2023-041 - Status of Recommendations - Table 3

13. To ensure program compliance with state law, Alameda Probation should, by April 2023, formalize comprehensive program standards for program providers that present clear guidance on the department's expectations and the documentation it will review to verify compliance with state law. The probation department should distribute these standards to program providers during their initial application and approval process and again annually during the renewal process.

14. To ensure that program providers comply with probation departments' standards and state law, Alameda Probation should develop and follow formalized policies and procedures for approving, renewing, and conducting comprehensive ongoing monitoring of program providers by April 2023. These policies should specify the frequency of monitoring, the documentation the department will require of program providers to demonstrate compliance, and the specific actions the department will take when a provider is noncompliant.

15. To comply with state law, Alameda Probation should immediately implement record retention policies to maintain documentation on all offenders for five years after the offenders complete or are terminated from probation.

16. To ensure that the courts can provide an offender with a selection of available program providers and their costs before the offender agrees to attend a program as a condition of probation, Alameda Probation should maintain standard program fee information and sliding fee scales for each of the providers it oversees, and make this information available to the courts by April 2023.

5. By November 2019, the district should develop contract monitoring procedures with defined staff roles and responsibilities, including retaining evidence of monitoring efforts. The district should also train its staff to follow these procedures.

6. By November 2019, the district should develop procedures specifying a designated location for staff to retain contracts and related documentation and identifying those staff who are responsible for ensuring that these documents are stored appropriately. The district should also train staff to follow these procedures.

7. By November 2019, the district should work with the county office to ensure that its new financial system includes unique identifiers for contract payment authorization documents.

8. To identify its contracted personnel's potential conflicts of interest, the district should develop and implement a process by November 2019 to assess whether contracted personnel should be classified as consultants and are therefore subject to the district's code for disclosing financial interests.

9. The district should immediately follow its conflict-of-interest code to ensure that all required individuals file Forms 700.

12. To ensure compliance with government transparency laws in future meetings, the board should ensure that it publicly identifies all parties involved in real estate negotiations prior to entering closed sessions.

19. To increase the board's accountability and ensure the prudent spending of district funds, the board should implement procedures by August 2019 requiring that its members document on their requests for reimbursement how their travel complies with district policy.

22. To demonstrate its commitment to improving its governance over the district's operations, the board should immediately direct district staff to track and prioritize the implementation of the remaining outstanding recommendations from the FCMAT audit report. The board should also direct staff to analyze the recommendations relating to its terminated contracts with Del Terra, identify those recommendations that will continue to be relevant after the appointment of a new construction manager and a new program manager, and implement policies to strengthen the district's monitoring of those contractors. The board should then monitor the status of the recommendations to ensure their implementation.

24. To reinforce the ethical principles, laws, and policies that the board must follow, the district should establish a policy by July 2019 to provide biennial training to board members on ethics, applicable government transparency, conflict-of-interest requirements, and district policies.

26. To ensure that the bond committee includes representatives from all required constituencies, the district should verify and document representation of the committee members that the board appoints.

28. To ensure that district staff have appropriate guidance when awarding contracts under emergency conditions, the district should create and implement by November 2019 policies and procedures describing the protocol for awarding emergency contracts, including the use of the district's standard contracting forms. The district should also train staff to follow these policies and procedures.

19. To ensure Bakersfield requests and reports Clery Act crimes from local law enforcement, the institution should by August 2018 create and begin following a procedure, in conjunction with a written agreement with local law enforcement, to obtain crime statistics for the annual security report.

2. To ensure that its board has a clear understanding of the district's financial position and of the unassigned funds available for programs and services for students, Bellflower should, by August 2022, revise its process for presenting its budget to the board for approval. The revised process should require district staff to present a financial overview that compares year-to-date budget amounts to year-to-date actual spending amounts.

3. To increase transparency, the board should, by August 2022, adopt a policy for Bellflower to have its financial auditor present the district's annual audited financial statements at a board meeting, along with an explanation of the district's financial health. Further the policy should also require the financial auditor to present the budget-to-actual comparison from the district's audit report and require district staff to explain variances.

4. To ensure that Bellflower is not underinvesting in its current students, the board should adopt a general fund reserve policy by August 2022 that establishes a healthy but reasonable reserve amount (target reserve) for the district. It should require Bellflower's staff to use the target reserve when determining funding available for the services the district provides, and staff should ensure that the budget presents any actions necessary to maintain the target reserve.

5. To ensure that it is providing consistent and adequate services to its students with disabilities, Bellflower should review all its current Individual Education Programs (IEPs) before December 2022. As part of its review, the district should validate that student IEPs comply with legal requirements and that it is providing the services listed on the IEPs. In the future, the district should, as part of its annual review of IEPs, ensure that the IEPs comply with legal requirements and that it is providing the services listed on the IEPs. Bellflower should also take steps to ensure that it has a robust process for identifying students who may have a disability and to appropriately and promptly evaluate those students.

6. To ensure that it provides consistent and adequate services to all students with disabilities, by October 2022, Bellflower should develop a process to review any instances of noncompliance that either Administrative Hearings or Education identifies, determine the reason for that noncompliance, and establish protocols to address similar problems in the future.

2. To best prepare to protect and care for people with access and functional needs, the county should revise its emergency plans by following the best practices that we included in our report. The county should begin implementing these practices as soon as possible. By no later than March 2020, the county should develop a schedule for completing updates to its emergency plans.

5. To ensure that the county maintains updated emergency plans that are consistent with current best practices, the county should adopt ordinances establishing requirements for the frequency with which the county must update its emergency plans and should set that frequency at no greater than five years.

8. To ensure that the county's emergency planning efforts more fully account for people with access and functional needs in the future, the county should adopt county ordinances that require the county's emergency managers to do the following during each update to the county's emergency plans: when planning to protect people with access and functional needs, adhere to the best practices and guidance that FEMA, Cal OES, and other relevant authorities have issued; report publicly to the boards of supervisors during emergency planning about the steps they have taken to address access and functional needs; consult periodically with a committee of community groups that represent people with a variety of access and functional needs; require that representatives of the community group committees present to the board of supervisors their review of the adequacy of the emergency plans.

8. To help ensure that recipients receive prompt approval for services and also receive all approved services, Butte County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

6. To adequately address its foundational purpose for existing, Calbright should immediately develop a robust implementation plan that aligns with best practices and translates its mission into actionable goals and strategies. It should complete that plan and begin implementing it by November 2021. At a minimum, Calbright should include in its implementation plan all of the following:

1. Its goals, which should include both its goals for completing the setup of the college and its student outcome goals. It should develop its student outcome goals based, at a minimum, on a comparison of the student outcomes for multiple other reasonably comparable educational programs.

2. The major steps necessary to achieve its goals.

3. The estimated resources and specific deliverables that each step will require.

4. The due dates and assigned staff for each deliverable or major step.

5. The criteria it will use for measuring its success and monitoring its progress.

6. A strategy and timeline for ending its reliance on the Foundation.

After completing its implementation plan, Calbright should review the plan at least every six months, and revise and update it as needed to account for major changes relevant to the college's implementation. By July 2022, Calbright should demonstrate that it has made consistent progress in implementing its plan.

To improve its accountability for its actions toward fulfilling its mission, Calbright should annually report to the Legislature its progress related to each step in its implementation plan.

9. To ensure that it is fulfilling its mission to help students obtain positive employment outcomes, including jobs in their field of study, earning gains, and upward mobility, Calbright should do the following:

1. By November 2021, develop and implement a specific plan that describes how it will assist its students in acquiring jobs, earning more income, or being upwardly mobile after graduation; the plan should include a path toward securing job placements for its students.

2. By the same date, also establish a method to collect and review data on student use of its career services, employment outcomes following graduation, and employer satisfaction with Calbright's preparation of its students.

3. By July 2022, Calbright should begin demonstrating that it has been successful at assisting its graduates in obtaining positive employment outcomes, including jobs in their field of study, earning gains, and upward mobility.

11. To assist its students in completing its programs, Calbright should immediately establish an efficient process to recognize previous training and experience and allow students to bypass areas of curriculum in which they have demonstrated competence.

11. To ensure that all instructors are aware of the accessibility standards for instructional materials, Cerritos should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

13. To ensure that its technology master plan supports the strategic goals of the district, Cerritos should update its master plan by June 2018, and should ensure that the plan includes detailed steps to accomplish its goals.

14. To increase the transparency of its annual review process, by June 2018, Cerritos should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

7. To ensure that their teachers and staff have the information necessary to respond consistently, promptly, and appropriately to reduce suicide risk, the six LEAs we reviewed should revise their policies by March 2021 to comply with state law and incorporate the best practices in Education's model policy.

14. To ensure its investigations are independent, timely, and thorough, CLERB should, by May 2022, discuss and modify its current agreement with the Sheriff's Department and the labor organization to allow CLERB's investigators to conduct independent interviews of Sheriff's Department sworn staff.

15. To ensure its investigations are independent, timely, and thorough, CLERB should, by May 2022, develop a comprehensive training manual for its investigators that outlines standard procedures for investigations. The manual should include a specific section dedicated to investigations of in-custody deaths, including guidance for evaluating the circumstances leading up to an in-custody death, such as the decedent's mental health history and the appropriateness of the decedent's housing assignment.

17. To ensure that it fully investigates all in-custody deaths, CLERB should revise its rules and regulations by May 2022 to include the following:

- Prioritization criteria for investigating in-custody deaths above all other investigations.

- Clarification that its investigations of in-custody deaths includes those classified as natural deaths.

17. To ensure that it applies the correct fee credits to developers, Lincoln should develop policies and procedures by September 2019 for establishing fee credits and maintaining adequate documentation to justify modifications to fee credits, including credits it awards based on changes in fee schedules and updated development agreements.

32. To improve its ability to recruit qualified applicants who reflect the diversity of its communities, by October 2022, San Bernardino Police should have a process for regularly monitoring data on the diversity of its current personnel, its new hires, and to the extent possible, its applicant pool. It should use these data to evaluate the success of its recruitment efforts and identify needed areas of improvement

35. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, San Bernardino Police should should begin using documented procedures that adhere to best practices to identify and review applicants' public social media profiles for content indicative of disqualifying biases, such as hate group affiliation.

36. To strengthen its relationships with its community and mitigate the effects of bias on its officers, San Bernardino Police should develop and begin implementing a documented strategy to do all of the following by April 2023:
- Collaborate with its communities to establish or leverage community advisory boards consisting of representatives of diverse groups. The strategy should specify how it will partner with the boards in the areas of recruitment, hiring, training, and community engagement, as well as how it will leverage the boards to obtain feedback on how it can better serve its community.
- Ensure that officers at all levels regularly participate in community engagement activities.
- Periodically survey its community to assess the effectiveness of its community engagement efforts and solicit feedback on how to improve its operations.

37. To proactively identify signs that officers may need additional training or supports to address possible biased behavior, San Bernardino Police 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. The system should include analysis of stops data that identifies officers based on indications of possible biased conduct.
- 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.

39. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San Bernardino Police should ensure it has implemented policies or procedures by January 2023 that require that the investigations apply a definition of bias that incorporates the following: biased conduct can include conduct resulting from implicit as well as explicit biases; conduct is biased if a reasonable person would conclude so using the facts at hand; an officer need not admit biased or prejudiced intent for conduct to reasonably appear biased; and biased conduct may occur in an encounter with the public, with other officers, or online, such as conduct on social media.

40. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San Bernardino Police should ensure it has implemented policies or procedures by January 2023 that require that the individuals handling bias-related investigations follow detailed investigative guidelines for identifying biased conduct and be specifically trained in how to perform these assessments.

41. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San Bernardino Police should ensure that by January 2023 it has formalized policies - such as through discipline matrices or broader discipline guidelines - specifying options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct. The department should 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.

18. To ensure program compliance with state law, Contra Costa Probation should, by April 2023, formalize comprehensive program standards for program providers that present clear guidance on the department's expectations and the documentation it will review to verify compliance with state law. The probation department should distribute these standards to program providers during their initial application and approval process and again annually during the renewal process.

19. To ensure that program providers comply with the probation department's standards and state law, Contra Costa Probation should develop and follow formalized policies and procedures for approving, renewing, and conducting comprehensive ongoing monitoring of program providers by April 2023. These policies should specify the frequency of monitoring, the documentation the department will require of program providers to demonstrate compliance, and the specific actions the department will take when a provider is noncompliant.

21. To ensure that the courts can provide an offender with a selection of available program providers and their costs before the offender agrees to attend a program as a condition of probation, Contra Costa Probation should maintain standard program fee information and sliding fee scales for each of the providers it oversees, and make this information available to the courts by April 2023.

4. To ensure that county jails identify inmates with mental illnesses and provide them with adequate mental health care, Alameda should immediately begin conducting mental health screening of all inmates upon admission to the county's jails.

5. To ensure that county jails have sufficient information to determine appropriate housing and supervision of inmates with mental illness, by June 2021, Alameda should develop a process requiring mental health providers to share with jails the mental health status of all inmates, such as whether they have a mild, moderate, or serious mental illness.

7. To ensure that it appropriately follows up on inmate deaths and works to prevent similar deaths from occurring in the future, Alameda should implement its updated inmate death follow-up process by June 2021.

9. Unless the Legislature clarifies its intent otherwise, to ensure that the counties prudently and appropriately spend realignment funds, the Partnership Committee at Alameda should, starting with its next annual budget, review and make budget recommendations to its board of supervisors for all realignment accounts, including the accounts that fund non-law enforcement departments and community-based organizations. Further, Alameda should ensure that it budgets all realignment funds to eliminate excessive surpluses in realignment accounts and prevent future surpluses beyond a reasonable reserve.

12. To ensure that the programs and services funded by public safety realignment funds are effective, beginning immediately, Alameda should conduct evaluations of the effectiveness of its programs and services at least every three years.

15. To ensure that the county reports accurate and consistent information to the Corrections Board, beginning with its next annual report, Alameda should consistently report all law enforcement and non-law enforcement expenditures funded through the accounts that constitute public safety realignment.

3. To comply with the State's jail capacity standards, Fresno should take steps to address overcrowding in its jails, while ensuring public safety.

6. To ensure that county jails have sufficient information to determine appropriate housing and supervision of inmates with mental illness, by June 2021, Fresno should develop a process requiring mental health providers to share with jails the mental health status of all inmates, such as whether they have a mild, moderate, or serious mental illness.

10. Unless the Legislature clarifies its intent otherwise, to ensure that the counties prudently and appropriately spend realignment funds, the Partnership Committee at Fresno should, starting with its next annual budget, review and make budget recommendations to its board of supervisors for all realignment accounts, including the accounts that fund non-law enforcement departments and community-based organizations. Further, Fresno should ensure that it budgets all realignment funds to eliminate excessive surpluses in realignment accounts and prevent future surpluses beyond a reasonable reserve.

13. To ensure that the programs and services funded by public safety realignment funds are effective, beginning immediately, Fresno should conduct evaluations of the effectiveness of its programs and services at least every three years.

16. To ensure that the county reports accurate and consistent information to the Corrections Board, beginning with its next annual report, Fresno should consistently report all law enforcement and non-law enforcement expenditures funded through the accounts that constitute public safety realignment.

11. Unless the Legislature clarifies its intent otherwise, to ensure that the counties prudently and appropriately spend realignment funds, the Partnership Committee at Los Angeles should, starting with its next annual budget, review and make budget recommendations to its board of supervisors for all realignment accounts, including the accounts that fund non-law enforcement departments and community-based organizations. Further, Los Angeles should ensure that it budgets all realignment funds to eliminate excessive surpluses in realignment accounts and prevent future surpluses beyond a reasonable reserve.

14. To ensure that the programs and services funded by public safety realignment funds are effective, beginning immediately, Los Angeles should conduct evaluations of the effectiveness of its programs and services at least every three years.

17. To ensure that the county reports accurate and consistent information to the Corrections Board, beginning with its next annual report, Los Angeles should consistently report all law enforcement and non-law enforcement expenditures funded through the accounts that constitute public safety realignment.

6. To help ensure that it has adequate levels of services and service providers in its area to meet the needs of people who are experiencing homelessness, the County of Mendocino should coordinate with its CoC to ensure that the CoC annually conducts a comprehensive gaps analysis in accordance with the plan it has developed under federal regulations. To be effective, the gaps analysis should consider whether adequate services are available in the areas where individuals are experiencing homelessness and should contain strategies to address any deficiencies.

16. To comply with federal regulations and ensure that its CoC's decisions reflect a variety of perspectives, the County of Mendocino should, by August 2021, coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.

21. To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the County of Mendocino should, by August 2021, coordinate with its CoC to assess the feasibility of establishing a dedicated telephone hotline for providing information about available services, assessing individuals' needs, and referring those individuals to appropriate housing or homeless service providers.

23. To increase the efficiency of the coordinated entry process, the County of Mendocino should coordinate with its CoC to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, it should use the referral data that HUD required CoCs to collect as of October 2020 to determine whether locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. If it finds that excessive delays exist, it should coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.

9. To help ensure that it has adequate levels of services and service providers in its area to meet the needs of people who are experiencing homelessness, the County of Santa Clara should coordinate with its CoC to ensure that the CoC annually conducts a comprehensive gaps analysis in accordance with the plan it has developed under federal regulations. To be effective, the gaps analysis should consider whether adequate services are available in the areas where individuals are experiencing homelessness and should contain strategies to address any deficiencies.

9. To ensure that the county's emergency planning efforts more fully account for people with access and functional needs in the future, the county should adopt county ordinances that require the county's emergency managers to do the following during each update to the county's emergency plans: when planning to protect people with access and functional needs, adhere to the best practices and guidance that FEMA, Cal OES, and other relevant authorities have issued; report publicly to the boards of supervisors during emergency planning about the steps they have taken to address access and functional needs; consult periodically with a committee of community groups that represent people with a variety of access and functional needs; require that representatives of the community group committees present to the board of supervisors their review of the adequacy of the emergency plans.

4. To best prepare to protect and care for people with access and functional needs, the county should revise its emergency plans by following the best practices that we included in our report. The county should begin implementing these practices as soon as possible. By no later than March 2020, the county should develop a schedule for completing updates to its emergency plans.

7. To ensure that the county maintains updated emergency plans that are consistent with current best practices, the county should adopt ordinances establishing requirements for the frequency with which the county must update its emergency plans and should set that frequency at no greater than five years.

10. To ensure that the county's emergency planning efforts more fully account for people with access and functional needs in the future, the county should adopt county ordinances that require the county's emergency managers to do the following during each update to the county's emergency plans: when planning to protect people with access and functional needs, adhere to the best practices and guidance that FEMA, Cal OES, and other relevant authorities have issued; report publicly to the boards of supervisors during emergency planning about the steps they have taken to address access and functional needs; consult periodically with a committee of community groups that represent people with a variety of access and functional needs; require that representatives of the community group committees present to the board of supervisors their review of the adequacy of the emergency plans.

22. To ensure that offenders are held accountable for complying with the conditions of their probation, Del Norte Probation should, by April 2023, formalize and implement comprehensive policies and procedures for domestic violence case management that clearly describe the department's expectations for probation staff's compliance with state law.

23. To ensure program compliance with state law, Del Norte Probation should, by April 2023, formalize comprehensive program standards for program providers that present clear guidance on the department's expectations and the documentation it will review to verify compliance with state law. The probation department should distribute these standards to program providers during their initial application and approval process and again annually during the renewal process.

24. To ensure that program providers comply with the probation department's standards and state law, Del Norte Probation should develop and follow formalized policies and procedures for approving, renewing, and conducting comprehensive ongoing monitoring of program providers by April 2023. These policies should specify the frequency of monitoring, the documentation the department will require of program providers to demonstrate compliance, and the specific actions the department will take when a provider is noncompliant.

25. To ensure that the courts can provide an offender with a selection of available program providers and their costs before the offender agrees to attend a program as a condition of probation, Del Norte Probation should maintain standard program fee information and sliding fee scales for each of the providers it oversees, and make this information available to the courts by April 2023.

7. To rectify the excessive reimbursement amounts it received for strike team assignments, the district should, by December 31, 2019, develop and implement a plan for returning to the paying agencies the excessive reimbursements it received for 2016 through 2018.

8. To rectify the excessive reimbursement amounts it received for strike team assignments, the district should, by December 31, 2019, work with Cal OES to identify the amounts of excess reimbursements the district received for 2013 through 2015 and then develop and implement a plan for returning those amounts to the paying agency.

10. To improve its financial viability and safeguard its ability to continue providing services to the Fallen Leaf Lake community, the district should, by December 31, 2019, monitor the financial risks it may face in the future, forecast their impact on its finances and budget, and plan and implement appropriate changes to its budget as necessary throughout the fiscal year.

11. To improve its financial viability and safeguard its ability to continue providing services to the Fallen Leaf Lake community, the district should, by December 31, 2019, limit the extent to which it relies on volatile revenue sources to balance its budget.

13. To improve its financial viability and safeguard its ability to continue providing services to the Fallen Leaf Lake community, the district should, by December 31, 2019, develop a five-year forecast of estimated revenues and expenditures and a plan to guide its decisions and actions in the event of fluctuations.

15. To ensure that it is fulfilling requests for alternate media services from students with disabilities in a timely manner, by June 2018, De Anza should establish procedures for monitoring its timeliness in responding to such requests so that it can periodically review its performance in completing the requests. Specifically, it should record and track sufficient information to be able to review how long it takes to complete requests. Additionally, De Anza should calculate the number of days it takes to complete requests, and periodically evaluate its performance against its time-frame goals. Further, to evaluate its performance, De Anza should establish a time-frame goal for completing alternate media requests.

16. To ensure that it promptly addresses any complaints it receives related to web accessibility and alternate media requests, De Anza should follow its new procedures for tracking and reviewing complaints related to accessibility.

17. To ensure that students with disabilities have equal access to instructional materials, by June 2018, De Anza should develop procedures to monitor and periodically review the accessibility of instructional materials. For example, De Anza could develop an accessibility checklist for instructors to complete when developing or selecting instructional materials, from which the college could periodically review a sample of course content to ensure that instructors completed the checklist and that the instructional materials comply with accessibility standards.

18. To ensure that its website complies with accessibility standards, by June 2018, De Anza should develop procedures to monitor website accessibility and incorporate steps to prevent instructors from publishing inaccessible content on the college's website. These procedures should include a tracking mechanism to demonstrate how many accessibility errors the college identifies and how long it takes to fix those errors.

19. To ensure that all instructors are aware of the accessibility standards for instructional materials, De Anza should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

21. To increase the transparency of its annual review process, by June 2018, De Anza should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

10. To help ensure that it has adequate levels of services and service providers in its area to meet the needs of people who are experiencing homelessness, the Fresno City Housing Authority should coordinate with its CoC to ensure that the CoC annually conducts a comprehensive gaps analysis in accordance with the plan it has developed under federal regulations. To be effective, the gaps analysis should consider whether adequate services are available in the areas where individuals are experiencing homelessness and should contain strategies to address any deficiencies.

12. To ensure that it adequately identifies its long-term strategies to address homelessness, the Fresno City Housing Authority should coordinate with its CoC to implement a planning process and develop a comprehensive plan that meets all federal requirements by August 2021. The planning process should ensure that the CoC updates its comprehensive plan at least every five years.

18. To comply with federal regulations and ensure that its CoC's decisions reflect a variety of perspectives, the Fresno City Housing Authority should, by August 2021, coordinate with its CoC to ensure that the CoC's board is representative of all relevant organizations.

19. To reduce barriers to CoC membership and to encourage participation, the Fresno City Housing Authority should coordinate with its CoC to conduct an analysis of whether its membership fee is necessary and, if it is not, to eliminate it by August 2021.

22. To ensure that individuals experiencing homelessness have adequate access to the coordinated entry process, the Fresno City Housing Authority should, by August 2021, coordinate with its CoC to assess the feasibility of establishing a dedicated telephone hotline for providing information about available services, assessing individuals' needs, and referring those individuals to appropriate housing or homeless service providers.

26. To increase the efficiency of the coordinated entry process, the County of Fresno City Housing Authority should coordinate with its CoC to determine how long it takes to locate individuals after they have been matched with a service provider. Specifically, it should use the referral data that HUD required CoCs to collect as of October 2020 to determine whether locating individuals after they have been matched with a service provider is a cause of delay in providing them with services. If it finds that excessive delays exist, it should coordinate with its CoC to implement processes such as deploying a dedicated team to locate these individuals when appropriate housing and services become available.

8. To ensure that their teachers and staff have the information necessary to respond consistently, promptly, and appropriately to reduce suicide risk, the six LEAs we reviewed should revise their policies by March 2021 to comply with state law and incorporate the best practices in Education's model policy.

15. To ensure that their teachers and staff have the knowledge necessary to identify and assist students at risk of self-harm and suicide, the six LEAs we reviewed should do the following:

- Revise their suicide prevention training materials by June 2021 to align with state law and incorporate the best practices in Education's model policy.

-LEAs that provide suicide prevention training should conduct it at the beginning of the school year.

21. To improve their students' access to mental health professionals, Kern High School District, Ukiah Unified, Gateway Charter, Redwoods Charter, and Heartland Charter should coordinate with their respective counties to request MHSA funding to employ additional school counselors, school nurses, school social workers, and school psychologists.

9. To help ensure that recipients receive prompt approval for services and also receive all approved services, Kern County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

1. To increase the objectivity and transparency of its minimum qualification requirements, when possible the Commission should create qualification requirements based on time spent working in District job classifications or equivalent experience, rather than using ambiguous terms such as "professional-level."

2. To increase transparency and ensure that it makes consistent decisions when assessing applicants' minimum qualifications, the Commission should establish a rule for its examiners by October 2021 that defines the key terms it uses when reviewing applications for minimum qualifications, such as "professional-level" and "recent."

4. To ensure that its examination process is fair and evaluates all candidates consistently, the Commission should establish a rule by October 2021 to require examiners to create detailed scoring benchmarks that provide raters guidance on how to rate individual evaluation factors.

5. To ensure that its examination process is fair and evaluates all candidates consistently, the Commission should establish a rule by October 2021 requiring that when it creates examinations it establish a method for determining candidates' overall scores based on the ratings of the individual evaluation factors.

6. To ensure that its examination process is fair and evaluates all candidates consistently, the Commission should establish a rule by October 2021 to require raters to provide written comments on rating sheets for each candidate, explaining the basis for the score they awarded.

7. To ensure that its examination process is fair and evaluates all candidates consistently, the Commission should establish a rule by October 2021 to require examiners to review scoring sheets to determine if raters have followed the Commission's candidate evaluation guidance, and if the raters have failed to follow the guidance request that the raters review their evaluation of the candidate.

9. To ensure that employees are aware that they can request intermittent payments while performing out-of-class work assignments, the Commission should immediately revise its claim form to include this option.

10. To ensure that employees receive prompt compensation for the higher-level duties they perform, the Commission should revise its rules by October 2021 to process employees' compensation for out-of-class work each month.

12. To ensure that employees are fairly compensated for the entirety of the out-of-class work they perform, the Commission should amend its rules by October 2021 to require employees to submit a copy of their out-of-class claim form to the Commission at the same time as they submit it to their supervisors, and use the date the Commission receives this copy of the form as the date of submission.

13. To ensure that it consistently identifies and responds to all complaints and to reduce the risk of retaliation against complainants, by October 2021, the Commission should amend its rules to clearly define complaints and create a formal process for addressing all complaints, including a process to elevate to the commissioners those complaints that are not resolved at lower levels.

14. To ensure that it consistently identifies and responds to all complaints and to reduce the risk of retaliation against complainants, by October 2021, the Commission should amend its rules to include a provision for submitting whistleblower complaints directly to the District's Office of the General Counsel and assign it the responsibility of designating an appropriate party to respond.

15. To ensure that it consistently identifies and responds to all complaints and to reduce the risk of retaliation against complainants, by October 2021, the Commission should amend its rules to establish that complainant information may not be shared with the subject of a whistleblower complaint.

16. To ensure that it treats applicants consistently when considering whether to debar them in the case of false statements or deception, the Commission should establish rules to require that examiners independently verify the reason for inconsistencies between applications.

17. To ensure that it treats applicants consistently when considering whether to debar them in the case of false statements or deception, the Commission should establish rules to require that examiners provide applicants with an opportunity to address the inconsistencies.

18. To ensure that it treats applicants consistently when considering whether to debar them in the case of false statements or deception, the Commission should establish rules to require that examiners document the steps taken to verify the disputed information and retain relevant supporting documentation.

19. To ensure that the Commission's practices align with the mission of the merit system, the Commissioners should establish rules that require staff to periodically report to them on how its practices compare to those of other entities with merit systems, along with any recommendations for improving the Commission's practices.

6. To ensure that it connects patients who have been placed on multiple short-term holds to appropriate ongoing treatment, Los Angeles should, by no later than August 2021, adopt a systematic approach to identifying such individuals, obtaining available mental health history information about these individuals, and connecting these individuals to services that support their ongoing mental health.

8. To ensure that conservatorships do not terminate because of the absence of testimony from doctors, Los Angeles should immediately implement a comprehensive solution to this problem, such as using its own staff as expert witnesses when individuals' treating physicians are unable to testify. In addition, by no later than August 2021, it should develop a revised approach to scheduling conservatorship hearings and trials so that it significantly reduces the rate at which doctors' failures to testify result in terminated conservatorships.

6. To ensure that its staff appropriately use SDM assessments to identify safety threats and risks, the department should incorporate SDM instructions into its policies and procedures by July 2019 and provide mandatory annual SDM training for applicable staff, supervisors, and other members of management by May 2020.

1. To ensure that Montebello takes the steps necessary to prevent state intervention and regain its positive financial certification, the county superintendent should direct Montebello to submit a corrective action plan to address the issues identified in this report including balancing its budget, amending and adhering to its hiring procedures, and establishing adequate safeguards to ensure that policies related to bond proceeds, conflicts of interest, and the approval of expenditures are implemented and followed.

2. To ensure that Montebello takes the steps necessary to prevent state intervention and regain its positive financial certification, the county superintendent should assist Montebello in developing a plan to justify its workforce size and cost in terms of its current and projected enrollment, including evaluating the necessity of current staff levels and personnel costs.

3. To ensure that Montebello takes the steps necessary to prevent state intervention and regain its positive financial certification, the county superintendent should evaluate the necessity of executive positions and adjust executives' salaries based on an analysis of the number and cost of executives in comparable districts.

4. To ensure that Montebello takes the steps necessary to prevent state intervention and regain its positive financial certification, the county superintendent should ensure that Montebello implements all of the recommendations detailed in the report.

26. To ensure that offenders are held accountable for complying with the conditions of their probation, Los Angeles Probation should, by April 2023, formalize and implement comprehensive policies and procedures for domestic violence case management that clearly describe the department's expectations for probation staff's compliance with state law.

27. To ensure program compliance with state law, Los Angeles Probation should, by April 2023, formalize comprehensive program standards for program providers that present clear guidance on the department's expectations and the documentation it will review to verify compliance with state law. The probation department should distribute these standards to program providers during their initial application and approval process and again annually during the renewal process.

28. To ensure that program providers comply with the probation department's standards and state law, Los Angeles Probation should develop and follow formalized policies and procedures for approving, renewing, and conducting comprehensive ongoing monitoring of program providers by April 2023. These policies should specify the frequency of monitoring, the documentation the department will require of program providers to demonstrate compliance, and the specific actions the department will take when a provider is noncompliant.

29. To ensure that the courts can provide an offender with a selection of available program providers and their costs before the offender agrees to attend a program as a condition of probation, Los Angeles Probation should maintain standard program fee information and sliding fee scales for each of the providers it oversees, and make this information available to the courts by April 2023.

11. To adequately assess the effectiveness of its programs at reducing juvenile crime and delinquency, Los Angeles should collect data on all participants in each JJCPA program and for each service it provides.

15. To accurately assess the effectiveness of its programs, Los Angeles should determine how to accurately identify in its case management system the JJCPA programs and services in which each individual participates or should enhance its system to provide this capability.

1. To ensure that its CCW licensing decisions align with its CCW policy, Los Angeles Sheriff should only issue licenses to applicants after collecting documentation of specific, personal threats against the applicants so as to satisfy its definition of good cause. If Los Angeles Sheriff believes that its public licensing policy does not include all acceptable good causes for a CCW license, then by March 2018 it should revise that policy and publish the new policy on its website. It should then immediately begin processing applications according to that revised policy.

2. To ensure that it only issues licenses to individuals after receiving evidence of residency, firearms training, and good moral character that aligns with its policy, Los Angeles Sheriff should only issue licenses after verifying that it has received this evidence. To avoid overlooking required evidence, Los Angeles should create procedures by March 2018 for its staff to follow to ensure that each CCW file contains the evidence its policy requires before issuing the license.

10. To ensure that it is only charging fees that state law allows, Los Angeles Sheriff should immediately cease charging applicants fees in addition to its license processing fee. Los Angeles Sheriff should reimburse applicants who paid the unallowable fees. Further, if Los Angeles Sheriff believes its license fee does not recover its entire cost of processing an initial application, it should complete a cost study and, if appropriate, revise its fee according to the results of that study and the maximum allowed fees under state law.

20. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, Los Angeles Sheriff should begin conducting standardized interviews of officer applicants that include questions designed to assess their experience working with diverse communities and their ability to do so effectively.

21. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, Los Angeles Sheriff should proactively seek and attempt to contact secondary references to obtain more candid information about applicants, such as information about past biased conduct or affiliation with hate groups.

22. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, Los Angeles Sheriff should should begin using documented procedures that adhere to best practices to identify and review applicants' public social media profiles for content indicative of disqualifying biases, such as hate group affiliation.

23. To strengthen its relationships with its community and mitigate the effects of bias on its officers, Los Angeles Sheriff should develop and begin implementing a documented
strategy to do all of the following by April 2023:
- Collaborate with its communities to establish or leverage community advisory boards consisting of representatives of diverse groups. The strategy should specify how it will partner with the boards in the areas of recruitment, hiring, training, and community engagement, as well as how it will leverage the boards to obtain feedback on how it can better serve its community.
- Ensure that officers at all levels regularly participate in community engagement activities.
- Periodically survey its community to assess the effectiveness of its community engagement efforts and solicit feedback on how to improve its operations.

24. To proactively identify signs that officers may need additional training or supports to address possible biased behavior, Los Angeles Sheriff 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. The system should include analysis of stops data that identifies officers based on indications of possible biased conduct.
- 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.

25. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Los Angeles Sheriff should ensure it has implemented
policies or procedures by January 2023 that require that misconduct investigations formally analyze whether an officer has acted in a biased manner whenever a complainant alleges bias, the facts of the incident indicate bias might have influenced an officer's behavior, or investigators recognize potential indications of bias during other reviews, such as use-of-force reviews.

26. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Los Angeles Sheriff should ensure it has implemented
policies or procedures by January 2023 that require that the investigations apply a definition of bias that incorporates the following: biased conduct can include conduct
resulting from implicit as well as explicit biases; conduct is biased if a reasonable person would conclude so using the facts at hand; an officer need not admit biased or prejudiced intent for conduct to reasonably appear biased; and biased conduct may occur in an encounter with the public, with other officers, or online, such as
conduct on social media.

27. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Los Angeles Sheriff should ensure it has implemented
policies or procedures by January 2023 that require that the individuals handling bias-related investigations follow detailed investigative guidelines for identifying biased
conduct and be specifically trained in how to perform these assessments.

28. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Los Angeles Sheriff should ensure that by January 2023 it has formalized policies - such as through discipline matrices or broader discipline guidelines - specifying options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct. The department should 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.

29. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Los Angeles Sheriff's policies should require that investigations include a formal determination that makes clear whether biased conduct occurred or not, as well as the rationale for reaching the determination.

30. To ensure that it accurately reports information about all complaints as required by state law, Los Angeles Sheriff should ensure that it reports to DOJ about all public complaints related to racial or identity profiling, including those that initially appear to be unfounded, and the disposition of those complaints.

31. To improve its ability to effectively investigate allegations of officer misconduct, by April 2023, Los Angeles Sheriff should finish its planned partial implementation of body-worn cameras, and should establish and begin implementing a time frame for equipping officers in each of its custody settings with body-worn cameras.

32. To ensure that state adult education funds are used in the most efficient and effective manner, the consortium should, within one year, develop policies and procedures to ensure the proper collection and reporting of enrollment, attendance, and expenditure data by consortium members. Periodically review enrollment, attendance, and expenditure data to ensure their accuracy.

26. To ensure that all instructors are aware of the accessibility standards for instructional materials, American River should include in its next collective bargaining negotiations a requirement for instructors to periodically attend accessibility trainings.

29. To increase the transparency of its annual review processes, by June 2018, American River should establish procedures requiring its departments to document attendees, input received, and agreements reached during meetings to consider instructional technology equipment requests.

5. To improve its current financial condition and ensure future viability, Montebello should, within 60 days, revise its fiscal stabilization plan and make the necessary cuts to fund its ongoing commitments.

6. To improve its current financial condition and ensure future viability, Montebello should create a robust budgeting process within 90 days using best practices of the Government Finance Officers Association to ensure Montebello's ability to meet its priorities while maintaining the required level of reserves that buffers the district from drastic cuts in times of economic instability.

7. To improve its current financial condition and ensure future viability, Montebello should, within 90 days, implement an effective budget monitoring process with regular budget-to-actual comparisons. This process should include safeguards against spending in excess of budgeted expenditures and require advance board approval of such spending before it occurs. For example, Montebello should require that the budget manager perform monthly reviews of budget-to-actual figures and provide detailed explanations to the board for any variances.

8. To ensure that Montebello hires the most qualified executive and management staff, Montebello should immediately adhere to its policies for hiring classified employees, including screening candidates to ensure that they meet the minimum qualifications. Montebello should also hold provisional employees to the same standards for minimum
qualifications as its policy requires.

9. To ensure that Montebello hires qualified classified employees, the personnel commission should, within 90 days, revise its policies to require the classified director to provide it with the education and work experience of any candidates on eligibility lists for high-ranking positions. It should also require the director of the personnel commission—the classified director—to provide it with a list of all provisional appointments, including information on how those employees meet the minimum qualifications.

10. To ensure that it does not violate state law, Montebello should immediately adhere to its policies and ensure that provisional employees do not work more than the legal maximum number of days of service.

13. To ensure that Montebello creates employee positions only when necessary, it should establish a policy within 30 days that requires a justification for why the district is creating a position. Additionally, in order to maintain transparency when creating new positions, Montebello should immediately begin to document its justifications.

14. To ensure that Montebello hires qualified certificated and classified employees, within 90 days the board should revise its policies to require the superintendent or his or her designee to provide information to the board about recruitments for high-ranking employees. The board should consider, at a minimum, the following information when approving appointments:
- The number of initial applicants.
- The number of candidates who passed the screening and interviewing steps.
- The education and work experience of the final candidate recommended by the superintendent or designee.

15. To ensure that Montebello is making hiring decisions free of bias or favoritism, within 90 days it should strengthen its hiring policies related to nepotism and conflicts of interest for classified and certificated personnel to include the following: establishing restrictions on immediate family members being involved in the screening and interviewing processes and definitions of what types of personal relationships fall under the nepotism policy, which work relationships the nepotism policy applies to, and what factors to consider when evaluating the potential impact of a personal relationship.

24. To ensure that Montebello spends its funds for allowable and reasonable purposes, it should implement an inventory tracking system that allows it to know where its equipment is located. Montebello should also periodically review its inventory listing to ensure that equipment is being properly used.

32. To ensure that its campuses provide the necessary resources and information to students about campus safety, Peralta should, by December 2018, develop all required policies related to campus safety in compliance with the Education Code.

6. To address its current financial problems, Sacramento Unified should do the following:

By March 2020, adopt a detailed plan to resolve its fiscal crisis. The plan should estimate savings under multiple scenarios and include an analysis that quantifies the impact of reductions the district can make to ongoing expenditures. Specifically, Sacramento Unified should consider the impact of possible salary adjustments for employees in different bargaining units and include the impact those salary adjustments would have on postemployment benefits, such as pensions. It should also use the most recently available data to estimate net savings from modifying the health care benefits it provides to employees, as well as the impact those modifications would have on the total compensation of the employees. Finally, it should calculate the impact of possible changes to district and employee contributions to fund future retiree health benefits. The district should use the plan it develops as the basis for its discussions of potential solutions with its teachers union.

8. To address its current financial problems, Sacramento Unified should do the following:

The district should adopt and disclose publicly a multiyear projection methodology. This methodology should disclose the assumptions and rationale used to estimate changes in salaries, benefits, contributions, and LCFF revenue—including changes in enrollment and the source and reliability of the data used to make these projections.

10. To prevent a similar fiscal crisis in the future, Sacramento Unified should do the following by July 2020:

Have the board adopt a budget methodology, including guidance on the use of one-time funds, the use and maintenance of district reserves, and the maintenance of a balanced budget. The methodology should use the Government Finance Officers Association's best practices as a guide and should address at least the following areas:

Including administrators from different divisions of Sacramento Unified into the budget development process to help ensure the accuracy of projections.

Establishing criteria and measures for success in the budget process, such as whether budget decisions were made with adequate input and deliberation and whether the budget was balanced without using reserves or one-time revenues for ongoing expenditures.

Developing and adhering to a multiyear funding budget plan, with the goal of realigning resources where necessary to fund ongoing expenses with ongoing revenue.

Conducting an analysis of variances in budgeted and actual revenues and expenditures at each interim reporting period. Sacramento Unified should then use this information to inform its estimates for the upcoming fiscal year's budget.

11. To prevent a similar fiscal crisis in the future, Sacramento Unified should do the following by July 2020:

Develop a long-term funding plan to address its retiree health benefits liability. The plan should include appropriate action necessary to ensure the district will be able to meet its obligations to its employees and retirees.

14. To prevent a similar fiscal crisis in the future, Sacramento Unified should do the following by July 2020:

Develop and adopt a succession plan that ensures that it has staff who have the training and knowledge necessary to assume critical roles in the case of turnover.

3. To ensure that staff are gathering consistent evidence from applicants to demonstrate residency, good moral character, and firearms training and are including which requirement applicants did not meet in its denial letters, by March 2018, Sacramento should create formal CCW processing procedures and train its staff to follow these procedures. These procedures should require staff to gather and evaluate the information the department believes is required to demonstrate that each of the criteria for a CCW license has been met, and they should also require staff to include which requirement applicants did not meet in its denial letters.

4. To ensure that staff are following its newly established procedures and to identify any need for additional guidance, by March 2018, Sacramento should establish a review process wherein it regularly reviews a selection of license files and denied applications to determine whether its staff are collecting sufficient and consistent documentation in accordance with its policies and are appropriately including which requirement applicants did not meet in its denial letters.

7. To ensure that it provides all required information to Justice, Sacramento should immediately inform Justice when it revokes a CCW license, including when it receives a prohibition notice from Justice.

16. To comply with federal law and best practices, San Bernardino should, before academic year 2020-21, distribute information about the educational rights of youth experiencing homelessness in public places, including schools, shelters, public libraries, and food pantries frequented by families of such youth, as federal law requires. Further, to mitigate families' and youth's hesitance to disclosing their living situation the LEA should include the protections set forth in federal and state laws in the information it distributes.

5. To ensure that the permit fees it charges are sufficient to pay for its permitting program, the San Diego Air District should, by December 2020, monitor the impact of the COVID-19 pandemic on San Diego County's economy and, when economic conditions allow, propose to the district board that it increase fees annually by the maximum percentage allowed until the district's revenue from permit fees is equal to the full cost of the permitting program.

5. To ensure that its staff appropriately renew CCW licenses, by March 2018, San Diego should establish a routine supervisory review of a selection of renewed licenses.

6. To ensure that it consistently obtains sufficient evidence to demonstrate that an applicant satisfies its requirements for a license, by March 2018, San Diego should develop guidance and train its staff on what good cause documentation staff should request from applicants. Further, it should train its staff regarding the expected documents for residency and training.

8. To ensure that it follows state law's requirements for revoking licenses, San Diego should immediately revoke CCW licenses and should then inform Justice that it has revoked licenses whenever license holders become prohibited persons. Additionally, San Diego should notify Justice when it suspends a license or a license is surrendered.

12. To ensure that it maximizes allowable revenue from its CCW program, San Diego should immediately pursue increasing its initial, renewal, and amendment fees to the maximum amounts allowable under state law.

17. To ensure that their teachers and staff have the knowledge necessary to identify and assist students at risk of self-harm and suicide, the six LEAs we reviewed should do the following:

- Revise their suicide prevention training materials by June 2021 to align with state law and incorporate the best practices in Education's model policy.

-LEAs that provide suicide prevention training should conduct it at the beginning of the school year.

30. To ensure that offenders are held accountable for complying with the conditions of their probation, San Joaquin Probation should, by April 2023, formalize and implement comprehensive policies and procedures for domestic violence case management that clearly describe the department's expectations for probation staff's compliance with state law.

32. To ensure that program providers comply with the probation department's standards and state law, San Joaquin Probation should develop and follow formalized policies and procedures for approving, renewing, and conducting comprehensive ongoing monitoring of program providers by April 2023. These policies should specify the frequency of monitoring, the documentation the department will require of program providers to demonstrate compliance, and the specific actions the department will take when a provider is noncompliant.

33. To comply with state law, San Joaquin Probation should immediately follow its record retention policies to maintain documentation on all offenders for five years after the offenders complete or are terminated from probation.

34. To ensure that the courts can provide an offender with a selection of available program providers and their costs before the offender agrees to attend a program as a condition of probation, San Joaquin Probation should maintain standard program fee information and sliding fee scales for each of the providers it oversees, and make this information available to the courts by April 2023.

43. To improve its ability to recruit qualified applicants who reflect the diversity of its communities, by October 2022, San José Police should have a process for regularly monitoring data on the diversity of its current personnel, its new hires, and to the extent possible, its applicant pool. It should use these data to evaluate the success of its recruitment efforts and identify needed areas of improvement.

47. To strengthen its relationships with its community and mitigate the effects of bias on its officers, San José Police should develop and begin implementing a documented strategy to do all of the following by April 2023:
- Collaborate with its communities to establish or leverage community advisory boards consisting of representatives of diverse groups. The strategy should specify how it will partner with the boards in the areas of recruitment, hiring, training, and community engagement, as well as how it will leverage the boards to obtain feedback on how it can better serve its community.
- Ensure that officers at all levels regularly participate in community engagement activities.
- Periodically survey its community to assess the effectiveness of its community engagement efforts and solicit feedback on how to improve its operations.

48. To proactively identify signs that officers may need additional training or supports to address possible biased behavior, San José Police 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. The system should include analysis of stops data that identifies officers based on indications of possible biased conduct.
- 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.

49. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San José Police should ensure it has implemented policies or procedures by January 2023 that require that misconduct investigations formally analyze whether an officer has acted in a biased manner whenever a complainant alleges bias, the facts of the incident indicate bias might have influenced an officer's behavior, or investigators recognize potential indications of bias during other reviews, such as use-of-force reviews.

50. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San José Police should ensure it has implemented policies or procedures by January 2023 that require that the investigations apply a definition of bias that incorporates the following: biased conduct can include conduct resulting from implicit as well as explicit biases; conduct is biased if a reasonable person would conclude so using the facts at hand; an officer need not admit biased or prejudiced intent for conduct to reasonably appear biased; and biased conduct may occur in an encounter with the public, with other officers, or online, such as conduct on social media.

51. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San José Police should ensure it has implemented policies or procedures by January 2023 that require that the individuals handling bias-related investigations follow detailed investigative guidelines for identifying biased conduct and be specifically trained in how to perform these assessments.

52. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, San José Police should ensure that by January 2023 it has formalized policies - such as through discipline matrices or broader discipline guidelines - specifying options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct. The department should 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.

11. To help ensure that recipients receive prompt approval for services and also receive all approved services, Stanislaus County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

53. To communicate to both the public and its officers its commitment to performing its duties in a fair and impartial manner, Stockton Police 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.

54. To improve its ability to recruit qualified applicants who reflect the diversity of its communities, by October 2022, Stockton Police should have a process for regularly monitoring data on the diversity of its current personnel, its new hires, and to the extent possible, its applicant pool. It should use these data to evaluate the success of its recruitment efforts and identify needed areas of improvement.

56. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, Stockton Police should proactively seek and attempt to contact secondary references to obtain more candid information about applicants, such as information about past biased conduct or affiliation with hate groups.

57. To better assess whether peace officer applicants have the ability to work with diverse members of their communities and whether they possess detectable disqualifying biases, by no later than October 2022, Stockton Police should should begin using documented procedures that adhere to best practices to identify and review applicants' public social media profiles for content indicative of disqualifying biases, such as hate group affiliation.

58. To strengthen its relationships with its community and mitigate the effects of bias on its officers, Stockton Police should develop and begin implementing a documented
strategy to do all of the following by April 2023:
- Collaborate with its communities to establish or leverage community advisory boards consisting of representatives of diverse groups. The strategy should specify how it will partner with the boards in the areas of recruitment, hiring, training, and community engagement, as well as how it will leverage the boards to obtain feedback on how it can better serve its community.
- Ensure that officers at all levels regularly participate in community engagement activities.
- Periodically survey its community to assess the effectiveness of its community engagement efforts and solicit feedback on how to improve its operations.

59. To proactively identify signs that officers may need additional training or supports to address possible biased behavior, Stockton Police 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. The system should include analysis of stops data that identifies officers based on indications of possible biased conduct.
- 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.

60. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police should ensure it has implemented policies or procedures by January 2023 that require that misconduct investigations formally analyze whether an officer has acted in a biased manner whenever a complainant alleges bias, the facts of the incident indicate bias might have influenced an officer's behavior, or investigators recognize potential indications of bias during other reviews, such as use-of-force reviews.

61. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police should ensure it has implemented policies or procedures by January 2023 that require that the investigations apply a definition of bias that incorporates the following: biased conduct can include conduct resulting from implicit as well as explicit biases; conduct is biased if a reasonable person would conclude so using the facts at hand; an officer need not admit biased or prejudiced intent for conduct to reasonably appear biased; and biased conduct may occur in an encounter with the public, with other officers, or online, such as conduct on social media.

62. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police should ensure it has implemented policies or procedures by January 2023 that require that the individuals handling bias-related investigations follow detailed investigative guidelines for identifying biased conduct and be specifically trained in how to perform these assessments.

63. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police should ensure that, by January 2023, it has formalized policies - such as through discipline matrices or broader discipline guidelines - specifying options for corrective actions beyond punitive discipline that are designed to change officer behaviors associated with biased conduct. The department should 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.

64. To ensure that it adequately investigates possible biased conduct and implements effective corrective actions, Stockton Police's policies should require that investigations
include a formal determination that makes clear whether biased conduct occurred or not, as well as the rationale for reaching the determination.

65. To ensure that it accurately reports information about all complaints as required by state law, Stockton Police should ensure that it reports to DOJ about all public complaints related to racial or identity profiling, including those that initially appear to be unfounded, and the disposition of those complaints.