Report 2013-036 Recommendation 18 Responses

Report 2013-036: Indian Gaming Special Distribution Fund: Counties' Benefit Committees Did Not Always Comply With State Laws for Distribution Fund Grants (Release Date: March 2014)

Recommendation #18 To: San Diego, County of

To ensure that the benefit committee members and other designated individuals comply with reform act requirements for filing statements of economic interests, the Lake, Riverside, and San Diego benefit committees filing officers should attend FPPC training so that they are aware of and meet the responsibilities under the reform act. Each of these benefit committees should also establish a formal process for ensuring that all required individuals file statements of economic interests. For example, each benefit committees filing officer should notify designated individuals of their responsibility to submit statements of economic interests and follow up with those who fail to file.

1-Year Agency Response

The County of San Diego's Clerk of the Board of Supervisors has a process to track Form 700s for all Boards, Commissions and Committees, with the support of IGLCBC staff. This process uses an internal tracking system, hosted by the COB that gives access to committee staff to track and submit forms. Additionally, the revisions to the bylaws to adopt the interest code are responsive to this finding to include all members and staff.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

This Audit Finding is listed as Pending. The IGLCBC requires all members and alternates of the IGLCBC complete form 700 documents, per the attached conflict of interest codes. The IGLCBC has had the practice of including staff related to the committee, and has included them on Committee Rosters, however the Committee can consider modifications to the conflict of interest codes to include staff responsibilities. The County of San Diego, through the Clerk of the Board, has a process to monitor FPPC training and filing Statements of Economic Interest. This will be considered further prior to the one year final response for this audit, in response to the findings. Those revisions will be provided to the California State Auditor when they are completed.

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

60-Day Agency Response

The audit finding is directed at members of the IGLCBC who either did not file a Form 700 or did not file on time. The IGLCBC has a process in place that requires staff and the filing officers to attend required training and shares this training information with the IGLCBC members. The IGLCBC will formalize these procedures in its the bylaws. However even without the formal change, the IGLCBC members have all filled appropriately in 2014, and IGLCBC staff will follow up with the filing and training requirements in future years.

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

San Diego County's response indicates that the benefit committee will formalize the procedures in its bylaws. We have assessed the response as pending until the benefit committee updates its bylaws and provides documentation to substantiate its claim of full implementation.

All Recommendations in 2013-036

Agency responses received are posted verbatim.