Summary

AUDIT HIGHLIGHTS . . .

Our review concerning the California Department of Motor Vehicles’ (DMV) disabled person parking placard program highlighted the following:

DMV does not sufficiently ensure applications for disabled person parking placards (placards) and disabled person or disabled veteran license plates (plates) are legitimate.
- Out of 96 applications we sampled, DMV approved 70 applications that did not include sufficient medical information to demonstrate that the applicant qualified.
- DMV approved applications that contained certifications of disabilities by unauthorized medical providers.
- DMV does not ensure the validity of medical provider signatures.
DMV has not canceled permanent placards for individuals who are likely deceased—as of
June 30, 2016, nearly 26,000 placard holders were age 100 or older.
State law provides no limits on the number of replacement placards a person may receive.
DMV has not established specific expectations to conduct regular sting operations for its district offices.
Local parking enforcement lacks immediate access to DMV’s placard information, limiting its ability to verify placards during enforcement activities.

Results in Brief

In reviewing the State’s disabled person parking placard program (placard program), we identified several improvements the Department of Motor Vehicles (DMV) and the Legislature can make that will reduce fraud and misuse. For example, DMV does not sufficiently review applications for disabled person parking placards (placards) and disabled person or disabled veteran license plates (plates) to ensure they are legitimate. Further, DMV issues renewal placards to many thousands of placard holders who are likely deceased because its process for identifying them is limited. Also, we found that state law provides no limitations on the number of replacement placards a person may receive, and we noted that two people each received more than 20 replacement placards over three years. In addition, we found that the enforcement of placard misuse would improve if DMV established reasonable goals for the number of enforcement activities it conducts. Finally, DMV could provide parking enforcement officials better information to determine whether a placard is valid or being misused.

California grants special parking privileges to people with certain disabilities outlined in state law. These people may apply for a placard to display in their vehicle or for a special license plate. To obtain placards or plates, they must submit a two‑page application to DMV that includes a description of the disability and a certification from an authorized medical provider. Both placards and plates allow these permitted individuals to park in parking spaces designated for people with disabilities, in metered spaces without paying the meter, and in time‑limited spaces without having to worry about those limitations. These benefits create a significant incentive for misuse.

Our review of applications for placards and plates found that most medical providers are not including enough information on applications when certifying disabilities. State law requires authorized providers to fully describe the illness or disability that qualifies the applicant for disabled person parking privileges. We expected that DMV would have a process in place to work with the Department of Consumer Affairs’ healing arts boards (health boards)—those responsible for licensing and investigating complaints against medical providers—to review a selection of these applications, as state law allows. However, DMV does not have agreements in place with the health boards. With the assistance of medical experts from the health boards, we reviewed a representative sample of 96 original applications DMV approved and found that 70 applications, or 73 percent, did not include a full description of the illness or disability. Projecting to the population of applications for placards or plates as a whole, this suggests that DMV approved up to 1.1 million applications from July 2013 through June 2016 without sufficient information to demonstrate that the applicant was qualified. According to the deputy chief of DMV’s Investigations Unit (Investigations), DMV has not worked with the health boards to review applications because DMV assumed the health boards would not provide DMV with information due to the privacy requirements in federal law. However, the medical experts we worked with were able to identify deficiencies in the applications without needing to review additional sensitive information. When DMV does not ensure that applicants include complete certifications, it creates opportunity for individuals to receive placards without a qualifying diagnosis.

Further, DMV does not have a process to review medical provider signatures to ensure that they are legitimate. DMV requires those medical providers certifying disabilities on placard applications to sign the applications. We compared the medical provider signatures included in our sample of 96 applications to official documents maintained by the boards that provided their medical licenses. Based on this comparison, we question whether 17 of the medical providers’ signatures reasonably matched official documents. Again, projecting this percentage of questionable signatures to the population of applications, we estimate that more than 260,000 applications approved from July 2013 to June 2016 may not be valid. When DMV does not review the validity of medical provider signatures, it risks issuing placards to individuals who submit fraudulent certifications.

DMV has not canceled permanent placards for thousands of individuals who are likely deceased. State law requires DMV to match placard records with the California Department of Public Health’s (Public Health) Vital Statistics file and to withhold renewals for permanent placard holders identified as deceased. DMV performs this match monthly. However, we compared the name and date of birth of active placard holders from DMV’s data to the U.S. Social Security Administration’s Death Master File (master file) and identified nearly 35,000 matches. Although this comparison indicates that DMV likely has not canceled thousands of deceased individuals’ placards, these results are not precise. For example, there might be a deceased person in the master file with the same name and date of birth as a placard holder in California who is alive. To identify deceased individuals using Public Health’s data, DMV relies on matches of the full name and date of birth. However, we found that DMV’s data did not always include correct names. Further, according to the chief of DMV’s registration operations division (registration division chief), DMV does not require applicants to provide documentation of their full legal name because DMV believes it lacks authority in state law to refuse applicants who do not provide such verification. As a result, someone intending to commit fraud could fabricate an application on behalf of a nonexistent or deceased relative, and DMV might well approve the application and issue the individual a permanent placard. Also, based on a separate analysis, as of June 30, 2016, we identified nearly 26,000 placard holders in DMV’s data that were age 100 or older. This number is significantly higher than the estimated 8,000 individuals that comprised California’s entire centenarian population as of 2014, indicating that DMV’s process for canceling placards of deceased individuals is inadequate.

In addition, some permanent placard holders have obtained many replacements. In reviewing DMV data, we found that nine individuals received 16 or more placards each from July 2013 through June 2016, including two who each received more than 20 replacements over that period. State law allows individuals to request replacement placards in the event their permanent placard is lost or stolen, and it does not limit the number of replacements an individual can receive. When state law allows individuals an unlimited number of permanent placard replacements, the number of placards in circulation and available for misuse grows.

The most common type of placard fraud DMV observes involves one person using another person’s valid placard. To catch this type of fraud or misuse, Investigations conducts sting operations wherein an investigator approaches a driver displaying a placard or plate and verifies that the placard or plate belongs to the driver or to someone being transported by the driver. However, Investigations has not established specific expectations for the number of sting operations its district offices must conduct. As a result, we found great variance across district offices, ranging from one to 18 sting operations from fiscal years 2013–14 through 2015–16. According to the deputy chief of Investigations, some offices did not conduct many sting operations because DMV has higher investigative priorities such as identity theft. Nevertheless, by not establishing reasonable goals to conduct regular sting operations, DMV fails to detect and deter as much of the continued placard misuse as it can, which affects those with disabilities who need special parking access.

In addition, local parking enforcement lacks immediate access to DMV’s placard information, limiting its ability to verify placards during its enforcement activities. Only law enforcement officials who are sworn peace officers have direct, immediate access to this information, whereas parking enforcement officers, who are non‑sworn, do not. We spoke to parking enforcement officials in six cities across the state—Berkeley, Fresno, Los Angeles, Sacramento, San Francisco, and Santa Cruz—and none reported having immediate access to DMV’s placard information. Instead, they generally must call local law enforcement dispatchers each time they need to verify a placard number. However, this process is time consuming, and four of the six officials we spoke with confirmed that their parking enforcement officials typically do not contact a dispatcher to determine whether placards are valid. According to the registration division chief, DMV could create and maintain a database containing the requisite information. This database could be used to grant immediate access to local enforcement officials in lieu of contacting local law enforcement. Without such a database, local parking enforcement cannot efficiently identify and seize placards that drivers are misusing.

Selected Recommendations

Legislature

To increase DMV oversight of applications for placards or plates, the Legislature should modify current law to require DMV to conduct at least quarterly audits of a selection of applications for placards or plates and to seek the health boards’ cooperation in doing so.

To assist DMV in more accurately identifying deceased individuals with active permanent placards, the Legislature should amend state law to require DMV to use the U.S. Social Security Administration’s Death Master File to inform its efforts to identify and cancel deceased individuals’ placards.

To assist DMV in identifying deceased placard holders, the Legislature should require that all who apply for a placard or plate include their full legal name and date of birth, and provide satisfactory proof of this information at the time of application.

To reduce the risk of placard misuse, the Legislature should limit to no more than two the number of replacements of permanent placards an individual may obtain during the two‑year placard renewal period. The Legislature should require that those desiring replacements beyond that limit reapply and submit new certifications of disability.

DMV

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 that 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 obtaining copies of provider signatures and routinely comparing the signatures with those on a sample of placard applications. Investigations should confirm questionable signatures with providers.

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 justification for missing the goal. Further, Investigations should monitor its district offices’ effectiveness in meeting the quarterly goals.

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.

Agency Comments

DMV agreed with our recommendations and stated that it will implement them.