Learning Lab

LSC's New 1610 Program Integrity Compliance Guidance (Issued August 26, 2022) - Everything You Always Wanted to Know and More!

This session will feature four LSC panelists discussing the content and application of LSC's new Program Letter 22-3 which seeks to provide more detailed guidance to LSC grant recipients on how they can maintain objective integrity and independence from organizations that engage in LSC restricted activity. The session will be moderated by the Director of LSC's Office of Compliance and Enforcement with the goal of helping attendees understand the history and background information of the regulation, the factors that LSC examines when it conducts a program integrity review, and best practices LSC grantees can implement to ensure program integrity.

  • To provide more detailed guidance to LSC grant recipients on how they can maintain objective integrity and independence from organizations that engage in LSC restricted activity.
  • To help attendees understand the history and background of the regulation, the factors that LSC examines during program integrity reviews, and best practices grantees can implement to ensure program integrity.
  • To provide information to LSC grant recipients about how LSC conducts Program Integrity reviews and enforces the regulation.

Carolina Caicedo, Esq.

Program Counsel III, Office of Compliance and Enforcement

Legal Services Corporation

Carolina Caicedo is a Program Counsel with the Legal Services Corporation's Office of Compliance and Enforcement. Carolina joined LSC in 2018 and is responsible for a compliance oversight portfolio consisting of 10 LSC grantees. She leads and participates in compliance reviews, provides guidance to grantees to ensure compliance with the LSC Act, regulations, and other implementing authorities, conducts investigations of potential violations, and makes recommendations for program compliance improvements. Carolina also develops and conducts training and technical assistance reviews for grantee staff to help bolster grantee compliance. She currently serves on the LSC Program Integrity Working Group and was Co-Chair of LSC’s Diversity, Equity, and Inclusion Committee (2020-2021). Prior to joining LSC, Carolina was Director of Legal Advocacy at the American Diabetes Association where she oversaw a program that provided legal advice and advocated for the rights of individuals living with diabetes in the areas of employment, education, public accommodations, and in correctional facilities. Carolina began her legal career as a Staff Attorney at Georgia Legal Services Program where she represented clients in civil legal matters in the areas of family law, housing, access to public benefits, eviction prevention, farmworkers rights, and access to education.

Shila Mashhadishafie, Esq.

Program Counsel III, Office of Compliance and Enforcement

Legal Services Corporation

Shila Mashhadishafie is a Program Counsel within the Legal Services Corporation’s Office of Compliance and Enforcement. Shila joined LSC in 2006 and often serves as team leader of the review teams responsible for assessing compliance with the LSC Act and implementing authorities. Shila’s areas of expertise within OCE are in Program Integrity; use of non-LSC and LSC funds (45 CFR Part 1610) and Cost Allocation (45 CFR Part 1630). She also serves as the Chair of the Program Integrity Working Group and served as lead trainer for Executive Director Orientation Webinars, and new OCE program counsels and temporary employees. Prior to joining OCE, Shila was a Senior Prosecutor in the Narcotics Division at the Office of the State’s Attorney for Baltimore City. Shila served as the Chair of the Partners for Justice Conference Planning Committee and as a Board Member for the Pro Bono Resource Center.

Stefanie Davis, Esq.

Deputy General Counsel and Ethics Officer, Office of Legal Affairs

Legal Services Corporation

Stefanie Davis is the Deputy General Counsel for Administrative Law and Regulatory Practice and Ethics Officer in the Office of Legal Affairs (OLA) at the Legal Services Corporation (LSC). Her portfolio includes regulatory drafting and statutory interpretation, managing OLA’s Graduate Law Fellow and internal training programs, and coordinating the work of LSC’s Opioid and Veterans Task Forces. She is the author of the first-ever chapter on access to justice in administrative proceedings in the recently published ABA Guide to Federal Agency Adjudication (3d ed.) and a regular speaker on both access to justice issues and the opioid epidemic. She joined LSC in 2013 from the Office of the General Counsel at the U.S. Department of Health and Human Services. She began her legal career at the Washington Legal Clinic for the Homeless in Washington, DC. Ms. Davis is licensed to practice law in Maryland, the District of Columbia, and New Mexico. She is the president of the New Mexico State Bar Foundation Board of Directors. She is a 2002 graduate of Georgetown University Law Center and holds a Bachelor of Arts in Psychology magna cum laude from the University of New Mexico.

Lora Rath, JD

Director, Office of Compliance and Enforcement

Legal Services Corporation

Lora M. Rath is the Director of LSC’s Office of Compliance and Enforcement (OCE). OCE staff members, including attorneys and fiscal specialists, conduct on-site and desk reviews of organizations receiving LSC funds and also provide training and technical assistance to ensure compliance with the statutory and regulatory requirements, as well as restrictions, that accompany LSC funding. Lora was hired into OCE in April 2001 - serving first as a Program Counsel before being promoted to Deputy Director in 2007 and then to Director in 2012. As a Program Counsel, Lora served as a team member or the team leader on numerous on-site compliance reviews, and in her role as Deputy Director she was responsible for overseeing the 1630 and 1627 review and approval processes. Prior to joining OCE, Lora was the Director of Policy & Planning for the Veterans Benefits Department of Paralyzed Veterans of America, a service organization that advocates for quality health care and benefits for our nation's veterans. She also served as a veterans law specialist at The Veterans Consortium Pro Bono Program.

Joseph Hinkley, CPA

Fiscal Compliance Analyst III, Office of Compliance and Enforcement

Legal Services Corporation

Joe Hinkley is a Fiscal Compliance Analyst in the Office of Compliance and Enforcement at Legal Services Corporation. As a fiscal compliance analyst, Joe provides oversight of compliance with LSC fiscal regulations and provides guidance and assistance to grantees regarding fiscal-related issues. Joe joined LSC in 2021 and has served on the LSC Program Integrity Working Group since joining. Prior to joining LSC, he worked as a contractor at the Transportation Security Administration testing internal controls over financial reporting. Earlier in his career, he worked at KPMG to help conduct financial audits of various federal agencies.

Key:

Complete
Failed
Available
Locked
Evaluation
2 Questions