Client Board Member Eligibility

Note: This policy was recommended by the the LANC Board of Directors' Client Eligibility Ad Hoc Committee and adopted on February 25, 2005 by the Legal Aid of North Carolina Board of Directors.

Client Board Member Eligibility

Persons desiring to serve as client representatives to the LANC Board of Directors stand for client elections or are appointed for vacant seats on the Board pursuant to LANC policies and bylaws, and subject to LSC regulations. LSC Regulation 1607 requires that Client Board members be financially eligible to receive legal services at the time they are elected or appointed to serve on the Board. In order for the Board to follow the regulation, nominees to the Board must be screened for financial eligibility prior to election. Nominees will therefore be required to disclose personal financial information as if applying for the provision of services. The Board members are not trained to undertake such screening, and it would be inappropriate for Board members to review the personal financial information of nominees to the Board. This policy is intended to provide a mechanism for the Board to fulfill its duty of ensuring compliance with the LSC regulations while maintaining the strictest confidentiality of the information nominees provide for screening purposes.

Policy

Persons who are being considered for appointment or election as client representatives to the LANC Board of Directors shall be informed by their respective electing or appointing organization or body (the "Sponsor"), prior to accepting nomination, of the requirement of financial eligibility and the necessity of providing personal financial information for use in determining financial eligibility. Such prospective nominees shall be informed that the financial information provided will be seen and reviewed only in accord with this policy.

The Sponsor shall provide prospective nominees desiring to serve as client representatives to the LANC Board of Directors a copy of this policy and shall provide the prospective nominee with the name and contact information of the Assistant Director for Compliance (the "ADC"). If after reviewing this Policy the prospective nominee wishes to be considered for election or appointment to the Board, the prospective nominee shall contact the ADC to arrange to be screened for financial eligibility to receive legal services. The prospective nominee shall be afforded the choice of being screened either by the ADC or by the Regional Manager in the service area in which the prospective nominee resides ("local screening"). In either event the prospective nominee shall be required to provide only the information which would normally be gathered and considered in an actual application for the provision of legal services in the service area in which the prospective nominee resides.

If the prospective nominee chooses local screening, he or she shall make contact with the appropriate Regional Manager, submit to the intake procedures designed to guarantee the highest degree of confidentiality, and if determined to be financially eligible will inform the Regional Manager that the determination should be reported to the ADC. The information submitted by the prospective nominee shall be recorded but not maintained by the local program. Instead, the candidate's financial eligibility information shall be transmitted to the ADC and be recorded and maintained by the ADC as provided below for eligibility screenings done by the ADC.

If the prospective nominee chooses to be screened by the ADC, the ADC shall obtain from the prospective nominee the information which would normally be gathered and considered in an actual application for the provision of legal services in the service area in which the prospective nominee resides.

The ADC shall record the information, on a paper form only, which form shall provide a place for the prospective nominee to indicate the accuracy of the information. The ADC shall then promptly mail or deliver a copy of the form to the prospective nominee. If accurate the prospective nominee shall so indicate and return the form to the ADC, and the ADC shall then determine from such information whether the prospective nominee is financially eligible to receive legal services ("1607 eligible"). If the information is not accurate the prospective nominee shall correct the information in writing on the same form, confirm the accuracy of the corrected information, and return the corrected form to the ADC, who shall then determine from such corrected information whether the prospective nominee is 1607 eligible.

If the ADC or the Regional Manager determines that prospective nominee is 1607 eligible, the ADC shall promptly in writing inform the prospective nominee, their Sponsor, and the Chair of the Nominating Committee. The ADC shall retain the original form and the copy on which the prospective nominee confirmed the accuracy of the information used in the determination, and shall take reasonable measures to safeguard the documentation until returned to the prospective nominee in accord with this policy.

If the ADC or the Regional Manager determines that prospective nominee is not 1607 eligible, the ADC shall promptly in writing inform the prospective nominee and their Sponsor, and inform each of the procedure provided for appeal of the initial eligibility determination, which shall be the same procedure available to actual applicants for legal services, except that no appeal will lie to the Board or any committee of the Board.

If at any point the prospective nominee fails to timely appeal a determination that she or he is not financially eligible to receive legal services, or exhausts their appeal rights under this policy, or the prospective nominee or their Sponsor withdraws the prospective nominee from consideration for election or appointment to the Board, the original form and the copy on which the prospective nominee confirmed the accuracy of the information used in the determination shall be returned to the ADC who shall take reasonable measures to safeguard the documentation until the ADC determines that any right of the prospective nominee or their Sponsor to initiate a grievance or further appeal to LSC has expired, at which time the ADC shall destroy the forms.

If at any point the prospective nominee is determined to be 1607 eligible, the forms shall be returned to or retained by the ADC, who shall take reasonable measures to safeguard the documentation until the later of the date on which the prospective nominee is withdrawn from consideration for appointment or election to the Board, or fails to be appointed or elected to the Board, or is appointed or elected to the Board, completes the term for which the 1607 determination was made, and the ADC has determined that the documentation is no longer needed for the purpose of showing compliance with LSC Regulation 1607, at which time the ADC shall destroy the forms.

No personal information regarding the 1607 eligibility of any prospective nominee is to be communicated in any manner to the Board or any person except in execution of the procedure set out herein, unless upon the express permission of the prospective nominee. Access to the 1607 eligibility information of those prospective nominees seeking seats on the Board is strictly limited to those persons executing the procedure set out herein and shall not be communicated or used for other purposes without the express permission of the client. Information regarding client representative eligibility shall be retained no longer than necessary to satisfy LSC audit requirements.

 

 

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Legal Aid of North Carolina is a statewide, nonprofit law firm that provides free legal services in civil matters to low-income people in order to ensure equal access to justice and to remove legal barriers to economic opportunity.

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