Report 2021-112 Recommendation 4 Responses
Report 2021-112: The Child Abuse Central Index: The Unreliability of This Database Puts Children at Risk and May Violate Individuals' Rights (Release Date: May 2022)
Recommendation #4 To: Justice, Department of
Until the Legislature amends state law and DOJ develops processes to use the CWS/CMS data for child abuse background checks, DOJ should collaborate with Social Services by November 2022 to identify and reconcile all reports that should have been submitted to CACI by counties. Work with counties to enter all missing reports into CACI by June 2023. This collaboration should not be limited to the reports in our four-year audit period.
Annual Follow-Up Agency Response From May 2026
DOJ's ability to implement this recommendation has been impacted by limitations in DOJ's statutory authority to access the information required to complete this work. While the recommendation directs DOJ to take action in coordination with DSS, DOJ does not have statutory authority to directly obtain CWS/CMS data and therefore must rely on DSS to identify and reconcile the reports.
As of May 2026, DOJ's understanding from information provided by DSS is that the reconciliation process for all reports requiring submission to the CACI, including those outside the audit period, has commenced and is ongoing. DSS reported that these broader reconciliation efforts involve reviewing CACI grievance hearing documentation within CWS/CMS, providing technical assistance to counties, and conducting follow-up to support accuracy in reporting. DSS is also working to incorporate BCIA 8583 forms into the CARES case management system in a future release, anticipated for 2027 or 2028.
DOJ has taken all actions possible within its existing statutory authority towards implementation of this recommendation, and further progress toward full implementation is dependent on continued reconciliation efforts by DSS and county welfare agencies.
In addition to working towards full implementation of this recommendation, DOJ has also engaged in collaborative discussions with DSS and county welfare agencies to design and implement an electronic portal through which BCIA 8583 forms can be submitted directly to DOJ. The objective of this solution is to enhance the accuracy, timeliness, and security of child abuse report submissions and to provide greater transparency to reporting counties regarding the status of their reports within the repository. The target date for the portal to become operational is August 2026.
- Estimated Completion Date: TBD
California State Auditor's Assessment of Annual Follow-Up Status: Pending
Per DOJ's response, it has not fully implemented this recommendation.
Annual Follow-Up Agency Response From October 2024
On September 12, 2024, DOJ informed DSS that it is reviewing options to prepare a data extract based on DSS's review and data requirements to facilitate the implementation of this recommendation. Collaborative discussions with DSS regarding data exchange requirements are ongoing.
The reconciliation process for all reports required for submission to the CACI has not yet commenced, as efforts have been focused on reconciling the 36,000 reports missing dates of birth and the 27,000 reports previously unsubmitted to the CACI.
- Estimated Completion Date: TBD
California State Auditor's Assessment of Annual Follow-Up Status: Pending
Per DOJ's response, it has not fully implemented this recommendation.
1-Year Agency Response
DOJ is working with the county agencies as each entity identifies missing or incomplete CACI reports. The DOJ and DSS are in discussions concerning a data exchange for reconciliation purposes. In June 2023, the DOJ is preparing a data extract of substantiated reports to provide to DSS. The DSS has indicated there are challenges with the CMS/CMS historical data, however, both agencies are in discussions concerning potential solution(s) and the next meeting is scheduled for June 2023.
- Estimated Completion Date: TBD
- Response Date: May 2023
California State Auditor's Assessment of 1-Year Status: Pending
Per DOJ's response, it has not fully implemented this recommendation.
6-Month Agency Response
This recommendation relies entirely upon DSS and the counties identifying the reports that should be in CACI, the counties then submitting complete BCIA 8583 forms to DOJ. DOJ has no way to identify reports that should have been submitted. However, DOJ will enter all completed BCIA 8583 forms that it receives from the counties. There is no further action for DOJ.
- Estimated Completion Date: Unknown
- Response Date: November 2022
California State Auditor's Assessment of 6-Month Status: Pending
Per DOJ's response, it has not implemented this recommendation.
60-Day Agency Response
This recommendation is not fully implemented because implementation of this recommendation requires the availability of several data sources that are outside DOJ's purview. These sources include DSS and county data that identify which substantiated child abuse reports meet the statutory requirements for inclusion in CACI. Currently, DOJ has no recourse to identify the reports that counties should have submitted to CACI. To secure reliable CACI background check responses, DOJ will continue to enter all completed BCIA 8583 forms that it receives from California's counties.
- Estimated Completion Date: Unknown
- Response Date: July 2022
California State Auditor's Assessment of 60-Day Status: Pending
Per DOJ's response, it has not implemented this recommendation.
All Recommendations in 2021-112
Agency responses received are posted verbatim.