Report 2017-129 Recommendation 13 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 #13 To: Rehabilitation, Department of
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.
Annual Follow-Up Agency Response From November 2023
The Department is currently developing a Request for Applications for Traumatic Brain Injury and expects to award grants in or about July 2024. Thereafter, the Department will submit documentation demonstrating full implementation of this recommendation.
- Estimated Completion Date: August 2024
California State Auditor's Assessment of Annual Follow-Up Status: Pending
Annual Follow-Up Agency Response From October 2022
The Department awarded grants through the RFA for the Traumatic Brain Injury Program in March 2022. The Program Director notified the Chief Deputy by sending an official memorandum summarizing the evaluation process and the evaluation panel's recommendation before posting the Notice of Intent to Award. The Department will provide the CSA contact the memo from the Program Director to the Chief Deputy that was sent via email prior to posting the Notice of Intent to Award.
- Completion Date: March 2022
California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented
Since we made this recommendation, Rehabilitation has modified its grant manual, including the responsibilities for reviewing the evaluations of grant applications and issuing a summary memorandum to the director and chief deputy. Currently, the manual assigns responsibility for reviewing the evaluation process to a Post Evaluation Review individual or team designated by the administrative services deputy director, and the program director administering the grant issues a summary memorandum to the director and chief deputy. The manual does not designate the person responsible for reviewing and approving the memorandum and recommended awardees before publishing the notice of intent to award, as we recommended. Thus, until it does so, we will continue to report this recommendation as not fully implemented.
The intent of our recommendation served two purposes. First, for a separation of duties, the individual or team conducting post evaluation reviews should be appointed and overseen separately from the program staff who select the initial evaluators and oversee the grant administration. Thus, if followed, Rehabilitation's revisions to its grant manual accomplish this goal. Second, to ensure that the director and chief deputy are fully informed of critical aspects of the grant process, we recommended that Rehabilitation designate the person responsible for reviewing and approving the memorandum and intended awardees. However, Rehabilitation has not implemented this portion of the recommendation.
Further, we found inconsistencies in the documentation Rehabilitation provided regarding the Traumatic Brain Injury Program grant mentioned in its response. For example, the program deputy, rather than the administrative services deputy, appointed the post evaluation reviewer. Further, the program deputy inaccurately described the evaluation review in the summary memorandum to the director and chief deputy, stating that the review did not observe any discrepancies in evaluator scoring or noncompliance with scoring instructions, even though the post evaluation review noted several issues with evaluators not appropriately supporting their scores. Additionally, Rehabilitation could not demonstrate that the director or chief deputy reviewed or approved the memorandum and intended awardees before the department published the notice of intent to award.
We look forward to reviewing Rehabilitation's progress in implementing this recommendation during its future responses.
- Auditee did not substantiate its claim of full implementation
- Auditee did not address all aspects of the recommendation
Annual Follow-Up Agency Response From October 2021
The Department put out a Request for Application (RFA) for the Traumatic Brain Injury Program September 2021. The Program Director will notify the Chief Deputy by sending an official memorandum summarizing the evaluation process and the evaluation panel's recommendation before posting the Notice of Intent to Award. Per CSA's request the Department will provide documentation that will demonstrate full implementation of the CSA recommendation after grant award.
- Estimated Completion Date: 1/2022
California State Auditor's Assessment of Annual Follow-Up Status: Pending
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.
- Completion Date: February 2020
California State Auditor's Assessment of Annual Follow-Up Status: Pending
Rehabilitation's grant solicitation manual does not require its technical review team to issue a memorandum to the director and chief deputy summarizing the evaluation process and the evaluators' recommended grant awardees. Despite its grant solicitation manual assigning responsibility to the review team for reviewing and verifying that the evaluation panel followed applicable scoring instructions and processes, Rehabilitation did not demonstrate that the review team conducted such a review for its most recent grant. As such, it also did not summarize its findings to the director and chief deputy. Further, Rehabilitation did not demonstrate that it appointed an individual who was responsible for reviewing and approving the memorandum and recommended awardees before publishing the notice of intent to award. Until it addresses these concerns, we will continue to report this recommendation as not fully implemented.
- Auditee did not substantiate its claim of full implementation
- Auditee did not address all aspects of the recommendation
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.
- Estimated Completion Date: July 2020
California State Auditor's Assessment of Annual Follow-Up Status: Pending
1-Year Agency Response
The Department has revised the GSM to include these recommendations and will carry out these practices in future grant solicitations.
- Estimated Completion Date: August 2019
- Response Date: July 2019
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.
- Estimated Completion Date: GSM Interim Guidance - October 2018: Final GSM - After regulatory process has concluded
- Response Date: January 2019
California State Auditor's Assessment of 6-Month Status: Pending
60-Day Agency Response
The Department has revised the GSM to include these recommendations and will carry out these practices in future grant solicitations.
- Estimated Completion Date: October 2018 for Interim GSM; Final GSM after regulatory process has concluded
- Response Date: September 2018
California State Auditor's Assessment of 60-Day Status: Pending
All Recommendations in 2017-129
Agency responses received are posted verbatim.