Pro Bono Innovation Fund grants are subject to the same rules and regulations as other LSC grants. For guidance on the operation and responsibilities of LSC and our grantees, please review Laws, Regulations & Guidance.

Grant Assurances

Grant awards are also subject to Pro Bono Fund grant assurances. View grant assurances from past grant cycles:

• 2017 Pro Bono Innovation Fund Grant Assurances
• 2016 Pro Bono Innovation Fund Grant Assurances
• 2015 Pro Bono Innovation Fund Grant Assurances
• 2014 Pro Bono Innovation Fund Grant Assurances

Budget Modifications

Organizations that are awarded funding from the Pro Bono Innovation Fund must obtain prior written approval for changes to the funding portion of the project budget when either

1. cumulative changes exceed the greater of 10 percent of the total grant amount or $10,000 or
2. an individual item adjustment exceeds 20 percent of the affected budget line item and represents a change of at least $5,000.

The funding portion of the project budget is Column A on the project budget template. Cumulative changes of less than $10,000 and individual line item adjustments of less than $5,000 do not require approval.

If you make any request to modify the budget, you must email the grant administrator. Current grant administrators are Mytrang Nguyen and Meredith Horton. Requests cannot be made by anyone other than the grantee, and your email should include

1. a description of budget change needed
2. reason(s) for the budget change
3. a revised project budget reflecting the change

The grant administrator will notify you of whether your request has been approved or has not been approved. If your budget modification request has been approved, a modified budget will be saved in our online grants application system.

In the event that an expense has been incurred that is different from the approved project budget, you must immediately contact the grant administrator and seek approval of the modifications.

Conflicts of Interest Policy

You agree that you and your staff have reviewed and will comply with the Conflicts of Interest Policy. You are also required to

• distribute the Conflicts of Interest Policy to the persons covered by it
• ensure that the persons covered by the policy sign the Conflict of Interest Disclosure Form
• maintain, in a single location, these forms and written updates to them with a statement of the resolution of each conflict situation with documentation of the decision/resolution of the conflict, including a statement about the whether the transaction involved is or is not in the best interest of your organization

Your board of directors shall serve as the final interpretive and enforcement authority for you with respect to this Conflicts of Interest Policy. LSC retains the ultimate authority to determine whether your organization's actions comply with the requirements of this policy.

Program Integrity Requirement

Like all LSC grantees, Pro Bono Innovation Fund grantees must comply with the LSC program integrity requirement, 45 CFR Part 1610.8, that they maintain objective integrity and independence from any organization that engages in LSC-restricted activities.

Grantees will structure, monitor, and maintain any Pro Bono Innovation‐funded collaborations with non-LSC legal aid providers consistent with maintaining overall program integrity. Additionally, grantees 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 the project activities.

Third-Party Contracts

Third-party contracts involving Pro Bono Innovation Fund grants can raise several compliance considerations.
You should review the following resources before contracting:

• Grant Assurances
• Program Letter 10-03
• External Opinion 2002-2008
• Property Acquisition and Management Manual
• Sample request for proposal

Grant Assurances

The grant assurance on contracting sets forth additional requirements when your legal aid organization enters into contracts for services. This applies to all 2014 and 2015 grants.

All procurement transactions must be conducted in a manner to provide, to the maximum extent practical, open and free competition. All third-party expenditures, regardless of cost, must be appropriately documented and are subjected to 45 CFR Part 1630.

The grant assurance also includes requirements for grants where your organization expends more than $3,500 of Pro Bono Innovation Fund grant dollars on a single contract for goods provided or services to be performed by a third party that is not otherwise subject to the LSC Property Acquisition and Management Manual.

Program Letter 10-03

Program Letter 10-03, Third-Party Contracting of TIG Funds, provides guidance on requirements for third-party contracts made by our grantees with Technology Initiative Grant funds and is also applicable to Pro Bono Innovation Fund grants.

The guidance set forth in the Program Letter does not represent a change in LSC policy. It is intended to serve as a reminder to our grantees about existing requirements and to provide additional examples of how these requirements are likely to apply in the Pro Bono Fund and Technology Initiative Grant context.

External Opinion 2002-2008

The Office of Legal Affairs External Opinion 2002-2008 discusses rules respecting subgrants and transfers in the context of TIG-funded statewide website activities.

The external opinion sets forth some examples and guidance regarding whether third-party contractor activities that might arise on a website project could qualify as subgrants.

Property Acquisition and Management Manual

The Property Acquisition and Management Manual governs the use of LSC funds, including Pro Bono Innovation Fund grants, to acquire, use, and dispose of real and nonexpendable personal property.

Our grantees that least or purchase equipment or property over $10,000 must obtain the required approval in advance of the purchase or lease.

If your organization is applying for grant funding, you may include the approval request and supporting documentation in your grant application.

Sample Request for Proposal

Issuing a request for proposal ensures that contracts are awarded competitively and that your organization obtains best value for the services and/or equipment required.

A sample document assembly RFP from our Technology Initiative Grant can be utilized by legal aid organizations seeking vendors for similar document assembly initiatives. Sections of the sample RFP may also apply to a broader range of technology projects.

No Cost Extensions

Pro Bono Innovation Fund grants are issued for 18 or 24-month project periods. Your organization may request a one-time, no-cost extension if you cannot complete your project before the end of the grant term.

The grant term is defined as the period of time your organization has to complete a Pro Bono Innovation Fund project and all associated grant reporting. Email the grant administrator if you are requesting to extend the grant term. You must provide supporting reasons and a revised project date when project activities will cease and the final report will be submitted.

Requests to extend a grant term must be made prior to the end of the grant term. A no-cost extension may be requested when the following conditions are met:

• The end of the grant term is approaching.
• There is a programmatic need to continue project activities.
• There are sufficient funds remaining to cover these activities during the extended period.

The grant administrator will initiate any amendments to the grant agreement, which will go through an approval process within LSC that could take several weeks. We ask that you consider this in your planning when you make this request.

Please note that a no-cost extension does not automatically extend the term of any subgrant funded under the Pro Bono Innovation Fund grant.

Termination Policies & Procedures

Pro Bono Innovation Fund grants can be terminated for four reasons:

1. By default, if the grantee fails to provide required documentation on time, unless LSC, in its sole discretion, provides a written waiver or extension.
2. By modification or withdrawal when the grantee and LSC agree that the grant or project should end early by mutual consent.
3. By termination based on LSC concerns about grantee performance.
4. By default, if the grantee ceases to be an LSC grantee.

In situations one and four, the grant automatically terminates and closeout procedures will be initiated for the grant. This includes the consideration of what funds, if any, will be provided for any activities 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 the above reasons, your organization agrees that it will

• work with LSC staff to close out the grant
• provide a final accounting of grant funds
• provide a lessons learned report detailing why the grant failed
• return any unspent funds

Grants Terminated through Failure to Provide Required Documentation on Time

When a grantee is overdue for a reporting deadline by more than 30 days, LSC will issue 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 of 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 the appeal 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:

• 60-day termination notice when reporting is 30 days past deadline. The grant is suspended.
• 30-day termination notice when reporting is 60 days past deadline.
• Termination notice sent by the Office of Program Performance director if deficiencies are not cured within 30 days of the 30-day termination notice. This notice informs the grantee of the right to appeal this decision within 15 days by filing a Notice of Appeal with LSC.
• The grantee has an additional 15 days to submit a written response or request a meeting with LSC's president.
• LSC's president issues the final decision on whether to terminate the grant.

Grants Terminated by Mutual Consent

At any time during a grant term, LSC and the grantee can agree to terminate the grant by mutual consent.
Closeout 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 Office of Program Performance director and the LSC president.

Grants Terminated Based on Performance

LSC may terminate the grant based on concerns regarding grantee performance.

We will provide the grantee with at least 30 days advance written notice of the proposed termination along with the basis for such a decision. Notices of termination will be issued by the Office of Program Performance director.

The grantee may submit a written response to the notice and request a meeting with the Office of Program Performance director to discuss the proposed termination. The director will issue a final decision on whether to terminate the grant. 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 LSC president. The president's decision will be in writing and is final.