Report 2014-110 All Recommendation Responses

Report 2014-110: California Department of Resources Recycling and Recovery: The Beverage Container Recycling Program Continues to Face Deficits and Requires Changes to Become Financially Sustainable (Release Date: November 2014)

Recommendation for Legislative Action

To better ensure the Beverage Container Recycling Program (beverage program) is financially sustainable, the Legislature should consider enacting statutory changes that increase revenue, reduce costs, or a combination of both. Our report lists some specific proposals for the Legislature's consideration in Table 3, which begins on page 19 of our report.

Description of Legislative Action

The Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

The Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

Legislation has not been introduced to specifically address this recommendation. Assembly Bill 2110 was introduced on February 17, 2016, to serve as a placeholder for changes to the State Beverage Container Recycling and Litter Reduction Act; however, the bill was not pursued.

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Introduced

Description of Legislative Action

Legislation has not been introduced to specifically address this recommendation. However, AB 2110 was introduced on February 17, 2016, to serve as a placeholder for changes to the State Beverage Container Recycling and Litter Reduction Act.

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

Description of Legislative Action

Legislation has not been introduced addressing this recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

Unknown

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation #2 To: Resources Recycling and Recovery, Department of

To ensure it can demonstrate that its fraud prevention efforts are maximizing financial recoveries for the beverage program, CalRecycle should both modify and annually update its fraud management plan to include the following:
- By December 31, 2014, formally establish a systematic process for analyzing, monitoring, and responding to the risk of fraudulent recycling of out-of-state beverage containers.
- Develop fraud estimates—by type of fraudulent activity—that quantify the potential financial losses to the beverage program and the methodology CalRecycle used to develop these estimates.
- Identify the amount of actual fraud in the prior year by type of fraudulent activity, such as the financial losses resulting from the redemption of out-of-state beverage containers or the falsification of reports used to substantiate program payments.
- Identify the amount actually recovered for the beverage program in the form of cash for restitution and penalties resulting from fraud.

Annual Follow-Up Agency Response From October 2021

CalRecycle formed a unit within DOR to focus on fraud: Data Analysis & Risk Evaluation. The DARE unit spent a year developing tools within our tracking system DORIIS to identify and extract data elements including types of fraud. CalRecycle now has the tools in place to identify fraud through data collection and analysis and are exploring work with a third party with expertise in forecasting. In addition, DOJ continues to provide data points for criminal arrests and the associated fraud. CalRecycle has increased our partnerships and bolstered our joint training programs with DOJ and CDFA including training to over 100 CDFA staff at California border access points. Calecycle and DOJ have increased training with attorneys and enforcement staff and several joint partnerships leading to success in court proceedings in several cases. In the future, CalRecycle will implement a cross departmental data system which will help bolster our data capacity, fraud activity by type and analysis.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From September 2020

CalRecycle continues to work towards improved fraud management plans. The Data Analysis and Risk Evaluation (DARE - a unit established in 2017) became fully staffed as of September 2020. The DARE unit creates, develops, and implements various tools that better analyze and assess the potential risks of fraudulent activities. The unit also helps to quantify known financial losses to the program due to fraudulent activities.

The risk assessment tools developed by DARE have continued to produce successful results in 2020. The unit is currently processing data sets that will help to quantify known losses due to fraudulent activities. Because of DARE becoming fully staffed in September 2020, the final step in the methodology process of quantifying financial losses is still on track to be finalized by December 31, 2020.

CalRecycle and the California Department of Justice (DOJ) met in December 2019 to discuss the final steps of jointly developing the fraud estimates. The data points have been gathered and totals have been calculated to quantify known losses to the Fund. A comprehensive method to estimate the level of criminal fraud affecting the program has also been completed.

CalRecycle developed a process and is continually Identifying amounts recovered for the beverage program for restitution and penalties resulting from fraud.

Based on the preliminary results, CalRecycle does not need to currently contract out for additional work on the fraud estimates.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2019

CalRecycle continues to work towards improved fraud management plans. While the department experienced delays fully staffing the Data Analysis and Risk Evaluation (a unit established in 2017), the unit will be fully staffed by the end of 2019. The DARE unit creates, develops, and implements various tools that better analyze and assess the potential risks of fraudulent activities. The unit also helps to quantify known financial losses to the program due to fraudulent activities.

In 2018, these risk assessment tools were tested with great success. The Recycling Program Enforcement Branch (RPEB) was able to identify 30 recycling centers and processors that were committing fraud and recommended revocation for these sites. RPEB also recommended three recycling center applications be denied. This new data set will help to quantify known losses due to fraudulent activities. Because of the delay in staffing this new unit, the final step in the methodology process of quantifying financial losses may be delayed until December 31, 2020.

CalRecycle and the California Department of Justice (DOJ) have spent the last year gathering the data points needed to develop a comprehensive method to estimate the level of criminal fraud affecting the program. A meeting has been scheduled with DOJ in December 2019, to discuss the final steps of jointly developing the fraud estimates.

Based on the results of this work, and the future availability of funding, CalRecycle may contract for additional estimation work.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2018

CalRecycle has developed several risk assessment tools to better focus enforcement efforts. A new unit has been created (Data Analysis and Risk Evaluation) in order to implement the use of these new risk assessment tools. The new unit is not yet fully staffed but is projected to be by mid 2019. This new unit will identify and quantify known financial losses to the program from fraudulent activity (from both administrative and criminal cases).

CalRecycle incorporated the lessons learned from its work with the Department of Justice (DOJ) and the recommendations from the State Auditor when developing the next contract. On June 27, 2017, CalRecycle entered into a new contract with the Department of Justice from July 1, 2017 through June 30, 2020. In order to properly develop fraud estimates, the new contract added this specific language:

"In collaboration with CalRecycle, DOJ will develop a method by which to estimate the level of criminal fraud affecting the Beverage Container Recycling Program and the portion of fraud DOJ is preventing with their efforts."

CalRecycle and DOJ are currently in the process of gathering data points in order to develop a comprehensive method to estimate the level of criminal fraud affecting the program.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

The Imported Materials Unit now uses a process to analyze, monitor, and respond to the risk of fraudulent recycling of out-of-state beverage containers.

CalRecycle has identified and quantified known financial losses to the program from fraudulent activity associated with known criminal activity.

CalRecycle has initiated reconciling restitution amounts owed from criminal activity with payments. CalRecycle is determining any outstanding restitution owed. CalRecycle has not yet updated the case management system to identify the amount of fraud in the prior year by type of activity or the amount recovered. Higher-priority enhancements have taken precedence. CalRecycle is finalizing procedures to better track referrals from CalRecycle to the Department of Justice through to invoicing and disposition.

Precisely estimating fraud is difficult and estimates are potentially inaccurate. While CalRecycle manages fraud risk to the best of its ability and via cooperation with partners, identifying additional potential fraud losses and risks requires expertise that CalRecycle does not have in-house. A formal statistical estimation is needed, and CalRecycle is exploring options to conduct this work. DOJ has conducted a preliminary fraudulent activity risk assessment by county to better utilize their agents. Similarly, CalRecycle is developing a risk assessment tool to better focus enforcement efforts. CalRecycle estimates this tool will be ready by the end of 2018. CalRecycle and DOJ are collaborating to develop a comprehensive method to estimate the level of criminal fraud affecting the program. CalRecycle and DOJ will use known fraud and other factors to characterize and estimate—as well as possible—potential losses. DOJ and CalRecycle will meet in January 2018 to further develop their approaches. Based on the results of this work, and the future availability of funding, CalRecycle may contract for additional estimation work.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2016

Process and procedural documentation were completed on 1/15/15. Through the establishment of the Imported Materials Unit, a systematic process for analyzing, monitoring, and responding to the risk of fraudulent recycling of out-of-state beverage containers was implemented.

There is currently no estimated completion date for the following:

Fraud estimates. CalRecycle does not have in-house staff with the necessary expertise to develop the fraud estimates. A formal methodology based upon further study and statistical estimation is necessary. CalRecycle would need to contract for these services. Given the ongoing structural deficit in the CBCRF, CalRecycle does not anticipate having funds for this project in the foreseeable future.

Identification of fraud. CalRecycle has not updated the DORIIS case management system to identify the amount of actual fraud in the prior year by type of fraudulent activity. This improvement item is currently on CalRecycle's DORIIS Ticket Prioritization List. To date, higher priority DORIIS enhancements and improvements have taken precedence. Once DORIIS is updated, CalRecycle may be able to implement CSA's recommendation.

Amount recovered after fraud. CalRecycle has not updated the DORIIS case management system to identify the amount actually recovered resulting from fraud. This improvement item is currently on CalRecycle's DORIIS Ticket Prioritization List. To date, higher priority DORIIS enhancements and improvements have taken precedence. Once DORIIS is updated, CalRecycle may be able to implement CSA's recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

CalRecycle fully implemented process and procedural documentation that formally establish a systematic process for analyzing, monitoring, and responding to the risk of fraudulent recycling of out-of-state beverage containers. Seven additional LT positions have been hired to execute this systematic process.

CalRecycle does not have in-house staff with the necessary expertise to develop the fraud estimates. CalRecycle believes a formal methodology based upon further study and statistical estimation is necessary. Given the wide variety of variables, associated complexity, and the professional expertise and skill needed to effectively design and develop such a model, CalRecycle would need to contract out for these services. Unfortunately, given the ongoing structural deficit in the CBCRF, CalRecycle does not anticipate having funds for this project in the foreseeable future.

CalRecycle has not fully updated the DORiis case management system to identify the amount of actual fraud by type and identify the amount actually recovered. When the update is completed DORiis will be able to fully implement CSA's recommendation

California State Auditor's Assessment of 1-Year Status: Not Fully Implemented

6-Month Agency Response

Process and procedural documentation for Imported Empty Beverage Container Reporting and Inspection Program was completed on January 15, 2015.

Notice to known recyclers in Arizona and Nevada was issued on January 16, 2015. Final draft of notice to all major truck rental companies is pending review by the CalRecycle Legal Office as of April 28, 2015.

On April 2, 2015, CalRecycle, Division of Recycling, Enforcement Branch staff, representatives from DOJ, and the AG's Office educated state and local law enforcement/code enforcement personnel, whose jurisdictional boundaries include CDFA border stations, about illegal importation and illegal CRV redemption of imported out-of-state beverage containers occurring within their respective jurisdictions. 35 state and local law enforcement/code enforcement personnel attended the workshop. CalRecycle's objective is to secure assistance from state and local law enforcement personnel to detect, deter and interdict individuals illegally importing and/or attempting to illegally redeem out-of-state empty beverage containers for CRV. Additional outreach and education sessions will be conducted during 2015.

Notice was issued to all certified processors and posted on CalRecycle's webpage on November 12, 2014.

Initial notice was issued to all certified and registered program participants and posted on the CalRecycle webpage on November 12, 2014. Notice included a webpage link where select information submitted on Imported Material Reports (IMR) is posted for program participants to reference. Since issuance of the initial notice in November 2014, CalRecycle routinely posts updated IMR information to the CalRecycle webpage on a monthly basis

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

60-Day Agency Response

Finalize process and procedural documentation associated with the implementation of the Imported Empty Beverage Container Reporting and Inspection Program

Send a notice to all major truck rental companies and all recyclers currently operating in Arizona and Nevada to ensure and document that they have been educated and informed as to the illegality of redeeming, attempting to redeem, or aiding in the redemption of imported empty beverage containers.

Participate in a series of education and training sessions for local law enforcement agencies whose jurisdictional boundaries include CDFA operated Quarantine Inspection Stations and roads which can be used to bypass CDFA border stations.

November 12, 2014: DOR issued a notice to all certified processors regarding the current regulations as they pertain to receipt and processing of imported loads of single-stream recyclable materials which included imported empty beverage containers.

November 12, 2014: DOR issued a notice to all certified and registered program participants to inform them of information associated with persons importing empty beverage containers.

CalRecycle will release a Request for Proposal (RFP) by in 2015-2016 for the development of fraud estimates, by type of fraudulent activity, in an effort to quantify potential financial losses to the beverage container recycling fund.

Develop specific criteria to clearly identify/flag administrative cases in the Division of Recycling Integrated Information System (DORiis) which contain allegations of fraud.

The identified restitution and/or civil penalty amounts will serve as the basis for the calculation of the actual fraud amount by the type of fraudulent activity for the prior year.

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

Recommendation #3 To: Resources Recycling and Recovery, Department of

To allow for public input and to prevent any legal challenges claiming that its policies and procedures regarding prepayment holds constitute unenforceable underground regulations, CalRecycle should adopt these policies and procedures as regulations in accordance with the Administrative Procedure Act.

Annual Follow-Up Agency Response From October 2021

PRC section 14552(a) and section 14573.7 authorizes CalRecycle to establish and implement prepayment control auditing systems before authorizing payment for refund value, administrative costs, or administrative fees claims submitted by a processor, recycling center, curbside program, community service program, or dropoff or collection program. The Department has established a prepayment auditing process to protect the integrity of the BCRF as authorized by statute. CalRecycle is conducting rulemaking to clarify this process in regulations and anticipates submitting the rulemaking package to the Office of Administrative Law by December 2022. In addition, the process of developing and changing Regulations is being addressed by CalRecycle. The department has recently received resources to establish a Regulatory Unit within the Legal Division, DOR will benefit from this unit specializing in regulation development.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From September 2020

CalRecycle conducted three informal regulatory workshops on December 2015, February 2016, and May 2016. CalRecycle is in the process of drafting a regulatory package. The estimated date to submit a draft regulatory package to the Office of Administrative Law for initial public comment is June 1, 2021. The rules take effect on October 1, 2021.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2019

CalRecycle conducted three informal regulatory workshops on December 2015, February 2016, and May 2016. CalRecycle is in the process of drafting a regulatory package. The estimated date to submit a draft regulatory package to the Office of Administrative Law for initial public comment is December 31, 2019. The rules take effect on April 1, 2020.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2018

CalRecycle has conducted three (3) informal regulatory workshops: December 2015, February 2016 and May 2016. CalRecycle currently in the process of drafting the requisite regulatory package. The revised estimated completion date to submit draft regulatory package to OAL for initial public comment in 2019.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From November 2017

CalRecycle has conducted three (3) informal regulatory workshops: December 2015, February 2016 and May 2016. CalRecycle currently in the process of drafting the requisite regulatory package. The revised estimated completion date to submit draft regulatory package to OAL for initial public comment in 2018.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Annual Follow-Up Agency Response From October 2016

CalRecycle has conducted three (3) informal regulatory workshops: December 2015, February 2016 and May 2016. CalRecycle currently in the process of drafting the requisite regulatory package. The revised estimated completion date to submit draft regulatory package to OAL for initial public comment in 2017.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Informal Regulatory workshop schedule for 12/8/15. Target for promulgation of regulations September 2016.

California State Auditor's Assessment of 1-Year Status: Not Fully Implemented

6-Month Agency Response

CalRecycle will initiate a rulemaking procedure to, at a minimum, seek public input, clarify requirements, and detail processes pertaining to the pre-payment hold and inspection process. It is expected that the rulemaking process will take six to eighteen months to complete depending upon the number and complexity of comments received during the public comment period.

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

60-Day Agency Response

CalRecycle will initiate a rulemaking procedure to, at a minimum, seek public input, clarify requirements, and detail processes pertaining to the pre-payment hold and inspection process. It is expected that the rulemaking process will take six to eighteen months to complete depending upon the number and complexity of comments received during the public comment period.

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

Recommendation #4 To: Resources Recycling and Recovery, Department of

To ensure that all appropriate redemption payments are identified and made to the beverage program, CalRecycle should do the following:
- Contract with the California Board of Equalization (Equalization) to determine the feasibility and cost of transferring its revenue collections duties and audit reviews to Equalization.
- Should CalRecycle find that it is feasible and cost effective, it should pursue legislative changes that enable Equalization to collect revenues for the beverage program at the point-of-sale and remit the money to the beverage program.

Annual Follow-Up Agency Response From October 2016

A feasibility study and cost estimate was completed by Equalization in November 2015 to determine the feasibility and cost of transferring CalRecycle's revenue collection and audit duties to Equalization. For collection of revenue alone, the study estimated an annual increased cost to CalRecycle of $45 million and 514.2 PY's. CalRecycle would still be responsible for any administration costs and activities beyond collection. Based on the increased cost to the Fund, CalRecycle has determined that while technically feasible it is not cost effective to have BOE collect revenue at point of sale locations at this time.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

1-Year Agency Response

CalRecycle has entered into an agreement with Equalization to determine feasibility and cost of transferring its revenue collections duties and audit reviews to Equalization.

California State Auditor's Assessment of 1-Year Status: Not Fully Implemented

6-Month Agency Response

Meeting has been scheduled with BOE on May 12th to explore executing an interagency agreement to address recommendations in the findings. According to BOE there may need to be several meetings just to identify the scope of work and resources needed.

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

60-Day Agency Response

December 10, 2104 submitted a letter to Board of Equalization Chairman Jerome Horton.

If BOE agrees to proceed with a feasibility assessment, and the department in consultation with the board finds it is practical and cost effective, then an interagency agreement can be pursued. An ultimate determination of BOE's role in collecting CRV revenue will be informed by this assessment. Final determinations must be evaluated in the context of cost effectiveness and programmatic efficiency.

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

Recommendation #5 To: Resources Recycling and Recovery, Department of

To ensure it effectively uses resources, CalRecycle should renegotiate its agreement with the California Department of Justice (Justice) to pay based on the cases CalRecycle refers, limiting costs to investigations over a predefined period of time. CalRecycle could agree to increase the budget for a particular investigation if Justice demonstrates that it has developed promising leads.

Annual Follow-Up Agency Response From October 2018

CalRecycle evaluated the data and work the Department of Justice (DOJ) provided from the past DOJ contract. CalRecycle used this information in order to determine if there was a better way to identify the return on investment along with the effectiveness and efficiencies of each investigation. CalRecycle incorporated the lessons learned from its work with DOJ and the recommendations from the State Auditor when developing the next contract.

On June 27, 2017, CalRecycle entered into a new contract with the Department of Justice from July 1, 2017 through June 30, 2020. In order to ensure effective use of resources, the new contract added this specific language:

1. DOJ and CalRecycle will work together to prioritize referrals by potential harm to the Beverage Container Recycling Fund, expected time commitments on priority cases, an opportunity for both DOJ and CalRecycle to provide input on referral cases, and develop a written protocol for communication and information sharing.

2. The Quarterly Status report will include Attorney General Statistics.

3. DOJ will compile documentation that summarizes the overall DOJ arrests over the contract period and captures restitution ordered, evidence seized, and estimated fraud amounts of each case.

Since the beginning of the new contract, CalRecycle has ensured that DOJ has adhered to the new language. DOJ has provided the necessary data in order to ensure the continuous review of the effectiveness and efficiency of the contract by CalRecycle.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

Although CalRecycle's revised contract with the Department of Justice (DOJ) does not specifically address our recommendation, we believe that its actions resolve our overall concern. Specifically, as indicated on pages 36 and 37 of our report, our concern was that CalRecycle paid DOJ significantly more to investigate criminal activity than the financial recoveries that resulted from those efforts—in particular, we indicated that DOJ's investigations resulted in a return of less than 3 cents for every dollar paid to DOJ. Further, we noted that a single investigation could span multiple years. Thus, our recommendation was that CalRecycle pay based on the cases it refers to DOJ, limiting costs to investigations over a predefined period of time. CalRecycle could agree to increase the budget for a particular investigation if DOJ demonstrated that it has developed promising leads.

The revised contract calls for increased collaboration between CalRecycle and DOJ to prioritize investigations and establish expected time commitments on cases. The contract also requires DOJ to provide quarterly status reports that include, among other things, a budget summary, closed case summary, and number of arrests. Further, CalRecycle will review the performance of the agreement at the end of each fiscal year to ensure it is meeting the intended goals.

Annual Follow-Up Agency Response From October 2016

The construct outlined in CSA's recommendation for a renegotiated interagency agreement (IA) has been deemed unfeasible by both CalRecycle and DOJ. CalRecycle believes DOJ's past efforts are more significant than what was listed in the BSA Audit Report. CalRecycle will continue to work with DOJ under the existing interagency agreement construct to develop evidence based benchmarks to better capture results of their efforts. CalRecycle will also evaluate appropriate objectives and lessons learned from its work with DOJ when developing the next IA.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

The construct outlined in CSA's recommendation for a renegotiated interagency agreement has been deemed unfeasible by both CalRecycle and DOJ. CalRecycle believes DOJ's past efforts are more significant than what was listed in the BSA Audit Report. CalRecycle will continue to work with DOJ under the existing interagency agreement construct to develop evidence based benchmarks to better capture results of their efforts. CalRecyle also will evlauate appropriate objectives and lessons learned from its work with DOJ when developing the next IA.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

We stand by our recommendation. As we further describe on pages 36 through 39 of our audit report, CalRecycle pays Justice significantly more to investigate criminal activity than the financial recoveries that result from its efforts. CalRecycle provided no evidence to support its claim that Justice's past efforts are "more significant" than what was listed in our final report. Nevertheless, we are pleased that CalRecycle sees value in better demonstrating the financial return to the beverage program resulting from Justice's investigations.

6-Month Agency Response

At the quarterly meeting on April 22, 2015, both DOJ and CalRecycle discussed development and capture of improved performance metrics to highlight both the efforts and impacts of DOJ's investigations. Additionally, on May 20-21, CalRecycle will host a two-day workshop with representatives from Department of Justice/Bureau of Investigation and the Attorney General's Office. The workshop will identify issues and opportunities for enhancing our collective ability and authority to effectively combat beverage container program fraud associated primarily with the importation and subsequent illegal CRV redemption of out-of-state beverage containers.

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

60-Day Agency Response

CalRecycle & DOJ will continue our efforts to collaborate and pursue collective success under the terms, conditions and funding mechanisms in the current interagency agreement. CalRecycle will revisit this CSA Audit recommendation for potential implementation at the end of the term of the current interagency agreement which is currently June 30, 2017.

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

We stand by our recommendation. As we further describe on pages 36 through 39 of our audit report, CalRecycle pays Justice significantly more to investigate criminal activity than the financial recoveries that result from its efforts.

Recommendation #6 To: Resources Recycling and Recovery, Department of

To ensure that CalRecycle has consistent evidence of the results of completed prosecutions and the amounts ordered in restitution, it should develop a status report to be issued quarterly by the Attorney General's Office (attorney general) that summarizes, among other things, the status of pending cases, recently closed cases, and amounts of restitution that are due to the beverage program as a result of the attorney general's prosecutions.

1-Year Agency Response

CalRecycle has developed a report in a narrative form that summarizes the status of pending cases, recently closed cases, and amounts of restitution that are due to the beverage program as a result of the attorney general's prosecutions. This report is included in the quarterly report that we get from the Bureau of Investigation.

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

6-Month Agency Response

CalRecycle will work with the Attorney General's Office to develop the recommended status report.

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

60-Day Agency Response

CalRecycle will work with the Attorney General's Office to develop the recommended status report.

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

All Recommendations in 2014-110

Agency responses received are posted verbatim.