Report 2021-112 Recommendation 7 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 #7 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, and to prevent omissions in CACI reporting, DOJ should develop policies and procedures by November 2022 to reconcile CACI with monthly reports from Social Services to verify that counties have submitted—and DOJ has entered or deleted as appropriate—all reports into CACI.

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 develop processes in coordination with DSS, DOJ does not have statutory authority to directly obtain CWS/CMS data and therefore relies on DSS to identify and reconcile the reports. DSS does not currently have the ability to provide DOJ with automated monthly reports from CWS/CMS for reconciliation purposes.

To support implementation of this recommendation, DOJ has developed the capability to generate monthly reports that DSS and county welfare agencies can use to confirm that DOJ has received all records that DSS or the county welfare agencies have transmitted to DOJ, in any given month. Since January 1, 2025, DOJ has created monthly reports reflecting data received by DOJ and has made those reports available to DSS and county welfare agencies upon request. However, DOJ cannot reconcile the information within the DSS database. The long-term goal is to automate the distribution of these reports to counties through the electronic reporting solution, as described below.

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 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 to become operational is Aug 2026.

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 development of monthly reconciliation reports remains pending. On September 12, 2024, DSS indicated it would engage its development team—currently working on the new database set to replace the CWS/CMS—to incorporate the generation of monthly reports into the system's development requirements.

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 county agencies as each entity identifies missing or incomplete CACI reports and is also in discussions with DSS concerning a data exchange for reconciliation purposes. 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 a potential solution(s) and the next meeting is scheduled for June 2023. The DOJ and DSS have agreed to develop a monthly reconciliation report to ensure data reconciliation efforts are implemented going forward. The DOJ and DSS will be meeting in June 2023 to further discuss details.

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 can't be fully implemented as DOJ must depend on DSS and county data that are outside of its control. In the interim, DOJ has provided guidance to DSS, reiterating that counties must completely fill out the BCIA 8583 form in order to ensure the report is included in CACI. If counties accurately and fully complete their reporting, this will help avoid future discrepancies and the ongoing need for reconciliation. DOJ will continue to enter all completed BCIA 8583 forms that it receives from the counties. No further action is required for DOJ.

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 as DOJ must depend on DSS and county data that are outside of its purview. In the interim, DOJ has provided guidance to DSS, reiterating that counties must completely fill out the BCIA 8583 form in order to ensure the report is included in CACI. If counties accurately and fully complete their reporting, this will help avoid future discrepancies and the ongoing need for reconciliation. DOJ will continue to enter all completed BCIA 8583 forms that it receives from the counties.

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.