oversight

Legal Services Corporation: More Needs to Be Done to Correct Case Service Reporting Problems

Published by the Government Accountability Office on 1999-09-20.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to Congressional Requesters




September 1999

                 LEGAL SERVICES
                 CORPORATION
                 More Needs to Be
                 Done to Correct Case
                 Service Reporting
                 Problems




GAO/GGD-99-183
United States General Accounting Office                                            General Government Division
Washington, D.C. 20548




                                    B-283551
                                    September 20, 1999

                                    The Honorable Dick Armey
                                    The Honorable Dan Burton
                                    The Honorable Tom Latham
                                    The Honorable Dan Miller
                                    The Honorable Charles Taylor
                                    House of Representatives

                                    The Legal Services Corporation (LSC), operating through grantees,
                                    provides legal assistance in civil matters to low-income individuals. In the
                                    past year, LSC’s Office of Inspector General (OIG) and we have identified
                                    misreporting by grantees on both the number of cases they closed during
                                    calendar year 1997 and the number they had open at the end of that year.
                                    The accuracy of the data is important because LSC has used case statistics
                                    to seek increased funding for LSC, and Congress has considered these case
                                    statistics in determining funding for LSC.

                                    As agreed with your offices, we determined (1) what efforts LSC and its
                                    grantees have made to correct problems with case service reporting and
                                    (2) whether these efforts are likely to resolve the case reporting problems
                                    that occurred in 1997.

                                    LSC revised its written guidance and issued a new handbook to its
Results in Brief                    grantees to clarify case reporting requirements. Based on telephone
                                    interviews with a sample of 79 LSC grantee executive directors, we
                                    estimate that 90 percent of grantees viewed the new guidance as having
                                    clarified reporting requirements, overall. Virtually all grantees said they
                                    responded to the new requirements by making or planning to make one or
                                    more changes to their program operations. However, many grantees
                                    indicated that they were unclear about certain aspects of LSC’s reporting
                                    requirements, particularly regarding (1) the specific information required
                                    on client assets, (2) the information required for documenting
                                    citizenship/alien eligibility for services provided over the telephone, (3) the
                                    criteria for avoiding duplicate counts of cases, and (4) who can provide
                                    legal assistance to clients in order for the service to be counted as a case.

                                    LSC initiated a self-inspection procedure in which grantees were required
                                    to review their 1998 case data and submit certification letters to LSC if
                                    they found that the extent of error in their data was 5 percent or less.
                                    Grantees who could not certify their 1998 data were required to develop



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             corrective actions that would address the problems identified. About 75
             percent of the grantees submitted letters to LSC certifying that the error
             rate in their 1998 data was 5 percent or less, while about 25 percent of the
             grantees submitted letters to LSC indicating that they could not certify
             their 1998 data. According to LSC, about 30 of the 50 grantees with the
             largest caseloads were unable to certify their 1998 case data.

             We could not assess whether the number of certified and uncertified
             programs that LSC obtained for 1998 was correct, lower, or higher than it
             should be. This is because LSC did not provide grantees with a
             standardized way of reporting their self-inspection results, and LSC’s
             instructions on how to conduct the self-inspections may have led some of
             the smaller grantees to select too few cases to reliably assess the amount
             of error in their case data. In addition, some grantees did not correctly
             interpret LSC’s case reporting requirements. LSC is planning to consider
             alternative ways of training grantee staff so that they gain a better
             understanding of the reporting requirements.

             For these reasons, we do not believe that LSC’s efforts to date have been
             sufficient to fully resolve the case reporting problems that occurred in
             1997. This report includes recommendations to LSC for clarifying its case
             reporting guidance to grantees and improving its procedures for
             conducting future self-inspections.

             LSC was established in 1974 as a private, nonprofit, federally funded
Background   corporation to provide legal assistance to low-income people in civil
             matters. LSC provides the assistance indirectly through grants to
             competitively selected local programs. LSC distributes funds to the
             grantees on the basis of the number of low-income persons living within a
             service area. Grantees may receive additional funding from non-LSC
             sources.

             During 1998, LSC funded 262 local grantees that operated through
             approximately 900 neighborhood law offices employing about 3,600
             attorneys and 1,400 paralegals. Each local program is governed by its own
             board of directors and is required to spend at least 12.5 percent of its LSC
             grant to encourage private attorney involvement (PAI) in delivering legal
             services to low-income clients. In fiscal years 1998 and 1999, LSC received
             appropriations of $283 million and $300 million, respectively.

             LSC’s authorizing legislation restricts it from engaging in lobbying; political
             activities; class actions except under certain conditions; and cases
             involving abortion, school desegregation, and draft registration or



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desertion from the military. Annual appropriations laws have placed
additional restrictions on the activities in which LSC grantees can engage,
even with non-LSC funds. In 1996, for example, grantees were prohibited
from engaging in challenges to welfare reform, litigation on behalf of
prisoners, representation in drug-related public housing evictions, and
representation of certain categories of aliens.

Grantees must serve only those clients who meet financial and
citizenship/alien eligibility requirements. With respect to client financial
eligibility, local programs are to establish their own criteria, which, in
general, require that clients’ income not exceed 125 percent of the federal
poverty guidelines. With appropriate documentation of the grantee’s
decision, clients who are between 125 percent and 187.5 percent of the
federal poverty level may be found eligible. LSC regulations require that
grantees (1) adopt a form and procedure to obtain eligibility information
and (2) preserve that information for audit by LSC. With regard to
citizenship/alien eligibility, only citizens and certain categories of aliens
are eligible for services. For clients who are provided services in person, a
citizen attestation form or documentation of eligible alien status is
required. For clients who are provided services on the telephone, grantees
must document that they made inquiries regarding the individuals’
citizenship/alien eligibility.

LSC uses a Case Service Reporting (CSR) system to gather quantifiable
information from grantees on the services they provide that meet LSC’s
definition of a case. The CSR Handbook is LSC’s primary official guidance
to grantees on how to record and report cases. According to the 1999 CSR
Handbook, which revised and expanded the guidance in LSC’s 1993
Handbook, information about cases is an important indicator of the
number of legal problems that programs address each year, and LSC relies
on such case information in its annual request for federal funding for legal
services.

Audit reports on five grantees issued by LSC’s OIG between October 1998
and July 1999 reported that all five grantees misreported the number of
cases they had closed during calendar year 1997 and the number of cases
that remained open at the end of that year. The OIG found that all five
grantees overstated the number of closed cases, while four overstated and
one understated open cases. The OIG attributed the overreporting to such
factors as (1) counting as cases telephone calls in which individuals were
not provided any legal assistance and only partial eligibility determinations
were made; (2) counting wholly non-LSC funded cases as LSC cases; (3)
double counting of the same cases; (4) reporting cases as closed during



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                         1997, or as still open at the end of 1997, when service ceased in prior years;
                         and (5) counting as cases the provision of services to over-income clients.
                         In June 1999, in response to Congress’ request for information on whether
                         the 1997 case data of other LSC programs had problems similar to those
                         reported by LSC’s OIG, we issued a report on our audit of five of LSC’s
                         largest grantees: Baltimore, Chicago, Los Angeles, New York City, and
                                      1
                         Puerto Rico. We found similar types of reporting errors at the five
                         grantees and estimated that, overall, 75,000 of the 221,000 open and closed
                                                                                          2
                         cases that the five grantees reported to LSC were questionable. Interviews
                         that we conducted with LSC officials and executive directors of the 5
                         audited grantees indicated that they had taken or were planning to take
                         steps to correct the causes of these case-reporting problems.

                         Our objectives were to determine (1) what efforts LSC and its grantees
Objectives, Scope, and   have made to correct problems with case service reporting, and (2)
Methodology              whether these efforts are likely to resolve the case reporting problems that
                         occurred in 1997.

                         To address the objectives, we reviewed documents that contained LSC
                         case reporting guidance, interviewed cognizant officials at LSC
                         headquarters, and conducted structured telephone interviews with a
                         random sample of grantee executive directors. Specifically, we reviewed
                         LSC regulations and LSC’s 1993 and 1999 CSR Handbook, as well as
                         supplemental guidance that LSC distributed to grantees in the form of
                         program letters and frequently asked questions and answers about case
                         reporting. We also collected documentation and interviewed LSC officials
                         and grantee executive directors to gather information about a self-
                         inspection process that LSC required all grantees to undertake in order to
                         determine the accuracy of their 1998 case data. In our telephone
                         interviews with executive directors, we asked if the directors viewed LSC’s
                         case reporting requirements as being clear, what changes they have made
                         or planned to make as a result of the requirements, and the results of their
                         self-inspection of 1998 case data. We also interviewed LSC officials and
                         grantee executive directors about areas of case reporting that they felt
                         needed further clarification.



                         1
                          Legal Services Corporation: Substantial Problems in 1997 Case Reporting by Five Grantees
                         (GAO/GGD-99-135R, June 25, 1999).
                         2
                          Our estimate was based on file reviews of random samples of cases that the five grantees reported as
                         closed during 1997 and open at the end of 1997. In addition, we reviewed random samples of
                         potentially duplicate cases for four grantees. We estimated that, overall, 75,000 (+/-6,100) cases were
                         questionable.




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                         To identify the universe of LSC grantees, an LSC official referred us to the
                         list of LSC programs on the corporation’s Internet Web site. As of July 15,
                         1999, the Internet site listed 256 programs. From this list, we randomly
                         selected 80 programs for our sample. We developed the interview
                         instrument, pretested it with executive directors from two grantees,
                         revised the instrument based on the pretest results, and completed
                         approximately 1-hour-long structured interviews by telephone with the
                         executive directors of 79 of the 80 programs, for a 99 percent response
                         rate. (After numerous attempts over several days, we were unable to
                         contact the executive director of one LSC grantee.) Our sample was
                         designed so that we could generalize our findings with 95-percent
                         confidence and a maximum 10-percent margin of error to the universe of
                         LSC grantees.

                         We performed our work from July through September 1999 in accordance
                         with generally accepted government auditing standards. We requested
                         comments on a draft of this report from the President of LSC. LSC’s
                         comments are discussed at the end of this letter and included as appendix
                         I.

                         LSC issued a new CSR Handbook and distributed other written
LSC Clarified CSR        communications intended to clarify reporting requirements to its grantees.
Requirements and         Most grantees indicated that the new guidance helped clarify LSC’s
Grantees Have Been       reporting requirements, and virtually all of them indicated that they had or
                         planned to make program changes as a result of the requirements. Many
Making Program           grantees, however, identified areas of case reporting that remained unclear
Changes to Comply        to them.
With the Requirements,
but Some Grantees
Remain Unclear About
Certain Requirements
LSC Issued New CSR       To address specific problems identified by the OIG and LSC’s own internal
                         program reviews, LSC has issued revised reporting guidance. In November
Guidance                 1998, LSC issued the 1999 CSR Handbook, which replaced the 1993 CSR
                         Handbook. The 1999 handbook instituted changes to some of LSC’s
                         reporting requirements and provided more detailed information on other
                         requirements than previously existed. LSC also distributed program letters
                         and a list of frequently asked CSR questions and answers that further
                         elaborated on points made in the 1999 handbook.

                         The 1999 CSR Handbook instituted several notable changes to case
                         reporting requirements. These included (1) procedures for timely closing



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of cases; (2) procedures for management review of case service reports;
(3) procedures for ensuring single recording of cases; (4) requirements to
report LSC-eligible cases, regardless of funding source; and (5)
requirements for reporting PAI cases separately. In addition, grantees were
required to use automated case management systems and procedures that
would ensure that program managers had timely access to accurate
information on cases and the capacity to meet their reporting
requirements.

On November 24, 1998, LSC informed its grantees that two of the changes
in the 1999 CSR Handbook were to be applied to the 1998 case data. The
two changes pertained to timely closing of cases and management review
of case service reports. The timely closing provision required grantees to
ensure that cases in which legal assistance had ceased in 1998, and was
not likely to resume, would be closed prior to grantees’ submission of case
service reports to LSC in March 1999. To the extent practicable, cases in
which the only assistance provided to the client was counsel and advice,
brief service, or referral after legal assessment were to be closed in the
year in which these types of service were provided. Cases involving other
types of service were to be closed in the year in which program staff
determined that further legal assistance was unnecessary, not possible, or
inadvisable and a closing memorandum or other case-closing notation was
prepared. The management review provision required the executive
director, or a designee, to review the program’s case service reports prior
to their submission to LSC in order to ensure their accuracy and
completeness.

The remaining new provisions of the 1999 CSR Handbook were not
applicable to 1998 cases. For example, for 1998, there was no requirement
for grantees to ensure that cases were not double counted. For 1999, LSC
is requiring the use of automated case management systems and
procedures to ensure that cases involving the same client and specific legal
problem are not reported to LSC more than once. For 1998, grantees could
report only those cases that were at least partially supported by LSC funds.
For 1999, LSC is requiring grantees to report all LSC-eligible cases,
regardless of funding source. LSC intends to estimate the percentage of
activity spent on LSC service by applying a formula that incorporates the
amount of funds grantees receive from other funding sources compared
with the amount they receive from LSC. For 1998, grantees were required
to report their LSC-funded PAI cases together with non-PAI cases. For
1999, PAI cases are to be reported separately.




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                             In addition to changing certain reporting requirements, the 1999 handbook
                             also provides more detailed guidance to grantees than the 1993 handbook.
                             For example, the 1999 handbook provides more specific definitions of
                             what constitutes a “case” and a “client” for CSR purposes. The 1999
                             handbook also addresses documentation requirements that were not
                             discussed in the 1993 handbook. For example, the 1999 handbook
                             indicates that, except for telephone service cases, the client’s file must
                             contain an attestation of citizenship or documentation of alien eligibility in
                                                                       3
                             order for the case to be reported to LSC. The 1999 handbook also imposes
                             requirements for documentation of information on client income and
                             assets. The handbook states that, for all cases reported to LSC, the
                             eligibility documentation must include specific information about income
                             and assets. The 1999 handbook also contains a requirement that legal
                             assistance, to be counted as a case, must be provided by an attorney or
                             paralegal.
                                                                                                               4
Grantee Directors Reported   On the basis of our survey, we estimate that over 90 percent of grantee
                             executive directors viewed the changes in the 1999 CSR Handbook as
That They Are                being clear overall, and virtually all of them planned to or had made at
Implementing Changes to      least one change to their program operations as a result of the revised case
Comply With Reporting        reporting requirements. Program changes that were cited included revising
Requirements                 policies and procedures, providing staff training, modifying forms and/or
                             procedures used during client intake, implementing computer hardware
                             and software changes, and increasing review of cases.

                             Nearly half of the grantees indicated that they planned to or had revised
                             their policies and/or procedures to comply with the 1999 handbook
                             requirements, and slightly less than a third planned to or had conducted
                             staff training on the requirements. Respondents told us that the focus of
                             their training was on such issues as the current definition of a case, how to
                             determine and document clients’ financial eligibility, how to determine and
                             document citizenship/alien eligibility, timely closing of cases, and
                             prevention of duplicate case reporting.

                             More than half of the grantees indicated that they planned to or had
                             changed their intake forms and/or procedures. Of the 41 respondents who


                             3
                              The requirement for documentation is contained in LSC regulations, at 45 C.F.R. 1626.6(a) and
                             1626.7(a). However, the 1999 CSR Handbook specified for the first time that the case could not be
                             reported to LSC if the documentation was missing.
                             4
                             All percentage estimates presented in this report have 95 percent confidence intervals with a margin of
                             error of 10 percent or less.




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made this comment, 26 said they were making these changes in order to
document client income and assets.

Slightly over 40 percent of the grantees reported that they planned to or
had made computer changes. The computer changes included such actions
as adding new fields to their automated case management (e.g., to ensure
that client eligibility and acceptance information is recorded), making
programming changes (e.g., to identify duplicate cases, ensure that cases
are not assigned separate numbers for the same client with the same legal
problem, and better document client assets), and installing new software
(e.g., to generate reports so that they can track how long cases are open).

About 10 percent of grantee executive directors indicated that they could
better comply with CSR requirements if they had uniform case
management software. LSC, too, believes that grantees’ case management
systems should provide for more consistency in the collection and
processing of CSR information. According to an LSC official, LSC is
developing a strategy for modifying grantees’ case management systems so
that data errors can be detected and prevented. As part of the strategy,
LSC has hired an expert in case management systems and is working to
develop standard input requirements for these systems. LSC intends to
work with case management system vendors to modify the systems so that
they prevent cases from being accepted if grantees do not record the
required compliance information. LSC expects modifications to the case
management systems to be implemented in calendar year 2000 and
available for application to grantees’ 2000 CSR data. In the nearer term,
LSC plans to work with a contractor to develop customized case
management queries that would enable grantees to detect and remedy
errors in their 1999 case data. In 1999, LSC plans to pilot test the computer
queries at five programs that have the most commonly used case
management systems.

Nearly three-fourths of the grantees indicated that they planned to or had
increased their review of cases to comply with LSC requirements.
Respondents cited such review activities as more intense monitoring of
open cases, to ensure that they are closed in a timely manner, and more
thorough monitoring of PAI cases. Some grantees said they have directed
increased attention to reporting requirements during routine reviews of
cases, while others said they instituted more frequent reviews of cases.
One executive director reported to LSC that managing attorneys would
meet with all case-handling staff and reemphasize the importance of
keeping accurate activity records. These managing attorneys are to
monitor compliance with the requirement initially on a weekly basis and



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                           then on a random basis. If deficiencies are discovered, the managing
                           attorney is to direct the case handler to correct them immediately, and the
                           managing attorney is to recheck the file within 48 hours to ensure
                           compliance with the directive. Another executive director told us that his
                           program had not previously reviewed CSR data. He said that they now are
                           reviewing reports, along with listings of open and closed cases, to ensure
                           their compliance with LSC guidelines. Some executive directors said that
                           they planned to become more involved in reviewing case files and case
                           management reports.

                           Many grantees reported making other efforts to comply with reporting
                           requirements, such as disseminating the new handbook to case handlers,
                           developing compliance checklists, emphasizing the importance of
                           compliance to staff, sending written instructions or memos to staff,
                           holding meetings and discussions, providing more feedback to case
                           handlers, and more stringently enforcing requirements.

Many Grantees Remain       Although most of the grantee executive directors reported that the new
                           LSC guidance helped clarify requirements, many of them also indicated
Unclear About Certain      that they were still unclear about certain requirements and that additional
Reporting Requirements     clarification was needed. Among the areas of confusion or uncertainty that
                           executive directors identified were requirements pertaining to asset and
                           citizenship/alien eligibility documentation, single recording of cases, and
                           who can provide legal services.

                         • Asset documentation: The 1999 CSR Handbook states that, for all cases to
                           be reported to LSC, the eligibility documentation should include specific
                           information about income and assets. About 30 percent of the executive
                           directors indicated that LSC’s requirements for documenting client assets
                           were clear only to some, to little, or to no extent. Of the 24 respondents
                           who gave this response, 23 made comments to the effect that LSC should
                           clarify what it means by assets and asset limits and/or clarify its
                           documentation requirements for client assets. In a July 14, 1999, program
                           letter to grantees, LSC noted that although many grantees inquire about
                           applicants’ assets, they do not consistently document either the inquiries
                           or the applicants’ responses. In its program letter, LSC sought to clarify its
                           requirements for documenting and preserving the asset information
                           obtained from each applicant. Because we conducted our telephone
                           survey in late July and early August, we do not know how many of the
                           executive directors with whom we spoke had reviewed LSC’s July 14
                           guidance and felt that it sufficiently clarified their questions concerning
                           asset documentation. However, two respondents told us that LSC’s July 14
                           guidance was still unclear. One respondent said, for example, that the



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  program letter left unclear the meaning of the term “household goods,”
  whether exempted assets had to be documented, who was to value the
  goods, and who was to determine what to count and what not to count as
  part of assets. Our own analysis of LSC guidance on the asset issue
  indicated that LSC has not been consistent in its directives to grantees
  about the specificity of asset information they must have in order to
  comply with CSR reporting requirements. For example, in its March 24,
  1999, communication on frequently asked CSR questions and answers, LSC
  instructed grantees to document, at minimum, the total amount of
  household assets accessible to the client. In its July 14, 1999, program
  letter, LSC instructed grantees to identify and document all of the liquid
  and nonliquid assets of all persons who are resident members of a family
  unit.

• Citizenship/alien eligibility documentation requirements for telephone
  cases: The 1999 CSR Handbook does not explicitly address the citizenship
  or eligible alien status documentation requirements for situations where
  assistance is provided only over the telephone. Nearly one-fourth of the
  executive directors indicated that LSC’s documentation requirements in
  this area were clear only to some, to little, or to no extent. Of 19
  respondents who gave this response in our survey, 15 said that more
  clarification was needed on the grantees’ documentation responsibilities.
  Respondents said, for example, that they were confused about exactly
  when they needed to obtain a written attestation, whether it was sufficient
  simply to record that questions about citizenship/alien eligibility had been
  asked, whether certain types of service required documentation while
  others did not, and whether the requirement changed if an individual
  receiving assistance over the telephone came into the office to drop off
  documents. In its July 14, 1999, program letter to grantees, LSC sought to
  clarify its requirements for documenting citizenship/alien eligibility
  information in telephone cases. LSC stated that it requires recipients to
  make appropriate inquiry of every telephone applicant and record the
  inquiry and response. All such documentation is to be maintained in the
  client file. We do not know how many of the respondents to our survey
  were familiar with LSC’s July 14 guidance when we interviewed them in
  late July and early August.

• Single recording of cases: The 1999 CSR Handbook requires that programs
  ensure that cases involving the same client and specific legal problem are
  not recorded and reported to LSC more than once. Over one-fourth of the
  executive directors indicated that the requirement for preventing duplicate
  case reporting was clear only to some, to little, or to no extent. Of the 22
  respondents who gave this response in our survey, 17 said that the



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  distinction between specific and related legal problems is difficult to
  determine. Several respondents cited examples in family law cases where
  more than one problem can arise within one family case. Depending on the
  situation, it was not clear to them at what point legally related issues
  become separate enough to count as separate cases. One respondent
  indicated that attorneys in his program have a hard time interpreting this
  requirement, and that he got calls every week about this issue.

• Provider of legal assistance: The CSR handbook requires that legal
  assistance be provided by an attorney or paralegal in order for a service to
  be called a case.5 Slightly over 40 percent of executive directors indicated
  that LSC was clear only to some, to little, or to no extent about who can
  provide such legal assistance. Respondents noted in our telephone survey,
  for example, that the terms “case handler,” and “paralegal” are not clearly
  defined, and that they did not know whether nonlawyers (e.g., intake
  workers) who are supervised by lawyers can provide legal assistance.
  Comments made to us by the executive directors revealed that grantees
  held varying views about who can provide legal assistance to clients.
  Several respondents specifically stated that this is an important issue that
  LSC should address in its handbook. Our own analysis of LSC guidance on
  this issue indicates that LSC has not been consistent in its advice to
  grantees. For example, in its communication with grantees on frequently
  asked CSR questions and answers, LSC stated that a telephone
  conversation between an intake specialist and a caller who was accepted
  for service can be counted as a case if the caller received some advice that
  addressed a specific legal problem. LSC officials told us that LSC’s current
  position on this issue is that the person giving legal advice must be
  someone who is authorized to practice law or is under the supervision of
  an attorney in accordance with local rules of practice. Therefore, legal
  advice can be given by a (1) lawyer, (2) paralegal, or (3) intake specialist
  or law student under the supervision of a lawyer, as long as the assistance
  does not violate local rules of practice.




  5
   The 1999 CSR handbook does not explicitly state that legal assistance must be provided by an attorney
  or paralegal. However, section VIII of the handbook states that, to be reported as a case, the legal
  assistance must meet the definition of “case” in 45 CFR 1635.2(a). This regulation defines a case as a
  form of program service in which an attorney or paralegal provides legal services.




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                           LSC sought to determine the accuracy of grantees’ case data by requiring
Most Grantees              that grantees do self-inspections of their open and closed caseload data for
Certified to the           1998. Grantees were required to determine whether the error rate in their
Accuracy of Their 1998     data exceeded 5 percent. If the error rate was 5 percent or less, they could
                           certify that their data were substantially correct. If the error rate was
CSR Data, but              higher than 5 percent, they were to determine how the problems identified
Questions About Data       could be addressed. LSC found that about three-fourths of the grantees
Accuracy and               were able to certify to the substantial accuracy of their data. LSC used the
Interpretation Remain      results of the self-inspections to estimate the total number of case closings
                           in 1998. Our review of LSC’s self-inspection process raised concerns about
                           the accuracy and interpretation of the results, and what the correct
                           number of certifying programs should be.

LSC Grantees Conducted     On May 14, 1999, LSC issued a memo to all grantees instructing them to
                           complete a self-inspection procedure by July 1, 1999. The purpose of the
Self-Inspections of 1998   self-inspection was to ensure that (1) grantees were properly applying
CSR Data                   instructions in the 1999 edition of the CSR Handbook that were applicable
                           to the 1998 data, and (2) LSC had accurate case statistical information to
                           report to Congress for calendar year 1998.

                           LSC provided detailed guidance to grantees on the procedures for the self-
                           inspection. Each grantee was to select and separately test random samples
                           of open and closed cases to determine whether the number of cases it
                           reported to LSC earlier in the year was correct. Grantees were to verify
                           that the case file contained a notation of the type of assistance provided,
                           the date on which the assistance was provided, and the name of the case
                           handler providing the assistance. Grantees were also to determine whether
                           assistance had ceased prior to January 1, 1998; was within certain service
                           categories as defined by the 1999 handbook; was provided by an attorney
                           or paralegal; and was not prohibited or restricted. Finally, grantees were to
                           verify that each case had eligibility information on household income,
                           household size, household assets, citizenship attestation for in-person
                           cases, and indication of citizenship/alien status for telephone-only cases.
                           According to LSC officials, the self-inspection was a single procedure that
                           was undertaken within a limited time period, and LSC did not expect the
                           self-inspection to resolve all case-reporting problems.

                           In requiring grantees to verify that their 1998 case files contained
                           information on client assets and an indication of citizenship/alien status
                           for telephone-only cases, LSC imposed stringent criteria on the self-
                           inspections. The criteria were stringent in that LSC had not promulgated
                           explicit documentation requirements related to these issues until it
                           released the 1999 CSR Handbook and July 14 program letter. Grantees



                           Page 12                              GAO/GGD-99-183 LSC Case Reporting Problems
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were not required to apply these new documentation requirements to their
1998 case data. Recognizing that in 1998 many grantees did not keep
sufficient documentation on assets or citizenship/alien eligibility to comply
with the stringent self-inspection requirements, LSC allowed grantees
some latitude in determining whether they were in fundamental
compliance with the requirement that legal assistance only be provided to
eligible individuals. In conversations with grantee executive directors
during the self-inspection, LSC officials advised them that if they had a
level of certainty that their program staff had asked questions about assets,
and if their certainty was sufficient for them to sign a form attesting to
this, that was an acceptable basis for asserting compliance with the
reporting requirement for assets. Similarly, if grantees were sufficiently
certain that, for telephone cases, their program staff had asked questions
about citizenship/alien status but had not documented the inquiry, that too
was acceptable. Finally, LSC allowed grantees some latitude with respect
to the requirement that an attorney or paralegal must be the provider of
legal assistance. LSC advised grantees during the self-inspection that it was
acceptable for them to count as valid cases instances in which legal advice
was given by a (1) lawyer, (2) paralegal, or (3) intake specialist or law
student under the supervision of a lawyer, as long as the assistance did not
violate local rules of practice.

If any single aspect of a case failed to meet LSC’s requirements, the case
was to be classified as an error for reporting purposes. If the grantees
found that their CSR case sampling had an error rate of 5 percent or less,
the program directors and policy board chairs were to sign a certification
form and return it to LSC. Grantees who could not certify to the
correctness of their 1998 CSR data were to submit a letter to LSC
describing (1) the problems they had identified during the self-inspection
process and (2) the corrective actions they had instituted to address the
problems. Grantees could resubmit their 1998 CSR data to LSC if they
identified one or more problems in the random sample and corrected their
entire 1998 database so that the problems no longer appeared. If, by
correcting the problems, the error rate in the data was reduced to 5
percent or less, the grantees could resubmit their 1998 data along with a
signed certification attesting to the substantial accuracy of the resubmitted
data. In this way, grantees who were unable to certify at one point in time
could certify at a later point in time. As of July 29, 1999, 26 grantees had
resubmitted their 1998 CSR data after having made corrections to the data,
and 20 of them had certified their data.




Page 13                              GAO/GGD-99-183 LSC Case Reporting Problems
                            B-283551




Most Grantees Certified     According to LSC officials, about three-fourths of the grantees certified the
                            accuracy of their 1998 case data. As of August 26, 1999, LSC documents
Their 1998 CSR Data                                            6
                            indicated that 199 of 261 grantees (76 percent) reported substantially
                            correct CSR data to LSC. The remaining 62 grantees (24 percent) did not
                            certify to LSC that their CSR data were substantially correct. On the basis
                            of the self-inspection results, LSC estimated that grantees closed 1.1
                            million cases in 1998.

                            LSC officials told us that they were surprised that such a large number of
                            grantees were able to certify their 1998 CSR data. They attributed the
                            lower-than-expected error rates to the following factors:

                          • The self-inspection did not attempt to identify duplicate cases. LSC
                            officials explained that, during most of 1998, LSC did not have a standard
                            regarding duplicate cases, and that they believed it would have been too
                            burdensome on grantees for LSC to require them to apply the new
                            standard retroactively. According to an LSC official, duplicate cases are
                            best caught at the time of intake. The official also noted that duplicate
                            cases had not in the past been found to be a major problem in comparison
                            with other identified problems.

                          • Grantees received the new 1999 CSR Handbook in November1998, and a
                            number of them had implemented the requirements that applied to their
                            1998 data by the time they submitted their 1998 case statistics.

                          • Grantees were aware of the problem that the OIG had identified with cases
                            coded as referral after legal assessment. That is, some programs had
                            inappropriately reported as CSR cases numerous instances of making a
                            telephone referral without providing legal advice and/or without
                            documenting an individual’s eligibility. Because grantees had been
                            sensitized to this issue, LSC officials believed that they were less likely to
                            count these referrals as cases in 1998.

                            According to LSC officials, CSR problems were more common at larger
                            grantees that had heavier case loads and multiple branches. They noted
                            that approximately 30 of the 50 grantees with the largest caseloads were
                            unable to certify their 1998 data. They hypothesized that larger programs
                            may have difficulty certifying if such programs have (1) numerous branch
                            offices, one or more of which are out of compliance with regulations and
                            causing reporting problems for the entire program, and/or (2) numerous

                            6
                             LSC funded 262 programs in 1998. Funding for one program was discontinued in 1999, and LSC has no
                            self-inspection results for this program.




                            Page 14                                        GAO/GGD-99-183 LSC Case Reporting Problems
                             B-283551




                             sources of funding and more compliance requirements, which could add to
                             the complexity of their reporting process. The officials acknowledged that
                             these hypotheses needed further exploration.

                             LSC officials also reported that noncertifying grantees identified two
                             principal problems. One pertained to the lack of citizenship attestations in
                             case files. The second pertained to the lack of information on client assets.
                             LSC officials also noted that some grantees had reported matters, such as
                             referrals, as cases, and some had reported cases as open when they did not
                             meet the timely closing requirement. In our telephone interviews with 79
                             executive directors, 24 reported that they did not certify their 1998 data to
                             LSC. Factors that the executive directors of noncertifying programs
                             believed greatly affected the errors in their 1998 data included lack of clear
                             guidance from LSC (cited by 11 respondents), computer problems (cited
                             by 7 respondents), and insufficient attention by their programs to
                             administrative matters (cited by 5 respondents).

                             Computer problems that were noted included difficulties merging
                             databases and using several different software packages, and problems
                             with upgrading the computer system.

LSC Used Self-Inspection     Based on the self-inspection results, LSC estimated that its grantees closed
                             about 1.1 million cases in 1998. LSC arrived at this figure by subtracting the
Results to Estimate Number   total number of closed cases estimated to be in error (135,498) from the
of Cases Closed                                                                                7
                             total number of cases that grantees reported to LSC (1,260,351). As of July
                             29, 1999, LSC estimated that its grantees’ total closed caseload for 1998
                                            8
                             was 1,124,853.

                             LSC intends to report only the estimated number of cases closed in 1998,
                             even though the self-inspections were to encompass both open and closed
                             cases. According to LSC officials, LSC has less confidence in the open-case
                             numbers than the closed-case numbers. One reason for this is that they
                             believe open cases are more likely than closed cases to have timely closing

                             7
                              LSC performed this calculation separately for certifying and noncertifying programs. For noncertifying
                             programs, LSC determined that 96,273 cases were reported in error out of grantees’ original submission
                             of 475,856 closed cases. For certifying programs, LSC subtracted 5 percent, or 39,225 cases, from
                             grantees’ original submission of 784,495 closed cases. LSC reduced the case statistics of certifying
                             programs by 5 percent to ensure that there would be no overstatement of cases for these programs.
                             8
                              In April 1999, prior to the self-inspection, LSC’s CSR database indicated that grantees closed 1,338,976
                             cases in 1998. The difference between the April 1999 figure and LSC’s July 1999 estimate of 1,260,351
                             closed cases—that is, the number reported closed prior to adjusting for the self-inspection results— is
                             attributable to the fact that some grantees who found data errors corrected them and resubmitted their
                             statistical results to LSC. Those who initially did not certify their data may have later certified them if
                             their corrections reduced their error rate to 5 percent or less.




                             Page 15                                            GAO/GGD-99-183 LSC Case Reporting Problems
                          B-283551




                          problems. A second reason is that some grantees experienced problems
                          when converting to a new computer system. System conversions
                          sometimes caused dates to be lost or cases to be mistakenly coded as
                          being open.

Self-Inspection Results   Our review of LSC’s self-inspection results raised some concerns about
                          LSC’s interpretation of the results and about the accuracy of the data
Raised Concerns           provided to LSC by grantees. As a result, we could not assess whether the
                          number of certified programs and case closures that LSC estimated for
                          1998 is correct, lower, or higher than it should be.

                          Although LSC provided instructions to grantees on how they should select
                          test samples and what case information they should verify, LSC did not
                          issue standardized procedures for grantees to use in reporting the results
                          of their self-inspections. Grantees that could not certify their data wrote
                          letters to LSC in which they described the errors they uncovered. The
                          letters contained varying degrees of detail about the errors. Some
                          programs provided an overall error rate and did not separately report how
                          much error they found in open and closed cases. Others provided detailed
                          information on both the number of errors found in open and closed cases,
                          respectively, as well as the number of errors broken out by type. Since LSC
                          did not have a standard protocol for collecting the results of the self-
                          inspections, in some cases LSC officials had to rely on interpreting grantee
                          letters that described the problems that were discovered. LSC officials
                          believe that their numerous contacts with grantees who called them to ask
                          questions about the self-inspections, combined with their analysis of the
                          grantee letters, enabled them to correctly determine the number of
                          certifying programs and estimate the number of closed cases.

                          We are uncertain how many programs should have been counted as
                          certified because we are uncertain if LSC applied a consistent definition of
                          “certification.” Most programs that were on LSC’s certification list
                          determined that they had error rates of 5 percent or less for both open and
                          closed cases. However, LSC placed some programs on the certified list if
                          the program’s overall error rate for closed cases was 5 percent or less,
                          even if the overall error rate actually was higher than 5 percent. We
                          encountered this situation in two instances in which executive directors
                          told us in telephone interviews that they did not certify their CSR data
                          because their overall error rate exceeded 5 percent. However, these
                          programs appeared on LSC’s list of certified programs. When we asked an
                          LSC official about this, he told us that they advised grantees that if their
                          closed case error rate did not exceed 5 percent, they should “partially
                          certify” their data. In response to our inquiry, the official reviewed the



                          Page 16                             GAO/GGD-99-183 LSC Case Reporting Problems
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certification letters submitted by nearly 200 grantees, and he identified 5
certified programs whose error rates for open cases exceeded 5 percent.
Given that some grantees submitted only an overall estimate of data error,
we do not know how many programs qualified to be certified overall, just
for closed cases, or just for open cases.

In another instance, an executive director told us that she did not certify
her program because 8 of the 14 case-handling offices had error rates
exceeding 5 percent. Nonetheless, this program appeared on LSC’s
certified list. An LSC official explained that, after reviewing the
information provided by this program, the official agreed that the program
should not have been classified as certified. In a fourth instance, in which
an executive director reported to us that he did not certify his program, an
LSC official said that, although they thought the grantee’s data had been
corrected, the program had not yet certified its data and might need to do
additional sampling.

We are also concerned that LSC’s instructions to grantees on how to
conduct the self-inspections may have led some of the smaller grantees to
select too few test cases to make a reliable assessment of the proportion of
error in their case data. For example, LSC instructed grantees to select
every tenth case for review if the program handled less than 1,000 cases in
1998. This was to be done separately for open and closed cases. Based on
1998 case statistics that grantees submitted to LSC between January and
March 1999, several programs would have based their certification
determinations on reviews of a relatively small number of cases. Seven
grantees had fewer than 300 closed cases, and 43 grantees had fewer than
300 open cases. Three programs had fewer than 300 cases combined. The
smallest program would have based its self-inspection on 3 closed cases
and 1 open case. We believe that, in general, samples of 30 or fewer cases
are too small to provide reliable estimates of the total number of case data
       9
errors. Because these were smaller grantees, this limitation would have
had little effect on LSC’s estimate of total closed caseload. However, it
could have affected—by either overstating or understating—LSC’s count
of the number of certified programs.

LSC does not know how well grantees conducted the self-inspection
process, nor how accurate the results are. We spoke with several executive

9
 To illustrate, a program that reviewed 30 closed cases and found a single error would have had a 3
percent error rate. However, the margin of error based on a sample size of 30 would range from about
0.1 percent to 17 percent at the 95 percent statistical confidence level. If the program found two errors,
it would have had a 7 percent error rate, with a margin of error ranging from 1 percent to 22 percent.
Statistically, the smaller the number of cases sampled, the larger the margin of error.




Page 17                                            GAO/GGD-99-183 LSC Case Reporting Problems
B-283551




directors who did not correctly follow LSC’s reporting requirements. In
one case, the executive director sought clarification from LSC
headquarters about the use of a CSR closure code and was given incorrect
verbal guidance. The situation concerned whether applicant files could be
closed as “client withdrew” cases when individuals who were accepted for
service and assigned to staff attorneys did not subsequently appear for a
meeting with the attorney. According to both the executive director and an
LSC official, the executive director was told that if the program attempted
to contact these individuals, by telephone or letter, to determine whether
they were still interested in obtaining legal assistance, they could be
counted as cases. The executive director told us that she would review her
entire database for this type of error and make corrections. This program
was included on LSC’s certified list, but we do not know whether the
program would stay on that list if all the errors were identified.

Another executive director told us that he was concerned that LSC did not
want grantees to count assistance over the telephone as a case. This is not
an entirely correct interpretation of LSC guidance since, under certain
conditions, LSC permits legal assistance over the telephone to be counted
as a case. Although this program was included on LSC’s certified list, any
valid telephone cases that were not counted would have erroneously
increased its error rate.

A third executive director told us that the timely closing rule required him
to close new cases in December. If the person sought assistance with a
similar problem in January, it would be treated as a new case because a
new reporting year had begun. In a March 1999 written communication
intended to supplement the 1999 handbook, LSC advised grantees to
exercise discretion about when to close cases that were opened near the
end of the year. LSC did not require grantees to close all cases at year-end.
These examples illustrate the possibility that incorrect interpretations of
LSC guidance may have resulted in some programs certifying their 1998
data when they shouldn’t have, and other programs not certifying their
1998 data when they should have. An LSC official told us that, although
they have conducted CSR training sessions for grantee executive directors,
there are thousands of case handlers in grantee offices who have not
received similar training. The official acknowledged that written guidance
and telephone contacts with grantees may not be sufficient to ensure
correct and consistent understanding of reporting requirements, and that
LSC may consider alternative ways of providing training to staff, such as
through videos.




Page 18                              GAO/GGD-99-183 LSC Case Reporting Problems
                    B-283551




                    Incorrect interpretations of LSC guidance could also have affected the
                    accuracy of LSC’s estimate of closed cases. The Inspector General told us
                    that his office has completed audits of six grantees’ 1998 case data. One
                    additional audit of a grantee’s CSR data had not yet been completed. The
                    six completed audits included both certifying and noncertifying grantees.
                    According to the Inspector General, the results of the six completed audits
                    would be provided to Congress by September 29, 1999.

                    LSC officials told us that the self-inspection was valuable and that LSC
                    plans to have grantees complete self-inspections again early next year as
                    part of the 1999 CSR reporting process. We agree that a self-inspection
                    process can be valuable, provided that grantees have clear, consistent, and
                    appropriate guidance on the procedures for reviewing their case data,
                    determining whether to certify the data, correcting errors, and providing
                    their results to LSC in a standardized way that facilitates validation of the
                    results.

                    LSC’s 1999 CSR Handbook and other written communications have
Conclusions         improved the clarity of reporting requirements for its grantees. However,
                    many grantees remain unclear about and/or misunderstood certain aspects
                    of the reporting requirements. LSC’s practice of disseminating guidance
                    primarily by written or telephone communications may not be sufficient to
                    ensure that grantees correctly and consistently interpret the requirements.

                    LSC sought to determine the accuracy of grantees’ 1998 case statistics by
                    requiring grantees to conduct self-inspections. However, we do not know
                    the extent to which the results of the self-inspection process are accurate.
                    The validity of the results are difficult to determine because LSC did not
                    standardize the way that grantees were to report their results, some of the
                    grantees used samples that were too small to assess the proportion of
                    error in their data, some grantees did not correctly follow LSC’s reporting
                    guidance, and LSC had done no verification of the grantees’ self-inspection
                    procedures.

                    We do not believe that LSC’s efforts, to date, have been sufficient to fully
                    resolve the case reporting problems that occurred in 1997.

                    We recommend that the President of LSC
Recommendations
                  • clarify and disseminate information on the specific information on client
                    assets that grantees must obtain, record, and maintain;




                    Page 19                              GAO/GGD-99-183 LSC Case Reporting Problems
                    B-283551




                  • clarify and disseminate information on the types of citizenship/alien
                    eligibility information grantees must obtain, record, and maintain for
                    clients who receive legal assistance only over the telephone;

                  • clarify and disseminate LSC’s criteria for single recording of cases;

                  • clarify and disseminate LSC’s policy concerning who can provide legal
                    assistance to clients for the service to be counted as a case;

                  • explore options for facilitating correct and consistent understanding of
                    reporting requirements, such as developing and disseminating a training
                    video for grantee staff;

                  • develop a standard protocol for future self-inspections to ensure that
                    grantees systematically and consistently report their results for open and
                    closed cases;

                  • direct grantees to select samples for future self-inspections that are
                    sufficient to draw reliable conclusions about magnitude of case data
                    errors; and finally,

                  • ensure that procedures are in place to validate the results of LSC’s 1998
                    self-inspection, as well as of any future self-inspections.

                    The President of LSC provided written comments on a draft of this report,
Agency Comments     which are printed in full in appendix I. LSC generally agreed with our
                    findings and stated that it intends to implement our recommendations.

                    Concerning the issue of the clarity of case reporting guidance, LSC’s letter
                    stated that LSC is troubled by our finding that some grantees are
                    continuing to have difficulty in this area. LSC’s letter reiterated a point that
                    we made in the report; namely, that the overlap in time between our data
                    collection effort and LSC’s distribution to grantees of a July 1999 program
                    letter intended to clarify client eligibility documentation requirements may
                    have caused some of the executive directors not to factor in the new
                    guidance when they responded to our telephone interview questions.
                    Although, as we state on pages 9 and 10 of the report, some respondents
                    may not have been familiar with LSC’s July 1999 guidance, two
                    respondents told us that they were familiar with the new guidance and that
                    they were still unclear about the requirements dealing with assets. We also
                    state on page 10 of the report that our own analysis indicated that LSC was
                    not consistent in its guidance to grantees on what asset information they
                    needed to obtain from clients. Therefore, we do not believe that grantees’



                    Page 20                               GAO/GGD-99-183 LSC Case Reporting Problems
B-283551




lack of clarity concerning reporting requirements on client eligibility was
due solely to the overlap in the time period of our data collection and
LSC’s distribution of the July 1999 program letter.

With respect to grantees’ lack of clarity about how to determine duplicate
case counting, LSC indicated that it will consider providing additional
guidance to grantees through further revisions to the CSR handbook. LSC
also indicated that it will revise the handbook to clarify the issue of when
legal assistance by nonlawyers can be reported as a case.

LSC also reiterated that it is developing additional methods to supplement
written guidance, including (1) conducting training and technical
assistance, (2) developing case management standards that would detect
and prevent cases from being accepted and reported if the required
eligibility documentation was not obtained, and (3) developing database
queries for grantees to apply to their case management systems to identify
instances where cases lacked required compliance documentation.

Concerning the self-inspection results, LSC noted that its principal purpose
in requiring grantees to self-inspect their 1998 case data was to ensure that
case-reporting guidance was being properly applied. LSC stated that
assessing the accuracy of the 1998 case statistics that grantees submitted
to LSC in March 1999 was a secondary purpose of the self-inspection. LSC
believes that the self-inspection increased grantees’ awareness of reporting
requirements and prompted them to make changes in their case reporting
practices. Indeed, in LSC’s view, the self-inspection requirement resulted
in more program improvements than did the 1999 CSR handbook and other
written guidance issued by LSC because grantees that identified significant
problems were required to take corrective actions. LSC notes correctly
that, in relation to the self-inspection, our report focuses on the accuracy
of LSC’s determination of the number of grantees that certified their data,
and the factors that affected the accuracy of LSC’s estimate of the total
number of closed cases in 1998. Our review focused on the stated goals of
the self-assessment. Although we did not assess whether, relative to LSC’s
other efforts, the self-inspection had a greater effect on grantees’
awareness of and compliance with CSR reporting, we do report that 26
grantees made corrections to their 1998 data as a result of their self-
inspections.

As arranged with your offices, unless you publicly announce the contents
of this letter earlier, we plan no further distribution until 7 days after the
date of this letter. At that time, we will send a copy of the report to the
Chairmen and Ranking Minority Members of LSC’s appropriations and



Page 21                               GAO/GGD-99-183 LSC Case Reporting Problems
B-283551




legislative committees and to Mr. John McKay, the President of LSC. The
major contributors to this report are acknowledged in appendix II. If you
or your staff have any questions concerning this report, please contact me
or Evi L. Rezmovic on 202-512-8777.




Laurie E. Ekstrand
Director, Administration of Justice Issues




Page 22                             GAO/GGD-99-183 LSC Case Reporting Problems
Page 23   GAO/GGD-99-183 LSC Case Reporting Problems
Appendix I

Comments From the Legal Services
Corporation




              Page 24      GAO/GGD-99-183 LSC Case Reporting Problems
                   Appendix I
                   Comments From the Legal Services Corporation




Now on pp. 9-11.




                   Page 25                                 GAO/GGD-99-183 LSC Case Reporting Problems
Appendix I
Comments From the Legal Services Corporation




Page 26                                 GAO/GGD-99-183 LSC Case Reporting Problems
Appendix II

GAO Contacts and Staff Acknowledgments


                  Laurie E. Ekstrand, 202-512-8777
GAO Contacts      Evi L. Rezmovic, 202-512-8777



                  In addition to those named above, Mark Tremba, Kristeen McLain,
Acknowledgments   Jan Montgomery, David Alexander, Barry Seltser, Lemuel Jackson,
                  Brian Lipman, and Walter Vance made key contributions to this report.




                  Page 27                            GAO/GGD-99-183 LSC Case Reporting Problems
Page 28   GAO/GGD-99-183 LSC Case Reporting Problems
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