Legal Services Corporation
For 25 Years, America's
Partner For Equal Justice
PROGRAM LETTER 2000-6
Board of Directors
Douglas S. Eakeley
John N. Erlenborn
Hulett H. Askew
LaVeeda M. Battle
John T. Broderick, Jr.
F. Wm. McCalpin
St. Louis, MO
Maria Luisa Mercado
Nancy H. Rogers
Thomas F. Smegal, Jr.
San Francisco, CA
Ernestine P. Watlington
This Program Letter is to provide guidance regarding submission for LSC approval of subgrant agreements for the year 2001.
Announcement of 2001 LSC grant awards is not expected until the first week of December, 2000; however, the subgrant approval process established in 45 C.F.R. Section 1627.3(a)(2) allows 45 days for LSC's review of proposed subgrant agreements. In order to meet this time line and to avoid disruption of subrecipient activities, applicants who contemplate entering into a subgrant agreement which has a January 1, 2001 commencement date should submit their subgrant approval requests without awaiting the announcement of their 2001 grants.
The time line established in 1627.3(a)(2) requires that subgrants with a January 1, 2001 commencement date be submitted to LSC for approval by November 15, 2000. However, in view of the timing of the funding process, we will consider any subgrant agreement received by December 1, 2000 to be submitted timely for a January 1, 2001 effective date.
Until further notice, we will continue the same procedures for approval of 2001 agreements as were used for the 2000 agreements and will use the same Subgrant Agreement Form used in 2000. Also included in this package are a 2001 Budget Form and a Subrecipient Profile Form which must accompany each request for approval of a subgrant agreement. To obtain approval, recipients should submit two fully executed copies of the agreement. In addition, recipients should ensure that an audit for each of their 2000 subgrants has been submitted to the Office of the Inspector General in accordance with the terms of the 2000 subgrant agreement.
To facilitate and expedite the review of your request for approval of 2001 subgrants , you are encouraged to use the Subgrant Agreement Form enclosed. If you do not use the Subgrant Agreement Form, your proposed agreement should, at a minimum, include the substance of the provisions in that form and must include the Budget Form and Subrecipient Profile Form, if it is to be approved.
In addition to 45 C.F.R Part 1627, subgrants are also affected by 45 C.F.R. Part 1610. This is the regulation designed to implement statutory restrictions on the use of non-LSC funds by LSC recipients. Section 1610.7 (c) is particularly relevant, which provides:
"For a transfer of LSC funds to bar associations, pro bono programs, private attorneys or law firms, or other entities for the sole purpose of funding private attorney involvement (PAI) activities pursuant to 45 C.F.R. Part 1614, the prohibitions or requirements of this part shall apply only to the funds transferred."
Since the accuracy of CSR reporting is critical, recipients must ensure that each subgrantee has a copy of the 1999 LSC CSR Handbook-Revised and that subgrantees comply fully with the CSR reporting guidelines.
Please contact Jay Brown, Program Analyst, at (202) 336-8828, if you have any questions regarding this memorandum.