Technology Intiative Grants (TIG) are subject to the same rules and regulations as other grants from the Legal Services Corporation (LSC). For guidance on the operation and responsibilities of LSC and its grantees, review the Rules & Regulations page on the LSC website. TIG awards are also subject to TIG Grant Assurances. Grant assurances from past TIG cycles and additional guidance are available below.
The TIG program requires administrative plans for grants where significant portions of project management are contracted out to third parties. (This requirement is not intended to apply where the contracts are primarily for hardware, software, or technical development work.) For any such grant, as identified by LSC staff, the recipient must submit and have approved by LSC an administrative plan that clearly outlines the grantee's duties and responsibilities for financial oversight and audits, project management, contract coordination, evaluation, and reporting. When the grantee is receiving part of the grant as a fee for this administration, the plan will detail who will exercise these duties for the grantee and how the fee was calculated. The recipient will then report on its fulfillment of the requirements of the approved administrative plan throughout the grant term.
If required, a grantee's assigned TIG Grant Administrator must review and approve the administrative plan before the grantee receives the initial payment on its grant. Additionally, grantees report on the administration and oversight activities conducted in accordance with its administrative plan throughout the project.
Current Cycle Policy: The Disclosure of Interest for Determination of Conflicts Policy ("Current Policy") applies to the 2012 and later TIG Award recipients. Each TIG recipient agrees: they understand and will comply with the Policy; that they will distribute the appropriate Policy to the persons covered by the Policy; that they will ensure that the persons covered by the Policy sign the Conflict of Interest Acknowledgement and Disclosure Form ("Disclosure Form"); that they will maintain in a single location these forms and any written updates of them related to new conflict situations, or additional information to correct an inaccurate or incomplete previously signed and provided Disclosure Form; and that they will maintain in that location a statement of the resolution of each conflict situation and confirmation that the decision on the conflict resolution is documented in the board minutes with a copy of such minutes or a reference to where they are located, including whether the transaction involved is or is not in the best interest of the Organization. The recipient’s board of directors shall serve as the final interpretive and enforcement authority for the recipient with respect to this Policy. LSC retains the ultimate authority to determine whether the actions of the recipient comply with the requirements of this policy.
2011 Cycle Policy: For the 2011 TIG cycle, this policy has been updated to the 2011 Disclosure of Interest for Determination of Conflicts Policy ("2011 Policy") and applies to the 2011 TIG Award recipients. 2010 TIG recipients shall continue to follow the 2010 Policy. For both policies, each TIG recipient agrees: they understand and will comply with either the 2010 Policy or the 2011 Policy; that they will distribute the appropriate Policy to the persons covered by the Policy; that they will ensure that the persons covered by the Policy sign the Conflict of Interest Acknowledgement and Disclosure Form ("Disclosure Form"); that they will maintain in a single location these forms and any written updates of them related to new conflict situations, or additional information to correct an inaccurate or incomplete previously signed and provided Disclosure Form; and that they will maintain in that location a statement of the resolution of each conflict situation and confirmation that the decision on the conflict resolution is documented in the board minutes with a copy of such minutes or a reference to where they are located, including whether the transaction involved is or is not in the best interest of the Organization.
These materials will be made available to LSC, including the OIG, and other authorized parties as per the general requirements regarding access to grantee records in applicable laws, regulations, policies, grant assurances and other applicable authorities, and these materials will be retained as per normal retention requirements for LSC grant related documents. Violations of this policy, including failure to identify and resolve these issues in a timely fashion, could result in disallowed costs under 45 C.F.R. Part 1630 as well as other options available to LSC.
TIG recipients, like all LSC grantees, must comply with the LSC program integrity requirement, 45 CFR § 1610.8, that grantees maintain objective integrity and independence from any organization that engages in LSC-restricted activities. Recipients will structure, monitor, and maintain any TIG‐funded collaborations with non-LSC legal services providers consistent with maintaining overall program integrity. Additionally, recipients will have a representative attend a mandatory LSC webinar on the program integrity requirements, if they are notified by LSC that their organization must attend based on the nature of its TIG activities.
Current TIG Grant Assurances require that recipients comply with technology standards developed by the legal aid community.
Third-party contracts involving LSC TIG funds can raise several compliance considerations. Grantees should review the following resources before contracting:
TIGs can be terminated for four reasons:
In situations (1) and (4) the grant automatically terminates and close-out procedures will be initiated for the grant, including the consideration of what funds, if any, will be provided for any milestones of the grant completed prior to the termination of the grant and what funds, if any, will be returned to LSC. When a grant is ended for any of these reasons, the recipient agrees that it will:
For Grantees That Fail to Provide Required Documentation On Time: When a grantee is overdue for a reporting deadline by more than 30 days, LSC will issue to the grantee a 60-day termination notice. This notice informs the grantee that the grant is suspended and will automatically terminate if the grantee does not obtain an extension to the reporting period or file the required report within the next 30 days. If the grantee does not respond within 30 days then LSC will provide a 30-day termination notice. If the grantee fails to respond to the second notice within 30 days of that notice then the grant will automatically terminate. If the grantee appeals the termination and it is denied, then the grant is terminated. A denial of an appeal that results in a termination may be appealed to the next higher LSC official.
The following timeline outlines the steps in the termination process for grantees that fail to provide timely documentation:
For Grants Ending by Mutual Consent: At any time during a TIG grant term LSC and the grantee can agree to terminate the grant by mutual consent. Close-out procedures will be initiated for the grant based on the terms of the termination agreement. Such agreement will be negotiated with the Grant Administrator and subject to approval by the LSC OPP Director and President.
For Grants Terminated Based on Peformance: LSC may terminate the grant based on concerns regarding grantee performance. LSC will provide the grantee with at least 30 days advance written notice of the proposed termination along with the basis for that decision. Notices of termination will be issued by the OPP Director. The grantee may submit a written response to the notice and request a meeting with the OPP Director to discuss the proposed termination. The OPP Director will issue a final decision whether or not to terminate the TIG. That decision may be appealed to the LSC President. The grantee has 15 days to file a notice of appeal and an additional 15 days to submit a written response. The grantee may also request a meeting with the President. The President’s decision will be in writing and is final.