Other Services Reporting
Starting in July 2001, all of our grantees began collecting information on non-case activities. LSC had long noted that our grantees provide referrals and community legal education, that they engage in outreach, and that they work cooperatively with other groups to address the needs of the low-income community.
In an October 4 memorandum, LSC announced the name change of the Matters Service Report to the Other Services Report. This was a name change only, not a substantive change. The name change was adopted to provide a more understandable description of these important activities.
Other services are defined as non-case services. Through other services reporting, legal aid organizations collect data on legal services provided to the low-income community other than services provided as part of the work performed on accepted cases. Other services are defined in 45 CFR Part 1620.2(b) and consist of the following:
- community legal education, including such activities as presentations, workshops, and the publication of brochures and newsletters on topics affecting low-income people
- pro se assistance, including courthouse help desks, pro se workshops, self-help materials kits and web-based self-help services
- referrals, including direction of applicants to other legal aid providers, private lawyers, social agencies, and community organizations
- outreach, including informational notices published in print media, TV spots, radio PSAs, and referral agreements with other agencies
- indirect services, including legal training to non-legal advocates who work with low-income people, such as social workers, teachers, and ministers
- other services, including mediation and ADR, and direct non-case services such as notarizing a document
Frequently Asked Questions
- Summary of Changes for Reporting 2011 Other Services
Summary of Changes for Reporting 2011 Other Services
Question 1 - The Other Services Report (OSR) has been greatly changed for 2011. Can you summarize the areas of change?
Answer 1 - For 2011, we are substantially reducing the scope of the Other Services Report (Form M). First, we are entirely eliminating Part B (which reports other services by type, parallel to the CSR). We seldom are asked for those kinds of breakdowns, do not use them for our own analyses, and feel that we can dispense with your reporting of this information. In addition, because we collect media reports on all of our grantees through electronic news services, we have concluded we can eliminate reporting of number of media items and newsletter articles. We are also eliminating Part VI (Miscellaneous Other Services), and non-statistical Parts IV Outreach) and V (Indirect Services).
The current best practice on measurement of Internet services is "unique visitors," as opposed to page views. We are therefore substituting a much simpler count of unique visitors to each program’s website(s) for the three current subsections that collect Internet page views with all the attendant detail; this one subsection is placed in Community Legal Education (CLE),and we no longer will ask you to try to separate CLE from Pro Se for this category.
We are adding one new subsection – the number of downloads of web items, separated into downloads of Community Legal Education items and downloads of Pro Se items. We believe that this will supply a more solid count of people actually assisted by this service and that programs have this information readily available.
While Form M has three remaining parts (Community Legal Education, Pro Se, and Referral) we have combined the three "pages" on which the information for these Parts is to be entered into one "page", so you will be able to make all your entries for Other Services in one place.
Question 2 – Why have you changed from counting "Page Views" to counting "Unique Visitors"?
Answer 2 – First, the purpose of the change is to collect a more conservative measurement of the number of persons being reached. We are aware this number will be a lot lower than the numbers we have been receiving. We are also aware that no measurement is anywhere near perfect, especially one that all programs can implement without adding a significant new burden. "Unique Visitors" is a widely used and accepted standard; it can be tracked easily by virtually all web analytic software, and we have adopted it for that reason.
Question 3 – What are the rules for counting "Unique Visitors"?
Answer 3 – The time period for measuring Unique Visitors is the calendar year, since this is the reporting period. Accordingly, someone who is a visitor in 2011 can be counted again when they visit in 2012. We cannot measure the number of different people who might use the same computer. Some computers are used by many people but will only be counted once. In the future, we may find a method that is not burdensome to collect better data and avoid this problem, but, as we are instituting this change for 2011 data as part of the simplification of Form M, we need a clear, simple and widely-recognized criterion for now.
Question 4 – How do we count items on Statewide websites?
Answer 4 – Currently, programs allocate the Page Views for their Statewide websites by a formula (such as relative poverty population or which program posted the material). Any such formula should be applied in the same way to the Unique Visitor data as it has in the past been applied to Page View data from Statewide websites.
Question 5 – You have added a new category of "downloads" to the OSR. What should we count as a download?
Answer 5 – An activity is considered a download when a user copies data, usually a file, from your website to his/her own computer or other viewing device. Any form, document, brochure, presentation or other file downloaded from the site to a computer counts.
Viewing a video or listening to an audio file is not a download and does not count.
If an item is printed out, that action can be counted as a "download", even though it isn’t technically a download, because the purpose of this category is to capture items that we know a person has actually taken for further use. We are, however, aware that, in most circumstances programs will not be able to detect whether an item is printed out and therefore will not be able to count printed out items.
Question 1 – Do we have to have documentation of the Other Services that we perform?
Answer 1 – The notation that the Other Service was performed in your case management system, data base, intake log or comparable record is sufficient.
Question 2 – What should we base our numbers on?
Answer 2 – You should be reporting solid counted numbers or reasonable estimates. If it is doubtful or if there is a question how many Other Services to count, you should err on the conservative side.
Question 3 – Can Other Services be reported regardless of funding source?
Answer 3 – Yes.
Question 4 – With the CSRs, we can report cases for eligible clients even if they are funded with non-LSC funds. Can we do the same with Other Services?
Answer 4 – If the activities reported are generally targeted towards eligible clients, they are reportable as Other Services, irrespective of the source of the funding. There is no eligibility checking for Other Services, although activities reported should be oriented toward and intended to assist eligible clients.
Question 5 – Do we have to count the Other Services performed by sub-grantees? What about those done by PAI programs?
Answer 5 – We would like you to collect all the Other Services information you can collect. If, in your best judgment, it is too burdensome to collect Other Services information in certain circumstances, then you don’t need to do it.
Question 6 – My program has been reporting certain non-case assistance in OSR Form M, Section VI, Direct Services. These services are: (a) individual assistance provided by a program paralegal to homeless persons in completing applications for other social and community services (e.g., handicapped transportation, health clinics, food stamps, etc.) – these services go beyond mere referral, but are not being counted as cases because no specific legal advice is being provided; and (b) individual assistance provided by our staff Social Worker to victims of domestic violence in completing applications to the Crime Victims Compensation Fund and providing crisis counseling at bi-weekly evening legal advice clinics, but this section has been discontinued. How do we handle such services?
Answer 6 – To the extent these services go beyond referrals and are significant in your work, they should be discussed in your Form L, Narrative. With the reduction and streamlining of the OSR Form M, there is no longer another place to report the number of these services.
Question 7 – Our program has a grant that allows the agency to provide Advice & Counsel and Limited Action to residents of a tri-county area who are slightly over LSC income eligibility (not funded by LSC or reported on CSRs to LSC). Do you want these reported as Other Services?
Answer 7 – Please do not report these activities in the Other Services Report. Although Other Services may be reported irrespective of client eligibility issues, the activities in question are not Other Services but cases. Cases may be reported only in the CSR's. Since these cases are not eligible for CSR reporting, they should not be included in any reports to LSC.
Question 8 – Do we use a separate report to keep track of any Other Services done by a PAI program, or do we combine them?
Answer 8 – For Other Services, we do not separate PAI from staff, so you should combine them.
Question 9 – When an intake specialist makes a referral or mails CLE materials to a client who has also received Advice& Counsel or Limited Action, and the CLE is on a different problem from the one advised about, can we count the CLE materials distributed or referral made?
Answer 9 – Yes. Whenever a referral or a mailing of CLE materials is for a problem different from the problem on which a client has received Counsel & Advice or Limited Action, the referral or CLE can be counted as an Other Service.
Question 10 – Must the codes we use to record Other Services in timekeeping correspond to the new LSC Other Services codes?
Answer 10 – No. All we require for an Other Services timekeeping entry is that it indicate it is for an Other Service. Some case management systems allow you to break down Other Services activities on time slips into specific activities, but that is not something LSC requires.
Although you need not change your codes in the timekeeping section to correspond to the LSC Other Services Codes, you may want to do so to avoid confusion for your staff. They may find it less confusing if the entries on the time slips and the entries on the Other Services slip are the same for the same activity.
Question 11 – Do we need to use the Other Services Codes to track Other Services for individuals? Our time keeping system captures much of this information without using the Other Services Codes.
Answer 11 – We created the Other Services Codes to make it easier for the programs to collect the data and report it to us. If you can accurately collect the data on Other Services and report it to LSC in the format we have requested without using the Other Services Codes, that is fine.
Question 1 – In calculating the "number of people receiving the service", do you want us to count only the person to whom we provide the service, or do you want the number of people in the household?
Answer 1 – You should count only the number of people receiving the service.
Question 2 – As part of our statewide planning, we distribute pamphlets of several other legal services programs. Do we count those pamphlets even though no LSC dollars were spent in producing them?
Answer 2 – Yes. You can count any pamphlets distributed to the general target population in your service area, regardless of the source of funds and regardless of whether you produced them or only distributed them.
Question 3 – I see that we can report "Measured" or "Estimated" numbers of Other Services. How do we decide which to say?
Answer3 – Any Other Services you have counted should be reported as "measured." Any additional Other Services that you have not counted but for which you have a reasonable basis for estimation should be estimated. The counted number plus the estimated number makes up the total for each model of each type of Other Services as reported under Section A, "Models Used."
Question 4 – We have had some difficulty in deciding when to count an Other Service as "Measured" or "Estimated", particularly in the areas of brochures. Is there any further guidance on this question?
Answer 4 – The following are guidelines with respect to legal education brochures. "Measured" and "Estimated" should be broken out along the lines of whether or not the program has direct control over the distribution of brochures. Following are some examples:
- Brochures that are distributed by the program in response to enquiries from the public.
- Brochures that are picked up at one of the program’s offices by visitors to the office.
- Brochures handed out at a community legal education meeting.
- Brochures dropped off in bulk for distribution at the local bar association, law school clinics or other community service organizations, in the event no one there counts them and/or returns the extras.
- Brochures left on tables at community legal education events and not collected afterward or counted.
Program personnel should use their discretion when counting brochures as "measured" or "estimated," using the above examples as guidelines. The principal distinction is the degree of control one has in ensuring that the brochure actually got into the hands of an interested citizen. In those cases it can be counted as "Measured." Less certain conveyances can be counted in "Estimated."
Question5 – Our web site is an integral part of a web site for all the legal services programs in our state. There is a common page that includes client education pamphlets. Someone could get to that site to read/download a pamphlet from our home page or from the home page of any of the other programs. How do you want us to count the page views?
Answer 5 – First, we are no longer counting "page views", but only unique visitors and, separately, downloads. You should work out a system to apportion and report web site unique visitors and page downloads that works most easily for you. There are two likely models for a statewide web site: (1) A common page (such as a site sponsored by the bar association) that has some materials and links to individual program sites; (2) A common site with information about all of the programs and content supplied by the programs, but no program has an individual site.
For model 2, you might take the total number of unique visitors, and apportion them among the partners by poverty population in the service area, or by program funding, or in some other reasonable manner. For model 1, you might apportion unique visitors to the common site in a similar manner as for 2, then add to that the unique visitors to the individual site. The same methods should be used for apportioning downloads.
Look at your situation and come up with a reasonable formula that works for you without being too burdensome.
Question 6 – What about the detail of the counting? For example, is it worth the trouble to provide the number of brochures distributed?
Answer 6 – One factor to consider is the burden of getting the information. If for example you can easily determine the number of brochures distributed (number of brochures printed minus the number of brochures left) please do so. In other instances, a count will be more complex and an estimate should be used. Count the information you can reasonably count, estimate what can reasonably be estimated and omit anything that cannot be counted or reasonably estimated.
Question 7 – Many of our program’s handbooks provide both basic legal information and self-help guidance. For example, our Renters Handbook describes the rights and responsibilities of landlords and tenants. It also provides detailed assistance for establishing a Warranty of Habitability claim under our state law. Many who receive this handbook are not financially eligible for LSC-funded services and so we would report these individuals as "Other Services" not "clients." Conceivably, we could differentiate the count by the reason for sending the handbook, but this would add another layer of complexity to the tabulation scheme. I'm assuming we can count these distributions in either category.
Answer 7 – You can count these distributions under either CLE or Pro Se; this is a judgment call as to which more accurately describes the assistance. You can also split them up, but, as you said, we do not want to add another level of complexity by asking you to track why the publication was sent out. You cannot report them as CSRs. However, you can report an activity as a CSR if a case handler has reviewed the person’s specific problem and rendered legal advice to the person along with the item distributed.
Question 8 – Our program receives grants from the United Way and other sources to print comprehensive handbooks such as the Renters Handbook. We distribute several thousand each year. Local social service agencies often ask for several hundred at a time. Can we count these?
Answer 8 – Yes, distributions in response to block requests can be counted. If you are uncertain if all of the handbooks provided in response to the block requests are distributed, you should report them under "Estimated" rather than "Measured" as discussed in Program Letter 02-9.
Question 1 – When an intake specialist makes a referral or mails CLE materials to a client who has also received Advice & Counsel or Limited Action, and the CLE or referral reiterates or supplements the advice given, do we count that CLE?
Answer 1 – For the CLE materials, we would interpret the mailing to be part of the Counsel & Advice or Limited Action, so it should not be counted separately. However, we do not want programs to expend any significant effort on this duplication issue. Therefore, if it is known at the time of entry that there is a CSR case, the CLE should not be entered, but we do not require that you check your Other Services against your CSR's to ferret out such instances.
For the referral if the case is closed as Counsel & Advice or Limited Action (CSR Categories A or B), the referral may be reported separately as an Other Service.
Question 2 – If we provide a legal presentation at a senior citizens meals site and distribute a brochure on the topic of the presentation as well as one that's unrelated to the presentation, can we count both "people" and "paper?"
Answer 2 – While we are not requiring duplication checking, you should avoid reporting methods that tend to run up numbers by counting more than Other Service for the same activity. Accordingly, you should count either "people" or "paper," but not both.
Question 3 – Some of our attorneys volunteer their time to run pro se divorce clinics. Participants are not screened for eligibility. May we count attendance at these? If we refer an individual to such a clinic, can we count this as a referral to "other source of assistance"? Does it matter that the referred individual may not be financially eligible for LSC-funded assistance (even if divorce without violence were within our case service priorities)? Obviously, if we count both the number who attend such clinics and those referred, duplication will exist to the extent that some people who are referred actually attend.
Answer 3 – If the activity is an activity of your program, you can count it. It is unclear from the question whether this is an activity of your program or just one that your personnel volunteer for. If it is an activity of your program, you can count the attendees as Other Services, presumably under pro se. If it is not an activity of your program, you can count the referred individuals as referrals. You should not do both. In general, if an activity is an activity of your program, you cannot count referrals to it, but you can count it under other types of Other Services.
Question 1 – Do we have to have documentation of eligibility information for Other Services?
Answer 1 – No.
Question 2 – If a person referred is definitely ineligible (we've done eligibility check and he turns out to be over income), do we count the activity (usually referral)?
Answer 2 – Yes. You may still count it as an Other Service.
Question 1 – Where there is a referral to more than one source, do you count it as one referral or multiple referrals?
Answer 1 – When you are doing a case and giving a referral, you can count both the case and the Other Service – the referral. As for multiple referrals if they are given out on one call to one individual, it still counts for only one referral. However, if the person should call another time and another referral is given at that time, it would count as a second referral.
Question 2 – We have an eligible client, we give advice, we also give a referral in the same problem code. For example, in a landlord-tenant case, we advise clients on whether they can withhold rent. We also refer them to private attorney for possible affirmative suit because attorney's fees are available. Do we report the referral?
Answer 2 – This is a case and should be counted as such, CSR Category A. The referral may also be reported as an Other Service. There are other instances in which you can report an Other Service for the same client for whom you report a case. For example, you could give Limited Action or even Settlement Without Litigation on a landlord-tenant issue involving nonpayment of rent and then refer the client to a city or state housing agency for financial assistance.
Question 3 – What about a referral where we don’t have a name or other information about someone calling in? They describe the situation and the intake worker knows immediately that a referral is appropriate and gives them the referral?
Answer 3 – This counts as a referral that is an Other Service. You don’t need the name of the caller for an Other Service (although you do need it for any CSR case).
Question 4 – On the Other Services service report for "Referred, not included in case service statistics," items 1 and 2, it appears that we do not count any referrals as Other Services from the legal services program to the PAI program. Is that correct?
Answer 4 – Yes, that is correct.
Question 5 – We have always tracked non-case referrals as calls come in, using an on-screen pop-up list of agencies. On the Referrals section of the Other Services Report, it is unclear to me which category certain referrals should go into.
Answer 5 – We do not expect too much time to be spent determining exactly into which category referrals fall. Whichever one in your judgment most nearly describes the referral should be used. Responses to specific questions are given below.
Question 5a – I am assuming that referrals to the IV-D Child Support Enforcement office would fall into the "Referred to other provider of civil legal services to low income people" even though they serve people of all income levels. Is that correct?
Answer 5a – Yes, that is correct because this best describes the referral.
Question 5b – In which Referrals category should referrals to the District Attorney's office or the Public Defender's office for Criminal Other Services be?
Answer 5b – This should be classified as 4 – Referred to other source of assistance, none of the above.
Question 5c – Several advocacy agencies to which we refer people have no lawyers, but assist clients with filing public benefits appeals or represent them at administrative hearings, such as Food Stamp fair hearings. Should we categorize them as "Referred to provider of human or social services (non-legal)," or "Referred to other provider of civil legal services to low-income people," or "Referred to other source of assistance, none of the above?"
Answer 5c – Even though they have no lawyers, the most descriptive classification is 1 – Referred to other provider of civil legal assistance.
Question 5d – We make many referrals to the clerks of various courts. Which Referral category should we use for this? "Referred to other provider of civil legal services to low income people"? "Referred to other source of assistance, none of the above"?
Answer 5d – This should be 1 – Referred to other provider of legal assistance.
Question 5e – We also make a lot of referrals to regulatory/enforcement agencies, such as the Worker's Compensation Board, the Human Rights Commission, the state Department of Labor, the Wage and Hour Board, the Insurance Policyholders Complaint Division, and the Consumer Affairs Division. Which referral category should we use for them?
Answer 5e – This is best described as 4 – Referred to other source of legal assistance.
Question 5f – I am assuming that referrals to the Equal Employment Opportunity Commission would fall into the "Referred to other provider of civil legal services to low income people," since they do have attorneys who would represent the client if they believe the complaint has merit. Is that correct?
Answer 5f – We agree.
Question 6 – Through our hotline service (like other programs throughout the country) we routinely refer callers to the private bar, another legal source if available, and one or more social service agencies. LSC seems to want us to track with specificity the type of referral. When all three referrals are made, what is the preferred coding choice? Would it be possible to add a code for multiple referrals?
Answer 6 – You just pick the coding for the one you consider the most significant. In the OSR, all such choices are the judgment of the program and LSC will not be second-guessing them. We have not seen sufficient demand for a "multiple referral code" to justify making this change.
Question 1 – We deliver quite a few types of service that used to be reportable in Form M of the OSR, but the streamlined OSR no longer has a place to report them. How can I report these services?
Answer 1 – For any type of service that you used to report in Form M of the OSR that you can no longer report, you should discuss it in the narrative Form L if it you consider it to be of significance in delivery of services to low-income people. If you do not consider the item of significance, there is no need to report it.
Question 2 – My program has over 110 projects which would fall into the areas of "other indirect service Other Services" or "collaborative service delivery models." From my reading of the instructions, I am to describe these projects as well as describing methods of estimating clients, other pro se activities, and other outreach activities. And it appears that I must do so in 300-1000 words. In addition to the description, you would like stories regarding these projects, or at least some of them. How am I to do this and stay within the word limit?
Answer 2 – The narrative portion of your Other Services Service Report should be 300-1000 words. It is not expected to address each project, but briefly to address each type of service, so there is no expectation of describing or even listing each project. Thus you would discuss what your program is doing in the area of economic development under "indirect service" Other Services and what else the other 32 indirect service projects are doing.
As for the vignettes, this is Section B of the narrative and is separate from and not included in the 300-1000 words length of Section A. The request is for two to five vignettes from among all your types of Other Services. There is no expectation of completeness here and, indeed, you are not even required to select an indirect service for one of these vignettes. As for estimation methods, this is Section C of the narrative and is, again, separate.
Thus, what you are asked to do in Section A is simply an overview of services provided, as the title says, touching on each of the three types of Other Services (if you have all three), Community Legal Education, Pro Se, and Referrals. You can also describe any activities you find especially significant in the areas formerly included in Form M – Outreach, Indirect Services, and Other. There is no request for a listing of all projects anywhere in the Other Services reporting package.