that’s the on the prevention side Going to investigations We have a hotline as you all know to receive complaints Related to fraud waste abuse. We also receive concerns or allegations directed from the EDS and other employees and as you know any potential frog the loss of $20 or more is required to be reported to the OIG and Again, most investigations are reactive in nature versus an FAA or RBA meaning we get an allegation and we’ve got a door best to bet that allegation and Determine whether or not we could just make a call to IDI Get some auditioning accompanying documentation and close it out, or do we have to go on site? For a review of that allegation get more information And develop the evidence to prove or disprove The allegation I want to make it clear also that a permit one of our goals is to disprove allegations and we know that going in and I can tell you that the majority of cases that we work are disproven So that thing that happens but sometimes we resolve it quickly, sometimes it takes a little more time If an invention does prove wrongdoing the goal is to hold people in programs accountable and to deter fraud and Then during the investigative visit two or three investigators may be on site for no more than a week We typically communicate with the IDI regarding the allegations of concern any of use of employees and witness will occur we will request documentation is touched with a specific allegation and then significant analysis analysis may be required a more of the complex issues that we get into an investigation will result in a report investigation our report will develop the facts and other supporting documentation to prove or disprove the allegation if an issue results in a potential criminal violation the ROI will refer be referred to a prosecutor for their decision and we have some additional types of reports that may Come through our investigative program, which is question cost which we almost know about meaning Our cost that is not adequately supported by Cost in terms of LSE standards a management information then ran where we have a just discover a systemic weakness which requires attention from LSE management We do different program initiatives or projects as well to test to investigative theory to gather more information on a specific program where we need more information, or maybe we believe that Program area might even better bolt to fraud So and then sometimes this these programs this can lead to best practices We find that particular grantees are doing a great job in a particular area that we want to share with other grantees across the country and then fraud alerts is when we have a Common fraud scheme or pattern that could impact grantee reparations when we get that information to you as quickly as we can with best practices so that you can again be aware of it educate education and provide best practices for to prevent that particular fraud that may be occurring in different programs and then throw a corner articles is a specific instance instance of fraud the Either through LLC preggers or within other grant making program. We want to bring to your attention. We just issued a fraud corner article nepotism we talked earlier about Freud corner article on insider threat of relates to information technology and related to phishing schemes and that’s my area of discussion for program visits for the OIG for investigations Good afternoon, this is Roxanne Caruso. I’m Dan’s counterpart in the Office of Inspector General and As always Dan gets to talk about the exciting things I get to talk about about it. So so I will talk today about the visits that the audit division conducts to grantees to perform audits The type of on it that we most commonly conduct is of selected internal controls The purpose is to assess the adequacy of internal controls in place over grantee operations including program expenditures fiscal accountability and compliance with Elysee Regulations essentially our mission is to ensure that congressional funds are spent appropriately efficiently and effectively a Team of auditors from the Office of Inspector General conducts the on-site visit generally the team consists of Three to five individuals and an auditor in charge leads the team on-site Usually there are between two and four staff auditors that are also on the team while on-site auditing interfaces and meets with members of Grantee staff including the executive director the chief financial officer or equivalent position Accounting and financial staff human resources staff payroll administrators and others as needed At the outset of the visit we normally ask Granting management to designate who on their staff they prefer serves as the primary contact for the audit team generally we find it’s the executive director the chief financial officer or a supervisor on the fiscal staff and During the visit the auditors conduct interviews with staff. They gather and review information. They review policies and procedures and Observe work processes usually accounting and financial staff are most involved But we do meet with other members of grantee staff as needed in terms of the materials requested and required for the visit in advance of the visit the auditor in charge emails a documentation request to the executive director of the program we try to do this in as far in advance as possible In order to allow grantee staff the appropriate time to gather and submit the documentation generally, we send those out two to four months in advance to the on-site visit and the request includes a number of items such as the grantees accounting manual any administrative or personnel manuals accounting information such as the general ledger chart of accounts check register fixed asset records and costs and derivative income allocation methodologies at any point during the audit on site four before after the auditors also may follow up with staff to request additional documentation in terms of the mode of transmission of documentation the OIG Usually asks grantees to upload Electronic documentation to a shared folder we find that that works best and we also ask grantees to gather and provide hardcopy Documentation that will be ready for the auditors review when they arrive on site The result of our off-site visit is an audit report conducted in accordance with government auditing standards There are several stages to the reporting process. And the first of that is an exit conference Prior to the conclusion of the visit generally on the last day the audit team conducts the meeting with grantee management to discuss The preliminary results of the audit and the purpose of that meeting is to ensure That grantee management is aware of any issues that were identified And to openly discuss the matters we strive as a team to be transparent as possible throughout the process and Operate in an environment of no surprises So to that end if we encounter any issues during the audit and we will communicate them with grantee management apps their hives The next step of the reporting process is issuance of a draft audit report the report summarizes the findings and recommendations Of the audit and we issue the draft report to grantee management for review and comment. It’s addressed to the executive director and we ask that they respond stating what actions if any they have taken or that they plan to take to address the recommendations contained in the report and we provide grantees 30 days to respond and their response in its entirety is included in the final report as an appendix and the final report with the grantees response is issued to the executive director and copied to the grantees board of directors LLC’s president Jim Sandman and vice president for grants management Lynn Jennings in total throughout this whole process we strive to make in a process that provides valuable and actionable feedback that helps grantee is ensure that congressional funds are spent in accordance with regulation and as Effectively and efficiently as possible Ok, thanks so much Dan and Roxanne, so we’re gonna move on to the office of compliance and enforcement Laura would you like to idle Started. Okay. That’s Thank You Tina Thank you everyone. My name is Laura Rath and as you know said I’m the director of the office of compliance and enforcement our office conducts several different times different types of visits But for today, I want to concentrate on the three that we do most frequently which your grantee would most likely experience So moving on the first one I want to talk about is the compliance review For those who have been at legal services arena for a while We used to call this the case service Case management system review about five years ago – due to the number of new areas we were looking at we decided to rename it the Compliance review because it’s basically a soups a soup to nuts review of your program if focuses on fiscal and regulatory compliance with the LSC, Act regulations and guidelines as well as accurate case service reporting and review also focuses and assesses on the strength of a grantees fiscal health and internal controls against the county guide for LSC grantees and other physical standards These reviews usually take place over a one-week period but can be shorter or longer depending on the size of the grantee the number of staff and the number of different offices and projects that your your Organization has because we want to review and assess every office while we’re there When determining which grantees to visit every year and what type of visit to do that grantee, we look at many different factors for a compliance review some of the most Significant factors are listed on this slide We don’t have for the time since the last compliance review We don’t have a definite cycle for how frequently we visit someone or visit a grantee But we don’t like it for it to go too long Most grantees are visited at least every seven years at this point in time self inspected inspector Inspection. Sorry error rates can be that you’ve had high rates for several years in a row the race from up from one year to another or even having consistently low rates are something that we look at and then as Dan mentioned Some time the Office of Inspector General or even the office of program performance Really? Concerns to us that are outside of their lanes of review that we then go on and look at when we go on site some of the other things we look at or issues noted in your audited financial statements and the number and significance of community Number and significance of complaints lodged against you with the corporations When we’re trying to make each of these visits as useful and as smooth as possible for both the OCE staff and for the grand So we asked for a lot of information in advance of the visit this screen just lists some of the documents that we asked for Roxanne in her Explanation listed a lot of things that the audit division looks at that are similar to what we asked for I’m not going to go into every item, but I just wanted to explain which case list We’re going to ask for two years of your CSR reportable cases as well as any cases that are open or closed in the current year and that’s because we want to look at the Patterns of how you’ve been doing compliance wise we want to see how things have changed over the last two to three years We asked for a variety of program policies and procedures because we want to make sure they comply with Elysee regulations and then we want to make sure that your staff are following your own policies and procedures in order to assess fiscal compliance and health we ask for access to general Ledger’s cash receipts various timekeeping and Personal activity reports as well as your property records and if you’ve received a special grant From LSC in the last five years. We’re going to ask for information regarding the use of those funds Before we get on site. We’ll ask for various documents such as the ones listed on the slide that they be available in hard copy when we arrived and Much like Roxanne talked about with the audit division We ask that these the documents requested in advance be sent to us electronically We have a box folder and we provide support to you for uploading those documents to us and we usually ask we send the document requests letter out anywhere between Four and six months in advance and ask for the documents to be to us about 62 or 45 to 60 days in advance. Okay The on-site review process has lots of moving parts and We have team is made up of attorneys and fiscal experts The attorneys are going to do case review and going back to even before we go on-site We will negotiate with you how we’re going to do case review and how we’re going to look at the sample cases in most cases grantees use Intermediaries who? answer questions of that are asked by the attorneys and in in advance of the review we give you a list or the the actual form that we Use we’re reviewing cases. So, you know the type of information that we’re going to be asking for We also do a lot of interviews These the next three areas are the areas were going to interview staff about or in addition to interviews We’re going to ask staff whether we can observe intake or whether we can do practice intakes with your intake staff We’re going to test your case management system to see how well it runs reports and the fiscal staff is going to test various Transactions to determine internal controls and whether they’re being followed At the end of the review before we leave well first of all every day at the end of the day or the earlier next morning the team leader will provide the executive director their preliminary findings from the day before or the day of so that When we do an exit conference on the very last day of the visit when we give the team gives their preliminary Findings. Nothing will be a surprise so the preliminary findings Even at the end of the week are just a roll up of things that we’ve been sharing with the executive director throughout the week after we leave we our goal is to provide each grantee with a draft report within 60 days of leaving the Program for statewide programs our goal is 90 days we’ve been fairly successful in meeting that goal for the last year because anyone who’s Received a recent visit will notice we’ve changed to exception reporting So your report will only list those areas in which we had a compliance concern that requires corrective action be taken Anything where there was compliance it will just have a check mark saying that we reviewed it We will not go into detail as to why it’s compliant We wanted to concentrate our efforts on and yours on the areas that need improvement The grantee then has 30 days to comment and in those comments they can tell us we misunderstood something or got something wrong and then we’ll negotiate with you to make sure that we Update the report correctly and also provide updates on any plan To take corrective action or to provide evidence on corrective action taken and I want want to make it clear that we don’t expect grantees to finish everything in that 30-day period we want you to be thoughtful in considering the Actions we want you to take so it is perfectly fine to respond to us What your plan of action is going to be over the next? Three four six months to complete a required corrective action rather than rushing through to finish something in 30 days then we incorporate your comments into a final report and much like the Audit division in the OIG does we include your comments in their entirety as an attachment to the final report? Which is issued to the executive director and the board If there are any required corrective actions that are still open when we issue the final report, we will continue to conduct follow-up Both by letter and by phone until we receive evidence sufficient to close all of the required corrective actions The next type of review that I want to talk about is the technical assistance review we’ve been doing these more and more frequently especially with the addition of Dina and her team These reviews are designed to help grantees both the management and the staff Learn and understand where where there are deficiencies in their policies. There are opportunities for improvement We focus on many of the same areas that we do in a compliance review But it’s to help newer Eady’s and and the grantees In a I don’t want to say safer environment But in a more collaborative environment rather than us coming in and doing an actual monitoring visit The things that we take into consideration when scheduling these are oftentimes grantees are asking for assistance So we find it better to go in and do a technical assistance review than doing a compliance review Especially as I said, it’s helpful to you an executive directors and also to new chief financial officers Or if we’ve been out on site and the grantee just isn’t able to resolve concerns that we had from a prior on-site review will potentially go out and do a Technical assistance with you to help you get over that hump and resolve the pending issues The materials requested in advance of a technical assistance review are very similar to the compliance review and the reason why we ask for cert for so much information is we’re really trying to make it very Particularized and specific to each grantee. So we’re reviewing Almost all of the same information as we would for compliance review because we want to know as much about the program before we get there so we can tailor our Trainings to the needs of that grantee one of the things we’re doing to also help with that Is this year? We’re starting to do brief Pre-survey pre visit surveys to enhance the training so I would ask if you’re an executive director or senior management talking to the team leader and Once you’re a staff member doing the pre surveys please be as honest as possible in answering the survey because it will make the Visit that much more beneficial to you in the program for a TA be the length that it depends on the number of Offices a number of staff because one is many staff to be able to participate as possible we will often ask that staff from one office travel to another office so that Staff from two different offices can work together because we find that working together. They are able to Come up with better opportunities for improvement than if they’re just looking at their own work The general review areas are Much the same as for technical as for a compliance review, but we do it a little bit differently Typically, we break it into morning and afternoon sessions each day in the morning. The attorneys will do a little bit of review about the intake related regulations and teach legal work staff how to do case review So they do the same case review teaching them to do this case review that we would do if it was a compliance reveal and we you Then we give your staff the forms that we fill out and we let them actually review the cases with our assistants We don’t sit with them But we kind of walk around the room and answer questions and we let the staff find Their own areas or challenges that they’re seeing in their colleagues cases at the same time in the morning Another group of our staff will be interviewing staff who do intake and private attorney work Interviewing your fiscal staff and testing some of the internal controls then in the afternoon Everyone regroups and based on the findings and observations and questions that were asked in the morning will give specific training on the areas that were, you know, the most concern or where the most questions were raised so that that way It’s tailored specifically to the needs that we’re seeing that day For these reviews. I wanted to mention that often time It’s made of both attorneys and fiscal compliance analyst but we’re finding that sometimes a grantee just has issues on the compliance side or on the Fiscal side. So we’re doing more and more just sending the fiscal team out by themselves So then it would just be your fiscal staff who’s involved in these reviews. But again, it depends on the specific needs of a particular grantee Benefits of this as I keep saying, you know, your staff is involved in it, so they have instant access to the results So it’s easier for them to immediately think of ways that they can improve or suggestions for improving how the program does things One of the other benefits is there isn’t an actual report instead we issue a letter which I in do it within 60 days Oftentimes it’s in a much shorter amount and it just summarizes the different areas that we saw the different recommended recommendations that we made so that you then have it in writing and I think the biggest benefit is that Your your grantee and your staff you get to meet the OCE folks and realize that we do Want to offer guidance and assistance? So this way they’re not as Hesitant in the future to call up and ask questions or to ask for some guidance Okay, the next one I want to review is the follow-up review and this one, um not so the purpose of this is to assess whether the grantee has taken sufficient steps to address requiring corrective actions needed during a prior OC visit Not every program or routine that has a compliance review will have a follow-up review The factors that we look at and considering whether to schedule follow-up review are the number and severity of the required corrective actions so if there are a lot of required for active actions you know that ways towards maybe we should go back and see how they’re doing the severity if it’s something simple like there was Somebody there were a few retainer agreements meeting missing that’s not so severe if there was a lot of violations of citizenship and Allie and Elizabeth Citizenship and alien eligibility that severe so we would weigh that more heavily But the biggest factor is the grantees responsiveness whether they were able to cure the deficiencies quickly whether whether they responded to our request for Updates and how confident we feel in the information that was provided to us in response to our questions so those are the things we consider when deciding whether to do a follow-up review and we try and do those within 12 to 24 months of finishing a compliance review a follow-up review is Very particular so your document request letter It could be very big or it could be very small Depending on the number of required corrective actions that we’re going to be following up on If it’s just a few we’re gonna ask the questions just based on those few required corrective actions however, if you had dirty required corrective actions, we’re going to be asking for a lot of documentation so it’s very particular and specific to the actual Grantee in question and All right. We are a couple slides behind What we look at the on-site activities are then Much like the document request letter is driven by the required corrective actions that we’re going to be Reviewing. So these are the subject areas that we may or may not be reviewing on a particular visit Again as I said, it depends on the required corrective actions and with that a visit can be Anywhere from two days to five days Depending on how much work we’re going to have to do on-site and how many different areas we’re reviewing the post review follow-up again depends on the situation If we go on site and find that the grantee was able to satisfy all of the required corrective actions And we’re just dotting our eyes and crossing our T’s we will just issue a simple letter saying what the required corrective actions were what the steps taken work and Letting you know that there’s no follow-up needed however, if there are required corrective actions still pending, or if we discover new required corrective actions That might be we need needed. We’re going to issue a draft report much the same as the compliance review report It will be an exception report. It will be issued within about 60 days of leaving site visit but again the grantee will have again the same 30-day comment period and then the same final report with the comments attached to it and again Ongoing follow-up as necessary. All required corrective actions are closed. So that is a brief overview of OSI visit Thank you so much. We’re gonna move on to Joyce from akemi the director of the office of program performance Joyce. Hi Thank You Dina So I’m going to talk about the visits that we conduct in the office of program performance We have listed here three visits program quality visits program engagement visits and technical assistance visits We also conduct a fourth type of visit which is called a capability assessment Visit that bullying occurs when we have more than one entity applying for funds for the same service area So in the essence of time, we will not discuss that type of visit here But we will include information about it and the materials all of them So I’m going to start with our program quality visits which are largest visits and where we review a grantees organizational capacity to deliver high quality legal services we use the legal we use the LSC performance criteria as our guide and On these visits we interview management staff board and community partners We do not interview everyone on staff, but we try To be very strategic about which offices we go to and which staff that we talk to every grantee has an assigned program liaison and that program liaison is usually the team leader of Any visit to a grantee some there there are instances where we have new Program liaisons and we may have to have a more experienced program liaison run a visit But typically your liaison is who will lead the visit team size will range It’s all dependent on how big your organization is it’s determined on Your staff size your geography your number of offices you may have There may be some characteristics within your program that may actually Need to require more resources and if there are certain issues that we may be aware of that we have to have Specialized knowledge about maybe you also have additional service areas. You have an agricultural worker grant and you have another service area for a Native American work and so we we will look at all of those pieces, but we use the performant the élysée performance criteria is broken up into four areas and we assigned team members to specific performance areas but the team works together to develop find findings and recommendations the team participants will be the liaison and other program counsel within our office and then also One or two temporary employees may be on the visit those temporary employees many of whom are former legal services executive directors or staff The timeline for program quality visits is lengthy grantees will be notified well in advance of the start of this timeline that you see on this slide and We will typically ask for an updated staff roster at the time. We agree upon a date for the visit This helps us determine if there have been any changes since you last reported staff in the grantee activity reports prior year All of our visits are usually determined by the start of the calendar year this timeline shows the process After a visit date has agreed upon and the program has discussed the upcoming visit with their program liaison Grantees received for received formal notification of the visit 75 days prior to the start of the visit and grantees are given 35 days to submit documents requested prior to the visit a staff survey will also be issued to the entire staff and Interview schedule will be developed and worked on in collaboration with the grantee the on-site visit starts with an entrance conference then moves to interviews of staff the board and community partners and Exit conference is held at the end of the visit where we herbally present preliminary findings and recommendations So the materials that we request for program quality visits Help us prepare for the on-site visit For example under performance area 1 we ask for documents related to a grantees needs assessment statement of priorities strategic plan Mission statement outcomes data if the grantee has already provided Elysee with this documentation We remove it from the document request and just ask for an update We ask for documents specific to each of the four performance areas in the élysée performance criteria if the materials and the materials to be provided we will Provide a more exhaustive list of the specific documents that we ask for After the visit we issue a report within 60 or 90 days depending on the size of the grantee organization the report will include Findings and tier 1 and tier 2 recommendations What? Tier 1 and tier 2 tier 1 recommendations are intended to have a direct impact Director major impact on program quality and/or program performance and grantees are required to respond to the tier 1 recommendations following the visit So program engagement visits can serve a number of different purposes including being an informational gathering visit follow-up to a program quality visit or prior recommendations and and/or to address an area of concern We have many new program liaisons within the office of program performance and have shifted some of our seasoned program Counsel to different grantee programs so many are learning about the work of each of the grantees and program engagement visits can serve as a great purpose of helping to inform program liaisons about the organization’s The participants that these visits are usually one to two people it’s usually the program liaison and Sometimes we will bring somebody With an area of expertise if we were focused on Say your pro bono program We might bring somebody from the pro bono Innovation Fund staff or if there were some Technology issues. We may be bringing somebody from our technology initiative grant program So the timeline for program engagement visits They are usually covered in one to two days And usually include an interview schedule depending on the purpose of the visit we will We will focus our interviews on to cover whatever the area is that we are focusing on But it’s usually a much more scaled-down Interview schedule than we have with our program probably as I like to refer to the program engagement visits as a much lighter touch than the program quality visit The materials requested for program engagement visits also varies depending on the purpose of the visit typically Program liaisons ask for updated information and data to help assess progress or to learn about the program The documents requested are of course Much less than what we require in a program quality visit But are still centered on the LSE performance career criteria. They’re just Usually focused on a very specific area of the performance criteria So for example, it’s the purpose of the program engagement visit centers on intake we may only ask for Updates to your intake manual or we may ask for some current intake data. We may ask for any updates to your Limited-english-proficiency plan, we may ask for report time client satisfaction And there were any changes to your intake policies or procedures or staffing or or any changes maybe to your hours of intake? so in that particular instance in that particular example We would also then probably interview mostly intake staff and management Actually, could you go back website so for the program engagement visits we Typically will send you a letter within 30 days of the visit that summarizes the summarizes what we’ve observed And then also may address some next steps. Sometimes we have some informal recommendations that come with that and and your program liaison will work with you to work on those recommendations Our third type of visit is the technical assistance visits and The purpose of these are usually laser focused on an issue or area that a grantee needs assistance to improve Sometimes these visits are requested by the grantee But typically they are conducted to address an area that the program liaison identifies as requiring attention These visits are conducted by the grantees liaison and sometimes will include a member of our training and technical assistance team G9, I’m not sure how long you’ve been In existence, but for the last year at least we’ve had training and technical assistance staff sometimes to join our liaisons to help provide the technical assistance It really depends on what the technical assistance is specifically for We’ve conducted technical assistance on board governance intake strategic planning pro bono activities needs assessments leadership it’s a pretty long list and These visits usually typically involve collaborative planning with The grantee leadership to help shape what the agenda is going to be what the goals are going to be what the objectives are going to be and Depending on the specific technical assistance being provided It’s usually a one to two day visit You know It just depends on how extensive the technical assistance is needed that is needed and the materials that are Either requested are usually centered on what the area of focus is for the technical assistance But of course very significantly depending on the area of focus for the technical assistance Excellent great. Thank you so much. So we’ve got about 10 minutes left. I wanted to feel just a couple of questions So I will pose these questions to the respective folks So the first question that’s come in is for Joyce and the question was How can we better coordinate data requests with the data? They already have for granting reporting and from other visits so then question I Take to mean that how can we not ask for the same thing over and over again? We are well aware of how much of a burden we have put on grantees to supply us with The same documents over and over again part of the reason for that is that sometimes we have been very siloed in where we collect and save our documents we are Moving into the future with the new grants management system this year that I think will help improve Our ability to know what we’ve already collected from our various different visits I say that with for OPC the office of program performance and the office of compliance and enforcement but there’s still a firewall between us and the OIG for obvious reasons and But as we move into new grants management system Which is very grantee centric we should be able to Lessen the multiple requests that you get in terms of documents Awesome, and one other question came in and you touched upon this a little earlier But someone asked what the specific meaning of tier 1 2 & 3 are so we don’t have three. We only have two you’re you either have Tier one recommendation or What we call a tier 2 recommendation we only issue these recommendations during through our program quality visits and And programs are required to respond to the tier 1 recommendations for a period of two years following their visit We refer to your one recommendations as those that are that have a direct and major impact on program quality and/or on program performance And and it’s only their Tier one recommendations that we require formal response to following the visit lesson We’ve had a couple of OCE questions come in So Laura one of the standards of evaluation for the program integrity visits. That’s a good question I didn’t even touch on and probably one with that I’m just gonna not really going to punt but I’m going to tell you that it’s based on the totality of the circumstances and because Every we all all of the parent-child Relationships are different So I can’t tell you what the standards of review are I would say to review part 1610 specifically subsection 7 which tells you the different criteria that we look at And then again, as I said, it’s so 10 the totality of the circumstances There’s not one factor that weighs more than another it’s looking at the whole situation We take those reviews very seriously. We do a lot of pre-visit work for those on the document request is very large when we go on site we look at things like the square footage that each organization is using if their shared spaces and We don’t make any we rarely make preliminary findings because we bring it back and we talk to our office of legal affairs Because we want to make sure that we’re applying it correctly and that we’re playing it evenly To any grantee that does a program integrity reviews. I hope that answers it a little bit because there’s no definitive answer It’s just everything is different okay, and We’ve also had several questions come in today about indirect costs, can you speak to that a little bit um presence? Yes So indirect costs and cost allocation is something that we are definitely looking at more closely as we have Beefed up the number of fiscal compliance analysts on staff. So We will ask for your cost allocation methodologies for both direct and indirect costs as part of a compliance review And we recognize that as we’ve been looking at it and paying more attention to this area that grantees are having to do a lot of work to revise their policies to Make them compliant and we are very happy to work with the grantees to develop a compliant policy Reach to me or to Stuart accent Felder. We’ll put you in touch with your fiscal compliance analyst if you have questions about Whether your particular policy needs to be tweaked. I also suggest that you review program letter 18-2 that we issued and about it was August of 2008 and we also put together Thanks to Dina a webinar that was issued last year Specifically looking at sixteen thirty point five and different things that a grantee should keep in mind When looking at their cost allocation methodology, okay So in the interest of time, we’re going to wrap up I wanted to follow up with just a couple of next steps. So, you know, you’re not left without any resources moving forward So our plan moving forward is to provide you all with a more detailed visits guide We hope this will help you to more focused to a more focused resource These guys will summarize each of the visits discussed today as well as others that may not have been discussed So this will be coming soon. And like I said, we hope this will serve as a really great resource Before our staff come on site We do realize that there were other questions that we were not able to get to today so if we were not able to get to those We’ll run a report and then we’ll follow up with an FAQ that answers some of the more significant questions very shortly as well If you do have any questions on these visits Please don’t hesitate to reach out to your respective program council or the your respective fiscal compliance analysts Those liaisons can be found in each of the respective offices in both OPP and OCE So we’re going to wrap up the webinar there. I will encourage you to stick around after I end the broadcast We have three survey questions That will pop up right at the end of the webinar and these will help us in planning future webinars So thank you for your participation We look forward to doing many more of these in the future to help you out with understanding legal services corporations policies procedures and visit Thanks so much

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