Report 2017-129 Recommendation 11 Responses

Report 2017-129: Department of Rehabilitation: Its Inadequate Guidance and Oversight of the Grant Process Led to Inconsistencies and Perceived Bias in Its Evaluations and Awards of Some Grants (Release Date: July 2018)

Recommendation #11 To: Rehabilitation, Department of

To increase the transparency of its selection process and to ensure that it receives the most qualified evaluators possible, Rehabilitation should issue a public solicitation for evaluators for each grant that includes a description of essential and desirable qualifications.

Annual Follow-Up Agency Response From October 2022

Consistent with the Department's commitment to improving our grant award process, the RFA for the Traumatic Brain Injury Program awarded in March 2022 included the public solicitation for evaluators. The Department also implemented the use of a matrix to evaluate the evaluator applications prior to final selection. The matrix included an initial review for conflict of interest.

The Department will provide the CSA contact the public solicitation for evaluators and the matrix used to evaluate the applications submitted by potential evaluators.

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


Annual Follow-Up Agency Response From October 2021

In regard to the previous solicitation that CSA mentions in the example, we note that the Department determined that there was no evidence of evaluator bias, and there was sufficient evidence that the evaluator understood their responsibilities as an evaluator and completed their duties as an evaluator free of bias.

Consistent with the Department's commitment to improving our grant award process, the Request for Application (RFA) for the Traumatic Brain Injury Program September 2021 includes the public solicitation for evaluators. The Department also implemented the use of a matrix to evaluate the evaluator applications prior to final selection. The matrix included an initial review for conflict of interest.

Per CSA's request the Department will provide documentation that will demonstrate full implementation of the CSA recommendation after grant award.

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

As we stated in our previous assessment, for its previous grant, Rehabilitation issued a public solicitation for evaluators, which included minimal qualification requirements. According to its Grant Solicitation Manual, Rehabilitation should also identify criteria that will disqualify potential evaluators who have the appearance of bias or conflicts of interest. However, Rehabilitation did not identify such criteria for that RFA. As a result, we found that one of its evaluators had at least an appearance of bias with one of the grant applicants. Aside from having evaluators self-certify that they are free from conflicts of interest or bias, Rehabilitation did not demonstrate that it has made efforts to ensure it receives the most qualified evaluators possible that are impartial and unbiased.


Annual Follow-Up Agency Response From October 2020

The Department revised the GSM in October 2018 to include these recommendations and implemented these practices during the Department's first RFA solicitation process after Report 2017-129 was published. These changes are contained in the GSM Interim Guidance: October 2018.

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

For its most recent grant, Rehabilitation issued a public solicitation for evaluators, which included minimal qualification requirements. According to its Grant Solicitation Manual, Rehabilitation should also identify criteria that will disqualify potential evaluators who have the appearance of bias or conflicts of interest. However, Rehabilitation did not identify such criteria for this RFA. As a result, we found that one of its evaluators had at least an appearance of bias with one of the grant applicants. Aside from having evaluators self-certify that they are free from conflicts of interest or bias, Rehabilitation did not demonstrate that it has made efforts to ensure it receives the most qualified evaluators possible that are impartial and unbiased.


Annual Follow-Up Agency Response From October 2019

The Department is in the process of developing confidentiality procedures applicable to the grant solicitation process and will carry out these practices in future grant solicitations.

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


1-Year Agency Response

The Department has revised the GSM to include this recommendation and will carry out these practices in future grant solicitations.

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


6-Month Agency Response

The Department has revised the GSM to include these recommendations and will carry out these practices in future grant solicitations.

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


60-Day Agency Response

The Department has revised the GSM to include this recommendation and will carry out these practices in future grant solicitations.

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


All Recommendations in 2017-129

Agency responses received are posted verbatim.