Testimony of the New York Legal Services Coalition 

The Chief Judge’s 2026 Hearing on Civil Legal Services in New York  

Presented by: Kristin Brown, Board President 

September 23, 2026

 Introduction 

Good afternoon, on behalf of the New York Legal Services Coalition (the Coalition) I want to express my gratitude for the opportunity to speak today about the work of our Coalition and our Members.  Our member organizations are deeply appreciative of the work of the Permanent Commission on Access to Justice, our Chief Judge and all of Court Leadership for their steadfast leadership in the effort to ensure equal justice for all New Yorkers. The funding allocated to New York's civil legal services providers by the Unified Court System is first in the nation in terms of quantity and quality, providing the flexibility to meet the needs of programs and communities in the moment – from unanticipated policy changes impacting clients, to funding losses; to crucial infrastructure and recruitment investments and more. As a result of your commitment and leadership, our members, our community is better positioned to meet the essential role we play in securing fairness, stability, and dignity for low-income individuals and families as part of our state's social safety net. 

I submit this testimony today with a request to you that you continue to make progress toward closing the well documented “justice chasm” with an increase of at least $25 million and a continued 3% cost of living adjustment. Any erosion of this investment, even modest, would directly destabilize programs and staff at a precarious moment in the legal landscape for the vast majority of our clients.  

Who We Are 

The New York Legal Services Coalition is a nonprofit organization that supports a unified network of 56 nonprofit civil legal services providers serving New York State. Our member organizations provide life-changing support to income-eligible New Yorkers, preventing eviction and homelessness, protecting survivors of domestic violence, securing income and benefits, accessing health care, facing consumer debt, ensuring education services, reuniting families, and obtaining lawful immigration status - services that are, the very “essentials of life.”  

Together, our member programs represent every county in New York and work to ensure that vulnerable residents can enforce their legal rights and meet their most basic needs. The majority of our clients are Black, Latine, Indigenous, and other people of color who, in addition to confronting pressing legal issues, must navigate justice and economic systems that are structurally biased in favor of those with greater resources. 

Our member organizations are a robust and diverse network of civil legal services providers who are united in our mission to secure justice for low-income and marginalized New Yorkers. Our membership reflects the expansive geography and complex demographic landscape of our state, comprising organizations that range from large, multi-county institutional providers to nimble, neighborhood-based grassroots agencies.  

New York is unique in the number of civil legal services providers based in our state, serving our residents and we celebrate that. The immense diversity of our state—spanning densely populated urban centers, sprawling rural regions, and deeply diverse  communities with wide-ranging cultural and linguistic needs— enables our Coalition to speak to the needs of providers of all types, serving vastly different communities.  

  • Our members span from the largest providers of civil legal services in the nation, located in New York City, to small hyper focused grassroots organizations serving specific  communities, or regions of the state, including parts of New York City.  

  • Our members include Legal Services Corporation (LSC) funded, pro bono focused, domestic violence, consumer, elder law and immigration focused, statewide training and systems change focused organizations.   

 

Our mission is to bring all of those perspectives together and speak as one, on behalf of our clients and our sector.  We do this through writing white papers and reports on topics such as state contracting reform, pay parity, immigration legal services and soon to be published, public interest student loan forgiveness.  We provide testimony to legislators and other policy making bodies about issues impacting our client issues and we work together to leverage more resources to represent New Yorkers in need.  

Regional Representation:  

  • Statewide & Multi-Region Representation: The coalition has 9 organizations that represent individuals across multiple regions or on a statewide basis. 

  • Empire Justice Center, Rural Law Center of New York, Immigrant Arc, Journey’s End Refugee Services, New York Legal Assistance Group, Scale Justice, Family Legal Care, Make the Road, Worker Justice Center 

  • Single Region Representation: The remainder of the Coalition consists of organizations that focus on a specific regions or multiple specific regions. 

  • New York City/ Long Island: The largest regional hub, with 35 organizations  

  • Western NY & Finger Lakes: There are 16 member organizations covering the western portion of the state. 

  • Upstate & Suburban Reach: Dedicated organizations serving Central NY (9), Northeastern NY (9), and the Hudson Valley (7). 

  1. Organization Size: 

  • Small & Emerging Organizations: We have 18 small organizations. The coalition is highly accessible to smaller, community-based organizations.  These smaller organizations are vital for niche advocacy and hyper-local community trust. 

  • Mid-Sized Organizations: 15 medium sized orgs.  

  • Large organizations:  At the top end, the coalition includes 16 large organizations. These organizations bring massive infrastructure, widespread resources, and high-volume service capabilities to the table. 

In 2026, the coalition gained seven new members. Out of those seven, four serve immigrant populations exclusively, which we believe is a direct response to the federal policy changes and funding challenges threatening providers and the communities they serve while at the same time, reflecting the ever growing need for for this type of legal services. Within this, there is a recognition that we are stronger together.  As we gain and collaborate with new voices, leaders, and advocates across the civil legal services sector during this pivotal time, the issue areas we focus on will shift, but there is a clear throughline – maximum flexibility in funding is critical to the stability of our sector and to ensure providers can continue to deliver “essential to life” services to those in need. 

Judiciary Civil Legal Services Funding 

This year’s Judiciary budget included a total of $179.5 million for Judiciary Civil Legal Services (JCLS), representing a $25 million increase and 3% cost of living adjustment. We are deeply appreciative of the Chief Judge’s increased investment, which, over the past year has helped sustain vital services for low-income communities.  

 

  1. Stability and Flexibility – Dual Features of JCLS  

I want to take a moment to highlight actions taken by OCA related to this year’s funding that have been particularly impactful for Coalition providers and relates directly to the way in which the current JCLS 5 year contract has stood out among funding streams by supporting both stability and flexibility for civil legal services providers. These actions have been crucial in the face of funding challenges, the constantly changing policy landscape and times of crisis for the clients we serve on a daily basis.   

 

For three years and counting, the Coalition has steadily worked to call attention to the ways in which state contracting and payment delays undermine the financial stability, recruitment and retention efforts and ability to provide services, for non-profit contractors across the sector.  To deepen our impact, we have developed a collaboration with four other non-profit membership organizations, the Human Services Council, New York Council on Nonprofits, Nonprofit New York, and Nonprofit Westchester1. This partnership has collectively drafted, introduced and passed with the sponsorship and support of Senator Mayer and Assembly Member Paulin through both houses of the legislature2, a total of three pieces of legislation S.9761 (Mayer) / A.10741 (Paulin) 3 and S.9855 / A.11179 (Paulin)4, all aimed at requiring state agencies to incorporate a series of best practices into all their contracts and payment processes.  

 

As the Coalition developed our list of recommendations, we consistently came back to our JCLS contract and payment processes as a model for all state agencies. This focused on the flexibility in funding utilization, ease of successful budget modifications when factors and needs change, the initiation of an increase in the administrative rate from 10% to 15%, and providing automatic 25% advances at the beginning of each contract year as well as other factors.   

 

Rather than detail the minutia of contracting and procurement best practices utilized by the Budget office at OCA, I will outline two steps taken this year that exemplify their overall supportive and flexible approach that sets the gold standard for other funding streams when it comes to fiscal processes.  This is invaluable as our organizations face rapidly evolving challenges and must be able to redirect resources toward salaries, cost-of-living adjustments, infrastructure, and programmatic services in order to keep programs whole and ensure our clients receive the comprehensive assistance they need.  

 

  1. Response to Late State Budget 

Two of the most impactful elements of JCLS funding is an annual automatic 25% advance on our five year contracts and the fact that the contracts are for five years.  In an environment where nonprofit providers must do the work first and be reimbursed quarterly, it’s common for organizations, particularly, but not exclusively, those of smaller size, to have regular problems with cash flow.  Three months of payroll, rent, health insurance and other standard monthly costs, as well as additional monthly costs when payments are delayed drain reserves and commonly result in organizations having to rely on lines of credit, take out loans and accrue non reimbursable interest costs and late payment fees. Some funders, but not all, will provide an advance payment at the beginning of the contract year. This practice has a significant impact on cash flow and has consistently been identified by nonprofits as a top recommendation for state contacting reform because of the positive impact on cash flow and financial stability.  Furthermore, five year contracts allow for long term planning, projections and saves a substantial amount of administrative time, with fewer procurements necessary. We were pleased that IOLA followed your lead in this way with their last multi-year procurement.  

 

This past year, the State Fiscal Year 2026-2027 budget was signed by Governor Hochul on May 28th, 2026, just shy of 2 months late past the April 1 deadline.  Because the JCLS contract year begins in March, an automatic advance is typically processed once the budget passes in April. Many providers were relying on that happening.  Knowing this, when the budget was delayed, OCA staff proactively arranged to provide a first, and then second one month advance to providers, providing cash relief while the budget was pending. They then provided a final month’s advance – all of which helped significantly with cash flow and financial stability during this time. We are not aware of any other funder doing this, and it will be going to the top of our list of impactful actions funders can take to support grantees in our contract reform advocacy.    

 

  1. Response to mid-contract funding increases 

For the past two years, as significant increases in JCLS funding have been included in the state budget, OCA has worked with the Comptroller’s Office to provide a 23 percent across the board increase to contracts, along with the 3% cost of living adjustment for a total 25% increase in funding each year. These general funding increases have been a lifeline for providers who are facing federal funding volatility, funding cuts, are negotiating union contracts, investing in cybersecurity and critical infrastructure upgrades, or simply covering costs for programs that “don’t pay for themselves” but are absolutely crucial to the client communities we serve.   

 

This funding distribution approach reflects our Coalition Membership request for JCLS funding to remain fully flexible going forward. There are only a handful of funders that provide this form of general funding that can be used to support organizational and client needs as they arise. IOLA and JCLS are the only two we have available in New York. This means we can invest in our sustainability through salary and infrastructure investments, financial stability by pivoting to fund emerging client issues and areas of law or mitigate funding cuts from other funders. It also allows us to focus on providing high quality, culturally responsive legal services based on the needs of the specific region, area of law and modality we serve.  

 

  1. Pay Parity and Workforce Retention 

Pay parity remains a crucial and ongoing urgent equity and sustainability issue for the legal services sector5. Adequate compensation is essential not only to recruit and retain attorneys, paralegals, social workers, and support staff, but also to safeguard the quality and continuity of services that clients depend on. Thanks to JCLS and IOLA’s support, legal services providers are beginning to make progress in reducing the unprecedented levels of staff attrition, in which many attorneys were leaving for government positions that offer significantly higher pay and stronger benefits.  Again, the flexible, supportive way the JCLS grant is currently administered, and the steps OCA has taken to provide general funding increases are key to the progress that has been made toward pay equity as a key to staff retention.   

  1. Example of JCLS impact with federal and other funding instability  

The shifting landscape of federal Victims of Crime Act (VOCA) funding and the subsequent New York State Office of Victims Services (OVS) procurement cycle continue to present real challenges for civil legal services organizations across the country and here in New York. This uncertainty was compounded when the prior procurement cycle was abruptly rescinded by the State Comptroller due to scoring discrepancies, forcing a rushed re-application process that resulted in significant cuts and de-funded legal services and crime victims organizations earlier this Summer. In response, our Coalition joined forces with three other victim serving member organizations to send a letter to Governor Hochul asking for her intervention.  

I am pleased to report that Governor Hochul responded by allocating an emergency $36 million infusion impacting  many victim assistance programs, reducing cuts to legal services and funding 15 additional applications.  However, at least one of our members remains completely unfunded, and several others still have sustained deep cuts. We are still evaluating the precise, long-term impact on our members.  

I’m sharing this because this is an example of where Judiciary Civil Legal Services (JCLS) funding is a critical mechanism that can help absorb these external procurement shocks, which are unexpected and difficult to manage. The stability and flexibility of JCLS allows providers to bridge funding shortfalls, to maintain workforce stability and avoid cutting core legal services. Staff can be retained to wind down active cases while managers make decisions about how to manage the situation thoughtfully and strategically.   

The VOCA example is emblematic of any situation in which a program sustains a funding loss, including other federal funding sources such as Legal Services Corporation, Department of Justice Violence Against Women Act (VAWA), Acacia Center for Justice Unaccompanied Minor Representation, as well as state or foundation funding.  JCLS funding is a crucial tool to keep programs stable in times of upheaval.  

 

Federal Threats: The Impact of H.R. 1 and Proposed Changes to PSLF 

I would be remiss if I did not mention that federal dynamics continue to impact our organizations and increasingly, our clients, in previously unimaginable ways. H.R. 1 is now being implemented and we are seeing restrictions imposed on immigrant communities’ access to Medicaid and SNAP benefits and work rules are now being imposed as well.  Our client communities are being pushed to the margins and their rights are being eroded every day.   

At the same time, once again, proposed cuts to the Legal Services Corporation (LSC) not only threaten LSC-funded providers’ ability to maintain staff and services but also impact the broader provider community as their ability to serve clients is reduced.  

Finally, we remain deeply concerned about the status of the federal Public Service Loan Forgiveness (PSLF) program.  The PSLF has been an essential tool to the recruitment and retention of staff attorneys carrying high student debt yet committed to working in the public sector.  

Conclusion  

I am proud to be here today to provide information about how important the JCLS funding has been to our members, describe why it’s so crucial to keep JCLS funding flexible as both a foundation and a backstop to keep our organizations strong and effective in the face of so much uncertainty.  I’m also happy to have the opportunity to give you a small sense of how vibrant, collaborative, diverse and highly effective our Coalition is. We know that when we speak in unity we are a powerful force for our clients and that is what we aim to be.  

I will close by reiterating our deep appreciation for your commitment and support, Chief Judge Wilson, along with Court Leadership, in continuing to invest in access to justice through JCLS funding and the Permanent Commission on Access to Justice.  We ask that you please continue to deepen that investment by providing at least an additional $25 million for JCLS and a 3% cost of living adjustment in the Judiciary Budget. We also ask that you provide the maximum amount of flexibility to funded organizations to be able to respond to locally identified civil legal needs, shifting client needs due to the rapidly changing policy environment, fill funding gaps and invest in the salaries, infrastructure and other necessities as needed to retain and support our staff.  

 

Thank you for your time and consideration.