Legal Services Corporation 

Performance Criteria 

April 2006 

(This version does not include references to the ABA Standards for Providers of 

Civil Legal Services to the Poor)

LEGAL SERVICES CORPORATION 

PERFORMANCE CRITERIA

TABLE OF CONTENTS 

• Introduction to the 2006 Edition of the LSC Performance Criteria ........................... 3 

• Performance Area One. Effectiveness in identifying the most pressing civil legal 

needs of low-income people in the service area and targeting resources to address

those needs. ....................................................................................................................... 7 

Criterion 1. Periodic comprehensive assessment and ongoing consideration 

of legal needs.............................................................................................. 9 

Criterion 2. Setting goals and objectives, developing strategies and 

 allocating resources .................................................................................. 11 

Criterion 3. Implementation......................................................................................... 13 

Criterion 4. Evaluation and adjustment........................................................................ 14

• Performance Area Two. Effectiveness in engaging and serving the low-income 

population throughout the service area. ..................................................................... 15 

Criterion 1. Dignity and sensitivity.............................................................................. 16 

Criterion 2. Engagement with the low-income population .......................................... 18 

Criterion 3. Access and utilization by the low-income population .............................. 19 

• Performance Area Three. Effectiveness of legal representation and other program 

activities intended to benefit the low-income population in its service area............. 21 

Criterion 1. Legal representation.................................................................................. 23 

Criterion 2. Private attorney involvement.................................................................... 30 

Criterion 3. Other program services to the eligible client population.......................... 31 

Criterion 4. Other program activities on behalf of the eligible client 

 population ................................................................................................. 33

LSC Performance Criteria 1 
• Performance Area Four. Effectiveness of governance, leadership and administration. ........................................................................................................................... 34 

Criterion 1. Board governance ..................................................................................... 36 

Criterion 2. Leadership ................................................................................................ 37 

Criterion 3. Overall management and administration .................................................. 38 

Criterion 4. Financial administration ........................................................................... 40 

Criterion 5. Human resources administration .............................................................. 41 

Criterion 6. Internal communication ............................................................................ 43 

Criterion 7. General resource development and maintenance........................................ 44 

Criterion 8. Coherent and comprehensive delivery structure....................................... 45 

Criterion 9. Participation in an integrated legal services delivery system ................... 46

LSC Performance Criteria 2 
INTRODUCTION 

 2006 EDITION 

 LEGAL SERVICES CORPORATION PERFORMANCE CRITERIA 

These introductory comments explain the background and purpose of the Performance Criteria

that follow. This edition of the Criteria is based on earlier versions first developed for the Legal Services 

Comparative Demonstration Project during 1993 and Legal Services Corporation peer review evaluations 

during 1994, and then for LSC program reviews and its competitive grants process from 1995 to the 

present. 

This revision to the Criteria is a key part of the Legal Service Corporation’s (LSC) overall quality

initiative, a multi-pronged strategy with a goal of ensuring that all Legal Services programs provide high 

quality legal assistance.1

 The LSC will continue to use the Criteria to guide LSC’s assessments of 

program performance generally and in the competitive grants process. The LSC has statutory

responsibility to ensure the provision of economical and effective delivery of legal assistance by Legal 

Services programs to eligible persons in all parts of the country, including U.S. territories.2

 Consistent

with that obligation, the Criteria are designed to guide the examination of Legal Services programs that 

provide comprehensive legal assistance to low income persons in a geographical service area, including

limited and full representation and other forms of legal services. In addition, the Criteria are designed to

provide the basis for evaluation of Legal Services programs that, through a state planning process are

designated as providers primarily of limited assistance, such as intake or hotline operations in connection 

with a comprehensive delivery system that provides a full range of services, including full representation. 

For purposes of LSC’s evaluations, Legal Services programs that primarily provide limited representation

are subject to the requirements of Performance Areas One, Two and Four, as well as the relevant portions

of Area Three. 

The LSC intends that the Criteria will continue to be a useful framework for internal program 

self-evaluations, planning and program development as well as external peer reviews and expert 

assessments by other funding sources, such as IOLTA programs and government agencies. Use by such

other funding sources may require some adaptation to reflect differences in mission, authorization or

restrictions. 

The twelve years since the adoption of the original Criteria have seen significant change and 

evolution in Legal Services programs around the country. State planning, mergers, closing or 

modification of many support centers, rapidly developing technology and applications, and explosion of

the Internet all have had major impact. The reduction in federal funding in 1995-1996 and restrictions 

adopted by the 104th Congress changed the face of Legal Services in many parts of the country. Legal 

Services programs, while still part of the only national civil legal assistance delivery system, in many 

 

1

 In these Criteria, the capitalized term “Legal Services” will be used to refer to programs funded by the Legal 

Services Corporation. 

2

 Pursuant to the Compact of Free Association, LSC also has the responsibility to ensure the provision of legal 

services to eligible clients in the Republic of the Marshall Islands, the Republic of Palau, and the Federated States of

Micronesia. 

LSC Performance Criteria 3 
Introduction 

states have become one of an expanded number of providers. Many of these other providers do not offer 

comprehensive services, nor are they subject to Legal Services’ restrictions on activities. This new 

landscape makes efforts at coordination, collaboration, and statewide planning essential. The Criteria

now reflect the importance of such coordination and planning, consistent with and subject to potential

differences in mission, authority and perspective. The Criteria also recognize that part of the 

responsibility of the Legal Services grantee or grantees in each state is to function as a part of an 

integrated delivery system, to the extent possible in coordination with other legal assistance providers. If 

the Legal Services program primarily provides limited representation, such as intake, advice, referral and

brief services, then the program is responsible for ensuring, through the state planning process, that there 

is a comprehensive and integrated delivery system utilizing LSC as well as non-LSC funded providers. 

 

Since 1993, the low-income population also has undergone many demographic and other changes. 

These Criteria highlight the importance of Legal Services programs taking full account of the significance 

of such changes, and the need to be aware of evolving legal needs, demographics and characteristics of

the low-income population in programs’ service areas. 

The creation of larger, more complex programs through the designation of larger service areas 

made effective program governance and management even more essential, and often more challenging. 

In addition, the reductions in federal funding in 1995-1996 accelerated efforts to diversify and increase 

non-LSC funding for Legal Services programs, adding still more management challenges. These Criteria 

take account of such changes. 

As with the 1993 version, these Criteria draw significantly on the American Bar Association 

Standards for Providers of Civil Legal Services to the Poor. At least three factors distinguish the Criteria 

from the Standards: (1) the Criteria are designed by the major national funding source for Legal Services 

programs, and in the first instance are meant to meet the needs of the LSC and its programs; (2) as noted,

the Criteria are primarily intended to support program evaluation; and (3) the Criteria reflect

congressional directives and restrictions and should be applied consistent with funding source 

requirements. However, both the Criteria and Standards share many common values and perspectives. 

References to pertinent sections of the revised ABA Standards will be included when adopted. 

These Criteria should be utilized with several perspectives in mind: 

 

(1) The Criteria are designed to be used in program evaluations, self-assessments and external 

reviews, by peers or other experts.3

Ongoing self-assessment and periodic external evaluation by individuals outside of the 

program with relevant experience and expertise, “peers” or other experts, are important ways

for programs to gain perspectives and ideas that can make them more effective. The Criteria

provide a framework for evaluation of Legal Services programs, to improve program 

performance and accountability. Within this framework, peers and other experts can offer 

judgments about program effectiveness. The Criteria do not themselves present quantitative

standards. The vision behind the original Criteria remains applicable: by providing a single 

framework for structured evaluations by peers or other experts, the Criteria support a 

consistent national system for measuring program performance. 

To promote utility as a measurement device, in each performance area the Criteria express 

three levels of increasing detail: (1) the individual criteria themselves, which describe in 

 

3

 As indicated, the LSC will continue to use the Criteria for its assessments of grantees, using LSC staff and outside 

reviewers with the requisite expertise. 

LSC Performance Criteria 4 
Introduction 

broad terms the desired effectiveness for that area; (2) the indicators, a set of specific 

markers or factors, which are suggestive of whether the criteria are being met; and (3) the 

areas of inquiry, a third level of detail, which provide specific guidance to reviewers in terms

of questions to be asked and topics to be examined. Both the indicators and the areas of

inquiry are intended to be illustrative of factors to be considered for each criterion. It is not

required that all aspects of indicators and areas of inquiry be examined, nor should reviewers

be limited to them. At the heart of the idea of review by experienced peers is the conviction

that such experts are able to supply additional factors on their own and make appropriate 

judgments about areas to pursue based on circumstances of the particular program. 

(2) The Criteria are designed to take account of the reality that Legal Services programs do not 

have sufficient resources to provide comprehensive services that fully meet all of the major

civil legal needs of low-income people in an entire service area.

Nationally, funding limitations prevent Legal Services programs from meeting more than a 

fraction of the need for their services.4

 As a consequence, such programs continually must

make difficult choices among very important needs and possible activities, and constantly

face tradeoffs in which an increased commitment in one performance area may mean a 

lessening of emphasis in another. The Criteria are constructed with the awareness that at

current resource levels programs may not be able to achieve the maximum theoretically

possible in each of the major performance areas. In conducting assessments under the 

Criteria, reviewers must keep in mind that programs are compelled to balance competing 

needs: to assist as many as possible; to have maximum effectiveness for those who are

clients; to have the broadest beneficial impact on the communities they serve; and to excel in

each of the four performance areas. 

 

The combination of limited resources and comprehensive responsibility for an entire service 

area creates a duty to focus on the most pressing civil legal needs. This concept of focusing 

on most pressing civil legal needs is central to the Criteria as a way of addressing the choice

and triage compelled by less than full funding. 

(3) The Criteria focus particularly on results and outcomes.

The Criteria emphasize looking at (a) the outcomes and results of program activity for clients 

and the low-income population, (b) processes and systems, and (c) other “input” factors such

as staff experience, equipment, office space, research capabilities, and many more. While 

results and outcomes for clients are central, examination of systems, processes, and inputs is 

also important, since their presence makes it more likely that successful outcomes can be

replicated consistently over time. 

The Criteria embody and give content to the requirements of effective and economical 

delivery required by Section 1007(a)(3) of the Legal Services Corporation Act. 

“Effectiveness” entails looking at the results achieved, while “economical” means trying to 

achieve a particular result as efficiently as possible. 

 

4

 The Legal Services Corporation. (2005). Documenting the Justice Gap in America: The Current Unmet Civil Legal

Needs of Low-Income Americans. www.lsc.gov/JusticeGap.pdf. 

 

 

 

LSC Performance Criteria 5 
Introduction 

(4) The Criteria embody a dynamic vision of program work, related to the specific needs, 

resources and situations in each particular community.

Perhaps most importantly, the Criteria are driven by a vision that a highly effective program

is, within the limits of its resources, continually engaged in a dynamic process involving

planning, delineating objectives, working to achieve those objectives, assessing results, and

incorporating the resultant experience and learning into plans for future work. The most

effective programs are constantly in processes of motion and change and are innovative and 

experimental. They continually adjust their approaches and strategies in response to new 

circumstances and ongoing judgments about which legal needs are most critical, which

avenues do and do not work, what resources are available, what to do about changed laws or

court precedent, and many other factors. The most effective programs constantly engage in 

informal assessment, and periodically incorporate more formal evaluative processes. To

capture this dynamism in the evaluation framework, the Criteria begin with an examination 

of the effectiveness of the program’s assessments of legal needs, and follow a logical flow: 

identification of the most pressing problems; setting goals, priorities and objectives;

developing delivery and advocacy strategies; targeting resources based upon the most 

pressing legal needs; implementing the objectives and working toward the desired, expressed

outcomes; and then assessing and evaluating the effectiveness of the efforts before making a 

new determination of need and going through the entire process again. 

The Criteria contemplate an assessment process that takes full account of the different 

situations in each program and community. They make no effort to predetermine which legal

needs or types of cases are most important, what kinds or levels of service should be 

provided, or how specific cases should be pursued. Such categorical and quantitative 

absolutes are not possible or helpful, given the enormous variety in circumstances from

community to community. Similarly, there is no strict checklist of specific processes, 

systems or factors, the presence or absence of which define whether or not a program is 

effective. These Criteria, however, collectively reflect LSC’s sense of current best practices

that promote delivery of high quality legal services. 

LSC Performance Criteria 6 
Performance Area One 

PERFORMANCE AREA ONE. Effectiveness in identifying the most 

pressing civil legal needs of low-income people in the service area 

and targeting resources to address those needs.5

The Performance Criteria acknowledge the central importance of strategic planning, and envision

a dynamic model in which such planning is followed by and interwoven with implementation and

evaluation, constantly adjusting objectives and strategies to better address the most critical civil legal 

needs of the low-income population. While much of a Legal Services program’s work is necessarily

reactive, responding both to major issues affecting the low-income population and to the problems faced

by individual clients, such reaction should occur within a well thought-out framework, designed to enable 

the program to be as effective as possible in staying focused upon and addressing the most pressing legal

needs of the low-income population it serves.6

Performance Area One does not require one particular form or method of assessment, such as 

written surveys, nor does it require extensive documentation of the planning process. Rather, the program 

should be able to demonstrate that it has, through whatever approaches it uses, come to a reasoned,

thorough assessment of the most pressing legal needs in the communities it serves. Based on this

assessment, the program should set out clearly how it is trying to address the identified needs. 

Criteria 

Criterion 1. Periodic comprehensive assessment and ongoing consideration of legal needs. The 

program periodically undertakes comprehensive assessment of the most pressing legal 

problems and needs, both addressed and unaddressed, of the low-income population in its 

service area, including all major segments of that population with special and similar legal

needs or access challenges. These comprehensive assessments should be made frequently 

enough, in light of their cost and administrative burden, to be reasonably calculated to

identify new developments and opportunities affecting that population. In between these 

periodic comprehensive assessments, the program is flexible and responsive enough, and 

has procedures and systems in place, to recognize and adjust to major new needs of its

target population that emerge or develop.

Criterion 2. Setting goals and objectives, developing strategies and allocating resources. In light

of its comprehensive and ongoing assessments of need, and its available resources, the 

program periodically sets explicit goals and objectives and develops strategies to achieve

them. Insofar as possible, these objectives should be expressed in terms of desired

outcomes for both individual clients and the low-income population as a whole or any of 

its major segments, as may be applicable. The program should consider and adopt 

strategies for its delivery approaches and its representation and advocacy that are

calculated to achieve the goals and objectives. Next, the program should express its 

objectives, to the extent possible, in terms of outcomes that can be measured or assessed, 

and allocate and target its resources, consistent with these goals, objectives and strategies. 

 

5

 Public Law 104-134, §§504(a)(9) and 504(c), as incorporated by Public Law 105-119, as well as 45 C.F.R. Part

1620, detail the statutory and regulatory requirements relating to priority setting. Performance Area One expresses

themes that go beyond these requirements. 

6 Where the term “legal needs” is used in these Criteria, it refers to civil legal needs. 

LSC Performance Criteria 7 
Performance Area One 

To the extent that pressing legal needs have been identified which the program will not, 

because of resources or other limitations, be able to address directly, the program should 

consider what other methods, including innovative or alternative delivery approaches, 

other legal assistance activity, or collaboration with or referral to other entities, might be 

employed to provide some measure of assistance to affected individuals or communities. 

Criterion 3. Implementation. The program pursues these goals, objectives and strategies, working to 

achieve the desired outcomes through legal representation and assistance, advocacy, and

other program work. 

Criterion 4. Evaluation and adjustment. The program regularly analyzes and evaluates the effectiveness of its delivery strategies and work, in major part by comparing the results 

actually achieved with the outcomes originally intended, and utilizes this analysis and 

evaluation to make appropriate changes in its goals, objectives, strategies and legal

assistance activity. Such adjustments should be made on a flexible and ongoing basis, not

just after the periodic comprehensive assessments. 

LSC Performance Criteria 8 
Performance Area One – Criterion 1 

Criterion 1. Periodic comprehensive assessment and ongoing consideration of legal needs. The

program periodically undertakes comprehensive assessment of the most pressing legal problems and 

needs, both addressed and unaddressed, of the low-income population in its service area, including all

major segments of that population with special and similar legal needs or access challenges. These 

comprehensive assessments should be made frequently enough, in light of their cost and administrative 

burden, to be reasonably calculated to identify new developments and opportunities affecting that 

population. In between these periodic comprehensive assessments, the program is flexible and responsive 

enough, and has procedures and systems in place, to recognize and adjust to major new needs of its target

population that emerge or develop. 

Indicators 

The program carries out the assessment

comprehensively, considering approaches that 

involve: (1) getting the views of those eligible 

for service (methods could include questionnaires, surveys, focus groups, dialogue and 

meetings with clients and community members 

or other suitable techniques); (2) getting the 

views of people and agencies that work with or 

know the problems of low-income people 

(possible sources include advocacy and social

service agencies, community organizations, 

judges who hear cases involving low-income 

people, representatives of the organized bar, and 

Legal Services staff and board members); (3)

analyzing available relevant data and other

information, including census figures and any 

legal needs studies for the state or program 

service area(s); and (4) utilizing available or

emerging technology, e.g., GIS mapping, to

shed the greatest possible light on the problems

of the low-income population. 

The program considers all civil legal problems 

and needs, broadly encompassing any matters

susceptible to resolution through legal 

representation and other program activity, 

including all primary needs such as decent and 

affordable shelter, adequate nutrition, access to 

quality health care, income sufficient for a

decent and secure life, physical and 

environmental safety and security, protection of

civil rights and fundamental dignity, education

and employment necessary to earn adequate 

income and function as a member of society, and 

problems that affect the safety, security and 

stability of families.

Areas of Inquiry 

How does the program assess the legal needs and 

problems of the client community? How does the 

program determine which of the needs identified 

merit the program’s attention? Did the program 

determine the views of client-eligible people as to 

which needs were most pressing and important?

Did the program take into account any recent

formal social science legal needs study in the area

or state? Did the program create opportunities for 

representatives of the low-income population to

express their legal needs orally, in their own 

words?

Did the program make inquiry into all relevant 

legal problem areas? Was it reasonably calculated to identify emerging and non-traditional

needs?

What population groups, particularly those with a 

high incidence of poverty, exist in the program’s 

service area? Were available technological aids, 

such as GIS mapping, utilized? Was relevant 

data examined? Who received and responded to

any needs assessment instrument? Which 

segments of the client population responded and

which did not? In what languages were surveys

administered? Were individuals without telephones able to participate? Taken as a whole, did

the assessment reasonably examine the special

needs of all major poverty population segments? 

LSC Performance Criteria 9 
Performance Area One – Criterion 1 

Indicators 

The program takes account of any problems or 

issues that uniquely or disproportionately affect 

distinct and significant segments of the eligible 

population, such as children, seniors, indigenous 

people, farmworkers, ethnic and racial groups, 

rural and urban dwellers, people with 

disabilities, immigrants, people recently released

from incarceration, and people who are not able 

to communicate well in English. 

As part of the assessment, the program analyzes

other providers and resources in the service area

that can help meet the identified needs and 

considers the relative impact on eligible clients 

of addressing or not addressing the identified

needs. 

The program has systems and approaches

reasonably calculated to identify new pressing 

issues and legal needs, both of individuals and

the target population as a whole, including

continuing engagement with and input from the 

low-income population, regular review of intake 

and case information, monitoring of local, state,

and national legal developments, and other

appropriate strategies. Such new legal needs 

may be either short or long term. 

The program demonstrates actual awareness of 

such new pressing issues and legal needs. The

program is able to identify developments, 

problems and needs in substantive areas not 

aligned with or expressly covered by any

existing specialty units or practice concentrations it may employ. 

The program has in fact, when viewed over 

time, made adjustments in its goals and 

objectives in response to such emerging issues

and needs, including emergency changes where

necessary, e.g., to respond to major natural 

disasters, or changes in law or policy, and also

including, where necessary and appropriate, 

modifications in specialized units and practice

concentrations. 

Areas of Inquiry 

Has the program identified events during the 

past twelve months, or since the last formal

assessment, which compel or suggest the need 

for change in goals or objectives? Has it 

actually made changes? Has it done so on an 

emergency basis if necessary?

How do such identified events compare with 

those identified by others outside the program? 

What screening for other types of problems is 

done at intake? What systematic review of 

intake and intake data is done to identify 

repetitive problems? 

What specialty units or practice concentrations 

does the program employ? Does it identify

needs and problems, and accept cases, outside of 

those areas?

LSC Performance Criteria 10 
Performance Area One — Criterion 2 

Criterion 2. Setting goals and objectives, developing strategies and allocating resources. In light 

of its comprehensive and ongoing assessments of need, and its available resources, the program 

periodically sets explicit goals and objectives and develops strategies to achieve them. Insofar as 

possible, these objectives should be expressed in terms of desired outcomes for both individual clients 

and the low-income population as a whole or any of its major segments, as may be applicable. The 

program should then consider and adopt strategies for its delivery approaches and its representation and 

advocacy that are calculated to achieve the goals and objectives. Next, the program should express its 

objectives, to the extent possible, in terms of outcomes that can be measured or assessed, and allocate and 

target its resources, consistent with these goals, objectives and strategies. To the extent that pressing legal

needs have been identified which the program will not, because of resources or other limitations, be able 

to address directly through such full representation, the program should consider what other methods, 

including innovative or alternative delivery approaches, other legal assistance activity, or collaboration

with or referral to other entities, might be employed to provide some measure of assistance to affected

individuals or communities. 

Indicators 

The program periodically articulates the

problems it intends to address and the goals and 

objectives it seeks to achieve, expressed to the

extent possible in terms of specific desired

outcomes, and communicates these goals and

objectives. Staff are aware of the goals, objecttives and desired outcomes. 

Strategies are developed to achieve the specified 

objectives. These strategies are reasonably 

calculated to achieve the specified objectives, 

and are reevaluated regularly and modified as 

appropriate. 

Resource allocation and staffing responsibilities 

reflect such objectives. 

In targeting resources, the program weighs the 

likely costs to be incurred against the likely 

benefit for clients and other low-income people. 

Specialized units and practice concentrations 

reflect such objectives, including such 

modifications as may be appropriate from time to 

time. 

The program has explicit, clear and specific case

acceptance policies, consistent with these goals

and objectives, and staff are aware of them. 

Areas of Inquiry 

Has the program set forth specific goals and 

objectives for its legal work in major substantive

areas, or through its projects, specialty units or

branch offices? Were the strategies selected after

consideration of a full range of available legal 

representation and advocacy approaches? Are the 

strategies selected reasonable and promising? Are 

resources allocated accordingly?

Are staff aware of the goals, objectives and case

acceptance policies?

Are there identified pressing problems that the 

program goals and objectives do not address?

Are there other sources of assistance to help 

address those problems that are being utilized?

Do the program’s case acceptance policies

provide clear guidance regarding the legal work it 

will undertake and the cases it will accept? 

Do the case acceptance policies reasonably relate

to the objectives it has identified? 

Has the program considered alternative delivery 

approaches? Has it assessed their likely benefit? 

Were the consideration and assessment thoughtfully and carefully done? 

LSC Performance Criteria 11 
Performance Area One — Criterion 2 

Indicators 

With respect to pressing legal needs that the 

program does not have sufficient resources to

address through full representation, or which do

not require such representation to achieve the 

outcomes desired, it considers the possibility of

alternative approaches such as providing advice 

only, limited or brief service, group clinics, 

interactive aids available through the Internet, 

kiosks or other technologies, other self-help 

materials, community legal education, training of, 

collaboration with and referral to other providers,

and other available responses. Before employing 

such alternatives, the program assesses their likely 

effectiveness for individual clients and the lowincome population, and continues to make such 

assessments on an ongoing basis.

When setting goals and objectives, the program

considers the need for legal assistance in all types

of civil legal cases and all types of representation 

identified through its assessment processes that

are consistent with funding requirements and 

restrictions, without regard to whether it has 

current staff expertise or specialization in the

particular area, making its decision on the basis of 

what areas of work are most important to meet

the most pressing legal needs of the eligible client 

population. 

Areas of Inquiry 

Is the program open to considering representation in all types of civil legal problems 

consistent with funding requirements and 

restrictions, or does it rule out certain types of 

cases or representation, e.g., transactional work, 

because of a current lack of expertise, specialty

units, or capacity on staff? 

LSC Performance Criteria 12 
Performance Area One — Criterion 3

Criterion 3. Implementation. The program implements these goals, objectives and strategies, 

working to achieve the desired outcomes, through legal representation and assistance, advocacy, and other 

program work. 

Indicators 

Given the goals, objectives and strategies, 

effective advocacy approaches are selected, after

considering all possible forums, legal approaches 

and available methods of achieving the desired

outcomes, in light of what is appropriate, likely to 

succeed, and cost-effective. 

Areas of Inquiry 

What are the advocacy and delivery approaches 

undertaken by the program? What options and

approaches have been considered to address the

issues that have been targeted or have been 

presented? Is the scope of options considered 

comprehensive and thoughtful? Which options

and approaches have been adopted? How 

successful were the chosen strategies?

LSC Performance Criteria 13 
Performance Area One — Criterion 4

Criterion 4. Evaluation and adjustment. The program regularly analyzes and evaluates the

effectiveness of its delivery strategies and work, in major part by comparing the results actually achieved

with the outcomes originally intended, and utilizes this analysis and evaluation to make appropriate 

changes in its goals, objectives, strategies and legal assistance activity. Such adjustments should be made

on a flexible and ongoing basis, not just after the periodic comprehensive assessments. 

Indicators 

The program engages in ongoing evaluation, both 

formal and informal, of the effectiveness of its

delivery strategies and work, and makes changes 

in program goals, objectives, and strategies where 

indicated by such internal or other external 

evaluations. 

The program regularly collects information and 

analyzes the effectiveness of its work, especially

in achieving the articulated objectives and desired

results. 

 

In its analysis and evaluation, the program 

considers the perspectives of clients and affected 

members of the low-income population, advocacy

and other organizations that serve it, and others in

a position to judge the effectiveness of the 

program’s efforts. 

The evaluations carefully examine the reasons why 

particular strategies and approaches did or did not

work, and whether alternative or innovative 

methods hold greater potential for future success. 

In considering adjustments, the program examines

available information concerning the effectiveness

of other legal assistance providers in the service

area. 

After considering evaluations of its work and all

other relevant information, the program in fact 

makes appropriate adjustments in its goals,

objectives, strategies and legal assistance activities. 

Areas of Inquiry 

What processes does the program use to assess

the effectiveness and results of its work on an 

ongoing basis? Do program staff examine the 

effectiveness of the program’s advocacy? Does 

the program generate regular reports? 

Does the program make use of other available 

information and data concerning the target 

population and its needs, as well as delivery,

representation and advocacy approaches that 

have worked in similar circumstances? Does the

program show evidence of periodically adjusting 

its approach to pressing client issues and needs

after self-assessment and evaluation? 

In between periodic formal needs assessments, is 

the program continually engaged on a number of 

levels with the population it is serving? Does the 

program engage members of the client 

population in discussions of the results of the 

program’s work? Are evaluations documented,

inclusive of the views of a wide range of

individuals and organizations likely to have 

helpful perspectives and information, and

thoughtful in their analysis? Is there evidence 

that the program actually made changes in goals, 

objectives, strategies or work after such

evaluations? 

What results have been achieved by the 

program’s advocacy? Are results or significant 

progress reported with regard to each of the 

substantive objectives identified by the program? 

What have been the principal benefits for clients 

as a result of the program’s advocacy?

LSC Performance Criteria 14 
Performance Area Two 

PERFORMANCE AREA TWO. Effectiveness in engaging and serving 

the low-income population throughout the service area. 

A program must have effective relations with its clients, on both an individual and service areawide basis. Performance Area Two sets forth the core values and tenets for creating and maintaining

effective relations with clients. 

Criteria 

Criterion 1. Dignity and sensitivity. The program conducts its work in a way that affirms and 

reinforces the dignity of clients, is sensitive to clients’ individual circumstances, is

responsive to each client’s legal problems, and is culturally and linguistically competent. 

Criterion 2. Engagement with the low-income population. The program is engaged effectively with

the population eligible for its services, including major and distinct segments of that 

population and, where appropriate and feasible, incorporates perspectives from that 

population and its major segments in its work and operations. 

Criterion 3. Access and utilization by the low-income population. Consistent with its goals, 

objectives and strategies, a program should, within the limits of its resources, be 

accessible to and facilitate effective utilization by the low-income population in its service 

area, including all major segments of that population, and all categories of people who

traditionally have had difficulties in getting access to or utilizing civil legal assistance. 

LSC Performance Criteria 15 
Performance Area Two — Criterion 1 

Criterion 1. Dignity and sensitivity. The program conducts its work in a way that affirms and 

reinforces the dignity of clients, is sensitive to clients’ individual circumstances, is responsive to each 

client’s legal problems, and is culturally and linguistically competent. 

Indicators 

Consistent with the applicable rules of 

professional conduct and funding requirements,

and within the limits of the legal assistance that 

the program has agreed to provide a particular 

client, the program identifies and attempts to 

achieve each client’s objective. 

Program operations are carried out in ways that

affirm client dignity and are sensitive to client

circumstances. 

The program has effective methods to assess 

clients’ reactions to its services, and addresses

problems identified through such assessments. 

Legal Services programs in a state, and to the

extent feasible other legal assistance providers in 

that state, collaborate so that clients do not 

experience multiple referrals before they reach 

the provider that will offer the maximum level

of service. 

Program services, communications and activities 

are conducted in a culturally and linguistically 

competent fashion, and reach the significant 

low-income population segments, given the

program’s explicit goals and objectives and

available resources. 

The program places primary importance on

establishing a relationship of trust and 

confidence with each client, ensuring that each

client understands the scope of representation, 

adhering to the client’s objectives, and 

informing and consulting with the client about 

all significant developments in the matter. 

Areas of Inquiry 

Does the intake policy and procedure reflect a 

concern for the client’s needs? Are office hours 

convenient, including for those who work, such

as being available during lunch or in the 

evening? How long are clients required to wait 

for an eligibility determination? For an initial

substantive interview? For a determination of

case acceptance? Are clients required to return 

more than once for such determinations? What 

is done for those for whom access is limited by

geography, disability, limited English proficiency, or other factors?

Is telephone intake conducted so as to minimize 

waiting time and the possibility of lost calls,

such as by offering callback or other 

alternatives? How long are clients kept in 

queue? Are they offered information during the 

time in queue? 

If representation is limited or denied, how are 

clients informed? Is there notification of a

grievance procedure? Is there referral of clients 

who are denied service or given limited 

assistance?

How well does the program keep clients

informed of developments in their case? Are 

clients consulted if a significant change in case

strategy is contemplated?

What is the reputation of the program among 

client and community groups? What do they say 

about telephone and in-person reception and 

intake? About the courtesy extended to clients 

by program staff? How does the program gauge 

client satisfaction? 

LSC Performance Criteria 16 
Performance Area Two — Criterion 1 

Areas of Inquiry

From observations of facilities: Are waiting 

rooms clean and comfortable? Are educational 

materials available in the waiting rooms? Is 

privacy provided for interviews, intake (by

telephone or in-person), and for client meetings? 

Do the Legal Services providers in the state 

articulate and follow a policy of minimizing the 

number of times a client is referred from one 

provider to another? Is this followed by nonLSC funded legal assistance providers as well?

Do potential clients experience a seamless and

efficient referral from their first point of contact 

to the eventual provider of service, without 

unnecessary delay? Does the program facilitate

referrals to other non-LSC providers, including

Web-based resources?

Does the program provide cultural competency

training for staff? Are the staff reasonably 

diverse? Do they reflect the diversity of the

community served? Does the staff demonstrate

cultural sensitivity in their work? 

LSC Performance Criteria 17 
Performance Area Two — Criterion 2 

 

Criterion 2. Engagement with the low-income population. The program is engaged effectively with

the population eligible for its services, including major and distinct segments of that population and,

where appropriate and feasible, incorporates perspectives from that population and its major segments in

its work and operations. 

Indicators 

Program staff regularly interact with the lowincome population as a whole and its major 

segments. 

The program is known to, and has the trust and

confidence of, the target population and its major 

segments. The program staff and governing body

continually work to get information, perspectives 

and advice from appropriate representatives of 

significant segments of the low-income client

population on major program decisions 

concerning priorities, objectives, plans, and 

strategies, and where appropriate and effective,

involve members of the low-income population

in the program’s work. 

Areas of Inquiry 

Is the program aware of and does it do outreach 

to all major segments of the low-income

population in its service area? 

Do staff members attend meetings or other 

gatherings in the communities they serve? Is

there regular communication and outreach 

through printed materials, television and radio,

and the Internet, including where appropriate in 

languages other than English? Are there 

meetings with leaders of major organizations in 

the communities served, such as groups of

tenants and parents, service providers, neighborhood associations, and similar entities? Are 

staff otherwise engaged with such 

organizations? 

Is there evidence of target population participation at board meetings or other forums? 

Is the program well known and respected among 

the low income population and its major 

segments throughout the service area? Does the 

program represent eligible community groups? 

LSC Performance Criteria 18 
Performance Area Two — Criterion 3

Criterion 3. Access and utilization by the low-income population. Consistent with its goals, 

objectives and strategies, a program should, within the limits of its resources, be accessible to and 

facilitate effective utilization by the low-income population in its service area, including all major 

segments of that population, and all categories of people who traditionally have had difficulties in getting

access to or utilizing civil legal assistance. 

Indicators 

The program regularly gathers and reviews 

information as to utilization by people who 

traditionally have access difficulties (seniors,

youth, indigenous people, those with physical and 

mental disabilities, the geographically isolated, 

homebound, immigrants, people recently released

from prison, people who are in institutions or

incarcerated, those who are illiterate or marginally

literate in any language, those with limited

English-speaking ability, migrants, and others), 

and seeks to address, consistent with funding 

requirements and restrictions and within the limits 

of its resources and program priorities, any 

significant access problems revealed by such 

analysis. In conducting such analysis, the program 

utilizes available data sources and technological 

applications. 

Consistent with program strategies and objectives 

and within the limits of its available resources: 

• The program in fact provides services to each of 

the major low-income racial, ethnic, and limited 

English proficient populations in its area, and

regularly assesses anomalies between caseload

and service area demo-graphics that suggest 

access barriers, and takes steps to address them. 

• Program staff evidence knowledge of

substantive issues and problems that have 

unique or disproportionate incidence or effect 

upon particular segments or categories of the 

low-income population. 

Program offices, office hours, intake and telephone

procedures, language capabilities of staff, 

procedures for communicating with non-English 

speaking people, and other facilities and procedures 

are all reasonably calculated to achieve the broadest 

possible access and utilization by clients, including 

populations with traditional access difficulties, and 

make reasonable accommodation for their special 

needs. 

Areas of Inquiry 

What do community members say about access to

and utilization of the program by people who 

traditionally have had difficulties in getting access

to or utilizing civil legal assistance? Are program 

management and staff aware of the specific factors

that affect particular populations’ access to and 

utilization of the program, such as local

transportation, particular cultural or linguistic 

barriers, divisions within the client population that

may affect the willingness of one group to utilize 

the program’s office, and other relevant factors? 

Do management and staff make deliberate and

informed decisions regarding outreach to isolated 

population segments? 

Has the program in fact identified isolated 

population segments and overcome specific 

barriers to their access to the program? Has the 

program engaged in periodic assessment of their 

effectiveness and addressed inadequacies? 

Are staff and management able to articulate 

specific substantive issues that affect particular 

isolated populations in the program’s service area? 

Do such staff articulations conform to the issues

identified by community members? Has the 

program considered these specific issues as it has 

developed its goals, objectives and strategies? 

Facilities review – Was there actual observation of

methods for providing services to non-English 

speaking people, the disabled, and other groups

that traditionally have access difficulties? 

LSC Performance Criteria 19 
Performance Area Two — Criterion 3 

Areas of Inquiry 

Was there actual observation of telephone and inperson reception and intake systems? Was there 

review and evaluation of office setting and office 

hours? 

Is the program in fact readily accessible to persons 

eligible to be clients? Are program offices easy to 

find and clearly marked? Are they accessible to

public transportation? Is there accessible parking? 

Do office hours make it possible for the working 

poor to seek services? Are facilities accessible to 

disabled persons? 

Are forms, community education materials, letters

to clients and other communications written at a 

level that marginally literate persons can

understand? Do staff have clear protocols of how 

to work with persons of any language who are 

illiterate? 

LSC Performance Criteria 20 
Performance Area Three 

PERFORMANCE AREA THREE. Effectiveness of legal representation 

and other program activities intended to benefit the low-income 

population in its service area. 

Performance Area Three addresses the program’s implementation of its goals, objectives and 

strategies through the delivery of services. These services include direct legal representation, activity by

private attorneys, and additional services and efforts to benefit the low-income population. 

Criteria 

Criterion 1. Legal representation. The program conducts its direct legal representation, in both full

and more limited forms, in an effective and high quality fashion which comports with 

relevant state requirements, governing professional ethics and practice of law, funding 

source requirements, relevant portions of the ABA Standards for Providers of Civil Legal 

Services to the Poor, and these Criteria, and in particular: 

a. The program has in place adequate capacity to carry out its work, insofar as its 

resources permit. 

b. The program utilizes systems, approaches, and techniques sufficient to ensure that the 

representation is carried out with maximum effectiveness. 

c. The program’s legal representation achieves as much as is reasonably attainable for 

the client, given the extent of the representation, the client’s objectives and the 

circumstances of the case. Consistent with applicable rules and decisions governing 

professional responsibility, program goals and objectives, client objectives, and 

funding requirements, in its representation and work the program maximizes the use 

of its resources and achieves in its representation and work the greatest possible 

benefits and systemic solutions for other low-income people who may face similar 

legal problems, and for the eligible population as a whole. 

Criterion 2. Private attorney involvement. The program effectively integrates private attorneys in its 

work in order to supplement the amount and effectiveness of its representation and other 

services to achieve its goals and objectives. 

Criterion 3. Other program services to the eligible client population. Consistent with its goals,

objectives and strategies, the program provides services in addition to direct client

representation that are designed to help low-income people address their legal needs and 

problems. Such services may include, but are not limited to, community legal education

(general legal information not predicated upon a client’s particular case or facts), assistance

for self-help activities and pro se appearances, offering or facilitating participation in

alternative dispute resolution, and other available approaches, utilizing the Internet,

websites, interactive media and other available technologies as appropriate. The program 

continually seeks to find innovative ways to deliver services and meet client needs. 

LSC Performance Criteria 21 
Performance Area Three 

Criterion 4. Other program activities on behalf of the eligible client population. Consistent with its 

goals, objectives and strategies, and within the limits of available resources and the terms 

of its funding, a program engages in other activities on behalf of its eligible client 

community that have a beneficial effect on systemic legal problems and economic 

opportunities of the eligible client population. These activities include, but are not limited

to, communication and liaison with the judiciary, organized bar, government agencies, 

academic and research centers, social service agencies, and other information sources, state

and national legal advocacy organizations, other organizations working on behalf of lowincome people, and other entities whose activities have a significant effect on the eligible 

client population. 

LSC Performance Criteria 22 
Performance Area Three — Criterion 1 

Criterion 1. Legal representation. The program conducts its direct legal representation, in both full

and more limited forms, in an effective and high quality fashion which comports with relevant state

requirements governing professional ethics and practice of law, funding source requirements, relevant

portions of the ABA Standards for Providers of Civil Legal Services to the Poor, and these Criteria, and

in particular: 

a. The program has in place adequate capacity and resources to carry out its work, insofar as 

its resources permit. 

Indicators 

Adequate capacity and resources include but are 

not limited to:

Diverse casehandlers and support staff who

are qualified to do the work assigned, have

necessary expertise in the legal areas in 

which the program works, have the 

commitment, cultural competency, language

capacity, skill and preparation necessary to 

carry out their responsibilities.

Access to necessary law library and 

research capacity, including prior relevant 

work produced by the program and other 

similar providers. 

Necessary up-to-date equipment and 

technology to support law office work. 

Adequate access to experts and litigation 

support systems. 

Systems for ongoing evaluation of the 

effectiveness of legal work, at both 

program-wide and individual casehandler

levels, examining both the results obtained 

and the efficiency and quality of the

methods utilized to produce those results. 

Other relevant representation support 

systems, including a uniform system for 

maintaining client files, a system for noting 

and meeting deadlines in representation, 

and a system for handling client trust funds 

separate from provider funds. 

Internal performance standards which

express expectations for casehandlers and 

other staff. 

Areas of Inquiry 

What is the experience level, education, and 

knowledge of staff?

• experience in legal services?

• other relevant experience? 

• knowledge of relevant aspects of 

substantive law and procedure? 

• cultural competency?

• language capacity? 

Are advocates aware of key issues related to 

their areas of substantive work? Do they 

regularly consider the relationship between

individual case issues and the broader issues

affecting the client community? Does the 

program have strategies and procedures in place 

to stay abreast of relevant developments and 

issues affecting the low-income population? 

Can staff discuss new legal developments and 

the relationship of such developments to their 

cases? Do they stay in touch with resources that

are likely to keep them apprised of new

developments and methodologies, such as 

specialized organizations and list serves? Are

staff able to identify key client issues outside of 

their areas of expertise?

Does the program have a comprehensive 

knowledge management strategy, so that it

collects and retains information and documents 

from staff and others in a readily accessible

fashion? Are the documents and information in

fact used?

Is there significant state and federal on-line 

research capacity available to all casehandlers 

and advocates? 

LSC Performance Criteria 23 
Performance Area Three — Criterion 1 

Indicators 

Where necessary to meet the identified most

pressing needs of the eligible client population, 

the program takes such steps as are required to 

develop the capacity to do the type of case or 

representation. Such steps may be more

frequently required to deal with legal problems 

or types of representation, e.g., transactional

work, which are traditionally less common in 

Legal Services program caseloads. Where 

necessary, the program supplements its staff

capacity with outside expertise.

Areas of Inquiry 

Do all staff have reasonably up-to-date computers, software, telephone systems and other 

technology? Are intake, case management, 

statistics, production of routinized legal work, 

legal research, document assembly, and interand intra-office communications thoroughly

integrated with the program’s telephone and 

computer system? Is other appropriate up-todate technology available and utilized? 

Do program advocates appropriately consider 

and utilize experts in their representation of 

clients? Does the program have a policy that

encourages and pays for the costs of necessary

discovery, such as depositions, and do casehandlers routinely use all appropriate methods of

discovery? 

Are staff members aware of the policy and 

procedures for approval of such expenditures? 

Does the program have systems in place to

gauge the efficiency and effectiveness of work 

by case type and activity, including systems to 

collect information about and assess the results 

of its work? 

Does the program have systems and written 

policies regarding case file maintenance 

standards, multiple tickler systems, case 

docketing, and a central calendar?

Are the systems utilized by staff? Do they 

describe them the same way as their supervisors 

and the written policy? 

Does the program conduct periodic review of 

open cases?

Does the program have written performance 

standards for staff? 

Has the program recently developed new staff 

capacity in additional areas of law or types of 

representation, after they have been identified 

through a periodic or ongoing needs assessment 

or in response to changes in the law? 

LSC Performance Criteria 24 
Performance Area Three — Criterion 1 

b. The program utilizes systems, approaches, and techniques sufficient to ensure that the

representation is carried out with maximum effectiveness. 

Indicators 

The program utilizes: 

Intake systems and case acceptance

procedures that follow program priorities 

and case acceptance policies and 

restrictions, clearly describe the appropriate

roles for both intake and casehandling staff, 

and adequately capture all relevant

information and encourage exploration of

appropriate issues beyond the problem

identified by the client. 

Case assignment procedures that 

appropriately take account of staff expertise 

and capacity, staff caseload and other work 

responsibilities, and other factors affecting 

the ability of staff to provide representation, 

and effectively maximize the benefits and 

minimize the drawbacks of specialization. 

Effective supervision of legal work, which 

includes regular and detailed supervisory 

review of cases. 

Effective training and personnel

development policies and procedures, with

sufficient training, either within the 

program, at the state level, or utilizing 

outside resources, to ensure that staff 

receive necessary initial instruction and 

continue to learn and stay abreast of new 

legal developments, strategies, and

techniques. 

Effective utilization of available outside 

resources, expertise and other support. 

Specific case handler standards that address

such issues as file maintenance practices

and documentation of case activity. 

Areas of Inquiry 

Is appropriate information gathered at each step

of the process to support necessary decisions? 

Do staff have adequate expertise for the

interview for which they are responsible? Are 

priorities and case acceptance policies followed?

Are expectations and roles for staff clearly 

expressed? Does the program use technology 

appropriately to support the intake and case 

acceptance process? Does the program 

regularly review case acceptance policies and 

adjust them as necessary and appropriate?

Is there an effective program policy regarding 

appropriate caseloads?

How does the program keep track of and 

manage caseloads?

Has the program undertaken a thoughtful 

analysis of the benefits and drawbacks of

specialization, in the context of its funding, staff 

size, geographical service area, office locations, 

emergent client need and other relevant factors? 

Has this analysis guided the program’s actual 

decisions? 

How are case assignments made? Are the

appropriate staff responsible for case assignment?

Is there a clear system for the supervision of

employees and of legal work? Is it written? 

Does the program review significant legal work 

and hold moot courts in significant cases? Are 

lines of authority and responsibility clear? Do 

supervisors know what is expected of them? 

Does the system include regular affirmative 

supervisory review of cases? Is the system and

procedure followed with a frequency for each 

staff member appropriate to the staffer’s level of 

experience and recent performance? Is the 

supervisor engaged in oversight of the 

development of case objectives and strategies? 

Are the supervisory efforts also reviewed 

regularly by more senior supervisors? 

LSC Performance Criteria 25 
Performance Area Three — Criterion 1 

Areas of Inquiry 

Does the program have a clear policy with regard

to training and staff development? Is it followed? 

Is there effective training and orientation of new 

employees? Are there individual professional

development plans that are periodically updated? 

Is there sufficient training for managers,

supervisors, casehandlers, and other program 

staff? Are there regular staff evaluations?

Does program staff make use of available support

from state and national advocacy and information

organizations? Do they utilize other outside

resources when possible? Is there a coordinated 

and integrated system for sharing in-house 

expertise? Does the program and its staff

systematically contribute to and utilize knowledge 

management efforts, including electronic and

other document and form banks, intellectual work 

product files, web sites, task force and other inhouse list serves, and similar efforts?

Are there written standards for casehandlers?

LSC Performance Criteria 26 
Performance Area Three — Criterion 1 

Indicators 

Individual staff engage in: 

Appropriate problem diagnosis and 

definition that elicits pertinent facts,

identifies the relevant legal issues and 

apprises the client of likely next steps and 

developments to be expected. 

Development and ongoing refinement of 

case objectives and strategy, including 

definition of the lawyer’s role and the 

choice of the most effective forum (court, 

legislative body, administrative agency,

alternative dispute resolution forum, other), 

with appropriate input from the client at 

relevant points. 

Effective implementation of the case

strategy, including appropriate and high

quality pursuit of informal, non-adversarial 

strategies, negotiation and settlement, 

alternative dispute resolution, preparation 

of pleadings and motions, conduct of 

necessary discovery, preparation for and 

conduct of hearings and trials, pursuit of 

necessary appeals (within program 

guidelines), memoralization and

enforcement of judgments, and pursuit of 

representation in non-judicial forums or 

approaches other than litigation. 

Areas of Inquiry 

Is the casehandler able to demonstrate from 

discussion of case files that the indicators are

satisfied?

Did the advocate develop and take necessary steps

to implement a coherent case strategy? Did the

advocate appropriately use other available 

resources in pursuing the case? Did the advocate 

reassess the strategy appropriately as the case

progressed?

Was the client’s problem considered in relation to 

other similar problems, in order to assess whether

strategies to achieve broader impact would be 

more efficient and appropriate? 

Was the client informed and consulted in the

formulation of the case objectives and major

assessments of advantages, disadvantages and

risks in various options as the case was pursued?

What is the quality of analysis, and of the strategic

options pursued? Were the most appropriate avenues for advocacy and representation pursued?

Were the methods selected executed in a high

quality and effective way?

LSC Performance Criteria 27 
Performance Area Three — Criterion 1 

Indicators 

To the extent a program engages in limited

representation, as distinguished from full 

representation, in addition to the foregoing 

processes and indicators that are applicable, it: 

Takes steps to ensure that the client understands and agrees to accept the more limited

form of assistance, consistent with the 

applicable rules of professional conduct and

the ABA Standards for Providers of Civil 

Legal Services to the Poor. 

Periodically evaluates the effectiveness of

such limited representation for the clients it is

intended to benefit, and then makes such

adjustments in scope and approach that may

be indicated in order to increase

effectiveness.

Takes steps to increase the likelihood that, as 

may be indicated in the circumstances, each

particular client understands and is able to 

benefit from the limited assistance that the

program is attempting to give, including

appropriate follow-up steps where indicated. 

Utilizes available external information, 

studies and analyses, as well as the program’s 

own experience, in making the determination

as to which types of eligible client

populations, individual clients and legal 

problems benefit most, and least, from the

various forms of limited representation. 

Ensures, if it provides such limited

representation as its sole or predominant

delivery approach, that it does so as a part of

a more comprehensive delivery system in the

service area in which other, non-LSC entities 

provide a full range of services, including full 

representation. 

Utilizes available technology to assist in such 

service delivery.

Areas of Inquiry 

In general, has the program given careful thought

to the likely effectiveness of limited

representation for the particular types of cases and

problems? Are its conclusions reasonable, given 

all of the relevant circumstances?

Does it effectively explain the nature of the 

limited representation to the client? 

Does it evaluate the effectiveness of its limited

representation efforts, and make indicated

changes?

Does it follow up with clients to make the 

representations as effective as possible? 

Has it thoughtfully considered which types of 

clients are best able to benefit from limited

representation? Are its conclusions reasonable?

Is there evidence that the limited representation

fits into a comprehensive system which also 

provides full representation?

Is there effective use of technology in delivery? 

For cases that the program refers to other

providers in certain substantive areas, does it have 

clear referral protocols with the receiving 

program? 

LSC Performance Criteria 28 
Performance Area Three — Criterion 1 

c. The program’s legal representation achieves as much as is reasonably attainable for the

client, given the extent of the representation, the client’s objectives and the circumstances

of the case. Consistent with applicable rules and decisions governing professional 

responsibility, program goals and objectives, client objectives, and funding requirements,

the program maximizes the use of its resources and achieves in its representation and work

the greatest possible benefits and systemic solutions for other low-income people who may

face similar legal problems, and for the eligible population as a whole. 

Indicators 

Results achieved are consistent, to the extent 

reasonably achievable, with the client’s objecttives. 

Results have achieved as much as reasonably 

attainable for the client, given the circumstances 

of the case, and, consistent with applicable rules 

and decisions governing professional responsebility, also have achieved as much as reasonably 

possible for other low-income people similarly

situated, and for the eligible population as a 

whole. 

The program tracks the benefits it achieves for

clients through representation and other

activities. 

Areas of Inquiry 

What does the casehandler describe as the

results of representation? What is the

relationship of the results to the client’s

objectives? What was reasonably attainable in 

the case? What in fact was attained? Was there 

a benefit to other low-income people with a 

similar problem, or for the client population as a 

whole? Did the program and casehandler seek 

to maximize any such benefits? Is it clear from 

the casehandlers’ responses to questions about 

the files that they took reasonable steps on 

behalf of the client -- affirmative defenses,

counterclaims, joinder of other parties, discovery and other opportunities for investigation

and development of claims, use of experts, 

pursuit of motions, trial preparation and

conduct, pursuit of appeals -- as appropriate to 

the particular case?

What information does the program collect and

use about the benefits it achieves for clients and

the communities in which they live? 

LSC Performance Criteria 29 
Performance Area Three — Criterion 2 

Criterion 2. Private attorney involvement (PAI). The program effectively integrates private attorneys in its 

work in order to supplement the amount and effectiveness of its representation and other services and achieve 

its goals and objectives. 

Indicators 

The program has a private attorney involvement (PAI) 

system and plan that seeks to fully involve private 

attorneys in the program’s delivery of legal services to 

eligible clients, and that includes effective recruitment, 

training, referral, support, oversight, evaluation and 

recognition. Where necessary and feasible, the 

program addresses typical needs of private attorneys

handling cases, such as malpractice coverage, costs of 

experts, depositions and the like (to the extent they 

would be addressed for program staff handling such 

cases), form pleadings, practice manuals, costs and 

other issues. 

Subject to availability, the program utilizes private 

attorneys in a full range of program activities, 

including direct representation (both full and limited),

counsel or support in major and complex litigation,

transactional work, community legal education, 

assistance to pro se parties (including clinics), training,

representation in non-judicial forums, and other work. 

In general, the program is thoughtful and innovative in

the ways that it uses the services of available private

attorneys.

Areas of Inquiry 

Does the program have a thoughtful, comprehensive

and effective written private attorney involvement plan 

which seeks to engage private attorneys in a wide 

range of program activities, consistent with the 

possibilities and practicalities presented by the private

bar in the particular service area? Is it followed?

Have the program’s recruitment efforts been 

successful? How many private attorneys have signed 

up to take pro bono cases? How many private 

attorneys took pro bono cases within the last twelve

months? How many private attorneys have signed up

to take Judicare cases? How many private attorneys

took Judicare cases within the last twelve months? Are 

Judicare cases assigned to attorneys directly rather than 

requiring clients to work from a list? 

How do referrals to private attorneys compare with the 

stated goals and objectives of the program? If they are 

not consistent, what is the explanation? Who decides 

which cases are sent to the private bar? What criteria 

are used? 

What do private attorneys say about their work with

the program? Does the staff support the PAI 

component? Does the director? 

Are procedures for referral, oversight and follow-up

effective and reasonable? Are they written and are 

they followed? How does the program gauge client 

satisfaction? 

What training is offered to participating attorneys? Are 

private attorney support needs addressed effectively?

Is there private attorney involvement in the wide range

of program activity specified in the Indicators? If not, 

are there appropriate explanatory factors and 

justifications? Has the program been thoughtful and 

innovative in the ways that it utilizes private attorneys? 

Is there effective recognition of contributing 

attorneys?

LSC Performance Criteria 30 
Performance Area Three — Criterion 3 

Criterion 3. Other program services to the eligible client population. Consistent with its goals, 

objectives and strategies, the program provides services in addition to direct client representation

that are designed to help low-income people address their legal needs and problems. Such services

may include, but are not limited to, community legal education (general legal information not 

predicated upon a client’s particular case or facts), assistance for self-help activities and pro se

appearances, offering or facilitating participation in alternative dispute resolution, and other

available approaches, utilizing the Internet, websites, interactive media and other available 

technologies as appropriate. The program continually seeks to find innovative ways to deliver 

services and meet client needs. 

Indicators 

To the extent that the program engages in

community legal education work, it: 

Has in place adequate capacity and 

resources to carry out its work, and stays 

abreast of, compiles and utilizes relevant 

material previously produced by others. 

Selects a clearly defined audience for the

community legal education activity,

consistent with program goals and

objectives and desired outcomes. 

Utilizes the most appropriate methods, 

given the subject matter, the audience, and 

available resources. Methods considered

should include Web sites, written material, 

videos, computers, other audiovisual 

technology, and in-person presentations, 

including meetings and trainings. 

Communicates effectively with its intended 

audience, in ways that are culturally and 

linguistically competent and understandable 

to an audience with low literacy skills. 

Conducts periodic evaluations of the 

effectiveness of its community legal 

education efforts, measured against 

objectives, expectations, and realistic

possibilities, and compares the costs of the 

results achieved with the costs of achieving 

equivalent or better results through other 

methods. 

Attempts to assess results, including efforts 

to assess actual outcomes for individuals

who were the target of the community legal

education activity.

Areas of Inquiry 

Are the objectives of the community legal 

education effort clear and reasonable? Do they 

relate appropriately to the program’s goals and 

objectives? Is the approach designed to educate 

its target population effectively? 

Does the program creatively use written

material, videos, computers, and audiovisual and

other available technology? 

Is the target audience considered in determining 

the methods used? 

Does the program evaluate the effectiveness of

its community legal education efforts in light of

the costs involved? 

Does the program collaborate appropriately with 

other providers and social service agencies in the 

writing and distribution of community education 

and client self-help materials?

LSC Performance Criteria 31 
Performance Area Three — Criterion 3 

Indicators 

To the extent that the program facilitates self-help

or pro se efforts, including Internet-based material

and interactive technologies, the program: 

Has in place adequate capacity and resources

to carry out such work, and compiles

available relevant information on the strengths 

and weaknesses of such pro se, self-help 

efforts. 

Experiments with and where indicated utilizes 

a range of self-help assistance strategies,

including development of self-help materials 

and videos, clinics and other group sessions, 

media, training other agencies, groups and 

individuals to be presenters, Internet-based

materials, kiosks, and other available 

technologies.

Utilizes past experiences, research and evaluation to design future program strategies. 

Targets a clearly defined audience which has 

the ability to carry out self-help activities in

the legal problem areas chosen for concentration. 

Effectively informs and assists its intended 

audience, and then regularly assesses the

effectiveness and limitations of such efforts,

evaluating whether the potential dangers and

weaknesses of pro se approaches are

outweighed by the benefits, and whether the 

program and client objectives are being met

effectively, consistent with applicable rules 

and decisions of professional responsibility. 

To the extent possible, assesses the benefits

achieved by persons assisted by pro se efforts 

in relation to the costs of those efforts and 

compared to the results achieved by persons 

assisted by other methods. 

The program deliberately seeks to experiment with

alternative and innovative means of providing

assistance to low-income people in legal matters. 

Areas of Inquiry 

Has the program given consideration to pro se

alternatives where appropriate?

Are persons who proceed pro se successful? How 

does the program know? 

How does the program address the need for 

individualized help for pro se persons? How 

many are assisted?

Has the program carefully considered the extent to

which it will provide follow-up assistance to pro

se litigants? Has it coordinated its pro se efforts 

with the courts? Is the program aware of the areas 

in which self-help clients are most likely to fail or

drop out? Has it attempted to develop means to 

address those “failure points”?

Does the program experiment with alternative 

delivery approaches, or otherwise demonstrate

innovation? 

LSC Performance Criteria 32 
Performance Area Three — Criterion 4 

Criterion 4. Other program activities on behalf of the eligible client population. Consistent with

its goals, objectives, and strategies and within the limits of available resources and the terms of its 

funding, a program engages in other activities on behalf of its eligible client community that have a

beneficial effect on systemic legal problems and economic opportunities of the eligible client 

population. These activities may include, but are not limited to, communication and liaison with

the judiciary, organized bar, government agencies, academic and research centers, social service

agencies, and other information sources, state and national legal advocacy organizations, and other

entities working on behalf of or serving low-income people, whose activities have a significant effect

on the eligible client population. 

Indicators

Consistent with its goals and objectives, as a part

of its strategic advocacy, a program maintains

effective communication, coordination and a 

general presence with the indicated institutions 

and entities and any others that can have a 

significant effect on its target population, to the

end of reducing the effect or extent of problems 

faced by that population through collaborative

work. 

To the extent that a program engages in such 

activities, it should have contacts, credibility,

reputation and experience sufficient to allow it 

to conduct such activities effectively.

Continuously evaluate the effectiveness of such

activities, measured against program objectives

and what was reasonably attainable, in relation 

to the costs of such efforts. 

Areas of Inquiry 

Are program staff aware of legislative 

developments that affect the low-income

population in the service area? Have they 

considered strategies that address problems at

policy levels? 

Does the program expect and support work to

address systemic legal problems and improved

economic opportunities benefiting the lowincome population? Does it collaborate with the 

private bar and others to achieve such change? 

Are program personnel engaged in undertakings 

such as committees and task forces that relate to 

program objectives? Do they have sufficient

experience, reputation, and credibility to be

effective?

Do staff work with government agencies, social 

service agencies, or research centers concerned

with issues affecting the service area? Do they

work with the organized bar and judiciary when 

possible to address legal access or other 

problems faced by the low-income population? 

Does the program have access to and review

current literature and research concerning 

innovations in delivery methods? 

Is management aware of innovative possibilities 

and developments in legal services delivery and

receptive to their application in the program?

Does the program train or have regular 

communication with lay professionals who work 

with low-income people? 

LSC Performance Criteria 33 
Performance Area Four 

PERFORMANCE AREA FOUR. Effectiveness of governance, 

leadership and administration. 

The program should be led and managed effectively with high quality administrative systems, 

procedures and performance. Good leadership and strong internal operations increase the likelihood of 

effective services, and decrease the risk that effective program services will be adversely affected by 

organizational problems. 

Criteria 

Criterion 1. Board governance. The program has effective board oversight and involvement in

major policy decisions, including board members who are each committed to the program

and its mission, and a board that holds program management accountable for effective 

performance in the areas delineated by these Criteria. The board also meets its

affirmative responsibility to help develop resources for the program, promote awareness 

of the program, enhance its effectiveness and influence and protect and defend the

interests of the organization. 

Criterion 2. Leadership. The program has effective leadership which establishes and maintains a 

shared sense of vision and mission, and emphasizes excellence, innovation and 

achievement of goals and objectives. 

Criterion 3. Overall management and administration. The program is well managed and

administered including: an effective management structure; processes and systems to

ensure compliance with all funder requirements and state and federal law; capacity to

address problems quickly and effectively; effective utilization of technology; effective 

administrative procedures; competent personnel; allocation of appropriate resources to 

management functions; and periodic evaluations of administrative operations. 

Criterion 4. Financial administration. The program has and follows financial policies, procedures 

and practices that comport with applicable requirements of the American Institute of 

Certified Public Accountants, federal, state and local government, and the program’s 

funding sources, and conducts effective budget planning and oversight. 

Criterion 5. Human resources administration. The program maintains effective human resources 

administration, including compliance with all applicable laws. 

Criterion 6. Internal communication. The program maintains effective intra-staff and staffmanagement communications and relations. 

Criterion 7. General resource development and maintenance. To the extent possible, and 

consistent with the program’s mission, the program seeks to maintain and expand its

base of funding, with the goal of increasing the quality and quantity of the program’s

services to eligible clients. The program also coordinates with and where possible 

utilizes outside resources such as academic institutions, social service organizations, 

foundations, corporations, organized bar associations, members of the private bar, and 

other institutions and individuals to supplement its efforts. The program works to

increase the overall resources devoted to the legal problems of the eligible client

population. 

LSC Performance Criteria 34 
Performance Area Four 

Criterion 8. Coherent and comprehensive delivery structure. Overall, the program management

maintains a delivery structure and approach that effectively utilizes and integrates staff,

private attorneys, and other components; emphasizes innovation and creativity in

delivery; is informed by current information concerning delivery research; is well-suited 

to meeting the most pressing legal needs of the service area; and, given available

resources, constitutes an effective and economical balancing of expenditures on the 

various functions and activities described in the four Performance Areas. 

Criterion 9. Participation in an integrated legal services delivery system. The program

participates in, and seeks to expand and improve, statewide (and regional if 

relevant) legal assistance delivery systems to achieve equal access to justice and 

to meet the civil legal needs for low-income persons in the state. 

LSC Performance Criteria 35 
Performance Area Four — Criterion 1 

Criterion 1. Board governance. The program has effective board oversight and involvement in

major policy decisions, including board members who are each committed to the program and its 

mission, and a board that holds program management accountable for effective performance in the

areas delineated by these criteria. The board also meets its affirmative responsibility to help 

develop resources for the program, promote awareness of the program, enhance its effectiveness

and influence and protect and defend the interests of the organization. 

Indicators 

The board is involved in major policy decisions,

aware of issues in and performance of the program 

while leaving day to day management of program 

operations to program management personnel. The 

board effectively evaluates the chief executive 

officer. 

The board as a whole, and members individually, are

committed to the program and its mission, are free 

from organizational or personal conflicts, attend 

meetings regularly, and as appropriate assist in

fundraising and development activity. 

As a whole, the board is appropriately diverse and

representative of the various geographical areas and 

low-income populations served by the program. 

The board effectively promotes and expands the 

reach and influence of the program in the

communities it serves, and develops additional 

resources for the program. 

The board exercises effective financial oversight. 

Areas of Inquiry 

How are major policy decisions made? Is the board 

supportive of the program? Are its individual members? Do board members and officers understand the

major issues at stake for the program? Are board 

members aware of and accurate in their perception of 

the requirements of the program’s funding sources? 

Is the board aware of any major problems or issues

within the program? How does the board exercise its 

oversight of program operations? Are board

decisions appropriately documented in board

minutes? Does the board exercise judgment independent of the executive director, where appropriate? How frequently does the board evaluate the 

executive director? Do board members assist effecttively in fundraising and development activity? Is

the board membership diverse and representative of 

the service area?

Are client board members actively engaged in board 

decision making? 

Does the board have a policy or practice that

effectively deals with conflicts of interest or

potential conflicts of interest? Is the policy or

practice in writing? Are organizational or individual 

conflicts addressed quickly and effectively?

Does the board meet its external responsibilities as 

delineated in this criterion? 

Are board members given appropriate orientation and

continuing training, including training on the role of

the board, potential conflicts of interest, and on

fiscal, fiduciary and other responsibilities? 

Does the board have a policy or practice regarding 

length of service on the board? 

What is the level of attendance at board meetings? 

What systems and procedures does the board have to 

ensure effective financial oversight?

LSC Performance Criteria 36 
Performance Area Four — Criterion 2 

Criterion 2. Leadership. The program has effective leadership which establishes and maintains

a shared sense of vision and mission, and emphasizes excellence, innovation and achievement of 

goals and objectives. 

Indicators 

Key program staff, starting with the executive 

director or chief executive officer, are

recognized as the program leaders. They frame 

a vision and inspire a culture of energy, 

creativity, innovation, excellence and achievement, built on trust, confidence, integrity and 

loyalty.

The program provides opportunities for the development of a diverse group of leaders. 

The program has a succession plan.

Areas of Inquiry 

Starting with the chief executive officer, are 

there recognized, positive and effective leaders 

in the program?

Is there a shared sense of vision and mission? Is

it expressed in written form? Are staff aware of

it? 

Does the program leadership effectively inspire

creativity and innovation, trust, confidence, 

integrity and loyalty?

Does the program provide opportunities for staff 

to develop and exercise leadership skills? 

Does the program have a clear and reasonable 

succession plan? Is it written?

LSC Performance Criteria 37 
Performance Area Four — Criterion 3 

Criterion 3. Overall management and administration. The program is well managed and

administered including: an effective management structure; processes and systems to ensure

compliance with all funder requirements and state and federal law; a capacity to address problems

quickly and effectively; effective utilization of technology; effective administrative procedures;

competent personnel; allocation of appropriate resources to management functions; and periodic 

evaluations of administrative operations. 

Indicators 

The program devotes appropriate resources to

management. 

The program has a management structure that 

effectively uses middle managers. 

The program has experienced, capable, and 

diverse management and administrative staff. 

The program provides effective training, 

supervision, and evaluation of management and

administrative staff. 

The program undertakes periodic evaluation of

management operations. 

The program makes major decisions in a way 

that incorporates relevant information and input. 

The program devotes appropriate resources to

establish and maintain its technological infrastructure. 

The program has developed and regularly 

updates an emergency plan to enable the 

program to maintain operations and to minimize 

disruption in the event of an emergency.

The program has a plan for providing client

services in the event of a disaster or emergency

affecting its client community. 

Areas of Inquiry 

Is there evidence of unusual disruption, such as 

frequent or repeated changes in procedures, key

personnel, board, or other basic operations? 

How are decisions made in the program? Are 

there clear procedures and policies? Is decisionmaking authority clear when delegated? Is 

decision-making timely and effective? Do staff

members know to whom to go for decisions? 

Is there evidence of effective periodic 

evaluation? Are evaluations linked to the program’s goals, vision or strategic initiatives? 

Is there any evidence of non-compliance with 

federal, state or funder requirements? 

Are problems addressed promptly? Are there

sufficient resources allocated to management

and administration? Are they excessive?

Does management provide effective leadership 

and management training and support to midlevel supervisors and personnel engaged in

administration and management? 

Does the program foster an environment that

emphasizes continuous learning, constructive 

evaluation and feedback, improvement and 

excellence?

Has the program made considered choices

regarding the proportionality of non-advocacy 

staff as compared to casehandlers, consistent 

with program resources, number of casehandlers, and type of work? 

Does the program have a policy for the use of its 

technology? Does the program use technology 

effectively to enhance the efficiency of program 

operations and service delivery? 

LSC Performance Criteria 38 
Performance Area Four — Criterion 3 

Areas of Inquiry 

Does the program have a plan in the event of an 

emergency or disaster 

• for preserving files, equipment and 

computer data bases; 

• for communication between staff and 

management ; and 

• for the relocation of the program’s 

work sites?

Does the program attempt to coordinate with 

state/local emergency preparedness entities? 

Does the program have a plan for providing

client services in the event of a disaster or

emergency affecting the client population?

LSC Performance Criteria 39 
Performance Area Four — Criterion 4 

Criterion 4. Financial administration. The program has and follows financial policies, procedures and practices that comport with applicable requirements of the American Institute of

Certified Public Accountants, federal, state and local government, and the program’s funding 

sources, and conducts effective budget planning and oversight. 

Indicators 

The program has sufficient, capable, trained and 

effective staff dedicated to financial administration. 

The program has detailed written policies and

procedures describing its financial operations 

which comply with all applicable requirement. 

The program follows such policies and procedures. 

Annual program audits do not reveal any

significant problems or issues; where such items

have been identified, the program addresses

them effectively and promptly. 

The program issues accurate financial statements

on a timely basis. 

Areas of Inquiry 

Do past audits or outside reports and evaluations 

reflect problems? Have any such problems been 

addressed? Is there any evidence of failure to 

comply with applicable funder or governmental 

requirements? 

Is the budget consistent with the program’s 

mission, goals and objectives? Does the program effectively adhere to its budget? 

Are there systems and procedures in place to

ensure periodic and effective financial oversight 

by management? 

Does the program engage in financial planning

beyond the current year? 

Does the program use up-to-date technology to

enhance efficient financial operations? 

LSC Performance Criteria 40 
Performance Area Four — Criterion 5 

Criterion 5. Human resources administration. The program maintains effective human 

resources administration, including compliance with all applicable laws. 

Indicators 

The program has sufficient, capable, trained and 

effective professional staff assigned to human

resources administration. 

The program has a capable, culturally competent

and diverse staff. 

The program’s hiring, supervision, promotion, 

compensation, and termination policies comply

with applicable laws, are efficient, and serve the 

mission, goals, and priorities of the organization. 

The program periodically assesses salaries and 

employee benefits. 

The program maintains and follows clear,

uniform and consistent personnel practices,

based upon written policies. 

The program conducts periodic effective 

evaluations of all staff, addressing areas where

improvement is required and, where appropriate,

using such evaluations as part of a comprehensive personnel development strategy. 

The program maintains accurate and timely 

personnel files, and protects the confidentiality

of personnel records as required by applicable 

law and contract. 

In its personnel administration, services, and

activities, the program avoids any discrimination, harassment or other improper conduct 

prohibited by law, and promotes equal employment opportunity. 

The program effectively retains quality staff and 

avoids undesirable rates of turnover. 

Staff relationships are professional, collegial and

positive. 

Areas of Inquiry 

What are the recruitment policies of the

program? 

What are the program’s fringe benefits and 

retention policies, such as LRAP, retirement 

plans, health insurance, and other benefits? 

Does the program regularly review its salary

structure and benefits? 

Does the program periodically review its human 

resources plans and policies?

What is the current composition of the staff?

Is the current composition of the program staff 

diverse in terms of experience, gender, race, and

disability status? 

Does the program conduct annual evaluations of

its entire staff? Do such evaluations include 

setting goals for staff? Is there a system for

tracking whether such goals are met?

Does the program evaluate internal and external 

factors related to turnover and recruitment

procedures in recent hirings? Does the program 

experience a high level of turnover or employee 

grievances?

Does the program provide promotion opportunities? 

Is there cultural competency training for all 

staff? Have they attended? 

What is the recent history and current status of

staff morale? Relations with management?

Relations among attorneys and casehandling

units? Relations between categories of staff, 

such as between attorneys and paralegals,

attorneys and secretaries?

Does management create and sustain an

environment that values and supports a diverse 

workforce? What has been the role of

LSC Performance Criteria 41 
Performance Area Four — Criterion 5 

Indicators 

The program does not have serious intra-staff 

problems which negatively affect program 

performance.

To the extent that there are or have been serious

morale or other internal personnel problems, the 

program is addressing or has addressed them 

effectively, and is taking or has taken 

appropriate steps to prevent their recurrence. 

Areas of Inquiry 

management in promoting improved relations to

aid better service delivery? ...among branch 

offices or units? ...with central administration?

...between the board and staff?

LSC Performance Criteria 42 
Performance Area Four — Criterion 6 

Criterion 6. Internal communication. The program maintains effective intra-staff and staffmanagement communications and relations. 

Indicators 

The program has systems and procedures for 

ensuring regular communication among all staff. 

The program has procedures for obtaining input

on significant decisions, and for resolving 

complaints and problems effectively and timely.

Decisions are quickly and effectively communicated to all those affected by them. 

Maximum use of technology is made to facilitate 

and enhance internal communication. 

Areas of Inquiry 

Is there evidence of regular and consistent 

efforts to communicate effectively within the

program? 

Do staff feel there is effective communication? 

Do there appear to be any problems caused by

the absence of effective communication?

Do staff feel that their input is sought on significant decisions?

How does the program use technology to facilitate and enhance communication? 

Does the program resolve employee complaints

and problems effectively and timely?

LSC Performance Criteria 43 
Performance Area Four — Criterion 7 

Criterion 7. General resource development and maintenance. To the extent possible, and 

consistent with the program’s mission, the program seeks to maintain and expand its base of 

funding, with the goal of increasing the quality and quantity of the program’s services to eligible

clients. The program also coordinates with and where possible utilizes outside resources such as

academic institutions, social service organizations, foundations, corporations, organized bar 

associations, members of the private bar, and other institutions and individuals to supplement its 

efforts. The program works to increase the overall resources devoted to the legal problems of the 

eligible client population.

Indicators 

The program has sufficient, capable, trained and 

effective staff dedicated to resource

development, or uses outside professional

development assistance as appropriate. 

The program makes reasonable efforts at and has 

success in expanding its funding base, has 

considered and attempted to secure funding from 

sources successfully accessed by Legal Services

programs, stays abreast of and pursues new

opportunities, is innovative in trying to develop 

new sources, and analyzes and evaluates

whether the requirements of a prospective 

funding source are consistent with the program’s 

mission, goals, priorities, objectives and

strategies. 

 

The program has attempted to develop and to the

extent possible has effective relationships with 

other major institutional resources in the service 

area that are involved or might be able to 

provide some support in the provision of legal 

assistance to eligible clients, as well as help in

expanding program funding. 

Areas of Inquiry 

Has the program made reasonable efforts to

expand its funding base? Has it been successful? 

Is the executive director or fundraiser aware of 

the options that are available and is there a

strategy to seek funds? Have creative

approaches and opportunities been developed? 

Are the results reasonable? 

Is the program coordinating development efforts 

with other community organizations and 

agencies serving the low-income population? 

To the extent it does not, is this deliberate choice 

based upon careful analysis of the relative value, 

or lack thereof, of such joint action?

Does the program employ a development 

professional, or have access to other professional 

development assistance? How effectively does 

it staff its development efforts? 

LSC Performance Criteria 44 
Performance Area Four — Criterion 8 

Criterion 8. Coherent and comprehensive delivery structure. Overall, the program management 

maintains a delivery structure and approach that effectively utilizes and integrates staff, private

attorneys, and other components; emphasizes innovation and creativity in delivery; is informed by 

current information concerning delivery research; is well-suited to meeting the most pressing legal 

needs of the service area; and, given available resources, constitutes an effective and economical

balancing of expenditures on the various functions and activities described in the four Performance 

Areas. 

 

Indicators 

The program has a reasonable, thoughtful and 

effective overall delivery system, which utilizes 

and integrates staff, private attorneys, volunteers, branch offices, outreach, and alternative

delivery methods, and which strikes an effective 

balance on key issues such as specialization, 

experience of staff, use of attorneys and 

paralegals, and other major design choices. 

The program’s choices about allocation of 

resources to competing activities and functions

are reasonable and balanced, and consistent with 

its mission, goals, priorities, objectives and 

strategies. 

Areas of Inquiry 

Does the program have in place and regularly 

use systems to gauge the efficiency and 

effectiveness of its overall delivery system?

Is there evidence of actual assessment of 

efficiency and effectiveness?

Is there evidence of change as a result of that 

assessment?

Is there evidence of experimentation and 

innovation? 

LSC Performance Criteria 45 
Performance Area Four — Criterion 9 

Criterion 9. Participation in an integrated legal services delivery system. The program 

participates in, and seeks to expand and improve, statewide (and regional if relevant) legal 

assistance delivery systems to achieve equal access to justice and to meet the civil legal needs

for low-income persons in the state. 

Indicators 

The program participates in statewide (and 

regional if relevant) efforts to provide lowincome persons in the state with equal access to

a full range of civil legal assistance services in 

all forums. 

The program participates in local, statewide (and 

regional if relevant) efforts to maximize the 

effective use of available human and financial 

resources and to increase such resources to 

better address the civil legal needs of the state’s

low-income populations. 

The program coordinates with other providers, 

the bar, law schools and other relevant entities in

seeking to ensure that support is provided to

advocates and managers, including training,

dissemination and exchange of information, and

communication and coordination among 

practitioners in key areas of law and practice. 

 

The program participates in statewide planning

and oversight activities to achieve an integrated 

statewide delivery system, and coordinates and 

collaborates with other civil legal aid providers, 

private attorneys, government and corporate

attorneys, the organized bar, courts and court

personnel, law schools, and other public and

private entities that provide legal and other 

social services to low-income persons. 

Areas of Inquiry 

Does the program participate in statewide (and 

regional if relevant) oversight activities to 

achieve an integrated statewide delivery system?

Is the program engaged in statewide efforts (and

regional efforts if relevant) to achieve the

availability of a full range of civil legal

assistance in all available forums?

Is the program engaged in statewide efforts (and

regional efforts if relevant) to eliminate barriers 

to access and provide meaningful services to

low-income persons in the state? 

Is the program engaged in statewide efforts (and

regional efforts if relevant) to utilize existing 

financial and human resources effectively and 

efficiently?

Is the program engaged in statewide efforts (and

regional efforts if relevant) to increase potential 

sources of funding, including financial

resources, volunteer and in-kind resources? 

Is the program engaged in statewide efforts (and

regional efforts if relevant) to provide support to

advocates and managers, including training,

dissemination and exchange of information, and

communication and coordination among 

practitioners in key areas of law and practice? 

As part of its efforts to expand access, provide a 

full range of services, maximize resources, and 

ensure support within the state, does the 

program coordinate and collaborate with other 

civil legal aid providers, private attorneys,

government and corporate attorneys, the 

organized bar, courts and court personnel, law 

schools, and other public and private entities that

provide legal and social services to low-income

persons? 

LSC Performance Criteria 46