San Mateo County Community College District

BETTY T. YEE California State Controller October 12, 2018 Kathy Blackwood, Executive Vice Chancellor Financial Services San Mateo County Community College District 3401 CSM Drive San Mateo, CA 94402 Dear Ms. Blackwood: The State Controller’s Office (SCO) performed a desk review of costs claimed by the San Mateo County Community College District for the legislatively mandated Integrated Waste Management (IWM) Program for the period of July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011. We did not include the costs claimed for the period of July 1, 2004, through June 30, 2005, in the review period because the statute of limitations to initiate the review has expired. We conducted our review under the authority of Government Code (GC) sections 12410, 17558.5, and 17561. Our review was limited to ensure that offsetting savings were properly reported in accordance with program requirements. This reissued letter report updates our previous letter report, dated October 20, 2015. The previous letter report identified $661,373 in unreported offsetting savings for fiscal year (FY) 2003-04, and FY 2005-06 through FY 2010-11. On July 27, 2018, the Commission on State Mandates (Commission) issued a decision in response to an Incorrect Reduction Claim filed by the district for the IWM Program. In its decision, the Commission concluded that our reduction of costs claimed for the first half of FY 2003-04 (which was based on a diversion rate of 50% rather than 25%) was incorrect and that the difference of $8,197 had been incorrectly reduced. In compliance with the Commission’s decision, we reduced the FY 2003-04 offsetting savings findings by $8,197, from $84,490 to $76,293. However, this adjustment does not result in additional allowable costs to the district, as the unreported offsetting savings finding for FY 2003-04 of $76,293 exceeds the amount claimed (of $45,560). We advised you of the revision to this letter report via email on September 8, 2018. The district claimed $843,392 for the mandated program. Our review found that $608,751 is allowable ($618,751 less a $10,000 penalty for filing a late claim) and $234,641 is unallowable. The costs are unallowable because the district did not report offsetting savings realized as a result of implementing its IWM plans, as described in the Revised Attachment 1–Summary of Program Costs, Revised Attachment 2–Summary of Offsetting Savings Calculations, and Revised Attachment 3–Review Results. The State paid the district $608,751. P.O. Box 942850, Sacramento, CA 94250  (916) 445-2636 3301 C Street, Suite 700, Sacramento, CA 95816  (916) 324-8907 901 Corporate Center Drive, Suite 200, Monterey Park, CA 91754  (323) 981-6802 Kathy Blackwood, Executive Vice -2- October 12, 2018 Chancellor If you have any questions, please contact Lisa Kurokawa, Chief, Compliance Audits Bureau, by telephone at (916) 327-3138. Sincerely, Original signed by JEFFREY V. BROWNFIELD, CPA Chief, Division of Audits JVB/ls Attachments RE: S16-MCC-9013R cc: Christian Osmeña, Vice Chancellor College Finance and Facilities Planning California Community Colleges Chancellor’s Office Frances Parmelee, Assistant Vice Chancellor College Finance and Facilities Planning California Community Colleges Chancellor’s Office Wrenna Finche, Director of Fiscal Standards and Accountability College Finance and Facilities Planning California Community Colleges Chancellor’s Office Chris Ferguson, Assistant Program Budget Manager Education Systems Unit, California Department of Finance Keith Nezaam, Staff Finance Budget Analyst Education Systems Unit, California Department of Finance Anita Dagan, Manager Local Government Programs and Services Division State Controller’s Office San Mateo County Community College District Integrated Waste Management Program Revised Attachment 1— Summary of Program Costs July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011 Actual Costs Allowable Review Cost Elements1 Claimed per Review Adjustment2 July 1, 2003, through June 30, 2004 Direct costs: Salaries and benefits $ 34,185 $ 34,185 $ - Fixed assets 1,575 1,575 - Total direct costs 35,760 35,760 - Indirect costs 10,256 10,256 - Total direct and indirect costs 46,016 46,016 - Less offsetting reimbursements ( 456) ( 456) - Less offsetting savings3 - ( 76,293) ( 76,293) Subtotal 45,560 ( 30,733) ( 76,293) Adjustment to eliminate negative balance - 30,733 30,733 Total program costs $ 45,560 - $ ( 45,560) Less amount paid by the State4 - Allowable costs claimed in excess of amount paid $ - July 1, 2005, through June 30, 2006 Direct costs: Salaries and benefits $ 3,054 $ 3,054 $ - Contract services 2,000 2,000 - Fixed assets 2,339 2,339 - Total direct costs 7,393 7,393 - Indirect costs 916 916 - Total direct and indirect costs 8,309 8,309 - Less other reimbursements ( 1,133) ( 1,133) - Less offsetting savings3 - ( 272,848) ( 272,848) Subtotal 7,176 ( 265,672) ( 272,848) Adjustment to eliminate negative balance - 265,672 265,672 Total program costs $ 7,176 - $ ( 7,176) Less amount paid by the State4 - Allowable costs claimed in excess of amount paid $ - 1 of 4 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 1 (continued) Actual Costs Allowable Review Cost Elements1 Claimed per Review Adjustment2 July 1, 2006, through June 30, 2007 Direct costs: Salaries and benefits $ 3,735 $ 3,735 $ - Indirect costs 1,121 1,121 - Total direct and indirect costs 4,856 4,856 - Less offsetting savings3 - ( 73,287) ( 73,287) Subtotal 4,856 ( 68,431) ( 73,287) Adjustment to eliminate negative balance - 68,431 68,431 Total program costs $ 4,856 - $ ( 4,856) Less amount paid by the State4 - Allowable costs claimed in excess of amount paid $ - July 1, 2007, through June 30, 2008 Direct costs: Salaries and benefits $ 2,083 $ 2,083 $ - Indirect costs 625 625 - Total direct and indirect costs 2,708 2,708 - Less offsetting savings3 - ( 66,407) ( 66,407) Subtotal 2,708 ( 63,699) ( 66,407) Adjustment to eliminate negative balance - 63,699 63,699 Total program costs $ 2,708 - $ ( 2,708) Less amount paid by the State4 - Allowable costs claimed in excess of amount paid $ - July 1, 2008, through June 30, 2009 Direct costs: Salaries and benefits $ 288,480 $ 288,480 $ - Indirect costs 86,544 86,544 - Total direct and indirect costs 375,024 375,024 - Less offsetting savings3 - ( 71,103) ( 71,103) Total program costs $ 375,024 303,921 $ ( 71,103) Less amount paid by the State4 ( 303,921) Allowable costs claimed in excess of amount paid $ - 2 of 4 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 1 (continued) Actual Costs Allowable Review Cost Elements1 Claimed per Review Adjustment2 July 1, 2009, through June 30, 2010 Direct costs: Salaries and benefits $ 231,812 $ 231,812 $ - Indirect costs 96,202 96,202 - Total direct and indirect costs 328,014 328,014 - Less offsetting savings3 - ( 74,456) ( 74,456) Subtotal 328,014 253,558 ( 74,456) Less late filing penalty5 - ( 10,000) ( 10,000) Total program costs $ 328,014 243,558 $ ( 84,456) Less amount paid by the State4 ( 243,558) Allowable costs claimed in excess of amount paid $ - July 1, 2010, through June 30, 2011 Direct costs: Salaries and benefits $ 54,503 $ 54,503 $ - Indirect costs 25,551 25,551 - Total direct and indirect costs 80,054 80,054 - Less offsetting savings3 - ( 18,782) ( 18,782) Total program costs $ 80,054 61,272 $ ( 18,782) Less amount paid by the State4 ( 61,272) Allowable costs claimed in excess of amount paid $ - 3 of 4 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 1 (continued) Actual Costs Allowable Review Cost Elements1 Claimed per Review Adjustment2 Summary: July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011 Direct costs: Salaries and benefits $ 617,852 $ 617,852 $ - Contract services 2,000 2,000 - Fixed assets 3,914 3,914 - Total direct costs 623,766 623,766 - Indirect costs 221,215 221,215 - Total direct and indirect costs 844,981 844,981 - Less other reimbursements ( 1,589) ( 1,589) - Less offsetting savings3 - ( 653,176) ( 653,176) Subtotal 843,392 190,216 ( 653,176) Adjustment to eliminate negative balance - 428,535 428,535 Subtotal 843,392 618,751 ( 224,641) Less late filing penalty5 - ( 10,000) ( 10,000) Total program costs $ 843,392 608,751 $ ( 234,641) Less amount paid by the State4 ( 608,751) Allowable costs claimed in excess of amount paid $ - _________________________ 1 GC section 17558.5(a) allows the SCO to initiate an audit no later than three years from the date on which a reimbursement claim is filed or last amended, whichever is later. However, if no funds are appropriated or no payment is made, the time to initiate the audit starts from the date on which the SCO makes the initial payment on the claim. The FY 2004-05 claim was fully paid and the three-year statute of limitations to initiate the review had expired by the time we initiated this engagement. 2 See Revised Attachment 3, Review Results. 3 See Revised Attachment 2, Summary of Offsetting Savings Calculations. 4 Payment information current as of September 24, 2018. 5 The district filed its FY 2009-10 annual reimbursement claim after the due date specified in GC section 17560. Pursuant to GC section 17568, the State assessed a late filing penalty equal to 10% of allowable costs, not to exceed $10,000 (for claims filed on or after August 24, 2007). 4 of 4 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 2— Summary of Offsetting Savings Calculations July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011 Offsetting Savings Offsetting Savings Realized Review Cost Elements Reported July – December January – June Total Adjustment1 July 1, 2003, through June 30, 2004 Skyline College: Maximum required diversion percentage 25.00% 50.00% Actual diversion percentage ÷ 74.41% ÷ 74.05% Allocated diversion percentage 33.60% 67.52% Tonnage diverted × ( 145.85) × (162.80) Statewide average landfill fee per ton × $36.83 × $38.42 Offsetting savings, Skyline College (1,805) (4,223) (6,028) Cañada College: Maximum required diversion percentage 25.00% 50.00% Actual diversion percentage ÷ 51.13% ÷ 71.04% Allocated diversion percentage 48.89% 70.38% Tonnage diverted × ( 94.70) × (479.85) Statewide average landfill fee per ton × $36.83 × $38.42 Offsetting savings, Cañada College (1,705) (12,975) (14,680) College of San Mateo: Maximum required diversion percentage 25.00% 50.00% Actual diversion percentage ÷ 44.13% ÷ 75.41% Allocated diversion percentage 56.65% 66.30% Tonnage diverted × ( 293.50) × (1,941.75) Statewide average landfill fee per ton × $36.83 × $38.42 Offsetting savings, College of San Mateo (6,124) (49,461) (55,585) Total offsetting savings, FY 2003-04 $ - $ (9,634) $ (66,659) $ (76,293) $ (76,293) July 1, 2005, through June 30, 2006 Skyline College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 72.90% ÷ 65.86% Allocated diversion percentage 68.59% 75.92% Tonnage diverted × ( 485.25) × (623.65) Statewide average landfill fee per ton × $39.00 × $46.00 Offsetting savings, Skyline College (12,980) (21,780) (34,760) Cañada College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 99.05% ÷ 55.19% Allocated diversion percentage 50.48% 90.60% Tonnage diverted × ( 10,497.40) × (144.55) Statewide average landfill fee per ton × $39.00 × $46.00 Offsetting savings, Cañada College (206,664) (6,024) (212,688) 1 of 5 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 2 (continued) Offsetting Savings Offsetting Savings Realized Review Cost Elements Reported July – December January – June Total Adjustment1 July 1, 2005, through June 30, 2006 (continued) College of San Mateo: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 61.26% ÷ 62.57% Allocated diversion percentage 81.62% 79.91% Tonnage diverted × ( 380.55) × (361.45) Statewide average landfill fee per ton × $39.00 × $46.00 Offsetting savings, College of San Mateo (12,114) (13,286) (25,400) Total offsetting savings, FY 2005-06 $ - $ (231,758) $ (41,090) $ (272,848) $ (272,848) July 1, 2006, through June 30, 2007 Skyline College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 65.86% ÷ 80.99% Allocated diversion percentage 75.92% 61.74% Tonnage diverted × ( 623.65) × (505.75) Statewide average landfill fee per ton × $46.00 × $48.00 Offsetting savings, Skyline College (21,780) (14,988) (36,768) Cañada College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 55.19% ÷ 58.83% Allocated diversion percentage 90.60% 84.99% Tonnage diverted × ( 144.55) × (136.30) Statewide average landfill fee per ton × $46.00 × $48.00 Offsetting savings, Cañada College (6,024) (5,560) (11,584) College of San Mateo: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 62.57% ÷ 56.74% Allocated diversion percentage 79.91% 88.12% Tonnage diverted × ( 361.45) × (275.40) Statewide average landfill fee per ton × $46.00 × $48.00 Offsetting savings, College of San Mateo (13,286) (11,649) (24,935) Total offsetting savings, FY 2006-07 $ - $ (41,090) $ (32,197) $ (73,287) $ (73,287) July 1, 2007, through June 30, 2008 Skyline College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 80.99% ÷ 80.99% Allocated diversion percentage 61.74% 61.74% Tonnage diverted × ( 505.75) × (505.75) Statewide average landfill fee per ton × $48.00 × $51.00 Offsetting savings, Skyline College (14,988) (15,925) (30,913) 2 of 5 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 2 (continued) Offsetting Savings Offsetting Savings Realized Review Cost Elements Reported July – December January – June Total Adjustment1 July 1, 2007, through June 30, 2008 (continued) Cañada College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 58.83% ÷ 58.83% Allocated diversion percentage 84.99% 84.99% Tonnage diverted × ( 136.30) × (136.30) Statewide average landfill fee per ton × $48.00 × $51.00 Offsetting savings, Cañada College (5,560) (5,908) (11,468) College of San Mateo: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 56.74% ÷ 56.74% Allocated diversion percentage 88.12% 88.12% Tonnage diverted × ( 275.40) × (275.40) Statewide average landfill fee per ton × $48.00 × $51.00 Offsetting savings, College of San Mateo (11,649) (12,377) (24,026) Total offsetting savings, FY 2007-08 $ - $ (32,197) $ (34,210) $ (66,407) $ (66,407) July 1, 2008, through June 30, 2009 Skyline College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 80.99% ÷ 80.99% Allocated diversion percentage 61.74% 61.74% Tonnage diverted × ( 505.75) × (505.75) Statewide average landfill fee per ton × $51.00 × $55.00 Offsetting savings, Skyline College (15,925) (17,174) (33,099) Cañada College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 58.83% ÷ 58.83% Allocated diversion percentage 84.99% 84.99% Tonnage diverted × ( 136.30) × (136.30) Statewide average landfill fee per ton × $51.00 × $55.00 Offsetting savings, Cañada College (5,908) (6,371) (12,279) College of San Mateo: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 56.74% ÷ 56.74% Allocated diversion percentage 88.12% 88.12% Tonnage diverted × ( 275.40) × (275.40) Statewide average landfill fee per ton × $51.00 × $55.00 Offsetting savings, College of San Mateo (12,377) (13,348) (25,725) Total offsetting savings, FY 2008-09 $ - $ (34,210) $ (36,893) $ (71,103) $ (71,103) 3 of 5 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 2 (continued) Offsetting Savings Offsetting Savings Realized Review Cost Elements Reported July – December January – June Total Adjustment1 July 1, 2009, through June 30, 2010 Skyline College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 80.99% ÷ 80.99% Allocated diversion percentage 61.74% 61.74% Tonnage diverted × ( 505.75) × (505.75) Statewide average landfill fee per ton × $55.00 × $56.00 Offsetting savings, Skyline College (17,174) (17,486) (34,660) Cañada College: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 58.83% ÷ 58.83% Allocated diversion percentage 84.99% 84.99% Tonnage diverted × ( 136.30) × (136.30) Statewide average landfill fee per ton × $55.00 × $56.00 Offsetting savings, Cañada College (6,371) (6,487) (12,858) College of San Mateo: Maximum required diversion percentage 50.00% 50.00% Actual diversion percentage ÷ 56.74% ÷ 56.74% Allocated diversion percentage 88.12% 88.12% Tonnage diverted × ( 275.40) × (275.40) Statewide average landfill fee per ton × $55.00 × $56.00 Offsetting savings, College of San Mateo (13,348) (13,590) (26,938) Total offsetting savings, FY 2009-10 $ - $ (36,893) $ (37,563) $ (74,456) $ (74,456) July 1, 2010, through June 30, 2011 Skyline College: Maximum required diversion percentage 50.00% --- Actual diversion percentage ÷ 80.99% ÷ --- Allocated diversion percentage 61.74% --- Tonnage diverted × ( 252.88) × --- Statewide average landfill fee per ton × $56.00 × --- Offsetting savings, Skyline College (8,743) --- (8,743) Cañada College: Maximum required diversion percentage 50.00% --- Actual diversion percentage ÷ 58.83% ÷ --- Allocated diversion percentage 84.99% --- Tonnage diverted × ( 68.15) × --- Statewide average landfill fee per ton × $56.00 × --- Offsetting savings, Cañada College (3,244) --- (3,244) 4 of 5 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 2 (continued) Offsetting Savings Offsetting Savings Realized Review Cost Elements Reported July – December January – June Total Adjustment1 July 1, 2010, through June 30, 2011 (continued) College of San Mateo: Maximum required diversion percentage 50.00% --- Actual diversion percentage ÷ 56.74% ÷ --- Allocated diversion percentage 88.12% --- Tonnage diverted × ( 137.70) × --- Statewide average landfill fee per ton × $56.00 × --- Offsetting savings, College of San Mateo (6,795) --- (6,795) Total offsetting savings, FY 2010-11 $ - $ (18,782) --- $ (18,782) $ (18,782) Summary: July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011 $ - $ (404,564) $ (248,612) $ (653,176) $ (653,176) _________________________ 1 See Revised Attachment 3, Review Results. 5 of 5 San Mateo County Community College District Integrated Waste Management Program Revised Attachment 3— Review Results July 1, 2003, through June 30, 2004; and July 1, 2005, through June 30, 2011 BACKGROUND— On March 25, 2004, the Commission adopted its statement of decision, finding that Public Resources Code (PRC) sections 40148, 40196.3, 42920 through 42928; Public Contract Code (PCC) sections 12167 and 12167.1; and the State Agency Model Integrated Waste Management Plan (February 2000) require new activities which constitute new programs or higher levels of service for community college districts within the meaning of Article XIII B, section 6, of the California Constitution, and impose costs mandated by the State pursuant to GC section 17514. Specifically, the Commission approved the test claim for the increased costs of performing the following specific activities:  Complying with the model plan (PRC section 42920(b)(3) and the State Agency Model Integrated Waste Management Plan, February 2000);  Designating a solid waste reduction and recycling coordinator (PRC section 42920(c));  Diverting solid waste (PRC sections 42921 and 42922(i));  Reporting to the Integrated Waste Management Board (Board) (PRC sections 42926(a) and 42922(i)); and  Submitting recycled material reports (PCC section 12167.1). In March 2007, the California Department of Finance and the Board filed a petition for a Writ of Mandate requesting that the Commission issue new parameters and guidelines giving full consideration to the community colleges’ cost savings (e.g. avoided landfill disposal fees) and revenues (from recyclables) generated by complying with the test claim statutes. The Judgment and a Writ of Mandate were issued on June 30, 2008, ordering the Commission to amend the parameters and guidelines to require that community college districts identify, and offset from their claims, cost savings realized as a result of implementing their IWM plans. On September 26, 2008, the Commission amended the parameters and guidelines for the original period of reimbursement because the court’s decision interprets the test claim statutes as a question of law. In compliance with GC section 17558, the SCO issues claiming instructions to assist community college districts in claiming mandated- program reimbursable costs. 1 of 4 San Mateo County Community College District Integrated Waste Management Program REVISED FINDING— The district did not report any offsetting savings on its mandated cost claims for the review period. We found that the district realized savings of Unreported offsetting $653,176 from implementation of IWM plans. savings The following table summarizes the unreported offsetting savings amounts by fiscal year: Offsetting Offsetting Fiscal Savings Savings Review Year Reported Realized Adjustment 2003-04 $ - $ (76,293) $ (76,293) 2005-06 - (272,848) (272,848) 2006-07 - ( 73,287) (73,287) 2007-08 - ( 66,407) (66,407) 2008-09 - ( 71,103) (71,103) 2009-10 - ( 74,456) (74,456) 2010-11 - ( 18,782) (18,782) Total $ - $ (653,176) $ (653,176) Section VIII. (Offsetting Savings) of the amended parameters and guidelines states: Reduced or avoided costs realized from implementation of the community college districts’ Integrated Waste Management Plan shall be identified and offset from this claim as cost savings, consistent with the direction for revenue in Public Contract Code sections 12167 and 12167.1. PCC sections 12167 and 12167.1 require agencies in state-owned and state-leased buildings to deposit all revenues from the sale of recyclables into the IWM Account in the IWM Fund, which is continuously appropriated to the Board for the purposes of offsetting recycling program costs. For the review period, the district did not deposit any revenue into the IWM Account in the IWM Fund. Our review found that the district realized reduced costs or avoided costs through implementation of its IWM plans that it did not identify and offset from its claims as cost savings. Offsetting Savings Calculation The Commission’s Final Staff Analysis of the proposed amendments to the parameters and guidelines (Item No. 8 – Commission hearing of September 26, 2008) states, in part: Cost savings may be calculated from the annual solid waste disposal reduction or diversion rates that community colleges must annually report to the Board pursuant to Public Resources Code section 42926, subdivision (b)(1). 2 of 4 San Mateo County Community College District Integrated Waste Management Program To compute the savings amount, we multiplied the allocated diversion percentage by the tonnage diverted, and then by the avoided landfill disposal fee, as follows: Allocated Diversion % Maximum Avoided Allowable Landfill Offsetting = Diversion % × Tonnage × Disposal Fee Savings Actual Diverted (per Ton) Diversion % This calculation determines the costs that the district did not incur for solid waste disposal as a result of implementing its IWM plans. The offsetting savings calculations are presented in Revised Attachment 2—Summary of Offsetting Savings Calculations. Allocated Diversion Percentage PRC section 42921 requires districts to achieve a solid waste diversion percentage of 25% beginning January 1, 2002, and a 50% diversion percentage by January 1, 2004. The parameters and guidelines state that districts will be reimbursed for all mandated costs incurred to achieve these levels, without reduction when they fall short of stated goals, but not for amounts used to exceed these state-mandated levels. Therefore, we allocated the offsetting savings to be consistent with the requirements of the mandated program. For calendar years 2000 through 2007, we used the actual diversion percentage reported by the district to the Board pursuant to PRC section 42926, subdivision (b)(1). In 2008, the Board began focusing on “per-capita disposal” instead of “diversion percentage.” As a result, the Board stopped requiring community college districts to report the actual amount of tonnage diverted. Consequently, the annual reports no longer identify a “diversion percentage.” Therefore, we used the 2007 diversion percentage to calculate the offsetting savings for FY 2007-08 through FY 2010-11. The district did not provide documentation supporting a different diversion percentage. Tonnage Diverted The tonnage diverted is solid waste that the district recycled, composted, and kept out of the landfill. For calendar years 2000 through 2007, we used the actual tonnage diverted, as reported by the district to the Board pursuant to PRC section 42926, subdivision (b)(1). As the Board stopped requiring community college districts to report the actual amount of tonnage diverted in 2008, we used the tonnage diverted in 2007 to calculate the offsetting savings for FY 2007-08 through FY 2010-11. The district did not provide documentation to support a different amount of tonnage diverted. 3 of 4 San Mateo County Community College District Integrated Waste Management Program Avoided Landfill Disposal Fee (per Ton) The avoided landfill disposal fee is used to calculate realized savings because the district no longer incurs a cost to dispose of the diverted tonnage at the landfill. For each fiscal year in the review period, we used the statewide average disposal fee provided by the California Department of Resources Recycling and Recovery, which was established in 2010 to replace the Board. The district did not provide documentation to support a different disposal fee. Recommendation The IWM Program was suspended in the FY 2011-12 through FY 2017-18 Budget Acts. Furthermore, commencing in FY 2012-13, the district elected to receive block grant funding pursuant to GC section 17581.7, in lieu of filing annual mandated cost claims. If the IWM Program becomes active again and if the district chooses to opt out of receiving block grant funds, we recommend that the district:  Follow the mandated program’s claiming instructions and the parameters and guidelines when filing its reimbursement claims; and  Offset all savings realized from implementation of the community college district’s IWM plans. 4 of 4