PROGRAM LETTER 98-6
To: All LSC Program Directors
From: Karen J. Sarjeant Acting Vice President for Programs
Date: July 6, 1998
Subject: State Planning Considerations
On February 12, 1998, the Corporation issued Program Letter 98-1 calling upon all LSC recipients to participate in a state planning process to examine, from a statewide perspective, what steps should be taken in their states to further develop a comprehensive, integrated statewide delivery system. The Letter poses seven questions recipients are to address in their planning processes and requests recipients to submit a report to LSC on or before October 1, 1998. Many recipients have asked LSC to provide further guidance and additional information about how the state planning process will affect LSC grant decisions. Recipients have also inquired about the format for the October 1 report. This Program Letter responds to these requests.
State Planning Considerations
The attached State Planning Considerations have been developed to provide recipients and other stakeholders with more information about statewide goals, capacities and approaches recipients should consider in their planning processes. A number of other sources of information that may assist state planners and upon which these Considerations draw are referenced in the Planning Considerations. We hope these Planning Considerations will help states develop effective plans to strengthen their delivery systems and services to clients. We encourage recipients with any questions about the State Planning Considerations or planning process to contact the LSC staff member responsible for their state.
How the State Planning Process Will Affect LSC Grant Decisions
The Corporation is directed under the LSC Act to "insure that grants and contracts are made so as to provide the most economical and effective delivery of legal assistance to persons in both urban and rural areas."(1). The state planning process will provide information that helps LSC exercise this statutory responsibility.
a. Duration of grants
The state planning process will provide information that helps LSC determine the duration of grants for service areas in the 1999 competition, i.e., service areas that are eligible for grants of up to three years commencing January 1, 1999.
In the 1998 LSC grant competition, we determined that grants in several states that were eligible for three year funding would be made for a shorter period. The decision to award grants for a shorter period was made for two reasons: (1) to encourage recipients in these states to develop further their plans for a comprehensive, integrated statewide delivery system; and (2) concern that the configuration of LSC-funded programs in these states did not constitute the most economical and effective structure for delivering legal services to the low-income community.
As with the 1998 competition, LSC will take into account state delivery plans and configuration of programs in determining the duration of grants for service areas now being competed. Where LSC believes states need to further develop their plans for a comprehensive, integrated statewide delivery system or where LSC remains concerned about the configuration of LSC-funded service areas, grants will be made for less than three years.
b. Service areas
1. 1999 Competition
The state planning process will not affect decisions about the number, size or configuration of service areas in competition this year.
2. 2000 and Future Competition Years
Information received through the planning process will affect future decisions regarding the most appropriate number, size and configuration of LSC-funded service areas to be competed for the year 2000 and beyond. This includes service areas that become scheduled for those years because of one or two year grant awards made in the present 1999 competition.
2. Grant Renewals
The state planning process will not affect decisions about the number, size or configuration of service areas up for renewal or the duration of grant renewals, i.e., previously made multi-year awards which are now up for renewal. Decisions on renewal of these grants will continue to be based upon a showing of the renewal applicant's continued ability "to perform the duties required under the terms of its grant."(2)
Format for the October 1 Report
The attached Instructions for State Planning Reports provide information about the structure and format of the reports due at LSC on or before October 1, 1998. Please contact the LSC staff member responsible for your state if you have any questions.
1 Legal Services Corporation Act, Section 1007(a)(3).
2 45 CFR 1634.11.