California Department of Public Health
March 15, 2021
Elaine Howle
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
The California Department of Public Health (Public Health) has reviewed the California State Auditor’s draft audit report titled “California Department of Public Health: It Could Do More to Ensure Effective Use of Federal Funds for Expanding the State’s COVID-19 Testing and Contact Tracing Programs.” Public Health appreciates the opportunity to respond to the report and provide our assessment of the recommendations contained therein.
Below we reiterate the audit findings and our response to the auditor’s specific recommendations.
Finding: “Public Health Is Exceeding Its Testing Targets, but Contact Tracing Efforts Statewide Are Lagging.”
Recommendation to Public Health:
To better leverage contact tracing as a tool to limit the spread of COVID-19, Public Health should do the following:
By May 15, 2021, reevaluate its contact tracing plan and update it to incorporate technological and medical advances in order to redefine how many tracing staff it believes California needs and for how long it will need them.
Management Response:
Public Health agrees with this recommendation. The California Connected Contact Tracing (CT) Program is working with Public Health and academic partners to develop a new contact tracing staffing model based on current scientific knowledge, actual data from the first ten months of California’s contact tracing response, and the State’s projected COVID-19 case numbers for 2021. This revised staffing model will also consider technology innovations that save staff time and expand local workforce capacity, including automated case and contact surveys and data portals that enable external partners such as schools and businesses to share core data for cases and exposed contacts with their local health jurisdictions. This model will include the estimated workforce needed within the variety of staffing roles that together implement contact tracing activities, for example: case investigators, contact tracers, contact tracing team leads and supervisors, clinical advisors, isolation and quarantine resource coordinators, and data entry and triage staff. Of note, this new model will not include projected cases and staffing needs in prisons, long-term care and skilled-nursing facilities, and other congregate settings that are not supported by Public Health’s community CT Program and its related contact tracing workforce. The new model and subsequent revised California contact tracing staff plan will be complete by May 15, 2021.
Recommendation to Public Health:
By June 15, 2021, create and implement an updated plan, in partnership with local health jurisdictions, to hire, train, and retain the number of tracing staff it determines is necessary to limit the spread of COVID-19, including expanding the pool of reassigned state employees functioning as tracing staff.
Management Response:
Public Health agrees with this recommendation. By June 15, 2021, local health jurisdictions and the CT Program will partner to expand local workforce capacity as needed to meet the current and projected needs of the COVID-19 response, according to the revised staffing plan developed by the CT Program. If necessary and the projected need cannot be met by local- and state-hired contact tracing staffing, the CT Program will continue to use the state redirected staffing pool to supplement the local health jurisdiction contact tracing workforce. In partnership with the UCSF/UCLA Virtual Training Academy and local health jurisdiction partners, the CT Program will ensure that the workforce is sufficiently trained to effectively perform its contact tracing duties.
Recommendation to Public Health:
By June 15, 2021, and in collaboration with local health jurisdictions, determine what barriers exist to contact tracers successfully identifying and contacting additional people who may have been exposed to COVID-19. It should then study those barriers and share best practices with the jurisdictions and encourage them to implement those practices that will be successful at overcoming the barriers.
Management Response:
Public Health agrees with this recommendation. By June 15, 2021, the CT Program will utilize data and information collected via the State’s contact tracing data management system (CalCONNECT) and reported by local health jurisdictions through monthly ELC reporting to determine the existing key barriers that hinder successful contact tracing efforts. The CT Program will gather information shared by local health jurisdictions via facilitated learning collaboratives, town halls, and/or CalCONNECT LHJ Council meetings, as well as information shared by other states, the Centers for Disease Control and Prevention (CDC), and other national partners to identify best practices for mitigating these barriers. The CT Program will share these best practices with California local health jurisdictions and will work with them to create mechanisms to facilitate implementation of these best practices using CalCONNECT system enhancements, workforce training and development opportunities, community engagement strategies, health promotion efforts, or other methods identified as important to implementation.
Finding: “Public Health Has Been Slow to Approve Grant Work Plans and Collect Quarterly Updates From Local Health Jurisdictions.”
Recommendation to Public Health:
To ensure that Public Health has all the necessary planning information in place related to the allocations it has made to the local health jurisdictions, by April 15, 2021, Public Health should review and approve all initial work plans that it has received.
Management Response:
Public Health agrees with this recommendation. There were 58 work plans submitted to Public Health for the ELC Enhancing Detection application. As of March 9, 2021, Public Health has approved 56 work plans, or 97%. Public Health will have the remaining two work plans approved by the recommended date of April 15, 2021.
Public Health has a team in place to collect and review future ELC applications. Public Health will be developing a timeline to follow for its internal review process ensuring timely approval of applications in an effort to maximize the local health jurisdictions planned activities.
Recommendation to Public Health:
To ensure that it is performing necessary oversight and can provide local health jurisdictions with guidance to improve their activities using the ELC COVID-19 funding, by April 15, 2021, Public Health should put in place procedures to ensure that it receives all required quarterly work plans and expenditure updates from local health jurisdictions to which it made grants.
Management Response:
Public Health agrees with this recommendation. Internal procedures for collecting progress reports and expenditure reports were in place on February 3, 2021. These procedures include a detailed process for reviewing the reports once received. Aside from what Public Health had included in the Direct Allocation letters issued on August 11, 2020, Public Health communicated a reminder for submission of such reports February 5, 2021 via email. These reminders will be issued on a regular basis moving forward to ensure submission of progress and expenditure reports.
Finding: “Public Health Was Lax in Performing and Securing Required IT Project Oversight for Its COVID-19 Test Results System.”
Recommendation to Public Health:
To ensure that the State has accurate COVID-19 data, and to help mitigate the risks it caused by not having IV&V conducted during the development phase of CCRS, Public Health should direct its IV&V consultant to monitor system performance and Public Health’s data validation efforts and provide regular reports on the system’s reliability until the IV&V contract expires in December 2021.
Management Response:
Public Health agrees with the recommendation and concurs regarding the importance of the Independent Verification and Validation (IV&V) process. While starting IV&V at project inception would have been ideal, Public Health agrees there is value in onboarding IV&V during any project phase. The IV&V consultants have been directed to monitor system performance and Public Health’s data validation efforts and provide regular reports on the system’s reliability until the IV&V contract expires in December 2021.
We appreciate the opportunity to respond to the audit. If you have any questions, please contact Mónica Vázquez, Chief, Office of Compliance, at (916) 306-2251.
Sincerely,
Tomás J. Aragón, MD, DrPH
Director and State Public Health Officer