2023-041 - Status of Recommendations - Table 2

6. To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: compile and aggregate the information from the facility approval forms into a database and take reasonable steps to ensure that the information is accurate and current.

7. To ensure that BRN is using up-to-date, accurate, and objective information to inform the governing board's enrollment decisions and to assess clinical capacity for student placements, by April 1, 2021, BRN should do the following: annually publish clinical capacity information on its website for public use.

9. To identify additional facilities that might offer clinical placement slots, by October 1, 2021, and annually thereafter, BRN should compare its nursing program database with OSHPD's list of health care facilities. BRN should share the results of its comparison with nursing programs by publishing this information on its website.

16. To ensure that it is able to meet its administrative monitoring obligations and that it uses housing bond funds in compliance with state law, regulations, and program guidelines, HCD should develop a long-term plan by January 1, 2019, for how it will avoid exceeding the administrative cost limits of those programs in the most immediate danger of overage and for how it will address instances when it has exceeded administrative cost limits. The plan should identify the programs at risk of exceeding the limit; the actions HCD will take for each program to gain efficiencies; its plan for moving staff between programs; a request for more money or legislative changes such as modifying the statutory limit on administrative spending, if necessary; and an evaluation of the consequences of not fulfilling its monitoring obligations.

18. To ensure that it complies with state law, prudently uses administrative funding, and promotes transparency, HCD should calculate and retain only funds equal to its actual administrative costs in instances when it does not disburse awarded funds to a recipient and subsequently grants the funds to another recipient.

19. To ensure that it does not exceed administrative cost restrictions and that it maximizes the funds intended to address target populations' housing needs, HCD should estimate when it will run out of administrative funds for any specific program, document its projection methodology, and provide underlying data and support for its estimates. The projections should include, but not be limited to, actual staff time spent on the program, the number of awards being monitored, and the length of monitoring. Staff should provide these projections and methodologies to management for review and approval by December 1, 2018, and then at least biannually thereafter.

3. To ensure its ability to more quickly provide CoCs with access to emergency funding that the federal government allocates to the State in the future, such as additional ESG-CV funding, the department should, by December 2021, develop a strategy that it can use in emergency situations to more efficiently complete or amend contracts and make funding available to recipients.

5. To ensure that it has the data necessary to measure the effect the ESG-CV program has in addressing homelessness, the department should immediately develop and implement a plan to collect outcome information either independently or through HDIS. Also, by March 2022, the department should begin reporting annually the outcome information it collects so that it can demonstrate the effectiveness of its programs and so that decision makers can use the reported data to inform budget and policy decisions.

4. To ensure that it adequately supports the vacancy rate adjustments it makes to needs assessments, by February 2023, HCD should perform a formal analysis of healthy vacancy rates and historical trends to inform those adjustments.

11. To better promote development of affordable housing on local surplus land, HCD should, by January 2023, update its guidelines on the local surplus property law to indicate how it will respond to instances where local agencies do not notify it of their intention to sell property before disposing of it, and where DGS was unable to issue a notice of violation before the sale. Further, HCD should seek legislative changes to the extent it believes they are needed to clarify its authority or the law.

12. To better promote development of affordable housing on local surplus land, HCD should, by January 2023, update its guidelines related to the local surplus property law to provide information on how it will assess and support good faith negotiations to mitigate the risk that local agencies may negotiate with developers in bad faith.

20. To ensure that counties include accurate information in their comprehensive plans and year-end reports, Community Corrections should review the information counties submit to it and follow up with them to obtain missing information or to clarify information that seems incorrect.

21. To better promote effective local efforts related to the JJCPA, Community Corrections should include on its website the capability for stakeholders, counties, and other interested parties to review and easily compare the JJCPA information of multiple counties. Specifically, its website should allow users to be able to select a specific type of JJCPA-funded program and easily review information the counties submitted for all programs associated with that program type. Community Corrections should determine the cost of providing this additional service and, if necessary, request additional resources.

4. To ensure that it efficiently and effectively administers state and federal grants, including any future emergency funds it might receive, Community Corrections should improve its standard grant policies and procedures by December 2021 to address the circumstances under which it will deviate from its solicitation requirements and the steps it will take to ensure that it informs all applicants--and potential applicants--of the deviations, such as by including this information in its grant solicitation or in subsequent communications made available to all potential applicants.

5. To ensure that it efficiently and effectively administers state and federal grants, including any future emergency funds it might receive, Community Corrections should improve its standard grant policies and procedures by December 2021 to address a thorough and documented evaluation of grant applications, including the justification for awards and an explanation of how it will solve instances in which an application does not comply with the solicitation's requirements, so that its decision to approve each application is justified.

6. To maximize the number of applicants that apply for grant funding, Community Corrections should ensure that its grant requirements are not overly burdensome and that they are achievable within the grant period.

8. To comply with federal and state requirements, and to ensure transparency, consistency, and fairness in its grant process, Community Corrections should post its grant procedures publicly on its website once it has improved its standard grant procedures.

9. To ensure that CDCR and the counties spend CESF funds appropriately and in a timely manner, Community Corrections should immediately develop and implement a plan to begin monitoring the use of CESF funds. This plan should include steps to ensure that it obtains and reviews required reports on time, takes action based on what it finds, and employs a strategy to identify potential instances of counties using CESF funds to supplant other funding.

19. To ensure that the county Partnership Committees report consistent and complete, and comparable information regarding their public safety realignment funding and activities, by September 2021, the Corrections Board should develop and distribute guidance to counties of its expectations for reporting financial information related to all public safety realignment accounts.

20. To ensure that the county Partnership Committees report consistent and complete, and comparable information regarding their public safety realignment funding and activities, by September 2021, the Corrections Board should develop and implement a process to review and analyze the information that counties provide about their realignment activities and expenditures each year.

21. To ensure that the county Partnership Committees report consistent and complete, and comparable information regarding their public safety realignment funding and activities, by September 2021, the Corrections Board should develop definitions for terms its asks counties to report on, including assault on staff and inmate risk level.

23. To ensure that the counties' detention facilities address health, fire, and life safety deficiencies in a timely manner and that the Governor and the Legislature are aware of these deficiencies, beginning with its next biennial report, the Corrections Board should incorporate inspection information that the state fire marshal and county departments of public health provide to counties into its corrective action process and its reports to the Governor and the Legislature.

24. To ensure that it provides state leadership and promotes best practices for counties to use, by March 2022, the Corrections Board should conduct an independent analysis of best practices, such as effective practices for restitution or rehabilitative programs, related to public safety realignment and publish the results.

25. To ensure that it provides state leadership and promotes best practices for counties to use, by March 2022, the Corrections Board should categorize the best practices it lists on its website for ease of reference to the counties.

26. To ensure that it provides state leadership and promotes best practices for counties to use, by March 2022, the Corrections Board should determine common county needs stemming from realignment and promote specific best practices that meet the common needs of counties, including best practices developed and adopted by California counties.

1. To increase public safety and reduce the likelihood of recidivism, Corrections should establish a separate category in the appropriate data system to track the individuals who would have qualified for the integrated services program. It should also ensure that staff in the institutions, including mental health clinicians and staff involved in prerelease planning, coordinate with parole to assign these individuals to parole agents with specialized caseloads who have the training and experience to serve this population. Corrections should focus its efforts on at least the eight counties that are losing the integrated services program and complete the steps noted in this recommendation by February 2021.

2. To increase public safety and reduce the likelihood of recidivism, Corrections should continue to meet with the appropriate staff in the behavioral health departments of the eight counties where the integrated services program currently operates to facilitate coordination among Corrections' staff, the providers, and the counties. The coordination should focus on smoothly transitioning current program participants to the county services they need and on developing processes for future parolees with mental illness and issues with homelessness who will transition to county services. Corrections should begin holding these meetings by October 2020 and continue them until all necessary processes are in place.

4. To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by determining the appropriate metrics to evaluate its processes and by setting goals related to those metrics.

5. To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by ensuring that it is collecting sufficient, consistent data to review those metrics.

6. To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by establishing a timeline for conducting reviews regularly, but at least every three years. Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

7. To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by reporting on its success in meeting its goals to the Council on Criminal Justice and Behavioral Health and the public. Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

8. To determine whether parolees with mental illness who have housing needs are receiving necessary services and support during their parole terms, Corrections should review its processes for connecting these individuals to county services by using the reviews to identify changes to improve its processes for connecting parolees to resources, including improving training for Corrections' staff.Corrections should develop its plan by July 2021 and include at least the eight counties formerly served by the integrated services program. Corrections should complete its first review by December 2021.

9. To communicate to both the public and its officers its commitment to performing its duties in a fair and impartial manner, CDCR should formalize a policy that aligns with best practices by, at minimum, declaring that biased conduct is prohibited, describing in detail what constitutes biased conduct, and outlining key compliance mechanisms.

14. To proactively identify signs that officers may need additional training or supports to address possible biased behavior, CDCR should, by April 2023, adopt a policy and implement procedures that align with best practices for an effective early intervention system. The system should do the following:
- Track and incorporate data at the officer level related to complaints, uses of force, and other indicators as appropriate, and use these data to identify officers who could benefit from early intervention.
- Specify a range of early intervention options—such as trainings, mentoring or other supervisory approaches, mental health services, or reassignment—with guidance about how to apply them to the particular circumstances of each officer's conduct. The system should require prompt interventions that address the identified issues with or patterns in the officers' conduct, including conduct related to bias.
- Require monitoring of the officers who receive intervention to evaluate whether their performance improves or whether additional interventions are needed.

15. To ensure that it adequately responds to potentially biased conduct, CDCR should continue to carry out its planned reforms of its misconduct investigation process. In doing so, it should adopt a clear and comprehensive definition of biased conduct, specify criteria for determining whether conduct meets that definition, document formal analysis of officers' conduct using the criteria, and provide training about how to perform these assessments.

16. CDCR should specify options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct and require that, when appropriate, these corrective actions—such as training and education—be part of the discipline that officers receive when they are found to have engaged in biased conduct.

17. To improve its ability to effectively investigate allegations of officer misconduct, by April 2023, CDCR should establish a time frame for equipping its remaining facilities with body-worn cameras and begin implementing that plan.

1. To ensure that Corrections has reliable tools for assessing the needs of its inmate population, it should validate COMPAS and CSRA by January 2020 and revalidate all of its assessment tools at least every five years.

8. To increase the space available for rehabilitation programs, by January 2020, Corrections should analyze and report on its current infrastructure capacity compared to its needs for the programs. The report should include the current space available and the square footage needed. If the report indicates that additional space is necessary, Corrections should work with the Legislature to address those needs.

13. To ensure that Corrections effectively and efficiently allocates resources and reduces recidivism, it should collaborate with C-ROB during fiscal year 2019-20 to establish annual targets for reducing recidivism and determining the cost-effectiveness of the programs. Corrections should also request federal grants tied to setting targets for recidivism reduction.

9. CalPIA should, in consultation with the Personnel Board, consider voiding appointments and requiring employees who acted in bad faith to return all compensation as the Table on page 22 [of the audit report] shows.

16. To ensure that Corrections is taking steps to reduce recidivism, C-ROB should monitor whether Corrections is developing appropriate recidivism targets and, in its annual report, should evaluate Corrections' progress toward meeting those targets.

1. To improve its ability to isolate each of its incentive programs' additional GHG reductions, by February 2022, CARB should establish a process to formally identify its incentive programs' overlap with other programs that share the same objectives. As part of that process, CARB should document how it will account for the overlap to allow the most accurate program measurement possible.

3. To improve its ability to identify the effectiveness of each of its incentive programs in reducing GHG emissions, by August 2021, CARB should develop a process to define, collect, and evaluate data on the behavioral changes that result from each of its incentive programs. Having done so, by February 2022, CARB should collect and analyze relevant survey information for all consumer-focused incentive programs, as well as information about the behavioral effects of programs that other entities offer, such as the federal tax credit.

4. To better assist the State in achieving its GHG goals, CARB should use the information we describe to refine its GHG emissions estimates for its incentive programs in its annual reports to the Legislature, the funding plans approved by its board, and any longer-term planning documents or reports.

11. To better demonstrate the socioeconomic benefits that its incentive programs achieve, by February 2022, CARB should do the following:
- Identify clear and measurable metrics it will use to assess each of the socioeconomic benefits it intends its programs to achieve.
- Develop a process to collect data, or use existing data, to measure and report on each metric.
- In its funding plans and annual reports, CARB should report to the Legislature and its board on the metrics.

12. To provide transparency to the Legislature and other stakeholders, beginning in 2022 and using the metrics and data described above, CARB should make funding and design recommendations in its funding plans and annual reports based on which programs are effective in producing socioeconomic benefits and at what cost.

14. To ensure that its incentive programs promote effective and equitable job training, by August 2021, CARB should develop a process to assess which programs should include a job training element. For those programs it identifies, by February 2022, CARB should direct its staff or its external program administrators to collect and report on the quality of job trainings and outcomes experienced by participants, including who received training, the credentials participants received as a result, any actual or expected wages they received as a result of participating in the training or for developing the relevant expertise, and the number of participants from disadvantaged communities or low-income communities and households.

3. To ensure that the public and policy makers have the information they need to make informed decisions, DTSC should, by no later than April 2021, identify and publicize a date by which it expects to complete cleanup for all properties that meet or exceed the standard for lead contamination of 80 ppm identified in DTSC's cleanup plan. It should post this information on its website and, at least every six months, publish an update that indicates whether it is on track to meet that expected completion date based on its rate of progress.

4. To ensure that it has sufficient funding to clean up all lead-contaminated properties in the cleanup site, DTSC should do the following:

-Identify the full amount of funding it needs to complete the cleanup of the 3,200 most contaminated properties and the remaining 4,600 contaminated properties. It should submit a request for funding in time for spring 2021 budget discussions that includes a range of funding options that spans from funding for the full cleanup to funding for only a portion of the remaining contaminated properties.

-Immediately revise its cost estimation methods to encompass the factors that it now knows will affect its overall costs. If needed, it should contract for expertise in determining accurate and complete estimates of the remaining cleanup cost.

7. If the State Water Board believes regulations are necessary to ensure that the regional boards and local jurisdictions follow its guidance regarding adequate and consistent information pertaining to their costs for storm water management, the State Water Board should adopt such regulations.

11. The State Water Board should revise its trash policy to focus it on local jurisdictions that have water bodies that are harmed by trash, as identified by the polluted waters list. In addition, the State Water Board should review the polluted waters list at least biannually to identify any additional water bodies recently determined to be harmed by trash and impose its trash policy on the applicable jurisdictions.

7. To minimize the prolonged periods during which Californians suffer without safe drinking water, the State Water Board should, by January 2023, develop metrics and performance benchmarks for key phases of the application and funding processes, including the number of days it should take to execute a funding agreement after it receives a complete application. It should also review recent past applications in light of these new metrics to identify common reasons for delays—including an increase in consolidation projects—and develop processes to overcome these delays.

8. To minimize the prolonged periods during which Californians suffer without safe drinking water, the State Water Board should, by January 2023, determine whether to change the way it assigns staff to projects, including whether to dedicate staff to working only on applications or on monitoring projects under construction.

14. To ensure that it has sufficient staff to process funding applications in a timely manner, by July 2023, the State Water Board should evaluate its progress in meeting its performance goals and assess whether its current staffing levels are sufficient. If the State Water Board finds that it needs additional staff to meet its goals or to prevent a backlog of applications, it should request additional funding from the Legislature to meet its staffing needs.

16. To ensure that it is maximizing the number of water systems that are aware of available technical assistance and funding options, including failing water systems and water systems serving disadvantaged communities, the State Water Board should immediately amend the contract with its current outreach provider to coordinate with the State Water Board to ensure that the provider does not work with systems already receiving technical assistance. The State Water Board should also develop a plan by January 2023 to avoid future outreach work that duplicates the efforts of its providers or of its staff.

23. To remedy the effects of the improper governmental activities this investigation identified and to prevent those activities from recurring, Food and Agriculture should require the DAA to establish a housing policy that outlines expectations for employees who stay overnight and includes a section on adequate recordkeeping to ensure that it charges applicable employees each time they stay overnight.

24. To remedy the effects of the improper governmental activities this investigation identified and to prevent those activities from recurring, Food and Agriculture should require the DAA to submit annual housing surveys to CalHR and to validate fair market value to determine the daily rate employees must pay each time they stay overnight and to subsequently charge employees that appropriate daily rate.

25. To remedy the effects of the improper governmental activities this investigation identified and to prevent those activities from recurring, Food and Agriculture should review other DAAs that provide state-owned housing to ensure that they have housing policies and that they charge employees appropriate daily rates for any overnight stays.

6. To improve the effectiveness of marketing of the Pet Lover's program, by August 2020, Food and Agriculture should contract with an eligible nonprofit organization, as state law allows, to carry out additional marketing and promotional activities for the program.

10. To ensure that the veterans homes receive all of the funding to which they are entitled, by the May 2019 budget revision, CalVet should seek an augmentation to its appropriation for the homes equal to the lease revenues it generated from July 2015 through June 2018. If CalVet believes the state law requiring lease proceeds to augment its appropriation is outdated, it should seek a change to state law.

8. To ensure that it does not authorize cost recovery, and the resulting rate increases, for activities that were part of a utility's previous general rate case, the CPUC should perform audits of the utilities' wildfire mitigation costs before approving recovery of those costs. In addition, the CPUC should implement sufficient safeguards to ensure the appropriateness of the costs passed on to customers

9. To ensure that utilities do not over-recover, or charge ratepayers more than they should for the activities they perform, the CPUC should make certain that if utilities request reimbursement for the costs questioned in the contractor audits, the utilities provide sufficient quantifiable and detailed analyses to substantiate that the costs were not paid for through the utilities' previously approved rates.

4. To ensure that it understands the statewide security status of reporting entities, CDT should increase its capacity to perform timely compliance audits of high-risk entities, which may entail hiring more staff or securing additional contracted audit support. Further, CDT should prioritize calculating maturity metric scores for the nine entities that it has audited but that do not yet have scores because it has not evaluated their privacy controls. CDT should complete these steps by the conclusion of the four-year oversight life cycle in June 2022.

5. Until it is able to conduct timely, objective audits of reporting entities, CDT should provide additional guidance to them by April 2022 on what constitutes a critical IT system and follow up annually to ensure that they complete the required self-assessments of those systems.

6. To ensure that it understands the statewide security status of reporting entities, CDT should utilize the information from the entities' self-assessments of their systems, as well as from the nationwide review, to annually help identify common areas that require improvement across multiple reporting entities.

5. To determine whether additional viable properties exist for affordable housing development, DGS should, by September 2022, contact the related agencies for the remaining properties it identified as potentially viable but for which it has not yet gathered additional information and make a determination as to the viability of the parcels those agencies possess.

6. To identify additional state-owned land suitable for affordable housing development, DGS should, by September 2022, develop a set of criteria to consistently evaluate state parcels for suitability as affordable housing sites.

7. To identify additional state-owned land suitable for affordable housing development, DGS should, beginning by July 2023 and every four years thereafter, conduct and document a review of all state-owned property and identify parcels that are potentially viable for affordable housing based on the established criteria. Once this review is complete, DGS should follow up with all possessing agencies to finalize property availability. Finally, DGS should work with HCD to prioritize the identified properties for development.

8. To increase the number of properties offered for affordable housing annually and to conduct a periodic review of all state owned properties, DGS should seek additional staffing as appropriate to provide dedicated support to the program, either by transferring existing positions or seeking a budget change for additional positions.

10. To improve the State's ability to track public property, DGS should do the following:

- By September 2022, begin reconciling the SPI and county assessors' real property records and update the SPI as necessary.

- Ensure that county and state real property records remain in alignment by reviewing records and resolving any mismatches in the year before each periodic review occurs.

1. Until such time as the Legislature authorizes Public Health to issue the emergency regulations to protect the health and safety of current and prospective hospice patients, Public Health should pursue its standard regulatory authority to address these issues.

11. To better ensure that children with lead poisoning are identified and treated, CDPH should prioritize meeting legislative requirements related to these issues, including doing the following by March 2020: Finish developing the lead risk evaluation regulations and include in them multiple risk factors, such as those used in lead risk evaluation questionnaires in other states. It should also commence the formal rulemaking process.

11. To improve the availability and transparency of information, Public Health should upload all inspection findings to Cal Health Find and review ownership data by May 2019.

6. To support LEAs' efforts to provide mental health services, Public Health should establish the support program for school health centers as state law requires. If Public Health lacks the funding to do so, it should request additional funds as needed. The support program should assist LEAs in establishing school health centers and in identifying and applying for available funding as authorized by law, such as Medi-Cal reimbursement and MHSA funds.

3. To comply with state laws and regulations and help ensure that staff involved in making governmental decisions during the grant process are impartial, Rehabilitation should ensure that they receive ethics training, which includes conflict-of-interest training, at least every two years.

13. To ensure that it provides sufficient oversight of the grant process, Rehabilitation should ensure that the technical review teams it assigns to grants provide the director and chief deputy with a memorandum summarizing the evaluation process and the evaluators' recommended grant awardees. Rehabilitation should also designate an individual responsible for reviewing and approving the memorandum and recommended awardees before it publishes its notice of intent to award.

14. If it finds errors in an evaluation that merit restarting the grant process, rescoring of applications, or convening a new evaluation panel, Rehabilitation should resolve any issues before it begins the rescoring process. It should also notify applicants to ensure that they are aware of any changes to the process due to the errors. Further, it should consider promulgating regulations and amending its grant manual to permit staff to request evaluators to rescore applications or convene a new evaluation panel when it finds issues with an evaluation.

15. To ensure that it consistently and thoroughly evaluates appeals, Rehabilitation should establish in state regulations and its grant manual that staff at the appropriate level of authority are to acknowledge all appeal requests, notify intended awardees that could be affected by the appeals, and inform the appellant of the qualifications of the review committee members. Staff at the appropriate level of authority must also notify all affected parties of the review committee's final decision within the time frame Rehabilitation establishes in regulations.

16. To ensure that Rehabilitation has appropriate oversight of its grant process and can sufficiently demonstrate that it followed the process, it should designate staff, separate from those involved in the respective grant process, to conduct a review of each grant process for procedural errors and evaluator prejudice, and whether evaluators supported their scores with evidence from the relevant applications before it awards grants.

17. To comply with federal and state requirements, and to ensure consistency and fairness in its grant process, Rehabilitation should revise and formalize the policies and procedures in its grant manual to incorporate the rules adopted by state regulation and to address the recommendations in this report. The grant manual should specify that any deviations from the required grant process must be for good cause and be documented.

18. To ensure that it consistently and thoroughly evaluates appeals, Rehabilitation should establish in state regulations and its grant manual a process for the review committees to request additional information from appellants or program staff. To allow time for an adequate review of any additional information, Rehabilitation should consider extending the time for review committees to issue their decision on appeals from 30 days to 45 days.

19. To ensure that it consistently and thoroughly evaluates appeals, Rehabilitation should establish in state regulations and its grant manual that to be able to rescore applications when necessary, the review committee members should be subject-matter experts or, if they are not subject-matter experts, the review committee should have the authority to recommend a new evaluation panel instead of rescoring applications itself when it identifies a reason to invalidate previous evaluations.

10. Until the Legislature amends state law and DOJ develops processes to use CWS/CMS, Social Services should immediately develop a process to collaborate with DOJ and counties to review the list of 27,000 reports of substantiated child abuse that were not in CACI and ensure that all eligible missing reports are forwarded to DOJ.

11. Until the Legislature amends state law and DOJ develops processes to use CWS/CMS, Social Services should by November 2022, develop monthly reports from CWS/CMS of cases of child abuse substantiated during the month and another list of cases that changed from substantiated to not substantiated, and then provide these reports to the counties and to DOJ.

12. Until the Legislature amends state law and DOJ develops processes to use CWS/CMS, Social Services should, by November 2022, ensure that all counties develop policies and procedures to review the monthly reports produced by Social Services and ensure that they have sent all appropriate reports to DOJ.

13. Until the Legislature amends state law and DOJ develops processes to use CWS/CMS, Social Services should, by November 2022, collaborate with DOJ to identify and reconcile all reports that should have been submitted to CACI by counties and work with counties to send all reports to CACI by May 2023. This collaboration should not be limited to the reports of our four-year audit period.

4. To help ensure that all recipients throughout the State receive prompt approval for services and receive all approved services, by August 2021 and annually thereafter, Social Services should require counties to submit required annual plans. These plans should include, at a minimum, a description of how each county will ensure that services are promptly approved and that recipients promptly receive the approved services.

5. To help counties prepare to meet future needs for IHSS services, Social Services should revise its regulations to require counties to include long-range projections and strategies in their annual plans.

6. To help ensure that recipients receive timely care, Social Services should, by August 2021, begin monitoring counties' compliance with the following: Approval of IHSS applications within 30 days, unless an extension for obtaining a medical certification applies. Prompt approval of IHSS applications for which the 45-day extension for a medical certification applies. Provision of services within 15 days of application approval.

7. For counties that struggle to comply with its regulations regarding providing timely services, Social Services should require—and regularly follow up on—corrective action plans from these counties.

4. In implementing our recommendations, CDSS should ensure that it does not unduly slow the delivery of P-EBT payments and that its notifications allow families sufficient time to use P-EBT payments before the payments expire.

1. To ensure that regional centers can better meet the required caseload ratios for all consumer groups, DDS should work with the regional centers, the Association of Regional Center Agencies (ARCA), and other state entities as necessary to update the core staffing formula to align with actual regional center staffing costs by June 2023.

2. To ensure that regional centers can better meet the required caseload ratios for all consumer groups, DDS should review and update as necessary the core staffing formula annually to ensure the continued adequacy of regional centers' salaries.

3. To ensure that regional centers conduct vendor monitoring as state law requires, DDS should, by October 2022, provide an initial training to all regional centers about the statutory requirements for vendor monitoring. This training should include the information the regional centers must assess as part of their quality and qualification reviews for each type of vendor, as well as best practices for ensuring that they complete all required reviews.

5. To ensure that regional centers conduct vendor monitoring as state law requires, DDS should, by January 2023, identify best practices among regional centers for tracking their quality reviews to ensure that they are completed as frequently as state law requires.

6. To ensure that regional centers conduct vendor monitoring as state law requires, DDS should develop guidelines for all regional centers to follow to ensure that they complete all required quality reviews.

7. To ensure that its processes are sufficient for identifying regional centers' noncompliance, DDS should, by January 2023, evaluate its processes for monitoring regional centers' performance of quality and biennial reviews.

8. To ensure that consumers have convenient access to services, DDS should establish standards for measuring consumers' access to services by January 2023.

9. To ensure that consumers have convenient access to services, DDS should continue to develop its new system for consumer records and ensure that the new system has the capability to allow regional centers to enter specific data elements that will enable them to assess the convenience of consumers' access to services using the established standards.

11. To ensure that regional centers provide statutorily required information to consumers about how to file a consumer rights complaint, DDS should, by January 2023, review all the written information that regional centers provide to consumers and the regional centers' procedures for providing this complaint process information to consumers.

7. To ensure that it has sufficient data to better identify usage barriers and disparities, DDS should update its in-home respite data by February 2023 to periodically track the amount of respite hours authorized and used by each regional center, and the usage of each service delivery option (Agency, EOR, or FMS). DDS should use this information and the data it already collects from the regional centers to identify potential limits, trends, and disparities related to in-home respite services. DDS should, at a minimum, analyze the usage of and authorization for in-home respite services across the categories we list in the report. That analysis should identify any disparities statewide, at individual regional centers, or among regional centers. If DDS identifies problematic disparities that suggest barriers to the use of in-home respite services, then it should take action to address them. For example, DDS should direct regional centers with low FMS usage to conduct additional outreach to ensure that families are aware of the benefits of this option.

8. DDS should review the policies of all 21 regional centers by October 2022 to ensure that they do not contain provisions imposing overall limits on the amount of in-home respite service hours authorized for families to receive each quarter and require revisions as necessary.

9. DDS should develop standard outreach materials by February 2023 that present key information about each respite service delivery option, including a description of each option and its benefits and drawbacks. It should provide these outreach materials in multiple languages on its website and to all regional centers to include on their websites and disseminate to all of the families that use centers' services so that they have the knowledge and opportunity to select the option that best fits their needs.

10. DDS should amend its contracts with the 21 regional centers by February 2023 to require all regional centers to have a plan for ensuring that they have an adequate number of service providers for all in-home respite service delivery options, including the FMS option.

11. DDS should amend its contracts with the 21 regional centers by February 2023 to direct them to train their service coordinators to explain the benefits of each of the in-home respite service delivery options so that families can determine which option will work best for them.

1. Because of the severe and potentially permanent damage that lead poisoning can cause in children, DHCS should ensure that all children in Medi-Cal receive lead tests by finalizing, by December 2020, its performance standard for lead testing of one- and two-year-olds. DHCS should use its existing data to assess the progress of managed care plans in meeting that performance standard and impose sanctions or provide incentive payments as appropriate to improve performance.

2. To ensure that families know about the lead testing services that their children are entitled to receive, DHCS should send a reminder to get a lead test for children who missed required tests. It should send this reminder in the required annual notification it is developing to send to families of children who have not used preventive services over the course of a year.

3. To increase California's lead testing rates and improve lead test reporting, DHCS should, by no later than June 2020, incorporate into its contracts with managed care plans a requirement for the plans to identify each month all children with no record of receiving a required test and remind the responsible health care providers of the requirement to test the children. DHCS should also develop and implement a procedure to hold plans accountable for meeting this requirement.

4. By September 2019, and periodically thereafter, DHCS should conduct another risk assessment and ensure that it includes a comprehensive evaluation of which contract areas—including conflicts of interest—it should focus on in its annual medical audits.

5. Going forward, DHCS should conduct a comprehensive risk assessment and ensure that it reviews health plans' conflict-of-interest controls at least once every three years.

6. DHCS should develop and issue an All-Plan letter or other binding guidance by March 2020 to the health plans that specifically defines what constitutes reasonable and necessary administrative expenses.

7. DHCS should provide guidance to health plans on what is a reasonable bonus program. In doing so, DHCS should perform the necessary oversight to ensure health plans comply with this direction.

1. To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, begin monitoring statewide alerts related to individuals identified as eligible for Medi-Cal in a county eligibility data system but not identified as eligible in the state eligibility system.

3. To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, expand its workgroup planning efforts to address all high-risk eligibility alerts included in the pilot program.

4. To reduce inappropriate payments made to medical providers and ensure eligible individuals' access to care, Health Care Services should, by August 2021, resume monitoring pilot program counties' progress in resolving high-risk eligibility alerts.

6. To ensure that it is addressing weaknesses in the counties' processes for making eligibility redeterminations, Health Care Services should resume county monitoring via focus reviews within four months of the end of the public health emergency.

1. To ensure that beneficiaries in Regional Model counties have adequate access to care, DHCS should identify by August 2020 the locations requiring additional providers and the types of providers required. It should also develop strategies for recruiting and retaining providers in those locations. If it requires additional funding to complete this assessment or to implement actions to address its findings, DHCS should determine the amounts it needs and request that funding from the Legislature.

11. To ensure that it makes informed decisions regarding the extension or renewal of its contracts with managed care health plans, DHCS should immediately begin the practice of requesting annual feedback from the counties that the health plans serve and of using that feedback in its decision-making process.

13. To ensure that beneficiaries in the Regional Model counties have reasonable access to care, DHCS should evaluate by June 2020 whether the structural characteristics of a COHS Model would be better suited to providing reasonable access to care in the Regional Model counties and notify the counties whether a COHS would improve beneficiaries' access to care. If some or all of these counties desire to transition to a COHS, DHCS should assist them in making that change after their current contracts expire.

14. To ensure that beneficiaries in the Regional Model counties have reasonable access to care, DHCS should evaluate by June 2020 whether it has the financial resources to provide assistance to counties interested in establishing a COHS or other managed care model after the current Regional Model contracts expire. If DHCS does not have the required financial resources, it should seek an appropriate amount of funding from the Legislature.

2. To recover inappropriately spent funds, prevent future erroneous payments, and ensure eligible individuals' access to care, Health Care Services should resolve the discrepancies we identified and recover erroneous payments where allowable by June 30, 2019.

3. To prevent future erroneous payments, Health Care Services should implement procedures by December 31, 2018 to ensure the timely resolution of system discrepancies. These procedures should include Health Care Services regularly following up on recurring, unresolved system discrepancies with the responsible county.

4. To prevent future erroneous payments, Health Care Services should establish procedures by December 31, 2018 that define when it will use its authority as defined in state law to sanction unresponsive counties that do not remedy known discrepancies.

6. To assist counties in addressing discrepancies, Health Care Services should reevaluate and update its guidance to the counties related to prioritizing MEDS alerts by December 31, 2018.

6. To increase access to preventive health services for children in areas where they are needed most, DHCS should identify by September 2019 where more providers who see children are needed and propose to the Legislature funding increases to recruit more providers in these areas.

8. To ensure that eligible children and their families know about all the preventive services they are entitled to through Medi-Cal, DHCS should include by May 2019 clearer and more comprehensive information about those services in its written materials and by September 2019 ensure annual follow-up with any children and their families who have not used those services.

11. To ensure that plans address underutilization of children's preventive services, DHCS should require plans by September 2019 to use their utilization management programs to identify barriers to usage specifically for these services and hold the plans accountable to address the barriers they identify.

12. To better ensure the accuracy of its data and ensure that California receives all available federal Medicaid funding, DHCS should require its EQRO to perform its encounter data validation studies annually using the most recent set of data available, and it should implement recommendations from its EQRO studies.

13. To ensure that plan provider directories are accurate, by September 2019, DHCS should begin using a 95 percent confidence level and not more than a 10 percent margin of error on its statistical sampling tool and should require at least 95 percent accuracy before approving a plan's provider directory. In addition, DHCS should ensure that its staff adhere to its policy to retain all documentation related to its review of provider directories for at least three years.

14. To mitigate health disparities for children of differing ethnic backgrounds and language needs, DHCS should revise by September 2019 the methodology for its EQRO's health disparity study to enable it to better make demographic comparisons, and it should use the findings to drive targeted interventions within plan service areas. It should publish this study annually.

16. To help increase utilization rates, DHCS should begin by September 2019 to monitor and identify effective incentive programs at the plan level and share the results with all plans.

18. To improve its ability to ensure that children are receiving recommended preventive health services, DHCS should create by September 2019 an action plan to annually address the EQRO's recommendations relating to children's preventive services, including recommendations left unaddressed from the previous two years' reports.

2. To ensure that health plans address underutilization of children's preventive services, DHCS should require plans to use their utilization management programs to identify barriers to usage specifically for these services and hold the plans accountable to address the barriers they identify.

3. To better ensure the accuracy of its data and ensure that California receives all available federal Medicaid funding, DHCS should require its External Quality Review Organization (external reviewer) to perform its encounter data validation studies annually using the most recent set of data available, and it should implement recommendations from its external reviewer studies.

4. To mitigate health disparities for children of differing ethnic backgrounds and language needs, DHCS should revise the methodology for its external reviewer's health disparity study to enable it to better make demographic comparisons, and it should use the findings to drive targeted interventions within health plan service areas. It should publish this study annually.

6. To ensure that eligible children and their families know about all the preventive services they are entitled to through Medi-Cal, DHCS should include clearer and more comprehensive information about those services in its written materials and ensure annual follow-up with any children and their families who have not used those services.

7. To ensure that health plan provider directories are accurate, DHCS should begin using a 95 percent confidence level and not more than a 10 percent margin of error on its statistical sampling tool and should require at least 95 percent accuracy before approving a health plan's provider directory. In addition, DHCS should ensure that its staff adhere to its policy to retain all documentation related to its review of provider directories for at least three years.

8. To increase access to preventive health services for children in areas where they are needed most, DHCS should identify where more providers who see children are needed and propose to the Legislature funding increases to recruit more providers in these areas.

6. To ensure that local mental health agencies appropriately spend MHSA funds, Health Care Services should publish its proposed regulations in the California Regulatory Notice Register by September 2018. It should then develop and implement an MHSA fiscal audit process, independent of the Medi-Cal reviews, to review revenues and expenditures for the most recent fiscal year.

12. To ensure that it awards funds to applicants who address the need for providers in health professional shortage areas, Health Care Services should amend its application selection process to require by June 2021 that all participants practice in geographic areas that have shortages of such health care professionals, and annually verify that participants continue to practice in such areas.

12. Health Care Services should use current data to revise and update the peer groups it uses to set Medi-Cal rates. In doing so, it should take into consideration the consolidation of the nursing facility industry.

1. Within 30 days, the Department of State Hospitals (State Hospitals) should consult with the California Department of Human Resources (CalHR) to obtain its determination about whether telepsychiatrists meet the criteria for safety retirement benefits. If CalHR determines that telepsychiatrists do not meet the criteria for safety retirement benefits, take immediate action to reclassify telepsychiatrists to the appropriate retirement category and notify all affected employees.

2. Within 30 days, State Hospitals should consult with CalHR, the California Public Employees' Retirement System, and the State Controller's Office (SCO) to retroactively correct any errors made to affected employees' retirement contributions, including Social Security deductions.

3. Within 60 days, State Hospitals should distribute CalHR's policy on the safety retirement benefits designation to HR staff at each state hospital facility and instruct staff to consult with CalHR as the law requires.

10. To ensure that the MHSA-funded triage grants are effective, the Oversight Commission should require that local mental health agencies uniformly report data on their uses of triage grants. It should also establish statewide metrics to evaluate the impact of triage grants by July 2018.

10. To ensure that it provides the public with nursing facility information that is accurate and comprehensible, Health Planning should update its regulations to do the following:

- Append additional schedules to the template for the annual cost report to enable nursing facilities to fully disclose related-party transactions.

- Provide a single location in the annual cost report template for nursing facilities to enter related-party transaction amounts next to the amounts they are claiming for Medi-Cal reimbursement.

- Create an additional schedule in the cost report template that depicts how a company is investing in quality-of-care improvements.

4. To ensure that students with disabilities have equal access to instructional materials, by June 2018, the Chancellor's Office should develop guidance for the community colleges on periodically monitoring the accessibility of instructional materials and on providing training to all instructors in making their materials accessible to students with disabilities.

7. To assist all community colleges in increasing transparency of their shared governance decision-making processes, by September 2018, the Chancellor's Office should issue guidance to the community colleges on establishing procedures to document the attendees, input received, and agreements reached during department meetings, including those to consider technology equipment requests.

2. To enhance the quality of information the selection committees have available when determining whether applications best meet the workforce program's goals, beginning with the fiscal year 2022-23 grant application period, the Chancellor's Office should provide examples that address all of the eligibility criteria.

3. To improve CSU's financial transparency with students and other stakeholders, the Chancellor's Office, with the approval of the trustees, should revise CSU policy by October 2019 to require that it publish information about CSU's discretionary surplus. At a minimum, the Chancellor's Office should revise its reserve policy to establish and justify a minimum sufficient level of reserve for economic uncertainty and require the Chancellor's Office to provide additional oversight to ensure that CSU maintains that level. This oversight should include monitoring, approving, and notifying the trustees of any uses of the reserve for economic uncertainty.

9. The Chancellor's Office should require that, by October 2019, the campuses publish the names of the alternate transportation committee members, the committee meeting minutes, and the committee meeting schedule on their parking and transportation services websites.

3. To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should revise its fee policy to require campuses to justify amounts for new or increasing fees by providing supporting documentation demonstrating the need for the fees, how they calculated the fee amounts, and how they determined that no other source of funding could pay for the needed services.

4. To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should extend its review responsibilities to include increases to existing mandatory fees.

5. To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

1. To protect the fairness and integrity of its admissions processes, the Office of the President should establish systemwide protocols for admissions processes by the fall 2021 admissions cycle that prohibit the following:
- Giving authority to any one person to make a final admissions decision.
- Consideration of an applicant's familial or other personal relationships to university staff or faculty in an admissions decision.
- Communication between a campus's development office and its admissions office about applicants and prospective applicants.

2. To protect the campuses' athletics admissions process from abuse, the Office of the President should require each campus to do the following by the fall 2021 admissions cycle:
- Have at least two reviewers verify the athletic talent of all prospective student athletes before their admittance. At least one of these reviewers should be from a department other than the athletics department. Each campus should develop standards for the level of talent that prospective student athletes for each of its teams must possess and then use those standards to verify the talent.
- Track student athletes' participation in the sport for which they were recruited. If a student does not participate in the sport for longer than one year, the campus should determine the reason why the athlete stopped participating and, if necessary, conduct a review of the circumstances that led to the student's admission to identify signs of inappropriate admissions activity.
- Review donations to athletic programs to determine whether those donations made before or after an athlete's admission may have influenced the athletic department's decision to request the athlete's admission.

4. Beginning with the fall 2021 admissions cycle, the Office of the President should oversee UC Berkeley's admissions process for at least three years. The Office of the President should ensure that all admissions decisions are merit-based and conform to the university's policies on admissions. Further, the Office of the President should facilitate the establishment of a culture of ethical conduct in admissions by providing regular training to admissions and development staff, conducting reviews of admissions decisions, and monitoring the admissions office's communications about applicants to ensure no inappropriate factors influence admissions activities.

5. To ensure that the university maintains a fair and consistent admissions process, the Office of the President should require each campus to take the following actions:
- By March 2021, document and implement a selection methodology that describes how it will choose applicants for admission, particularly when the applicants have received similar ratings from application readers. Further, the selection strategy should specify the reasons why a campus may choose an applicant with a low or uncompetitive rating instead of an applicant with a higher rating.
- Develop and implement processes to use when selecting applicants for admission for identifying applicants whom it has selected for admission and who are not eligible for admission to the university, and record their rationale for admitting those applicants despite their ineligibility.

7. To ensure that the university maintains a fair and unbiased admissions process, the Office of the President should require each campus to take the following actions:
- By March 2021, establish acceptable levels of application reader proficiency and maintain training and monitoring programs that ensure that its readers attain and sustain those levels. In addition, it should report annually to BOARS on those efforts and on reader consistency levels, including the frequency with which reader ratings align with campus guidelines for
rating applications.
- Beginning with the academic year 2021-22 admissions cycle, require each campus that does not admit all eligible transfer applicants to ensure that two readers review all transfer
applications.
- Beginning with the academic year 2021-22 admissions cycle, ensure that the second readers cannot see the ratings of first readers for both freshman and transfer applications.

8. To better ensure that implicit bias in the evaluation of applications does not affect applicants' chances at admission, the Office of the President should remove potentially biasing information from the application information that campuses can access.

10. To better safeguard the integrity of the university's admissions processes, the Office of the President should, by July 2021, begin conducting regular audits of the admissions processes at each of its undergraduate campuses, ensuring that it reviews each campus at least once every three years. These audits should be conducted by systemwide audit staff and include, but not be limited to, verification of special talents, communication between admissions staff and external parties regarding applicants, and other avenues for inappropriate influence on admissions discussed in this report. The audits should also endeavor to identify inappropriate admissions activity and deficiencies in the admissions process. The Office of the President should make the results of the audits public.

14. To maximize the available HEERF funds, UC Merced should review expenses it incurred in response to the pandemic since January 2020 and submit all eligible expenses to FEMA for reimbursement. The campus should reallocate any HEERF funds initially spent for these expenses to other purposes, such as replacing lost revenue or providing additional student aid.

15. To ensure that UC Merced receives all available federal funds, its office of student affairs should monitor its emails for grant award notifications and develop policies and procedures to review all federal award announcements to determine whether it is named as a recipient.

16. To comply with federal regulation, UC Merced should promptly spend the remainder of its CARES MSI funds and return the interest earned on those funds in excess of $500 to the federal government.

4. To make its appeal process more accessible to families who may not receive a satisfactory resolution from its contractors, Education should, by October 2018, require that its contractors share key information in their communications with families about the process for appealing notices. The required information should include valid grounds for a family to file an appeal as well as information or documentation Education would need in order to review the family's appeal of adverse decisions regarding their child-care services. Education should also require contractors to incorporate this information into contractually mandated staff training and into publicly available policies and procedures.

11. To ensure that its contractors can effectively make program improvements and maintain successes in ways that are meaningful to their stakeholders, Education should adopt measures to ensure its contractors follow the terms of their contracts by demonstrating that their board members conduct a critical appraisal of each education program.

3. To ensure that LEAs effectively use their ESSER and GEER funds before the spending deadlines to mitigate the effects of the pandemic on students, Education should develop a robust process for tracking LEAs' spending of these funds. As part of this process, Education should regularly assess LEAs' spending data to identify those that may be in jeopardy of not spending all of their allocations before the deadlines. This assessment should include projecting LEAs' future spending based on their spending patterns.

4. To ensure that LEAs effectively use their ESSER and GEER funds before the spending deadlines to mitigate the effects of the pandemic on students, Education should develop a robust process for tracking LEAs' spending of these funds. As part of this process, Education should follow up with identified LEAs to determine whether they have plans for spending all of their funds before the deadlines and whether these plans are reasonable.

16. To obtain its full share of the fiscal year 2017-18 Proposition 56 revenues, Education should negotiate with Finance and Public Health to ensure that it receives the full amount of its proportional share of the fiscal year 2017-18 Proposition 56 funds.

34. To ensure that it has the resources necessary to effectively meet its responsibilities under federal law, Education should complete a staffing analysis by May 2020 to determine the resources needed to meet its responsibilities for homeless education. This analysis should consider the resources needed to implement all of the recommendations in this report.

35. If Education determines that it needs additional resources, it should take the necessary steps, including reallocating existing resources within the department, to secure the needed resources.

2. To promote the adoption of the best practices that it has identified, Education should remind LEAs of the elements in its model policy. To do so, it should annually send a notice to all LEAs that describes suicide prevention resources, such as the model policy, and encourages their use. Education should also work with external organizations that maintain model policies, including the School Boards Association, to encourage the development of policies that are consistent with state law and best practices by no later than September 2021.

3. To encourage LEAs to incorporate elements of suicide prevention training that provide teachers and staff with the knowledge necessary to assist students at risk of self-harm and suicide, Education should remind all LEAs of the statutorily required elements for suicide prevention training.

4. To ensure consistency and transparency in overseeing QMEs, DWC should, by April 2020, develop and implement written policies and procedures that define and specify its internal processes for disciplining QMEs, including timelines for taking disciplinary action and for scheduling hearings or responding to settlement proposals.

5. To ensure consistency and transparency in overseeing QMEs, DWC should, by April 2020, develop and implement written policies and procedures that define its internal process for reappointing QMEs and how that process should proceed if any disciplinary investigations are pending.

7. To minimize the degree to which its process to change its regulations may result in the disparate treatment of card room owners, the bureau should temporarily approve or deny its backlogged games applications by July 2019.

12. To better align the revenue in the Gambling Fund with the costs of the activities that the fund supports, the bureau and the commission should conduct cost analyses of those activities by July 2020. At a minimum, these cost analyses should include the following:

-The entities' personnel costs, operating costs, and any program overhead costs.

-Updated time estimates for their core and support activities, such as background investigations.

-The cost of their enforcement activities.

Using this information, the bureau and commission should reset their regulatory fees to reflect their actual costs. Before conducting its fee study, the bureau should implement our recommendations to improve its processes for assigning applications, ensuring the completeness of applications, and developing time-reporting protocols.

21. To ensure that it can provide useful and accurate data on the locations where enforcement employees spend their time, the bureau should equip its time-reporting system by November 2019 with the capacity to track all hours employees spend at each card room and casino

2. To improve its ability to investigate possible fraud and abuse, DOJ should provide guidance to Public Health about the types of information Public Health should include when it refers complaints that allege fraud to DOJ. Further, DOJ should also document a procedure for following up on complaints that do not include adequate information.

4. To increase the effectiveness of hate crime prevention and response efforts, DOJ should provide additional guidance to law enforcement agencies by analyzing reported hate crimes in various regions in the State and sending advisory notices when it detects hate crimes happening across multiple jurisdictions. It should also seek the resources to implement these efforts, if necessary.

6. To ensure that its employees allocate their activities to the correct funding sources, the Bureau should:

-Formalize procedures for employees on how to properly track their time, including which activities may be charged to the distribution fund, and provide training on those procedures by October 2022.

-Conduct quarterly audits of employee timekeeping to ensure that employees appropriately track their time and that supervisors appropriately review and approve employee timesheets, beginning with the first quarter of fiscal year 2022-23.

-Continue with its planned rollout of a new timekeeping system in January 2025 and ensure that the new system does not allow employees to charge nontribal activities to the distribution fund.

3. Until the Legislature amends state law and DOJ develops processes to use the CWS/CMS data for child abuse background checks, DOJ should immediately develop a process for responding to child abuse background checks that includes checking CACI and the list of 298 reports of child abuse that were not supported by county records, and working with the California Department of Social Services to check the list of 27,000 reports of substantiated child abuse that were not contained in CACI. If the individual is on either list, DOJ should follow up with the relevant county to determine whether the individual's report should be included in CACI.

4. 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.

7. 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.

8. To ensure that authorized users have accurate and complete information, by July 2022, DOJ should send revised letters for the suspects whose reports of child abuse were omitted from CACI and for individuals inappropriately included in CACI. To ensure that it is able to revise expedited letters if they are later determined to be incorrect, DOJ should immediately begin maintaining a history of all responses to expedited background checks.

9. To ensure that suspects' information is deleted from CACI in accordance with state law, by November 2022, DOJ should research and address the 36,000 reports in CACI lacking birth dates by entering the suspect's correct birth date and removing suspects who no longer meet the CACI requirements.

6. To help address California's e-commerce tax gap and further ensure out-of-state retailers' compliance with state law regarding nexus, Tax Administration should implement a two-year pilot of its authorized reward program for information resulting in the identification of unreported sales and use taxes.

12. To ensure that it fulfills its responsibilities under state law, Cal OES should, by no later than June 2020, issue the guidance that state law requires it to produce related to access and functional needs, including guidance related to establishing disaster registries and guidance on evacuating people with access and functional needs.

13. To ensure that it adequately equips local jurisdictions to send alert and warning messages in languages that their residents will easily understand, Cal OES should do the following: provide clear direction to individuals who speak English so that they know which of the translated messages they should use in what specific circumstances; revise the messages it has provided so that local jurisdictions can more easily adapt them for use in a variety of disaster situations; expand its style guide to include terminology that emergency managers are likely to need to effectively modify their local messages and also to include translations for the other commonly spoken languages in the State.

4. To adhere to the Lottery Act's education funding requirements, beginning with fiscal year 2020-21, the Lottery Commission should require its staff to demonstrate that they have planned for education funding to be maximized and aligned with the proportionality requirement of the Lottery Act, and approve only those budgets that plan for such funding. It should then monitor actual education funding and ensure that it complies with the requirement.

7. To ensure that it receives value for the funding it spends on its fairs program, by January 2021, the Lottery should determine whether the program has increased its brand strength, customer loyalty, customer satisfaction, ticket sales, and profits. If the analysis determines that the Lottery has not achieved these benefits, it should terminate the program.

5. To ensure that the allocation of bonds aligns with the State's housing priorities and that its awards process is sufficiently transparent, the Tax Committee should, by May 2021, establish regulations to do the following:
- Consistently allocate bonds based on factors including demand for bond resources, use of previously allocated bonds, documented legislative priorities, and risk of allocated bonds being lost.
- Document and disclose annually in its public meetings and on its website the extent of any bonds lost, the purpose for which the bonds were allocated, and the rationale for the allocation.

14. To maximize the resources available for its core functions, CJP should immediately begin exploring options for relocating its office to a less expensive location and relocate as soon as possible.

5. To ensure that it is operating efficiently, the State Bar should assess the impact of its discipline system reorganization, including determining how the changes have affected its ability to efficiently resolve cases and fulfill its mandate to protect the public. Based on the assessment's results, the State Bar should determine whether additional changes to its organizational structure are warranted.

6. To determine whether the changes to its discipline process have been effective and to help it identify problems in specific phases of its process before they affect the backlog, the State Bar should implement methods to monitor its enforcement process performance, including comparing the trial counsel staff 's performance against its benchmarks.

8. To reduce its backlog of discipline cases and ensure that it has appropriately allocated resources to all phases of its discipline process, the State Bar should determine the staffing level necessary to achieve the goal it develops and recommends, as required by state law.

9. To reduce its backlog of discipline cases and ensure that it has appropriately allocated resources to all phases of its discipline process, the State Bar should work with the Legislature to establish the backlog measure and goal it develops and recommends, and to revise its reporting requirements accordingly. If necessary, the State Bar should also request the additional resources required to meet the goal.

4. To ensure that it fulfills its duties to investigate attorney misconduct, by April 2023, the State Bar should begin monitoring compliance with its new policy for identifying the circumstances in which investigators should continue to investigate even if the complainant withdraws the complaint.

8. To improve its ability to identify and prevent conflicts of interest that its staff may have with attorneys who are subjects of complaints, the State Bar should develop a process by July 2022 for monitoring the accuracy of the information in its case management system used to flag attorneys with whom its staff have declared a conflict of interest.

13. To ensure that it appropriately reviews complaints involving overdrafts and alleged misappropriations from client trust accounts, the State Bar should, by July 2022, revise its intake manual to disallow de minimis closures if the attorney has a pending or prior bank reportable action or case alleging a client trust account violation.

14. To ensure that it appropriately reviews complaints involving overdrafts and alleged misappropriations from client trust accounts the State Bar should, by July 2022, establish a monitoring system to ensure staff are following its policies for de minimis closures.

15. To ensure that it appropriately reviews complaints involving overdrafts and alleged misappropriations from client trust accounts, by July 2022, the State Bar should, when investigating client trust account-related cases and bank reportable actions not closed de minimis, require its staff to obtain both the bank statements and the attorney's contemporaneous reconciliations of the client trust account, and determine if the relevant transactions are appropriate.

6. To ensure that utilities are targeting the areas of highest fire risk for mitigation activities, the Energy Safety Office should revise its internal procedures for reviewing mitigation plans by March 2023 to designate the prioritization of mitigation activities as a critical issue that must be appropriately addressed before a mitigation plan can be approved.

10. To ensure that it maximizes the efficiency and effectiveness of its enforcement and permitting programs, the commission should, by January 2020, develop guidance that enumerates the violation types that the commissioners deem worthy of swift enforcement action, those that staff can defer for a specified amount of time, and those that do not warrant enforcement action or that can be resolved through fines.

16. To ensure that it maximizes the efficiency and effectiveness of its enforcement and permitting programs, the commission should, by January 2020, appoint a new citizens' advisory committee as required by law and determine a schedule for the committee to conduct regular meetings.

17. To ensure that it uses the abatement fund for the physical cleanup of the Bay, the commission should create a policy by January 2020 identifying the minimum amounts it will disburse and prioritizing the projects that it will support through disbursements to the appropriate entities.

18. To build on prior recommendations and ensure that it maximizes the effectiveness of its enforcement program, the commission should, by January 2021, conduct a workforce study of all its permit and regulatory activities and determine whether it requires additional staff, including supervisors, to support its mission.

20. To build on prior recommendations and ensure that it maximizes the effectiveness of its enforcement program, the commission should, by January 2021, update its existing database or create a new database to ensure that it can identify and track individual violations within each case, including the date staff initiate the standardized fines process for each violation. As part of this process, the commission should review its database and update it as necessary to ensure that it includes all necessary and accurate information, specifically whether staff initiated the standardized fines process for open case files and for those case files closed within the past five years.

22. To ensure consistency in its enforcement program, the commission should, by January 2021, create and implement regulations that define substantial harm, provide explicit criteria for calculating the number of violations present in individual enforcement cases, and specify a process to handle any necessary exceptions to the criteria.

23. To ensure consistency in its enforcement program, the commission should, by January 2021, create and implement regulations to allow it to use limited monetary fines to resolve selected minor violations that do not involve substantial harm to the Bay.

24. To ensure consistency in its enforcement program, the commission should, by January 2021, update its regulations on permit issuance to offer greater clarity on the types of projects for which staff may issue permits without commissioners' hearings.

11. Caltrans should calculate the cost of the vehicle misuse and pursue collection of the funds from the superintendent.

4. To enable policymakers and the public to track the Authority's progress toward meeting the federal grant deadline of December 2022, the Authority should, by January 2019, begin providing quarterly updates to the Legislature detailing the progress of the three Central Valley construction projects using an earned value model that compares construction progress to the projected total completion cost and date. The Authority should base these updates on the most current estimates available.