CLASP-NLADA Comment on Part 1611-Financial Eligibility Ju…

COMMENT ON NOTICE OF PROPOSED RULEMAKING PART 1611 – FINANCIAL ELIBILITY SUBMITTED BY THE CENTER FOR LAW & SOCIAL POLICY ON BEHALF OF THE NATIONAL LEGAL AID AND DEFENDER ASSOCIATION June 14, 2005 These comments are submitted to the Legal Services Corporation (LSC) by the Center for Law and Social Policy (CLASP) on behalf of the National Legal Aid and Defender Association (NLADA). NLADA is a membership organization that represents civil legal services programs, including those funded by LSC. CLASP serves as counsel to NLADA. On May 24, 2005, LSC published a Notice of Proposed Rulemaking (NPRM) in the Federal Register (70 FR 29695) for Part 1611 (Financial Eligibility) of the LSC regulations. The NPRM seeks comments on the proposal. Comments are due on June 23, 2005. The current NPRM is the product of a multi-year effort that began with a negotiated rulemaking (reg-neg) process initiated in 2001 when LSC convened a reg-neg working group consisting of representatives from NLADA, CLASP, the ABA’s Standing Committee on Legal Aid and Indigent Defense (SCLAID) and numerous field program representatives, as well as representatives of the LSC staff and the LSC Office of Inspector General (OIG). The full reg-neg group held three two-day meetings between January and April 2002 that resulted in a NPRM that was published for notice and comment in November 2002. The LSC Board was scheduled to review the comments and adopt a final ...