Report 2012-044 Recommendation 6 Responses

Report 2012-044: California Department of Education: Despite Some Improvements, Oversight of the Migrant Education Program Remains Inadequate (Release Date: February 2013)

Recommendation #6 To: San Joaquin County Office of Education

To guard against future conflicts of interest, San Joaquin should complete its evaluation and revision of its procurement policies and procedures, update its conflict-of-interest code, and ensure that all its managers receive conflict-of-interest training.

6-Month Agency Response

This letter is a follow-up to our letter of April 23, 2013, and is our six month report. As requested in your letter we received on March 1, 2013, we are responding within six months and one year on our efforts to implement recommendations that are within our statutory authority.

I. Evaluation and revision of procurement policies and procedures

Person Responsible: Jim Thomas, Deputy Superintendent of Business Services

As noted in our letter of April 23, SJCOE has revised its procurement procedures and policies to align with all applicable government codes and regulations that pertain to County Offices of Education.

The attached policy has been revised and approved by the Superintendent and will be implemented beginning September 1, 2013. (See Attachment A)

Proposed Timeline for Completion and Implementation: September 1, 2013

II. Update the Conflict-of-Interest Code

Person Responsible: Janai Stanton, Administrative Services Coordinator

As noted in our letter of April 23, SJCOE has updated and amended its conflict-of-interest code and it was approved at the San Joaquin County Board of Education's public meeting on April 17, 2013. Subsequently, the conflict-of-interest code was approved by the San Joaquin County Board of Supervisors at their June 18, 2013 meeting.

The final, approved minutes of the April 17, 2013 SJC Board of Education meeting are attached. (See Attachment B)

The agenda and final, approved minutes of the June 18, 2013 SJC Board of Supervisors meeting are attached. (See Attachments C and D)

III. Ensure that all managers receive conflict-of-interest training.

Person Responsible: Janai Stanton, Administrative Services Coordinator

All workshops and activities indicated on the timeline submitted as Attachment D with our April 23 letter have been completed.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

Beginning in March 2013, San Joaquin County Office of Education (SJCOE) requires that all custodial contracts must have three quotes from three independent vendors prior to selecting a vendor. These quotes are thoroughly reviewed by the Operations Department including adherence to its specifications and cost-effectiveness.

SJCOE's Operations Department is conducting a review of all existing custodial contracts to determine whether any costs appear to be excessive. If so, SJCOE will obtain quotes on those contracts and terminate the existing contracts if SJCOE can achieve significant savings.

SJCOE has requested a legal opinion as to the requirements of codes and regulations governing county offices of education regarding procurement policies and procedures. Upon receipt of this information, SJCOE will ensure that its procurement procedures and policies align with all applicable government codes and regulations.

SJCOE has updated and amended its conflict-of-interest code and the code was approved at the San Joaquin County Board of Education's public meeting on April 17, 2013.

Three conflict of interest training workshops have been scheduled for management staff in April and May of 2013. SJCOE will schedule and conduct annual conflict-of-interest training workshops for management staff in subsequent years.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

All Recommendations in 2012-044

Agency responses received after June 2013 are posted verbatim.