Appendix A

A Comparison Between Parking Benefits for People With Disabilities in California and Select Other States

To understand how disabled person parking benefits might differ in other states, we selected nine states to review, as listed in Table A. We selected neighbor states as well as larger states and others for geographic diversity. As Table A shows, California and one other state we reviewed do not require placard holders to periodically reapply for disabled parking placards or plates. Further, several states we reviewed offer free metered parking with varying or no time restrictions. Additionally two states—Illinois and Michigan—have established two‑tiered systems. In both of these states, all individuals with placards may park in specially designated disabled spaces; however, to receive free parking in metered spaces, individuals must have a disability that limits their ability to use a parking meter.

Table A
A Comparison of Selected Disabled Person Parking Policies in California and Other States
State	Periodic Reapplication Requirements for Permanent Placards	Parking Benefits for People with Disabilities Holding Appropriate Placards or Other Permits
State	Periodic Reapplication Requirements for Permanent Placards	The State Exempts Persons With Disabilities From Parking Meter Fees*	Disabled Person Must Abide by Time Restrictions	Disabled Person May Park in Designated Parking Spaces
California	No	Yes	No	Yes
Florida	Yes (up to 4 years)^†	Yes	May park up to four hours in metered spaces; however, local ordinances may extend that time.	Yes
Illinois‡	Yes (4 years)^†	Fee-exempt placard holders only.	No time restrictions for fee-exempt placard holders at meters with time limits of more than 30 minutes.	Yes
Massachusetts	No	Yes	No	Yes
Michigan^‡	Yes (4 years)	Fee-exempt permit holders only.	Yes	Yes
Nevada	Yes (10 years)	No	May park up to four hours in time-restricted spaces.	Yes
North Carolina	Yes (5 years)^†	No	No	Yes
Oregon	Yes (up to 8 years)^†	Free metered parking for wheelchair users in zones with time limits above 30 minutes. Local parking authorities may allow other disabled parking permit holders the same free meter privileges.	No time restrictions for zones with limits greater than 30 minutes.	Yes
Pennsylvania	Yes (5 years)	No, although upon expiration of the meter, a one‑hour grace period is allowed before a citation is issued. Persons with disabilities not paying a meter upon arrival will be cited without the grace period.	May park up to one hour longer than posted time limits except where local ordinances accommodate heavy traffic.	Yes
Washington	Yes (5 years)^†	Yes	No. Local jurisdictions may impose time limits of no less than four hours.	Yes

Sources: California State Auditor’s analysis of laws and other publicly available information for the selected states as well as interviews with officials from Illinois, Michigan, and Oregon.

* Localities in states without a statewide exemption of parking meter fees may nevertheless have such an exemption.

^† Requires recertification of the disability.

^‡ States employing a two-tiered system for placards require that individuals must have qualifying physical limitations, such as an inability to handle coins because of limited motor control in both hands, to be entitled to free, unlimited metered parking. These are fee-exempt placard holders. Other disabled individuals may use designated parking spaces, but do not receive free parking without consideration of time limits.

Appendix B

Disabled Person Parking Placard Abuse Cases Investigated by the Department of Motor Vehicles’ Investigations Unit,
Fiscal Years 2013–14 Through 2015–16

The Joint Legislative Audit Committee asked the California State Auditor to evaluate the extent to which the Department of Motor Vehicles (DMV) investigates placard‑related complaints. As described in the Introduction, DMV’s Investigations Unit (Investigations) receives complaints from external parties, such as the public or law enforcement, but the majority of the cases it reviews are self‑initiated and are a result of sting operations that it conducts.

Table B presents information we obtained and reviewed from Investigations’ database. The table summarizes, by fiscal year, the number of cases Investigations initiated through sting operations and those it initiated based on a complaint from an external party. Further, the table shows the outcomes for each of the cases that Investigations initiated, listed according to the fiscal year in which DMV initiated the case.

Table B
Investigations Initiated by the DMV’s Investigations Unit Fiscal Years 2013–14 Through 2015–16
	Fiscal years						Total
	2013–14		2014–15		2015–16
	External Complaints	Initiated by DMV’s Investigations Division	External Complaints	Initiated by DMV’s Investigations Division	External Complaints	Initiated by DMV’s Investigations Division
Total cases initiated	142	683	160	1,046	178	979	3,188
Total cases opened for investigation	122	676	138	1,032	150	964	3,082
Case Outcomes
Cases still open or in review as of August 18, 2016*	3	63	6	112	57	418	659
Closed—no investigation or no violation	51	14	76	18	54	39	252
Closed—warning issued	47	119	25	177	46	94	508
Closed—conviction	21	305	9	461	9	227	1,032
Closed—dismissed	4	116	6	147	2	117	392
Closed—other^†	16	66	39	131	11	84	347
Totals^‡	142	683	161	1,046	179	979	3,190

Source: California State Auditor’s analysis of data from the DMV’s investigations database, as of August 18, 2016.

* According to a deputy chief in Investigations, some of these cases are still open because of DMV’s policy that investigators should not close cases until they have been adjudicated. In cases open longer than one year, the investigation is likely complete but the investigator has not obtained the court adjudication in order to close the case.

^† Includes cases not prosecuted due to statute of limitations, cases the local district attorney rejected, duplicate cases, and cases with an unknown disposition due to inconsistencies in outcome reporting.

^‡ The table shows 3,188 cases initiated but provides case statuses for 3,190 cases. This is because Investigations’ data set containing information on closed cases contained two more closed cases than the data set containing all entered cases. DMV was unable to provide a reason for this discrepancy, and the difference is not significant.

Appendix C

Scope and Methodology

The Joint Legislative Audit Committee (Audit Committee) directed the California State Auditor to perform an audit of the Department of Motor Vehicles’ (DMV) disabled person parking placard program, including reviews of medical certifications, identified and canceled placards belonging to deceased individuals, and investigated placard‑related complaints. Table C.1 lists the objectives that the Audit Committee approved and summarizes the methods we used to address those objectives.

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Table C.1
Districts and Schools Employ a Variety of Best Practices
Audit Objective		Method
1	Review and evaluate the laws, rules, and regulations significant to the audit objectives.	Reviewed relevant state laws and regulations.

2	For a selection of issued or renewed placards over the past three fiscal years, determine the following:	To review the Department of Motor Vehicles’ (DMV) program for issuing disabled person parking placards (placards) and disabled person or disabled veteran license plates (plates), we selected a random sample from a population of the more than 1.4 million original plate and placard applications DMV approved from July 2013 through June 2016, the most recently completed three fiscal years. We used a 95 percent confidence interval and a 10 percent precision rate to determine an appropriate sample size of 96 applications. In some cases, we were able to conduct analyses on DMV’s data for the entire population of placards and plates, and chose to do so rather than rely on our sample. We note those instances in the audit objectives that follow. Analyzed data from DMV’s Vehicle/Vessel Registration Master File (registration system) to determine whether any placard holders had more than one active, permanent placard as of June 30, 2016, the midpoint of the two‑year period for permanent placards beginning July 2015.
	a. Whether the applicant has been issued more than one placard during the same two‑year period the initial placard is, or was, in force.
	b. Whether the name and signature of the medical provider who certified the qualifying disease or disability matches information on file with the applicable licensing board.	Using the representative sample described in Objective 2a, we compared the medical providers’ signatures on the applications with signatures on file with the appropriate Department of Consumer Affairs’ healing arts boards (health boards).
	c. Whether substantiating information retained by the medical provider who signed the placard application certification matches the statutory definition of a disabled person.	As we discuss in Chapter 1, state and federal law prevent DMV and the health boards from obtaining and reviewing information on patient diagnoses without obtaining patient consent, unless the applicable health board issues an investigative subpoena or obtains an otherwise valid legal order. Thus, we were unable to review substantiating information retained by the medical providers. As an alternative, we worked with the applicable health boards to have their medical experts review the disability certifications on our representative sample of applications to determine whether the information met requirements in state law.
	d. The number and percentage of placard holders who are deceased by comparing the database of active placard holders with the California Department of Public Health’s (Public Health) Office of Vital Records’ deceased persons data.	Reviewed DMV’s process for conducting a monthly comparison between Public Health’s data and DMV’s data to identify deceased placard holders. Further, using data from DMV’s registration system, determined whether those identified as deceased through this comparison from July 2013 through December 2014 were issued new permanent placards with an expiration date of June 30, 2017. We chose December 31, 2014, as the cutoff date because the earliest DMV would have issued a permanent placard with an expiration date of June 30, 2017, was January 1, 2015. We have reasonable assurance that DMV’s processes work as expected.
		As we note in Chapter 1, the U.S. Social Security Administration also maintains a database, known as the Death Master File (master file), of the deceased that has different sources for its data. To better assess whether DMV is identifying deceased placard holders, we compared DMV’s data to the master file. DMV identified three placard holders in our sample of 96 applications as deceased. The deaths occurred after they applied for placards. Identified the number of individuals with active permanent placards who were age 100 or older as of June 30, 2016, and compared the number to census data.
	e. How many placards have remained in circulation after a report by local authorities that a placard was confiscated, a report that a placard was stolen, a conviction for misuse of a placard, or other evidence that a placard was used or obtained fraudulently.	Reviewed data from the investigations database in DMV’s Investigations Unit (Investigations) and found that DMV had no record of complaints or investigations on the placards in our representative sample. Determined that none of the placards in our sample appeared within DMV’s records of placards seized by local authorities. In Objective 7, we reviewed DMV’s activities related to placards seized by enforcement officials.

3	Provide a breakdown of certifications by medical provider type over the past three fiscal years. Over that same time period, determine the number of fraudulently obtained placards by type of certification.	Identified the type of medical provider certifying disabilities on the applications in our representative sample. DMV does not always capture in its registration system information necessary to identify the type of medical provider. Therefore, we could not provide a breakdown of provider type based on the population as a whole. In Chapter 1, we discuss how this limits DMV’s ability to detect fraud. Further, although we found irregularities in some applications in our sample and reported them to Investigations, we did not definitively identify fraud.

4	Determine the extent to which the DMV compares its placard holder data against deceased persons data and thereby withholds renewals for deceased placard holders.	The procedures we performed that are described in Objective 2d also address this objective.

5	Examine the extent to which the DMV makes placard holder information available to eligible law enforcement and parking control agencies. Determine how promptly this information is made available.	Reviewed DMV processes for receiving and responding to information requests from law enforcement, parking enforcement, and government agencies. Reviewed a selection of 24 information requests DMV responded to by mail to determine how promptly DMV responded to those requests. Based on available information, we determined DMV generally met established goals—up to 10 days for standard requests and less than seven days for rush requests—for responding to requests. Reviewed DMV data on call waiting times for DMV’s law enforcement call center. Interviewed parking enforcement officials in six cities regarding the manner in which they obtain access to DMV’s placard information and their satisfaction with the ease of access to that information. We selected the six cities—Berkeley, Fresno, Los Angeles, Sacramento, San Francisco, and Santa Cruz—based on population, geographic location, and our perception of limited parking.

6	Over the past three fiscal years, determine the number of replacement placards DMV issued to replace reportedly lost or stolen placards and whether it appropriately canceled placards being replaced before issuing a replacement.	Analyzed data from DMV’s registration system to identify permanent placards that DMV replaced for any reason, including those reported as lost or stolen, and calculated the number of replacements per individual from July 2013 through June 2016. We determined that when DMV issues a replacement, it cancels the placard holder’s previous placard.

7	For the past three fiscal years, determine how often and how quickly the DMV canceled placards confiscated by local authorities.	Interviewed DMV management to document the process DMV uses to receive information from enforcement officials regarding seized placards and to cancel those placards. Reviewed tracking spreadsheets DMV used to record its activities related to seized placards. Reviewed a selection of 15 placard cancellation requests DMV received from January 2015 through September 2016. DMV had not retained original information from enforcement officials before January 2015, and thus we had to limit our review to this time period.
8	Examine how readily accessible, up‑to‑date, and accurate DMV’s placard information is to local authorities, particularly for placards reported as lost, stolen, surrendered, canceled, revoked, expired, or issued to someone appearing in the deceased persons database.	Interviewed local parking enforcement officials and in Objective 5 identified methods DMV uses to make information available to them. Assessed the accessibility and timeliness of this information in Objective 5.

9	Evaluate the extent to which DMV investigates placard‑related complaints and makes corresponding updates to its database, particularly for placards that may have been fraudulently obtained or erroneously issued, that were inappropriately lent or sold to another individual, or that were fraudulently duplicated or displayed.	Reviewed DMV’s process for receiving and investigating complaints of placard misuse and fraud. Reviewed cases from DMV’s investigations database coded as being specifically related to placard abuse and initiated from July 2013 through June 2016. Using this data, we determined the number of complaints and DMV‑initiated cases DMV investigated, as well as the outcomes of those investigations. Judgmentally selected and reviewed six of DMV’s placard misuse operations—sting operations—including the scope, results, and costs for each operation. In Objective 7, reviewed how DMV responds to requests for canceling seized placards, including those seized by Investigations.

10	Review and assess any other issues that are significant to the audit.	To identify possible best practices, judgmentally selected nine states and researched laws, policies, and procedures for their respective disabled person placard programs. Interviewed parking enforcement officials in the six cities we selected to address Objective 5 to identify the tactics those cities employ for combating placard misuse and to determine the extent to which the cities work with DMV to identify placard misuse.

Source: California State Auditor’s analysis of various documents, interviews, or data from the entities listed in the table.

Assessment of Data Reliability

In performing this audit, we obtained electronic data files extracted from the information systems listed in Table C.2. The U.S. Government Accountability Office, whose standards we are statutorily required to follow, requires us to assess the sufficiency and appropriateness of computer‑processed information that we use to support findings, conclusions, or recommendations. Table C.2 describes the analyses we conducted using data from these information systems, our methods for testing, and the results of our assessments. Although these determinations may affect the precision of the numbers we present, there is sufficient evidence in total to support our audit findings, conclusions, and recommendations.

Table C.2
Methods Used to Assess Data Reliability
Information System	Purpose	Methods and Results	Conclusion
Department of Motor Vehicles (DMV) Vehicle/Vessel Registration Master File (registration system) as of August 9, 2016	To select a random sample of original applications for disabled person parking placards (placards) and disabled person or disabled veteran license plates (plates) approved from July 1, 2013, through June 30, 2016, for review.	We performed data-set verification procedures and electronic testing of key data elements, and we did not identify any significant issues. This purpose did not require a data reliability assessment. Instead, we gained assurance that the population was complete. To test the completeness of DMV’s registration system, we haphazardly selected 29 placard or plate numbers from an independent information system. We then traced these placard or plate numbers to the registration system and found the data to be complete.	Complete for this audit purpose.
	To calculate the number of placards and plates active as of June 30, 2016. To determine the median age of individuals with placards active as of June 30, 2016. To identify the names and birthdates of individuals with permanent placards active as of June 30, 2016. To identify select placards and plates associated with individuals DMV determined were deceased. To quantify the number of individuals age 100 or older with permanent placards active as of June 30, 2016. To identify replacements of permanent placards that DMV issued, and to calculate the number of these replacements per individual, from July 2013 through June 2016. To detect individuals with more than one permanent placard active as of June 30, 2016. To determine whether DMV referenced medical provider license numbers in its registration system for select placards or plates.	We performed data-set verification procedures and electronic testing of key data elements, and we did not identify any significant issues. The registration system is a partially paperless system. For example, DMV automated the renewal of permanent placards and a process to identify permanent placards associated with individuals that are deceased. Thus, some transactions did not have supporting documentation available for review. Alternatively, we could have reviewed the adequacy of selected application controls, but we determined that this level of review was cost-prohibitive. To gain some assurance of the accuracy of DMV’s registration system transactions with supporting documentation, we traced key data elements to supporting documentation for a selection of 29 permanent placard transactions during the period July 2013 through June 2016, and we found no errors. To gain some assurance of the completeness of the data, we haphazardly selected 29 placard or plate numbers from an independent information system and traced these numbers to the registration system. We identified no exceptions through this testing.	Undetermined reliability for the purposes of this audit. Although this determination may affect the precision of the numbers we present, sufficient evidence exists in total to support our audit findings, conclusions, and recommendations.
U.S. Social Security Administration (Social Security) Death Master File (master file) as of September 30, 2016	To determine the death dates recorded for names and birthdates associated with permanent placards.	We performed data-set verification procedures and electronic testing of key data elements, and found no errors. Social Security does not guarantee the accuracy of the master file; however, we did not perform accuracy and completeness testing of its data because the source documents that support this data are maintained by the U.S. Government, and our access statute does not compel the U.S. Government to provide us records.	Undetermined reliability for the purpose of this audit. Although this determination may affect the precision of the numbers we present, sufficient evidence exists in total to support our audit findings, conclusions, and recommendations.
Data extracted from DMV’s investigations database related to cases focused specifically on placard abuse that were initiated from July 2013 through June 2016.	To calculate the number of investigations and their dispositions. To make a selection of investigations focused on placards opened from January 1, 2013, through June 30, 2016. To review the processes and timeliness of DMV’s Investigations Unit related to tracking investigations from the point of receipt of a complaint to case closure, and tracking dispositions of investigations.	We performed data-set verification procedures and electronic testing of key data elements, and did not identify any issues. We did not conduct accuracy or completeness testing on these data because the source documents required for this testing are stored at various locations throughout the State, making such testing cost-prohibitive.	Undetermined reliability for the purposes of this audit. Although this determination may affect the precision of the numbers we present, sufficient evidence exists in total to support our audit findings, conclusions, and recommendations.
Excel spreadsheets DMV uses to track information received from enforcement officials related to placards the officials seized and DMV canceled in 2016.	To determine the number of placards enforcement officials seized and reported to DMV and the number of those that DMV had recorded as lost or stolen.	We performed data-set verification procedures and found no errors. Further, we performed electronic testing and found no significant errors. We did not perform accuracy testing. We also obtained reasonable assurance that the spreadsheets were complete by requesting information on seized placards from six local parking enforcement officials. We noted that DMV recorded it had received 43 of the 44 placards we reviewed. There is no evidence DMV ever received the 44th placard, and therefore we did not expect it to be in the spreadsheet.	Undetermined reliability for the purpose of this audit. Although this determination may affect the precision of the numbers we present, sufficient evidence exists in total to support our audit findings, conclusions, and recommendations.