# Notice of Revisions to Performance Area Four of LSC's Performance Criteria
**AGENCY:**
Legal Services Corporation.
**ACTION:**
Notice of revisions to guidelines.
**SUMMARY:**
To provide grantees with the most effective guidance, in 2018 the Legal Services Corporation revised Performance Area Four to refine and expand the areas of inquiry to focus on those criteria for which LSC has found the most deficiencies, particularly Criteria 1 (Board Governance), 4 (Financial Administration), and 7 (General Resource Development). The 2018 revisions codify the work of LSC staff with numerous grantees and provide evidence-based guidance to recipients on how to run a high-performing nonprofit organization.
**FOR FURTHER INFORMATION CONTACT:**
Lynn Jennings, Vice President for Grants Management, Legal Services Corporation, 3333 K Street NW, Washington, DC 20007, (202) 295-1645, *[email protected].*
**SUPPLEMENTARY INFORMATION:**
LSC's Performance Criteria indicate that legal services programs should be led and managed effectively with high-quality governance, administrative systems, procedures, and policies. Good leadership and strong internal operations increase the likelihood of effective program services for clients.
Over the past several years, LSC has observed some areas of weakness in grantee governance through performance quality visits, compliance reviews, and Office of Inspector General (OIG) visits. The 2018 revisions codify the work of LSC staff with numerous grantees and provide evidence-based guidance to recipients on how to run a high-performing nonprofit organization.
Since 2010, LSC's Office of Program Performance has conducted 133 Program Quality Visits of 124 grantees. LSC issued 1,901 Tier One [^1] recommendations across the reports summarizing those visits. Of the 1,901 Tier One recommendations, 695 recommendations—36.5%, the most of any performance area—pertained to Performance Area 4. From 2011 to 2016, LSC's Office of Compliance and Enforcement conducted 111 Compliance Reviews of 106 grantees. LSC issued more than 1,200 Required Corrective Actions (RCAs) related to both regulatory and fiscal issues. Approximately 25% of the RCAs identified deficiencies in the grantees' financial administration. Additionally, OIG conducted 41 A-50 reviews between June 2012 and September 2017. As a result of those reviews, the OIG made 160 referrals to OCE. The referrals covered issues related to timekeeping, deficiencies in policies and procedures, cost allocation, and internal controls.
[^1] According to LSC's Office of Program Performance Procedure Manual:
• Tier One Recommendations are those recommendations that are determined to be significant and will be included in the next Request for Proposal to the grantee.
• Tier One Recommendations are those that *if addressed,* have the potential for significantly improving program quality and/or program performance within the short term, *i.e., two years.*
A Tier One Recommendation must:
• be stated in simple straightforward terms such that there is no doubt by the program that a response is required; and
• have an objective, the value of which equals or outweighs any additional burden that the recommendation imposes on the program (does not apply to statutory or regulatory requirements).
This is the background against which LSC evaluated the existing criteria for Performance Area 4. The statistics above gave LSC valuable information about which areas of grantee administration, leadership, and governance needed more rigorous evaluation.
These Performance Criteria are guidelines for ensuring high program quality. They are not requirements. They reflect best practices to which programs should aspire and which they should, to the extent possible and consistent with program resources, attempt to achieve. These revisions do not reflect a change in the purposes of the Performance Criteria stated in the Introduction to the 2007 revised version. The purposes of the Performance Criteria are twofold. First, the Performance Criteria “guide LSC's assessments of program performance generally and in the competitive grants process.” Second, the Performance Criteria serve as a “useful framework for internal program self-evaluations, planning, and program development, as well as external peer reviews and expert assessments by other funding sources.”
LSC will begin using the revised Performance Area 4 on June 1, 2018. LSC management recognizes that it may take time, guidance, and experience for all grantees to adjust to the revisions. LSC will, therefore, provide training and forums to discuss the implementation of the changes. When conducting program assessments, LSC staff will take the scope of the revisions and each program's capacity into consideration when making recommendations.
As the table below indicates, LSC reorganized the order of the Performance Criteria. The current Criterion 3—Overall Management and Administration—includes a limited review of a grantee's technology infrastructure and administration. To more accurately reflect the role technology plays in the daily operations of an organization and in providing efficient and effective client services, LSC proposed creating a separate, new technology criterion, Criterion 3: Technology Infrastructure and Administration. The criterion for Overall Administration and Management would now be Criterion 6, with Internal Communication being folded into the proposed Criterion 6.
| Current ordering of Performance Area 4 Criteria | 2018 Revised ordering of Performance Area 4 Criteria |
| --- | --- |
| Criterion 1: Board Governance | Criterion 1: Board Governance |
| Criterion 2: Leadership | Criterion 2: Leadership |
| Criterion 3: Overall Management and Administration | Criterion 3: Technology Infrastructure and Administration |
| Criterion 4: Financial Administration | Criterion 4: Financial Administration |
| Criterion 5: Human Resources Administration | Criterion 5: Human Resources Administration |
| Criterion 6: Internal Communication | Criterion 6: Overall Management and Administration |
| Criterion 7: General Resource Development and Maintenance | Criterion 7: General Resource Development and Maintenance |
*Criterion 1. Board Governance.* The program articulates a clear mission for the organization. Each board member demonstrates commitment to the program and its mission through consistent engagement in Board activities that involve all other board members. The board effectively engages in strategic organizational planning with program leadership and staff. It is responsible for major policy decisions, while holding organizational management accountable for effective performance of their responsibilities. The board assists with or oversees, as appropriate, the organization's efforts to develop and maintain resources. The board also promotes public awareness of the program in the community in a manner that aims to enhance the program's overall effectiveness and influence.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| As a whole, the board is appropriately diverse and representative of the various geographical areas and low-income populations served by the program | • Is the board membership diverse and representative of the service area? |
| The size of the board is conducive to effective oversight | • Is there evidence that the board's size facilitates the effectiveness of its operation? |
| When determining board tenure, the board struck a balance between longevity and board experience and the need for new ideas and insights | • What is the tenure of each of the board members, including the board chair(s)? |
| The board has processes and procedures for recruiting and orienting new board members | • Does the board have and follow established policies and practices regarding recruitment, qualification and retention and engagement of new members? |
| | |
| The board's committees structure promotes effective oversight of the organization | • What is the board's committee structure? |
| | |
| The board fulfills the meeting requirements of LSC regulations | • The board of directors meets at least four times a year. |
| The board has quorum requirements that are adhered to | • Is the board required to reach a membership attendance quorum before it can take formal action? |
| The board and committee meetings are well planned and focused to ensure that the board and its committees can carry out their oversight function | • Are there pre-circulated agendas for all board and committee meetings? |
| Meeting materials | • Do individual members feel that the board packets distributed in the board and committee meetings provide them with useful information about the program and equip them to participate meaningfully in the board or committee meeting? |
| Executive session | • Do board meetings include an executive session without any staff (including the executive director)? |
| The board members are engaged and regularly attend and participate in board and committee meetings | • What is the level of attendance at board and committee meetings? |
| Board and committee decisions are appropriately documented | • Are board decisions appropriately documented in board minutes? |
| | |
| The board and members individually, are committed to the program and its mission. The board properly discloses and manages any organizational or personal conflicts | • Is the board supportive of the program? |
| | |
| The board ensures that the program establishes and adheres to effective strategic planning | • Does the board adopt a mission statement, that has been collaboratively developed with management? |
| | |
| The board is involved in major policy decisions, aware of issues in and performance of the program, while leaving day-to-day management of program operations to program management personnel | • How are major policy decisions made? |
| | |
| The board exercises effective financial oversight | • Are board members aware of and accurate in their perception have a general understanding of the requirements of the program's funding sources. |
| Ensure funds are used for intended charitable purposes, and funds are appropriately accounted for | • How often does the board review financial statements and do they understand what the financial statements say? |
| The board safeguards investments | • Are policies in place to evaluate the organization's investment decisions and performance? |
| | |
| The board effectively evaluates the chief executive officer or executive director | • What is the process for evaluating the Executive Director and other top officers in the organization? |
| The boards practices appropriate oversight over the Executive Director's Compensation plan | • Is there a process for reviewing and setting executive compensation? |
| | |
| The board effectively promotes and expands the reach and influence of the program in the communities it serves | • Do individual members, including client members, speak on behalf of the organization to external audiences at appropriate opportunities? |
| | |
| The board effectively promotes and expands the reach and influence of the program in the communities it serves, and develops additional resources for the program | • Do board members assist effectively in fundraising and development activity? |
| The board ensures that the program is in compliance with state and local laws related to solicitation | • Has the organization adopted policies to ensure compliance with federal/state laws on solicitation of funds? |
| The board ensures donations comply with LSC Requirements | • Donations are properly recorded pursuant to LSC regulations |
| | |
| The board is committed to continuous improvement | • Does the organization maintain and provide its board members with an up-to-date board handbook or on-line resources? |
| | |
| The board ensures legal and ethical integrity and maintains accountability | • Does the board adopt and regularly evaluate a code of ethics that describes behaviors it wants to encourage and behavior it wants to discourage? |
| The board ensures transparency and accountability by making information available to the public on the program's mission, activities, finance and governance | • Are the program's Form 990 and annual report reported on its public website? Are these documents available to the public upon request? |
| The members of the board exercise independent judgment in general board decision-making | Is there evidence that board members engage in independent analysis of materials and information provided to them? |
*Criterion 2. Leadership.* The program has effective leadership that establishes and maintains a shared sense of vision and mission. Program leadership means a commitment to and achievement of the program's goals and objectives according to a model that emphasizes teamwork, transparency, excellence, effectiveness, efficiency, and innovation.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| Key program staff, starting with the executive director or chief executive officer, are respected and recognized as the program leaders | • Starting with the chief executive officer, are there recognized, positive, and effective leaders in the program? |
| Program leaders hold themselves accountable for motivating staff, and for promoting an environment that embraces mentoring and the professional development of all staff, helping them to achieve their fullest potential | • What specific leadership and professional development training and activities has the program provided? |
| Key staff are appropriately involved in decision-making processes | • Does the program's leadership seek the opinions and input of staff and other stakeholders in its decision-making processes? |
| The program's leadership demonstrates strong, effective communication skills and the capacity to engage in positive conflict resolution | • Beginning with the executive director or chief executive officer, is there evidence that the leadership of the program communicates effectively with the board, staff and community stakeholders? |
| | |
| Program leaders frame a vision and mission | • Is there a shared sense of vision and mission? |
| Program leaders model a high level of energy, commitment and integrity in carrying out the program's mission | • What mechanisms does the program's leadership use to measure program effectiveness and adherence to the mission and vision? |
| | |
| Starting with the executive director or chief executive officer, the program values and embraces diversity and provides opportunities for the development of a diverse group of leaders | • In what ways does the program and its leadership demonstrate inclusion and an appreciation for diversity? |
| | |
| The program has a leadership succession plan that addresses preserving institutional knowledge and strong leadership across all levels of program management | • Does the program have a clear and reasonable succession plan? |
Criterion 3. *Technology infrastructure and administration.* The program provides a stable and secure technology infrastructure sufficient for staff to work efficiently and effectively in the delivery of legal services and to support the operations of the organization. It devotes appropriate resources to provide the capacities outlined in LSC's “Technologies That Should Be in Place in a Legal Aid Office Today.”
| Indicators | Areas of inquiry |
| --- | --- |
| Technology planning is ongoing and integrated into the overall strategic plan of the program, includes staff input, and is reviewed and updated at least annually | • Who is involved in technology planning? |
| The program has competent IT staff and/or consultants with appropriate training and certifications to properly maintain and support its technology systems | • What type of network does the program have? |
| The grantee informs employees of their rights when using grantee-owned computers | • Does the grantee have a warning banner that appears while employees are logging on and notifies employees of their rights when using their grantee-owned computer? |
| The program devotes appropriate resources to establish and maintain its technological infrastructure, including planning and budgeting appropriately for ongoing replacement/upgrades of its technology systems | • What is the internet bandwidth in each office (any redundant connection available)? |
| The program has a proper written IT security program to include robust IT security policies and procedures regarding protecting client and case data, ensuring the security and integrity of passwords, use of the Internet and social media, policies for the use of mobile devices, and if staff can bring their own devices (BYOD) to access work documents. Staff are familiar with and follow such policies and procedures | • Is server equipment kept in a secure environment with appropriate ventilation and cooling? Are IT systems currently patched and updated? |
| The program has sufficient procedures to back up its data and has testing protocols to demonstrate that data recovery/protection policies work in practice | • What are the backup procedures? |
| The program stays informed of new technology developments and how it can make better use of technology to meet its mission | • What is the replacement cycle for technology equipment (desktops/laptops, servers, printers, scanners, copiers, telephones, etc.)? |
| | |
| Maximum use of technology is made to facilitate and enhance internal communication | • Does the program use technology effectively to enhance the efficiency of program operations and service delivery? |
| | |
| Program staff are provided with appropriate training on the use of technology | • Does the program have a policy for the secure use of its technology, including protecting data (including Personally Identifiable Information), use of the Internet and social media, password policies and if/when staff can bring their own devices? |
*Criterion 4. Financial administration.* The program has and follows financial policies, procedures, and practices that comport with Generally Accepted Accounting Principles (GAAP), requirements of the program's funding sources, and comply with federal, state and local government regulations. The program has established sound internal controls and conducts effective budget planning and oversight.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| The program has detailed written policies and procedures describing its financial operations which comply with all applicable requirements. The program follows such policies and procedures | • Is the program's accounting manual current and updated as appropriate? |
| The program has sufficient, capable, trained and effective staff dedicated to financial administration | • How many financial staff does the program have? |
| Top management and the governing body are actively involved in the budgeting process. The budget is updated periodically and changes/variances are reviewed. The program engages in financial planning beyond the current year | • Is the budget consistent with the program's mission, goals, and objectives? |
| The program maintains LSC funds held for immediate operating expenses in federally-insured bank accounts | • Does the recipient adhere to LSC Investment Guidelines? |
| | |
| The recipient's governing body has fulfilled its fiduciary responsibility to the program through the establishment of a financial oversight committee or committees. The financial oversight committee(s) has at least one member who is a financial expert or the board has access to a financial expert | • Has the board established a financial oversight committee or committees that perform the roles of a finance committee and an audit committee? |
| The governing body regularly determines the compensation of the program's Executive Director | • Does a governing body set and review the compensation of the Executive Director using an independent compensation consultant, comparable pay studies from other nonprofit organizations, and/or a compensation survey? |
| The Executive Director's expenses are approved by a member of the board | • Are there procedures in place that require approval of the Executive Director's expenses by a member of the governing body? |
| | |
| The program issues accurate financial statements on a timely basis | • Are the audited financial statements submitted to LSC in accordance with the LSC Audit Guide for Recipients and Auditors? |
| Executed one-time grants, such as TIG and PBIF awards, are reported separately in the program's audited financial statements in accordance with 45 CFR 1628.3(e) | • Are executed one-time grants, such as TIG and PBIF awards, reported either as a supplemental schedule of related revenue and expense or a separate column within the financial statement? |
| Annual program audits do not reveal any significant problems or issues; where such items have been identified, the program addresses them effectively and promptly | • Do past audits or outside reports and evaluations reflect problems? |
| | • Are audit findings repeated from one fiscal year end to the next in the audited financial statements? |
| | |
| The recipient has established and maintains adequate accounting records and internal control procedures. which is designed to provide reasonable assurance of achieving the following objectives: (1) Safeguarding of assets against unauthorized use or disposition; (2) reliability of financial information and reporting; and (3) compliance with regulations and laws that have a direct and material effect on the program | • There is sufficient segregation of duties. |
| | |
| The program has a contracting policy to prevent abuse, limit waste of scarce funds, and prevent possible questioned cost proceeding | • Does the program have a contracting policy? |
| | |
| The program has robust policies and safeguards in place to prevent fraud | • Assess the organization's segregation of duties. |
| | |
| The program's disbursements are approved in writing by an authorized individual | • Are procedures adequate to provide that salary and wage rates are approved by an authorized individual and employees are paid in accordance with approved wage and salary plans? |
| The program's criteria and procedures for purchases are documented | • Is there a procedure for proper payment and approval of expenditures at an appropriate level of management? |
| | |
| The program has established internal control procedures related to cash receipts | • Is initial accountability for cash established as soon as a cash item is received? |
| The program maintains a client trust fund and accounting system to account for funds held on the client's behalf | • Has the program established a method to determine the balance for each client trust account? |
| | |
| A physical inventory of property purchased with LSC funds is conducted at least once every two (2) years and the results are reconciled with property records | • Is a physical inventory conducted at least once every two (2) years? |
| The program has established adequate internal controls to safeguard its petty cash funds | • Is there a surprise count of petty cash conducted periodically? |
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| The program has established adequate procedures related to the subgranting of LSC funds to ensure compliance and proper fiscal oversight | • Does the subgrant agreement or contract with the sub recipient specify financial reporting responsibility? |
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| The program maintains fidelity bond coverage at a minimum level of at least ten (10) percent of the program's annualized LSC funding level for the previous fiscal year, or of the initial grant or contract | • Does the program carry at least the minimum level of fidelity bond coverage for fraud and employee dishonesty as described in 45 CFR Part 1629? |
| The program carries adequate fidelity bond coverage for all staff required to be bonded | • Does the program carry fidelity bond coverage for all staff required to be bonded: Every director, officer, employee and agent of a program who handles funds? |
| | |
| The program's accounting software is appropriate to support the operations and financial oversight of the organization | • Does the program use up-to-date technology to enhance efficient financial operation? |
| The program limits access to its accounting software | • Does the program limit access to its accounting software? |
*Criterion 5. Human resources administration.* The program promotes organizational excellence through the recruitment, management, and retention of a high-performing, diverse workforce consistent with its mission and goals. The program develops and communicates sound policies and procedures that ensure compliance with applicable federal, state, and local laws and has a knowledgeable, accessible, and professional staff to the program in the areas of recruitment and retention, training, professional development, compensation and benefits, performance appraisal, and organizational governing personnel development.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| The program has sufficient, capable, trained, and effective professional staff assigned to human resources administration | • Who is responsible for the human resources functions within the program? |
| The program has an employment handbook or manual with policies on hiring, supervision, promotion, compensation, and termination that are in compliance with applicable federal, state, and local laws | • Does the program have an employment handbook or manual with human resources policies? |
| The program engages in human resources planning and policies are reviewed periodically | • How often are the policies reviewed and updated? |
| The program maintains accurate and timely personnel files and protects the confidentiality of personnel records as required by applicable law and contract | • Where are personnel files kept? |
| The program has a document retention policy for personnel files and that policy is adhered to by managers | • Does the program have a document retention policy for personnel files? |
| | |
| The program has a capable, culturally competent, and diverse staff | • What is the current composition of the staff? |
| The program has a comprehensive recruitment strategy that employs a variety of methods and sources to recruit highly qualified candidates | • What are the program's recruitment practices? |
| The program has a formal orientation process for all new hires | • Is there a new hire orientation and is the orientation period defined? |
| The program is able to forecast and determine its human resource needs and tracks fluctuations in the workforce, including turnover rates | • What is the rate of turnover in the program? |
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| The program has a compensation and benefits structure that promotes staff recruitment, retention and professional development | • What are the program's fringe benefits and retention policies, such as a loan repayment assistance program, retirement plans, health insurance, and other financial and non-financial benefits? |
| The program periodically assesses salaries, employee benefits, bonuses and COLAs | • Does the program regularly review its compensation structure and benefits? |
| | |
| The program conducts regular and effective evaluations of all staff | • Does the program conduct performance evaluations or appraisals? |
| The program leverages its budget appropriately for training opportunities that would benefit its entire staff | • What training is available to staff? |
| The program conducts ongoing training for all staff on program policies, procedures, technology, and in substantive legal areas and advocacy skills | • Is there a formal, ongoing training for employees and managers (e.g., procedures, policies, technology, substantive legal areas)? |
| The program provides effective training for management and administrative staff | • Does the program provide effective leadership and management training and support to mid-level supervisors and personnel engaged in administration and management? |
| The program regularly conducts cultural competency training for all staff | • Is there cultural competency training for all staff? |
| | |
| To the extent that there are or have been serious morale or other internal personnel problems, the program is addressing or has addressed them effectively, and is taking or has taken appropriate steps to prevent their recurrence | • What is the recent history and current status of staff morale? |
| The program has developed a process to address internal complaints, suggestions, and feedback | • Does the program have a process accepting and resolving employee grievances? |
| Program offices are professional and provide adequate space for conducting the program's work | • Are program offices professional? |
*Criterion 6. Overall management and administration.* The program is well managed and administered: Including management structure; processes and systems to ensure compliance with all funder requirements and state and federal law; capacity to address problems quickly and effectively, robust intra-staff and staff-management communications; effective administrative procedures; allocation of appropriate resources to management functions; and periodic evaluations of administrative operations.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| The program devotes appropriate resources to management | • Does the program devote an appropriate level of resources to management and administration? |
| The program has a management structure that effectively uses middle managers | • How many middle managers are there? |
| The mix of program staff (managers, case handlers, and administrative staff) maximizes program resources to ensure the effective and efficient delivery of client services | • Has the program made considered choices regarding the proportionality of non-advocacy staff as compared to case handlers, consistent with program resources, number of case handlers, and type of work? |
| The program allocates appropriate resources to internal compliance | • Does the program have a compliance officer (or someone who serves in that role) to ensure compliance concerns are reported and managed effectively and efficiently? |
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| The program makes major decisions in a way that incorporates relevant information and input | • What is the program's decision making process? |
| The program has procedures for obtaining input on significant decisions, and for resolving complaints and problems effectively and timely | • Do staff feel that their input is sought on significant decisions? |
| The program's administrative structure, processes, and systems support compliance with state and federal laws, rules, and regulations | • Is there any evidence of non-compliance with state and federal laws, rules, and regulations? |
| The program's administrative structure, processes, and systems support compliance with funder requirements | • Is there any evidence of non-compliance with funder requirements? |
| | |
| The program has developed and regularly updates an emergency plan to maintain operations and to minimize disruption in the event of an emergency | • Does the program have a plan in the event of an emergency or disaster? |
| The program has a plan for providing client services in the event of a disaster or emergency affecting its client community | • Does the program have a plan for providing client services in the event of a disaster or emergency affecting the client population? |
*Criterion 7. General resource development.* Consistent with the program's mission, the program seeks to maintain and expand its base of funding with the goal of enhancing program services and organizational sustainability. The program implements a strategy designed to identify funding sources to advance the mission and goals of the program.
| Indicators | Areas of inquiry |
| --- | --- |
| | |
| The program has attempted to develop, and to the extent possible, has effective relationships with other major institutional resources in the service area that are involved or might be able to provide some support in the provision of legal assistance to eligible clients, as well as help in expanding program funding | • Who are the program's other major funders? |
| The program has sufficient, capable, trained, and effective staff dedicated to resource development, or uses consultant(s) or other organizations to supplement or lead that effort | • Who is responsible for the resource development efforts within the program? |
| The program has delineated responsibilities for resource development staff and communication (if applicable) staff | • How are the resource development activities integrated with the program's external communication efforts? |
| The program has engaged the board and staff in resource development and has provided adequate training | • Are staff and board actively engaged around resource development efforts? |
| | |
| The program has a written plan describing its strategy to ensure that the program is supported by sufficient financial resources consistent with its mission | • Does the program have a written resource development plan, and is resource development a part of its overall strategic plan? |
| The program has a diverse funding stream and continually explores opportunities for increased funding | • Has the program achieved diversity in funding: federal, state, local governments; individual donors; law firms; foundations; bar campaigns, restricted/unrestricted gifts? |
| The program is innovative in trying to develop new sources | • What tools does the program employ to engage new and existing donors? |
| The program uses former and existing clients and former board members as a part of its funding efforts | • Does the program engage former clients in its funding efforts? |
| The program sponsors events and activities to recognize its individual donors and supporters | • Does the program host donor recognition and cultivation events? How often? |
| | |
| The resource development plan has been approved by the board, is reviewed annually, and is consistent with the program's budget | • Is the cycle of organizational budgeting in line with the resource development plan? |
| The program has a process to evaluate cost effectiveness of resource development activities | • How does the program evaluate the cost effectiveness? |
| The program has carefully evaluated whether the requirements of prospective funding sources are consistent with the program's mission, goals, priorities, objectives, and strategies | • How does the program decide the priorities for funding? |
| The program has developed a system to track donor gifts and other funding. This system is integrated with other systems including the accounting software | • How does the program track gifts from donors and other funding sources? |
| The program monitors its efforts to ensure that its mission is being communicated accurately and clearly to potential donors and funders | • What efforts does the program make to ensure that its mission is being communicated accurately and clearly to the potential donors and funders? |
| The program seeks both monetary and in-kind support from donors, corporations, and other funders | • What is the mix of support the grantee receives from various donors? |
*Criterion 8. Coherent and comprehensive delivery structure.* Overall, the program management maintains a delivery structure and approach that effectively utilizes and integrates staff, private attorneys, and other components; emphasizes innovation and creativity in delivery; is informed by current information concerning delivery research; is well-suited to meeting the most pressing legal needs of the service area; and, given available resources, constitutes an effective and economical balancing of expenditures on the various functions and activities described in the four Performance Areas.
| Indicators | Areas of inquiry |
| --- | --- |
| The program has a reasonable, thoughtful and effective overall delivery system, which utilizes and integrates staff, private attorneys, volunteers, branch offices, outreach, and alternative delivery methods, and which strikes an effective balance on key issues such as specialization, experience of staff, use of attorneys and paralegals, and other major design choices | • Does the program have in place and regularly use systems to gauge the efficiency and effectiveness of its overall delivery system? |
| The program's choices about allocation of resources to competing activities and functions are reasonable and balanced, and consistent with its mission, goals, priorities, objectives, and strategies | |
*Criterion 9. Participation in an integrated legal services delivery system.* The program participates in, and seeks to expand and improve, statewide (and regional if relevant) legal assistance delivery systems to achieve equal access to justice and to meet the civil legal needs for low-income persons in the state.
| Indicators | Areas of inquiry |
| --- | --- |
| The program participates in statewide (and regional if relevant) efforts to provide low-income persons in the state with equal access to a full range of civil legal assistance services in all forums | • Is the program engaged in statewide efforts (and regional efforts if relevant) to achieve the availability of a full range of civil legal assistance in all available forums? |
| The program participates in local, statewide (and regional if relevant) efforts to maximize the effective use of available human and financial resources and to increase such resources to better address the civil legal needs of the state's low-income populations | • Is the program engaged in statewide efforts (and regional efforts if relevant) to utilize existing financial and human resources effectively and efficiently? |
| The program coordinates with other providers, the bar, law schools, and other relevant entities in seeking to ensure that support is provided to advocates and managers, including training, dissemination and exchange of information, and communication and coordination among practitioners in key areas of law and practice | • Is the program engaged in statewide efforts (and regional efforts if relevant) to provide support to advocates and managers, including training, dissemination and exchange of information, and communication and coordination among practitioners in key areas of law and practice? |
| The program participates in statewide planning and oversight activities to achieve an integrated statewide delivery system, and coordinates and collaborates with other civil legal aid providers, private attorneys, government and corporate attorneys, the organized bar, courts and court personnel, law schools, and other public and private entities that provide legal and other social services to low-income persons | • As part of its efforts to expand access, provide a full range of services, maximize resources, and ensure support within the state, does the program coordinate and collaborate with other civil legal aid providers, private attorneys, government and corporate attorneys, the organized bar, courts and court personnel, law schools, and other public and private entities that provide legal and social services to low-income persons? |
Dated: March 27, 2018.
Stefanie K. Davis,
Assistant General Counsel.