Report 2019-111 Recommendation 21 Responses

Report 2019-111: Mobile Home Park Inspections: The Department of Housing and Community Development Must Improve Its Inspection Processes to Better Protect Park Residents (Release Date: July 2020)

Recommendation #21 To: Housing and Community Development, Department of

To ensure that it is aware of any potential conflicts of interest that its inspectors may have, HCD should by September 2020 develop procedures to ensure that staff promptly notify the Form 700 filing officer of all inspectors hired or leaving HCD employment.

Annual Follow-Up Agency Response From July 2022

Form 700 manual fully implemented in February 2022 to ensure that staff promptly notify the Form 700 filing officer of all inspectors hired or leaving HCD employment.

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

1-Year Agency Response

HCD has developed the following process in response to this audit finding:

HCD's Human Resources Branch (HRB), will notify the Compliance Specialist upon the hiring or separation of any HCD employee. The HRB will do so via email (as it currently does with many other divisions and branches within the Department).

The Compliance Specialist will then contact the new/former employee and direct them to file the required statement/s. The Compliance Specialist will monitor filings on the SouthTec application to determine if the required statement/s have been properly filed. If they have not, the Compliance Specialist will notify the new/former employee of the need to file the required statement/s and provide the necessary notifications as directed by FPPC guidelines.

If the new/former employees do not comply with these notices and file the required statement/s, the Compliance Officer will report non-filers to the FPPC pursuant to FPPC guidelines.

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

HCD's Form 700 process manual describes adding new filers and altering the status of filers when they change positions within HCD so that the filer receives notification of requirement to file a Form 700. However, the manual does not establish procedures for ensuring that designated filers leaving employment complete their Form 700s. Additionally, the procedures do not specify the process for notifying the filing officer when inspectors start or end their employment with HCD, as we recommended.

6-Month Agency Response

HCD to draft procedures to ensure Form 700 filing officer is notified upon employment or separation of inspectors. HR responsibility upon separation of employee. HR notifies Form 700 coordinator (Compliance Specialist in LAD) of hiring or separation. The Form 700 coordinator is on an email that is sent out to many departments, including IT, when an employee joins the department or separates. Form 700 coordinator contacts employee or former employee to file either leaving office statement or assuming office statement. Form 700 coordinator continues to monitor filings on SouthTec to determine if statements have been filed. If they have not, second notices will be generated pursuant to FPPC guidelines. If they still have not filed these statements, Form 700 Coordinator will report non-filers to FPPC.

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

60-Day Agency Response

HCD to draft procedures to ensure Form 700 filing officer is notified upon employment or separation of inspectors. HR responsibility upon separation of employee. HR notifies Form 700 coordinator (Compliance Specialist in Legal Affairs Division) of hiring or separation. The Form 700 coordinator is on an email that is sent out to many departments, including IT, when an employee joins the department or separates. Form 700 coordinator contacts employee or former employee to file either leaving office statement or assuming office statement. Form 700 coordinator continues to monitor filings on SouthTec to determine if statements have been filed. If they have not, second notices will be generated pursuant to FPPC guidelines. If they still have not filed these statements, Form 700 Coordinator will report non-filers to FPPC.

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

All Recommendations in 2019-111

Agency responses received are posted verbatim.