Responses to the Audit
Use the links below to skip to the specific response you wish to view:
California State Transportation Agency
915 Capitol Mall, Suite 350B
Sacramento, CA 95814
916-323-5400
www.calsta.ca.gov
March 30, 2017
Ms. Elaine Howle, California State Auditor
California State Auditor's Office
621 Capitol Mall Suite, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
Attached please find a response from the California Department of Motor Vehicles (Department) to your draft audit report Department of Motor Vehicles: Administrative and Statutory Changes Will Improve Its Ability to Detect and Deter Misuse of Disabled Person Parking Placards (#2016-121). Thank you for allowing the Department and the California State Transportation Agency (Agency) the opportunity to respond to the report.
As noted in its response, the Department concurs with all recommendations in the report and already has established timelines to implement corrective action. We appreciate your identification of opportunities for improvement and your recommendations for best practices that the Department can follow.
If you need additional information regarding the Department’s response, please do not hesitate to contact Michael Tritz, Agency Deputy Secretary for Audits and Performance Improvement, at (916) 324-7517.
Sincerely,
BRIAN P. KELLY
Secretary
Attachment
cc: Jean Shiomoto, Director, California Department of Motor Vehicles
Department of Motor Vehicles
March 28, 2017
Brian P. Kelly, Secretary
California State Transportation Agency
915 Capitol Mall, Suite 350-B
Sacramento, CA 95814
Dear Secretary Kelly:
The Department of Motor Vehicles (DMV) thanks the California State Auditor (CSA) for the opportunity to respond to its draft report Department of Motor Vehicles: Administrative and Statutory Changes Will Improve Its Ability to Detect and Deter Misuse of Disabled Person Parking Placards (#2016-121), issued on March 24, 2017.
At the request of the Joint Legislative Audit Committee, the CSA conducted an audit of DMV’s administration of the disabled person parking placard program to assess the protocols used by the DMV in preventing and combating fraud in the placard program. As detailed below, we agree with the recommendations and are pleased to report that we have begun implementing the recommendations.
The CSA recommendations and DMV’s responses (in bold) are as follows:
Chapter 1: Inadequate Processes for Reviewing Applications and Revoking Placards Increase Misuse
- To reduce the risk of fraudulent applications, by September 2017 DMV should seek interagency agreements with the health boards responsible for licensing providers authorized to certify disabilities on placard applications. The agreements should include, but not be limited to, the following:
- A review by medical experts of a sample of placard applications each quarter to ensure the disability certifications meet state requirements. For any application that does not meet state requirements, DMV should require that the applicant and his or her provider submit the information needed so that the application meets state requirements. DMV should cancel the placards of those who do not respond within 90 days.
- A process for the health boards to develop guidance for medical providers related to how to meet state requirements.
- A process for obtaining copies of provider signatures and routinely compare the signatures with those on a sample of placard applications. Investigations should confirm questionable signatures with providers.
Response:
DMV concurs with this recommendation. DMV will seek to implement this recommendation through interagency agreements with the appropriate health boards. The agreements will include the elements recommended.
Planned completion date: September 30, 2017
- To help ensure the DMV approves only those applications that qualify for the placard program as specified in state law, DMV should provide additional direction and training to its staff that addresses the following program requirements by September 2017 and annually thereafter:
- The types of medical providers that may certify qualifying disabilities.
- The disability categories each type of medical provider may certify.
- The legibility of medical provider certifications.
- The entry of medical provider numbers into its registration system.
Response:
DMV concurs with this recommendation. DMV will provide direction and training to its staff. The training and associated materials will encompass all the specific elements recommended.
Planned completion date: September 30, 2017
- To identify potentially fraudulent applications, beginning immediately and quarterly thereafter, DMV Investigations should obtain placard application data from its registration system and analyze those data. At a minimum, this analysis should include a review of the following:
- Individuals who have been issued multiple active placards.
- Individuals who apply for an excessive number of replacement placards.
- Providers who certify an abnormally large number of placard applications.
- Individuals over 100 years of age with active placards.
Response:
DMV concurs with this recommendation. DMV will develop a process to utilize data mining tools to assist in identifying potentially fraudulent applications. The process will include the specific elements recommended.
Planned completion date: June 30, 2017
Chapter 2: Better Communication and Coordination Will Help Detect and Deter Misuse of Disabled Person Parking Privileges
- To better deter placard abuse, by September 2017 DMV should establish reasonable goals regarding the number of sting operations each of its district offices should conduct each quarter. If competing priorities require a district office to miss its goal for a given quarter, Investigations should document its justifications for missing the goal. Further, Investigations should monitor its district offices’ effectiveness in meeting the quarterly goals.
Response:
DMV concurs with this recommendation. Investigations will establish reasonable goals for the number of disabled placard operations conducted by each district office. Documentation will include a justification if a quarterly goal is not met. The process will include a method of monitoring and evaluating.
Planned completion date: September 30, 2017
- To help ensure that DMV’s sting operations are an effective deterrent to placard misuse, beginning immediately DMV should regularly publicize the results of all its sting operations through local and statewide media, on its website, and in materials distributed to the public at its field offices.
Response:
DMV concurs with this recommendation. DMV has begun publicizing the results of operations as evident with the March 15, 2017 Sacramento sting operation. DMV will establish procedures for publicizing the outcomes of the operations via the media, DMV’s website and distribution of information at the field office locations.
Planned completion date: June 30, 2017
- To properly equip its employees with the knowledge necessary to identify and report potential fraud indicators in placard applications, DMV should provide employees who process applications with training specific to the types of fraud that can occur in an application. This training should be provided by December 2017 and every other year thereafter.
Response:
DMV concurs with this recommendation. DMV will provide training related to potential fraud indicators to employees who process placard applications following the recommended timeframe.
Planned completion date: December 31, 2017
- To encourage reporting of allegations of placard abuse, Investigations should amend its policy to accept complaints by telephone and online by June 2017 and display the instructions for doing so prominently on its website.
Response:
DMV concurs with this recommendation. Investigations will establish a policy regarding accepting complaints by telephone and will establish a method of reporting placard misuse online including displaying instructions prominently on the website.
Planned completion date: June 30, 2017
- To better track the time needed to investigate placard-related cases, Investigations should immediately require investigators to indicate in Investigation’s database that cases are closed upon concluding the investigation and to continue to track the court’s adjudication of each case.
Response:
DMV concurs with this recommendation. Investigations staff will key a closing status at the conclusion of the investigation and will continue to track the court’s adjudication of each case.
Planned completion date: June 30, 2017
- To better monitor the results of its enforcement operations, Investigations should provide training and guidance to its investigators on how to use and consistently enter case disposition information into its database, and it should train its supervisors to regularly follow up with investigators to ensure that they do so.
Response:
DMV concurs with this recommendation. Investigations will provide training and guidance to its investigators to use and consistently enter case disposition information into its database. Supervisors will regularly monitor and follow up.
Planned completion date: July 31, 2017
- To better equip local parking enforcement officials to promptly identify invalid placards, by December 2018 DMV should develop and implement an application, database, or other technology that will allow non-sworn parking enforcement officials to have immediate access to information on placard status.
Response:
DMV concurs with the policy objective of this recommendation, and will expeditiously explore the feasibility and cost of developing and maintaining technology that will allow non-sworn parking enforcement officials access to placard status. DMV does note, however, that it has concerns with the proposed timeline given other pending high-priority information technology projects, some of which are statutorily required.
Planned completion date: To be determined
- To aid local placard enforcement efforts, by September 2017 DMV should develop guidance and training regarding strategies to combat placard misuse and notify local parking enforcement officials that the DMV guidance and training is available. As part of these efforts, DMV should include information on state law related to increasing citation penalties to fund enforcement efforts.
Response:
DMV concurs with this recommendation. DMV will notify local parking enforcement agencies through outreach, flyers, or informational memos that DMV guidance and training is available. The training plan will incorporate strategies to combat disabled person placard misuse, and will provide information on the existence of state law related to increasing citation penalties to fund enforcement efforts.
Planned completion date: September 30, 2017
- To track its effectiveness at cancelling seized placards, DMV should continue its new practice of keeping a record of the date staff take action to cancel a placard and assess whether DMV is meeting its goal of cancelling seized placards within 24 hours of receipt.
Response:
DMV concurs with this recommendation. DMV will continue its current practice.
Planned completion date: Ongoing
- To provide local enforcement agencies with an effective way to submit placard cancellation requests, DMV should immediately establish a dedicated fax number, a dedicated email address, and a specific mailing address to receive such cancelations. DMV should communicate this information to local parking enforcement by July 2017 and should develop a schedule for communicating this information to local parking enforcement in the future. By July 2017 and periodically in the future, DMV should inform local parking enforcement of the need to submit information on seized placards quickly in order to prevent the holder from requesting a replacement placard without having to submit a new medical certification.
Response:
DMV concurs with this recommendation. DMV has already partially implemented this recommendation through a dedicated mailing address and fax number. DMV will also create a dedicated email address and periodically publicize contact information in a memorandum to local government entities on the proper procedures for reporting as well as the criticality of timely action.
Planned completion date: July 31, 2017
- To reduce the risk of placard misuse, DMV should update its placards to indicate a return address if found or if the placard holder is deceased. DMV should prepare this update for the permanent placards it will issue in 2019 that will expire in 2021.
Response:
DMV concurs with this recommendation. The estimated date for manufacture is the first quarter of fiscal year 2018-2019. For reporting purposes, the completion date will coincide with the approximate delivery date for these materials at DMV inventory sites.
Planned completion date: January 1, 2019
- To raise public awareness about parking for people with disabilities in California and deter placard misuse, by September 2017 DMV should develop a plan for conducting a public outreach campaign about the effect that placard misuse has on people with disabilities and the penalties for misusing a placard.
Response:
DMV concurs with this recommendation. DMV will develop a public outreach campaign to raise public awareness.
Planned completion date: September 30, 2017
We appreciate the opportunity to provide a response on our plans to implement the CSA’s recommendations. If you have questions or concerns, please contact Mr. David K. Saika, Audits Branch Chief, at (916) 657-6480.
Sincerely,
JEAN SHIOMOTO
Director