Madera County

MADERA COUNTY Audit Report INTERAGENCY CHILD ABUSE AND NEGLECT INVESTIGATION REPORTS PROGRAM Penal Code sections 11165.9, 11166, 11166.2, 11166.9, 11168 (formerly 11161.7), 11169, 11170, and 11174.34 (formerly 11166.9) as added and/or amended by various legislation July 1, 1999, through June 30, 2015 BETTY T. YEE California State Controller January 2022 BETTY T. YEE California State Controller January 19, 2022 CERTIFIED MAIL—RETURN RECEIPT REQUESTED Todd E. Miller, CPA, Auditor-Controller Madera County 200 West 4th Street Madera, CA 93637 Dear Mr. Miller: The State Controller’s Office audited the costs claimed by Madera County for the legislatively mandated Interagency Child Abuse and Neglect Investigation Reports Program for the period of July 1, 1999, through June 30, 2015. The county claimed $1,518,250 for the costs of the mandated program. Our audit found that $468,092 is allowable ($515,678 less a $47,586 penalty for filing late claims) and $1,050,158 is unallowable. The costs are unallowable because the county estimated and misstated costs, overstated the number of referrals claimed for each cost component, misstated the productive hourly rates, overstated the benefit rates, overstated the related indirect costs, and overstated offsetting revenues. The State made no payments to the county. The State will pay $468,092, contingent upon available appropriations. Following issuance of this audit report, the Local Government Programs and Services Division of the State Controller’s Office will notify the county of the adjustment to its claims via a system-generated letter for each fiscal year in the audit period. If you have any questions, please contact Lisa Kurokawa, Chief, Compliance Audits Bureau, by telephone at (916) 327-3138. Sincerely, Original signed by KIMBERLY TARVIN, CPA Chief, Division of Audits KT/as Todd E. Miller, CPA, Auditor-Controller -2- January 19, 2022 cc: Elizabeth Cruz, Assistant Auditor-Controller Madera County Auditor-Controller’s Office Jim Boyajian, Assistant Auditor-Controller Madera County Auditor-Controller’s Office The Honorable Robert Poythress, Chairman Madera County Board of Supervisors Deborah Martinez, Director Madera County Department of Social Services Danny Morris, MBA, Ph.D., Deputy Director Madera County Department of Social Services Navdeep Singh, Fiscal Manager Madera County Department of Social Services Chris Hill, Principal Program Budget Analyst Local Government Unit California Department of Finance Steven Pavlov, Finance Budget Analyst Local Government Unit California Department of Finance Darryl Mar, Manager Reimbursement Section State Controller’s Office Everett Luc, Supervisor Reimbursement Section State Controller’s Office Madera County Interagency Child Abuse and Neglect Investigation Reports Program Contents Audit Report Summary ............................................................................................................................ 1 Background ........................................................................................................................ 1 Audit Authority.................................................................................................................. 3 Objective, Scope, and Methodology ................................................................................. 3 Conclusion .......................................................................................................................... 6 Follow-up on Prior Audit Findings .................................................................................. 6 Views of Responsible Officials .......................................................................................... 6 Restricted Use .................................................................................................................... 6 Schedule—Summary of Program Costs .............................................................................. 7 Findings and Recommendations ........................................................................................... 16 Attachment—County’s Response to Draft Audit Report Madera County Interagency Child Abuse and Neglect Investigation Reports Program Audit Report Summary The State Controller’s Office (SCO) audited the costs claimed by Madera County for the legislatively mandated Interagency Child Abuse and Neglect (ICAN) Investigation Reports Program for the period of July 1, 1999, through June 30, 2015. The county claimed $1,518,250 for the costs of the mandated program. Our audit found that $468,092 is allowable ($515,678 less a $47,586 penalty for filing late claims) and $1,050,158 is unallowable because the county estimated and misstated costs, overstated the number of referrals claimed for each cost component, misstated the productive hourly rates, overstated the benefit rates, overstated related indirect costs, and overstated offsetting revenues. The State made no payments to the county. The State will pay $468,092, contingent upon available appropriations. Background Various statutory provisions; Title 11, California Code of Regulations, section 903; and the Child Abuse Investigation Report (Form SS 8583), require cities and counties to perform specific activities when reporting child abuse to the State, as well as record-keeping and notification activities that were not required by prior law, thus mandating a new program or higher level of service.1 Penal Code (PC) sections 11165.9, 11166, 11166.2, 11166.9, 11168 (formerly 11161.7), 11169, 11170, and 11174.34 (formerly 11166.9) were added and/or amended by:  Statutes of 1977, Chapter 958;  Statutes of 1980, Chapter 1071;  Statutes of 1981, Chapter 435;  Statutes of 1982, Chapters 162 and 905;  Statutes of 1984, Chapters 1423 and 1613;  Statutes of 1985, Chapter 1598;  Statutes of 1986, Chapters 1289 and 1496;  Statutes of 1987, Chapters 82, 531, and 1459;  Statutes of 1988, Chapters 269, 1497, and 1580;  Statutes of 1989, Chapter 153;  Statutes of 1990, Chapters 650, 1330, 1363, and 1603;  Statutes of 1992, Chapters 163, 459, and 1338;  Statutes of 1993, Chapters 219 and 510;  Statutes of 1996, Chapters 1080 and 1081;  Statutes of 1997, Chapters 842, 843, and 844;  Statutes of 1999, Chapters 475 and 1012; and  Statutes of 2000, Chapter 916. 1 Form SS 8583 has been replaced with the Child Abuse or Severe Neglect Indexing Form (BCIA 8583). -1- Madera County Interagency Child Abuse and Neglect Investigation Reports Program The ICAN Investigation Reports Program addresses statutory amendments to California’s mandatory child abuse reporting laws. A child abuse reporting law was first added to the Penal Code in 1963, and initially required medical professionals to report suspected child abuse to local law enforcement or child welfare authorities. The law was regularly expanded to include more professions required to report suspected child abuse (now termed “mandated reporters”), and in 1980, California reenacted and amended the law, entitling it the “Child Abuse and Neglect Reporting Act” (Act). As part of this program, the Department of Justice (DOJ) maintains the Child Abuse Centralized Index (CACI), which has tracked reports of child abuse statewide since 1965. A number of changes to the law have occurred, including substantive amendments in 1997 and 2000. The Act, as amended, provides for reporting of suspected child abuse or neglect by certain individuals, identified by their profession as having frequent contact with children. The Act provides rules and procedures for local agencies, including law enforcement agencies that receive such reports. The Act provides for cross-reporting among law enforcement and other child protective agencies, and to licensing agencies and District Attorney’s (DA) offices. The Act requires reporting to the DOJ when a report of suspected child abuse is “not unfounded.” The Act requires an active investigation before a report can be forwarded to the DOJ. As of January 1, 2012, the Act no longer requires law enforcement agencies to report to the DOJ, and now requires reporting only of “substantiated” reports from other agencies. The Act imposes additional cross-reporting and recordkeeping duties in the event of a child’s death from abuse or neglect. The Act requires agencies and the DOJ to keep records of investigations for a minimum of 10 years, and to notify suspected child abusers that they have been listed in the CACI. The Act imposes certain due process protections owed to persons listed in the CACI, and describes other situations in which a person would be notified of his or her listing in the CACI. On December 19, 2007, the Commission on State Mandates (Commission) adopted a statement of decision finding that the test claim statutes impose a partially reimbursable state-mandated program upon local agencies within the meaning of Article XIII B, section 6 of the California Constitution and Government Code (GC) section 17514. The Commission approved the test claim for the reimbursable activities described in section IV of the program’s parameters and guidelines, performed by city and county police or sheriff’s departments, county welfare departments, county probation departments designated by the county to receive mandated reports, DAs’ offices, and county licensing agencies. The Commission outlined the following ongoing reimbursable activities:  Distributing the Suspected Child Abuse Report (Form SS 8572);  Reporting between local departments;  Reporting to the DOJ;  Providing notifications following reports to the CACI;  Retaining records; and -2- Madera County Interagency Child Abuse and Neglect Investigation Reports Program  Complying with due process procedures offered to persons listed in the CACI. The program’s parameters and guidelines establish the state mandate and define the reimbursement criteria. The Commission adopted the parameters and guidelines on December 6, 2013. In compliance with GC section 17558, the SCO issues the Mandated Cost Manual for Local Agencies (Mandated Cost Manual) to assist local agencies in claiming mandated program reimbursable costs. We conducted this performance audit in accordance with Audit Authority GC sections 17558.5 and 17561, which authorize the SCO to audit the county’s records to verify the actual amount of the mandated costs. In addition, GC section 12410 provides the SCO with general authority to audit the disbursement of state money for correctness, legality, and sufficient provisions of law. Objective, Scope, The objective of our audit was to determine whether costs claimed represent increased costs resulting from the legislatively mandated ICAN and Methodology Investigation Reports Program. Specifically, we conducted this audit to determine whether costs claimed were supported by appropriate source documents, were not funded by another source, and were not unreasonable and/or excessive.2 The audit period was July 1, 1999, through June 30, 2015. To achieve our objective, we performed the following procedures:  We reviewed the annual mandated cost claims filed by the county for the audit period and identified the significant cost components of each claim as salaries, benefits, and indirect costs. We determined whether there were any errors or unusual or unexpected variances from year to year, and we reviewed the claimed activities to determine whether they adhered to the SCO’s claiming instructions and the program’s parameters and guidelines.  We completed an internal control questionnaire by interviewing key county staff. We discussed the claim preparation process with county staff to determine what information was obtained, who obtained it, and how it was used.  We assessed the reliability of data generated by the county’s information management system (payroll reports and county expense claims) and the statewide child welfare system (Child Welfare Services [CWS]/Case Management System [CMS]) by interviewing county staff and examining supporting records. We determined that the data was sufficiently reliable to address the audit objectives. 2 Unreasonable and/or excessive costs include ineligible costs that are not identified in the programs parameters and guidelines as reimbursable costs. -3- Madera County Interagency Child Abuse and Neglect Investigation Reports Program  We interviewed county staff members to determine what employee classifications were involved in performing the reimbursable activities during the audit period.  We assessed whether the average time increments (ATIs) claimed for each fiscal year of the audit period to perform the reimbursable activities were reasonable per the requirements of the program.  We reviewed and analyzed the detailed referral listing generated by the CWS/CMS and provided by the county to determine the total eligible number of referrals for the Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office cost component. We identified and excluded non-mandate-related referrals and referrals ineligible for reimbursement (see Finding 1).  We reviewed and analyzed the detailed referral listing generated by the CWS/CMS and provided by the county to determine the total eligible number of referrals for the Complete an Investigation for Purposes of Preparing the Report cost component. We identified and excluded duplicate referrals, referrals initiated by Madera County’s Department of Social Services (DSS) staff as the mandated reporter and subsequently investigated by CWS staff, and general neglect referrals from the population, as they are ineligible and unallowable for reimbursement. We judgmentally selected as a non-statistical sample of 250 referrals for testing to determine the allowable number of referrals investigated. Based on our review of these referrals, we determined that DSS staff members had performed investigation activities on these referrals. We recalculated the costs based on the allowable number of referrals (see Finding 2).  We reviewed and analyzed the detailed referral listing generated by the CWS/CMS and provided by the county to determine the total eligible number of referrals for the Forward Reports to the Department of Justice cost component. Prior to January 1, 2012, both substantiated and inconclusive reports were eligible for reimbursement; as of January 1, 2012, forwarding inconclusive reports to DOJ is not reimbursable. We identified and excluded duplicate referrals and general neglect referrals from the population, as they are ineligible and unallowable for reimbursement. We relied upon the results of our review of the 250 referrals that were judgmentally selected as a non- statistical sample. Based on our review, we found that 216 out of the 250 referrals were eligible. Based on our testing results, we found that a Form SS 8583 was prepared and submitted to the DOJ for 167 (26 out of 45 in fiscal year [FY] 2000-01; 28 out of 45 in FY 2004-05; 36 out of 45 in FY 2007-08; 32 out of 36 in FY 2011-12, and all 45 in FY 2014-15) out of 216 referrals. Consistent with the American Institute of Certified Public Accountants’ Clarified Statement on Auditing Standards (AU-C) section 530, we calculated a weighted average based on the results of our testing. We projected the results by applying the weighted average of 77% to the total number of eligible referrals to determine the total allowable number of referrals for which DSS staff members prepared and submitted a Form SS 8583 to the DOJ during the audit period. We recalculated the costs based on the allowable number of referrals (see Finding 3). -4- Madera County Interagency Child Abuse and Neglect Investigation Reports Program  We reviewed and analyzed the detailed referral listing generated by the CWS/CMS and provided by the county to determine the total eligible number of referrals for the Notifications Following Reports to the Child Abuse Central Index cost component. Prior to January 1, 2012, both substantiated and inconclusive reports were eligible for reimbursement; as of January 1, 2012, forwarding inconclusive reports to DOJ is not reimbursable. We identified and excluded duplicate referrals and general neglect referrals from the population, as they are ineligible and unallowable for reimbursement. We relied upon the results of our review of the 250 referrals that were judgmentally selected as a non-statistical sample. Based on our review, we found that 216 out of the 250 referrals eligible. Based on our testing results, we determined that CACI notifications were sent for 143 (21 out of 45 in FY 2000-01; 20 out of 45 in FY 2004-05; 33 out of 45 in FY 2007-08; 29 out of 36 in FY 2011-12; and 40 out of 45 in FY 2014-15) out of 216 referrals. Consistent with AU-C section 530, we calculated a weighted average based on the results of our testing. We projected the results by applying the weighted average of 66% to the total number of eligible referrals to determine the total allowable number of referrals for which CACI notifications were sent to suspected child abusers by DSS staff members during the audit period. We recalculated the costs based on the allowable number of referrals (see Finding 4).  We traced productive hourly rate (PHR) calculations for all employee classifications performing the mandated activities to supporting information in the county’s payroll system (see Findings 1 through 5).  We traced benefit rate calculations for all employee classifications performing the mandated activities to the General Ledger Budgets and Actuals with Encumbrances reports (see Findings 1 through 6).  We verified the county’s indirect cost calculations by applying a rate of 10% (approved by the Office of Management and Budget in Circular A-87) to direct labor costs. We recalculated indirect costs based on the audit adjustments made to claimed salaries for each cost component (see Findings 1 through 5).  We traced offsetting revenues to supporting documentation. We determined that the ratios used by the county to calculate offsetting revenues were reasonable. We recalculated offsetting revenues based on the audit adjustments made to total direct and indirect costs (see Finding 7). We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective. We did not audit the county’s financial statements. -5- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Conclusion As a result of performing the audit procedures, we found instances of noncompliance with the requirements described in our audit objective. We found that the county claimed unsupported costs, ineligible costs, and overstated costs that were funded by other sources, as quantified in the Schedule and described in the Findings and Recommendations section of this audit report. For the audit period, Madera County claimed $1,518,250 for costs of the legislatively mandated ICAN Investigation Reports Program. Our audit found that $468,092 is allowable ($515,678 less a $47,586 penalty for filing late claims) and $1,050,158 is unallowable. The State made no payments to the county. The State will pay $468,092, contingent upon available appropriations. Following issuance of this audit report, the SCO’s Local Government Programs and Services Division will notify the county of the adjustment to its claims via a system-generated letter for each fiscal year in the audit period. Follow-up on We have not previously conducted an audit of the county’s legislatively mandated ICAN Investigation Reports Program. Prior Audit Findings Views of We issued a draft audit report on December 15, 2021. Todd E. Miller, CPA, Auditor-Controller, responded by letter dated December 29, 2021, Responsible agreeing with the audit findings. The county’s response is included as an Officials attachment. Restricted Use This audit report is solely for the information and use of Madera County, the California Department of Finance, and the SCO; it is not intended to be and should not be used by anyone other than these specified parties. This restriction is not intended to limit distribution of this audit report, which is a matter of public record and is available on the SCO website at www.sco.ca.gov. Original signed by KIMBERLY TARVIN, CPA Chief, Division of Audits January 19, 2022 -6- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule— Summary of Program Costs July 1, 1999, through June 30, 2015 Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 1999, through June 30, 2000 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 12,214 $ 3,538 $ (8,676) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 87,808 21,997 (65,811) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,270 1,149 (2,121) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,044 615 (1,429) Finding 4, 5, 6 Total direct costs 105,336 27,299 (78,037) Indirect costs 7,308 2,272 (5,036) Finding 1-5 Total direct and indirect costs 112,644 29,571 (83,073) Less offsetting revenues and reimbursements (39,425) (10,350) 29,075 Finding 7 Subtotal 73,219 19,221 (53,998) Less late filing penalty2 - ( 1,922) (1,922) Total program costs $ 73,219 17,299 $ (55,920) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 17,299 July 1, 2000, through June 30, 2001 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 13,430 $ 4,101 $ (9,329) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 102,834 27,368 (75,466) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,533 1,345 (2,188) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,208 721 (1,487) Finding 4, 5, 6 Total direct costs 122,005 33,535 (88,470) Indirect costs 8,464 2,790 (5,674) Finding 1-5 Total direct and indirect costs 130,469 36,325 (94,144) Less offsetting revenues and reimbursements (45,664) (12,714) 32,950 Finding 7 Subtotal 84,805 23,611 (61,194) Less late filing penalty2 - ( 2,361) (2,361) Total program costs $ 84,805 21,250 $ (63,555) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 21,250 -7- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2001, through June 30, 2002 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,087 $ 2,641 $ (11,446) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 100,085 19,355 (80,730) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,070 1,068 (2,002) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,919 572 (1,347) Finding 4, 5, 6 Total direct costs 119,161 23,636 (95,525) Indirect costs 8,267 1,945 (6,322) Finding 1-5 Total direct and indirect costs 127,428 25,581 (101,847) Less offsetting revenues and reimbursements (44,600) ( 8,953) 35,647 Finding 7 Subtotal 82,828 16,628 (66,200) Less late filing penalty2 - ( 1,663) (1,663) Total program costs $ 82,828 14,965 $ (67,863) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 14,965 July 1, 2002, through June 30, 2003 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,335 $ 2,932 $ (11,403) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 114,922 25,371 (89,551) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,341 1,334 (2,007) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,089 714 (1,375) Finding 4, 5, 6 Total direct costs 134,687 30,351 (104,336) Indirect costs 9,344 2,448 (6,896) Finding 1-5 Total direct and indirect costs 144,031 32,799 (111,232) Less offsetting revenues and reimbursements (50,411) (11,480) 38,931 Finding 7 Subtotal 93,620 21,319 (72,301) Less late filing penalty2 - ( 2,132) (2,132) Total program costs $ 93,620 19,187 $ (74,433) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 19,187 -8- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2003, through June 30, 2004 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 13,966 $ 3,478 $ (10,488) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 120,715 30,415 (90,300) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,164 1,347 (1,817) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,978 722 (1,256) Finding 4, 5, 6 Total direct costs 139,823 35,962 (103,861) Indirect costs 9,700 2,772 (6,928) Finding 1-5 Total direct and indirect costs 149,523 38,734 (110,789) Less offsetting revenues and reimbursements (52,333) (13,557) 38,776 Finding 7 Subtotal 97,190 25,177 (72,013) Less late filing penalty2 - ( 2,518) (2,518) Total program costs $ 97,190 22,659 $ (74,531) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 22,659 July 1, 2004, through June 30, 2005 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,532 $ 4,611 $ (9,921) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 116,162 33,551 (82,611) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,897 1,329 (1,568) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,810 713 (1,097) Finding 4, 5, 6 Total direct costs 135,401 40,204 (95,197) Indirect costs 9,394 2,973 (6,421) Finding 1-5 Total direct and indirect costs 144,795 43,177 (101,618) Less offsetting revenues and reimbursements (50,678) (15,112) 35,566 Finding 7 Subtotal 94,117 28,065 (66,052) Less late filing penalty2 - ( 2,807) (2,807) Total program costs $ 94,117 25,258 $ (68,859) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 25,258 -9- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) July 1, 2005, through June 30, 2006 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,668 $ 4,474 $ (10,194) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 113,467 30,860 (82,607) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,883 1,438 (2,445) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,427 771 (1,656) Finding 4, 5, 6 Total direct costs 134,445 37,543 (96,902) Indirect costs 9,327 2,656 (6,671) Finding 1-5 Total direct and indirect costs 143,772 40,199 (103,573) Less offsetting revenues and reimbursements (50,320) (14,070) 36,250 Finding 7 Subtotal 93,452 26,129 (67,323) Less late filing penalty2 - ( 2,613) (2,613) Total program costs $ 93,452 23,516 $ (69,936) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 23,516 July 1, 2006, through June 30, 2007 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 16,627 $ 6,265 $ (10,362) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 130,425 45,430 (84,995) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,356 1,746 (1,610) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,097 935 (1,162) Finding 4, 5, 6 Total direct costs 152,505 54,376 (98,129) Indirect costs 10,580 3,778 (6,802) Finding 1-5 Total direct and indirect costs 163,085 58,154 (104,931) Less offsetting revenues and reimbursements (57,080) (20,354) 36,726 Finding 7 Subtotal 106,005 37,800 (68,205) Less late filing penalty2 - ( 3,780) (3,780) Total program costs $ 1 06,005 34,020 $ (71,985) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 34,020 -10- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2007, through June 30, 2008 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 15,650 $ 5,012 $ (10,638) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 109,279 35,198 (74,081) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,835 1,208 (1,627) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,772 646 (1,126) Finding 4, 5, 6 Total direct costs 129,536 42,064 (87,472) Indirect costs 8,987 3,013 (5,974) Finding 1-5 Total direct and indirect costs 138,523 45,077 (93,446) Less offsetting revenues and reimbursements (48,483) (15,777) 32,706 Finding 7 Subtotal 90,040 29,300 (60,740) Less late filing penalty2 - ( 2,930) (2,930) Total program costs $ 90,040 26,370 $ (63,670) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 26,370 July 1, 2008, through June 30, 2009 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,774 $ 5,654 $ (9,120) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 108,140 39,345 (68,795) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,796 1,383 (1,413) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,748 744 (1,004) Finding 4, 5, 6 Total direct costs 127,458 47,126 (80,332) Indirect costs 8,843 3,308 (5,535) Finding 1-5 Total direct and indirect costs 136,301 50,434 (85,867) Less offsetting revenues and reimbursements (47,705) (17,652) 30,053 Finding 7 Subtotal 88,596 32,782 (55,814) Less late filing penalty2 - ( 3,278) (3,278) Total program costs $ 88,596 29,504 $ (59,092) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 29,504 -11- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2009, through June 30, 2010 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 15,870 $ 5,918 $ (9,952) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 120,618 38,598 (82,020) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,903 1,382 (1,521) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,814 740 (1,074) Finding 4, 5, 6 Total direct costs 141,205 46,638 (94,567) Indirect costs 10,001 3,303 (6,698) Finding 1-5 Total direct and indirect costs 151,206 49,941 (101,265) Less offsetting revenues and reimbursements (52,922) (17,479) 35,443 Finding 7 Subtotal 98,284 32,462 (65,822) Less late filing penalty2 - ( 3,246) (3,246) Total program costs $ 98,284 29,216 $ (69,068) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 29,216 July 1, 2010, through June 30, 2011 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 17,121 $ 6,644 $ (10,477) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 142,015 51,962 (90,053) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,502 1,350 (1,152) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,564 724 (840) Finding 4, 5, 6 Total direct costs 163,202 60,680 (102,522) Indirect costs 11,520 4,283 (7,237) Finding 1-5 Total direct and indirect costs 174,722 64,963 (109,759) Less offsetting revenues and reimbursements (61,153) (22,737) 38,416 Finding 7 Subtotal 113,569 42,226 (71,343) Less late filing penalty2 - ( 4,223) (4,223) Total program costs $ 1 13,569 38,003 $ (75,566) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 38,003 -12- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2011, through June 30, 2012 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 17,338 $ 7,529 $ (9,809) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 161,978 68,732 (93,246) Finding 2, 5, 6 Forward Reports to the Department of Justice 2,453 1,370 (1,083) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,533 734 (799) Finding 4, 5, 6 Total direct costs 183,302 78,365 (104,937) Indirect costs 12,712 5,434 (7,278) Finding 1-5 Total direct and indirect costs 196,014 83,799 (112,215) Less offsetting revenues and reimbursements (68,605) (29,330) 39,275 Finding 7 Subtotal 127,409 54,469 (72,940) Less late filing penalty2 - ( 5,447) (5,447) Total program costs $ 1 27,409 49,022 $ (78,387) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 49,022 July 1, 2012, through June 30, 2013 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 15,840 $ 6,545 $ (9,295) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 150,502 62,660 (87,842) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,331 833 (2,498) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 2,082 444 (1,638) Finding 4, 5, 6 Total direct costs 171,755 70,482 (101,273) Indirect costs 11,730 4,814 (6,916) Finding 1-5 Total direct and indirect costs 183,485 75,296 (108,189) Less offsetting revenues and reimbursements (64,220) (26,354) 37,866 Finding 7 Subtotal 119,265 48,942 (70,323) Less late filing penalty2 - ( 4,894) (4,894) Total program costs $ 1 19,265 44,048 $ (75,217) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 44,048 -13- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 July 1, 2013, through June 30, 2014 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 14,818 $ 5,794 $ (9,024) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 130,722 47,599 (83,123) Finding 2, 5, 6 Forward Reports to the Department of Justice 3,065 615 (2,450) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 1,915 331 (1,584) Finding 4, 5, 6 Total direct costs 150,520 54,339 (96,181) Indirect costs 10,225 3,692 (6,533) Finding 1-5 Total direct and indirect costs 160,745 58,031 (102,714) Less offsetting revenues and reimbursements (56,261) (20,311) 35,950 Finding 7 Subtotal 104,484 37,720 (66,764) Less late filing penalty4 - ( 3,772) (3,772) Total program costs $ 1 04,484 33,948 $ (70,536) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 33,948 July 1, 2014, through June 30, 2015 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 9,688 $ 6,000 $ (3,688) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 67,221 54,319 (12,902) Finding 2, 5, 6 Forward Reports to the Department of Justice 1,303 620 (683) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 814 333 (481) Finding 4, 5, 6 Total direct costs 79,026 61,272 (17,754) Indirect costs - - - Finding 1-5 Total direct and indirect costs 79,026 61,272 (17,754) Less offsetting revenues and reimbursements (27,659) (21,445) 6,214 Finding 7 Total program costs $ 51,367 39,827 $ (11,540) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 39,827 -14- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Schedule (continued) Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference1 Summary: July 1, 1999, through June 30, 2015 Direct costs – salaries and benefits: Reporting between local departments Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office $ 2 34,958 $ 81,136 $ ( 153,822) Finding 1, 5, 6 Reporting to DOJ Complete an Investigation for Purposes of Preparing the Report 1,876,893 632,760 (1,244,133) Finding 2, 5, 6 Forward Reports to the Department of Justice 47,702 19,517 (28,185) Finding 3, 5, 6 Notifications Following Reports to the Child Abuse Central Index 29,814 10,459 (19,355) Finding 4, 5, 6 Total direct costs 2,189,367 743,872 (1,445,495) Indirect costs 146,402 49,481 (96,921) Finding 1-5 Total direct and indirect costs 2,335,769 793,353 (1,542,416) Less offsetting revenues and reimbursements (817,519) (277,675) 5 39,844 Finding 7 Subtotal 1,518,250 515,678 (1,002,572) Less late filing penalty2,4 - (47,586) (47,586) Total program costs $ 1,518,250 468,092 $ (1,050,158) Less amount paid by the State3 - Allowable costs claimed in excess of amount paid $ 4 68,092 _________________________ 1 See the Findings and Recommendations section. 2 The county filed its FY 1999-2000 through FY 2012-13 initial reimbursement claims after the due date specified in GC section 17560. Pursuant to GC section 17561, subdivision (d)(3), the State assessed a late filing penalty equal to 10% of allowable costs, with no maximum penalty amount (for claims filed on or after September 30, 2002). 3 Payment amount current as of December 29, 2021. 4 The county filed its FY 2013-14 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). -15- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Findings and Recommendations FINDING 1— The county claimed $234,958 in salaries and benefits for the Cross- reporting from County Welfare to Law Enforcement and the District Unallowable salaries Attorney’s Office cost component during the audit period. We found that and benefits – Cross- $81,136 is allowable and $153,822 is unallowable. Unallowable related reporting from indirect costs total $10,179, for a total finding of $164,001. County Welfare to Law Enforcement and The DSS misclassified cross-reporting activities under the Additional the District Cross-reporting in Cases of Child Death cost component. We moved the Attorney’s Office cost Additional Cross-reporting activity costs to the Cross-reporting from component County Welfare to Law Enforcement and the District Attorney’s Office cost component. The reimbursable activity for this cost component consists of cross-reporting by county welfare to law enforcement and the DA’s office every known or suspected instance of child abuse. To calculate the claimed salaries and benefits, the county multiplied the ATI by the number of referrals cross-reported, then multiplied the resulting hours by a PHR and related benefit rate. During testing, we found that the county overstated the number of referrals cross-reported, misstated the PHRs, overstated the benefit rates and related indirect costs. The county overstated these costs because it did not claim costs in accordance with the program’s parameters and guidelines or the SCO’s Mandated Cost Manual. The following table summarizes the claimed, allowable, and adjusted costs for the Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office cost component by fiscal year: Fiscal Amount Amount Audit Unallowable Total Audit Year Claimed Allowable Adjustment Indirect Costs Adjustment 1999-2000 $ 1 2,214 $ 3,538 $ (8,676) $ (553) $ (9,229) 2000-01 1 3,430 4,101 (9,329) (591) (9,920) 2001-02 1 4,087 2,641 (11,446) (760) (12,206) 2002-03 1 4,335 2,932 (11,403) (758) (12,161) 2003-04 1 3,966 3,478 (10,488) (701) (11,189) 2004-05 1 4,532 4,611 (9,921) (667) (10,588) 2005-06 1 4,668 4,474 (10,194) (702) (10,896) 2006-07 1 6,627 6,265 (10,362) (718) (11,080) 2007-08 1 5,650 5,012 (10,638) (727) (11,365) 2008-09 1 4,774 5,654 (9,120) (629) (9,749) 2009-10 1 5,870 5,918 (9,952) (705) (10,657) 2010-11 1 7,121 6,644 (10,477) (739) (11,216) 2011-12 1 7,338 7,529 (9,809) (681) (10,490) 2012-13 1 5,840 6,545 (9,295) (635) (9,930) 2013-14 1 4,818 5,794 (9,024) (613) (9,637) 2014-15 9 ,688 6,000 (3,688) - (3,688) Total $ 2 34,958 $ 81,136 $ (153,822) $ (10,179) $ (164,001) Number of Referrals Cross-reported For FY 1999-2000 through FY 2013-14, the claimed number of referrals cross-reported was obtained from the CWS/CMS via online access to the California Child Welfare Indicators Project, a collaborative venture -16- Madera County Interagency Child Abuse and Neglect Investigation Reports Program between the University of California Berkeley and the California Department of Social Services. For FY 2014-15, the DSS obtained the claimed number of referrals cross-reported directly from the CWS/CMS. The county provided a detailed referral listing generated by the CWS/CMS. During our review, we found that this listing included non- mandate-related referrals and referrals ineligible for reimbursement. We recalculated the allowable costs using the supported number of referrals cross-reported to law enforcement and the DA’s office. The county overstated salary and benefit costs as a result of overstating the number of referrals cross-reported. The following table summarizes the claimed, allowable, and adjusted number of referrals for the Cross-reporting from County Welfare to Law Enforcement and the District Attorney’s Office cost component by fiscal year: Fiscal Claimed Allowable Audit Year Referrals Referrals Adjustment 1999-2000 2 ,387 1 ,146 ( 1,241) 2000-01 2 ,585 1 ,232 ( 1,353) 2001-02 2 ,671 8 88 ( 1,783) 2002-03 2 ,677 8 81 ( 1,796) 2003-04 2 ,569 9 24 ( 1,645) 2004-05 2 ,633 1 ,124 ( 1,509) 2005-06 2 ,618 9 67 ( 1,651) 2006-07 2 ,923 1 ,189 ( 1,734) 2007-08 2 ,710 9 19 ( 1,791) 2008-09 2 ,520 9 60 ( 1,560) 2009-10 2 ,722 1 ,041 ( 1,681) 2010-11 2 ,901 1 ,201 ( 1,700) 2011-12 2 ,849 1 ,269 ( 1,580) 2012-13 2 ,611 1 ,143 ( 1,468) 2013-14 2 ,393 9 85 ( 1,408) 2014-15 1 ,562 9 92 ( 570) Total 4 1,331 1 6,861 ( 24,470) Productive Hourly Rate The DSS provided actual salary and benefit cost data generated by the county’s payroll system for the DSS staff members responsible for performing the mandate-related activities during the audit period. We used this actual salary cost data to calculate the average annual salary amount for employees in the Social Worker I through IV classifications. We divided the average annual salary amount by 1,800 productive hours to calculate the PHR. As explained in Finding 5, we found that the county misstated the claimed PHRs for FY 1999-2000 through FY 2006-07, FY 2008-09, FY 2010-11, FY 2012-13, and FY 2013-14. Benefit Rate The DSS provided General Ledger Budgets and Actuals with Encumbrances reports identifying the actual departmental salary and benefit costs for the audit period. We used the actual benefits from these reports to calculate the department-wide benefit rates for the audit period. -17- Madera County Interagency Child Abuse and Neglect Investigation Reports Program To calculate the benefit rates, we divided the total actual departmental benefits by the total actual departmental salaries. As explained in Finding 6, we found that the county overstated the claimed benefit rates in FY 1999-2000 through FY 2008-09. Criteria Section IV, “Reimbursable Activities,” of the parameters and guidelines begins: To be eligible for mandated cost reimbursement for any fiscal year, only actual costs may be claimed. Actual costs are those costs actually incurred to implement the mandated activities. Actual costs must be traceable and supported by source documents that show the validity of such costs, when they were incurred, and their relationship to the reimbursable activities. A source document is a document created at or near the same time the actual cost was incurred for the event or activity in question. Source documents may include, but are not limited to, employee time records or time logs, sign- in sheets, invoices, and receipts…. The claimant is only allowed to claim and be reimbursed for increased costs for reimbursable activities.... Increased cost is limited to the cost of an activity that the claimant is required to incur as a result of the mandate. Section IV, subsection B.2, “Reporting Between Local Departments,” of the parameters and guidelines states, in part: b. Cross-Reporting of Suspected Child Abuse or Neglect from County Welfare and Probation Departments to the Law Enforcement Agency with Jurisdiction and the District Attorney’s Office …. 2) County welfare departments shall: i. Report by telephone immediately, or as soon as practically possible, to the agency given the responsibility for investigation of cases under Section 300 of the Welfare and Institutions Code, and to the district attorney's office every known or suspected instance of child abuse, as defined in Penal Code section 11165.6, except acts or omissions coming within subdivision (b) of section 11165.2, or reports made pursuant to section 11165.13 based on risk to a child which relates solely to the inability of the parent to provide the child with regular care due to the parent’s substance abuse, which shall be reported only to the county welfare department. Reimbursement is not required for making an initial report of child abuse and neglect from a county welfare department to the law enforcement agency having jurisdiction over the case, which was required under prior law to be made “without delay.” ii. Send a written report thereof within 36 hours of receiving the information concerning the incident to any agency, including the law enforcement agency having jurisdiction over the case, to which it is required to make a telephone report under Penal Code section 11166. As of January 1, 2001, initial reports may be made by fax or electronic transmission, instead of by telephone, and will satisfy the requirement for a written report within 36 hours. -18- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Section V, subparagraph A.1, “Salaries and Benefits,” of the parameters and guidelines states: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims, and  Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported. County’s Response The county agreed with the audit finding. The county claimed $1,876,893 in salaries and benefits for the Complete FINDING 2— an Investigation for Purposes of Preparing the Report cost component Unallowable salaries during the audit period. We found that $632,760 is allowable and and benefits – $1,244,133 is unallowable. Unallowable related indirect costs total Reporting to the State $83,661, for a total finding of $1,327,794. Department of Justice: Complete an This component provides reimbursement for costs associated with Investigation for reviewing the Form SS 8572, conducting initial interviews with involved Purposes of Preparing parties, and writing a report of the interviews for review by a supervisor. the Report cost Additionally, per the program’s parameters and guidelines, time spent component performing an initial investigation of a Form SS 8572 is reimbursable only if that Form SS 8572 is generated by another agency. Investigation of a Form SS 8572 generated by a department that is also the mandated reporter is not eligible for reimbursement. To calculate the claimed salaries and benefits, the county multiplied the ATIs by the number of referrals investigated, then multiplied the resulting hours by a PHR and related benefit rate. During testing, we found that the county overstated the number of referrals investigated, misstated the PHRs, and overstated the benefit rates and related indirect costs. The county overstated these costs because it did not claim costs in accordance with the program’s parameters and guidelines or the SCO’s Mandated Cost Manual. -19- Madera County Interagency Child Abuse and Neglect Investigation Reports Program The following table summarizes the claimed, allowable, and adjusted costs for the Complete an Investigation for Purposes of Preparing the Report cost component by fiscal year: Fiscal Amount Amount Audit Unallowable Total Audit Year Claimed Allowable Adjustment Indirect Costs Adjustment 1999-2000 $ 8 7,808 $ 21,997 $ (65,811) $ (4,261) $ ( 70,072) 2000-01 1 02,834 27,368 (75,466) (4,857) ( 80,323) 2001-02 1 00,085 19,355 (80,730) (5,351) ( 86,081) 2002-03 1 14,922 25,371 (89,551) (5,927) ( 95,478) 2003-04 1 20,715 30,415 (90,300) (6,030) ( 96,330) 2004-05 1 16,162 33,551 (82,611) (5,578) ( 88,189) 2005-06 1 13,467 30,860 (82,607) (5,689) ( 88,296) 2006-07 1 30,425 45,430 (84,995) (5,891) ( 90,886) 2007-08 1 09,279 35,198 (74,081) (5,060) ( 79,141) 2008-09 1 08,140 39,345 (68,795) (4,740) ( 73,535) 2009-10 1 20,618 38,598 (82,020) (5,808) ( 87,828) 2010-11 1 42,015 51,962 (90,053) (6,357) ( 96,410) 2011-12 1 61,978 68,732 (93,246) (6,467) ( 99,713) 2012-13 1 50,502 62,660 (87,842) (5,998) ( 93,840) 2013-14 1 30,722 47,599 (83,123) (5,647) ( 88,770) 2014-15 6 7,221 54,319 (12,902) - ( 12,902) Total $ 1 ,876,893 $ 632,760 $ (1,244,133) $ (83,661) $ ( 1,327,794) Number of Referrals Investigated For FY 1999-2000 through FY 2013-14, the claimed number of investigated referrals was obtained from the CWS/CMS via online access to the California Child Welfare Indicators Project. For FY 2014-15, the DSS obtained the claimed number of investigated referrals directly from the CWS/CMS. The county provided a detailed referral listing generated by the CWS/CMS. During our review, we found that the listing included duplicate referrals; referrals initiated by DSS staff members as the mandated reporter, and then investigated by the CWS staff; referrals that were “evaluated out”; and general neglect referrals. Referrals that were initiated by the DSS staff members as the mandated reporter, and then investigated by CWS staff; referrals that were “evaluated out” and not investigated; and general neglect referrals are not mandate-related. Therefore, we determined that the costs claimed for these referrals are ineligible for reimbursement. Duplicate referrals are also unallowable. We recalculated the supported number of referrals investigated for the audit period. For testing purposes, we judgmentally selected a non-statistical sample of 250 referrals (50 out of 758 in FY 2000-01; 50 out of 754 in FY 2004-05; 50 out of 595 in FY 2007-08; 50 out of 1,068 in FY 2011-12; and 50 out of 828 in FY 2014-15) from the population of 11,981 supported referrals. Based on our review, we determined that DSS staff members had performed investigation activities on the referrals that were selected for testing purposes. Therefore, the allowable number of referrals investigated for the audit period totals 11,981. We recalculated the allowable costs based on the allowable number of referrals investigated. The county claimed overstated salary and benefit costs as a result of overstating the number of referrals investigated for the audit period. -20- Madera County Interagency Child Abuse and Neglect Investigation Reports Program The table below summarizes the claimed, allowable, and adjusted number of referrals for the Complete an Investigation for Purposes of Preparing the Report cost component by fiscal year: Fiscal Claimed Allowable Audit Year Referrals Referrals Adjustment 1999-2000 1,615 657 (958) 2000-01 1,863 758 (1,105) 2001-02 1,786 600 (1,186) 2002-03 2,020 703 (1,317) 2003-04 2,090 745 (1,345) 2004-05 1,981 754 (1,227) 2005-06 1,906 615 (1,291) 2006-07 2,158 795 (1,363) 2007-08 1,781 595 (1,186) 2008-09 1,736 616 (1,120) 2009-10 1,947 626 (1,321) 2010-11 2,265 866 (1,399) 2011-12 2,505 1,068 (1,437) 2012-13 2,335 1,009 (1,326) 2013-14 1,987 746 (1,241) 2014-15 1,020 828 (192) Total 30,995 11,981 (19,014) Productive Hourly Rate The DSS provided actual salary and benefit cost data generated by the county’s payroll system for the DSS staff members responsible for performing the mandate-related activities during the audit period. We used this actual salary cost data to calculate the average annual salary amount for employees in the Social Worker I through IV classifications. We divided the average annual salary amount by 1,800 productive hours to calculate the PHR. As explained in Finding 5, we found that the county misstated the claimed PHRs for FY 1999-2000 through FY 2006-07, FY 2008-09, FY 2010-11, FY 2012-13, and FY 2013-14. Benefit Rate The DSS provided the General Ledger Budgets and Actuals with Encumbrances reports identifying the actual departmental salary and benefit costs for the audit period. We used the actual benefits from these reports to calculate the department-wide benefit rates for the audit period. To calculate the benefit, we divided the total actual departmental benefits by the total actual departmental salaries. As explained in Finding 6, we found that the county overstated the claimed benefit rates in FY 1999-2000 through FY 2008-09. Criteria Section IV, “Reimbursable Activities,” of the parameters and guidelines begins: To be eligible for mandated cost reimbursement for any fiscal year, only actual costs may be claimed. -21- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Actual costs are those costs actually incurred to implement the mandated activities. Actual costs must be traceable and supported by source documents that show the validity of such costs, when they were incurred, and their relationship to the reimbursable activities. A source document is a document created at or near the same time the actual cost was incurred for the event or activity in question. Source documents may include, but are not limited to, employee time records or time logs, sign in sheets, invoices, and receipts…. The claimant is only allowed to claim and be reimbursed for increased costs for reimbursable activities....Increased cost is limited to the cost of an activity that the claimant is required to incur as a result of the mandate. Section IV, subsection B.3, “Reporting to the State Department of Justice,” of the parameters and guidelines states: a. From July 1, 1999 to December 31, 2011, city and county police or sheriff’s departments, county probation departments if designated by the county to receive mandated reports, and county welfare departments shall: 1) Complete an investigation for purposes of preparing the report Complete an investigation to determine whether a report of suspected child abuse or severe neglect is unfounded, substantiated or inconclusive, as defined in Penal Code section 11165.12, for purposes of preparing and submitting the state “Child Abuse Investigation Report” Form SS 8583, or subsequent designated form, to the Department of Justice. Except as provided in paragraph below, this activity includes review of the initial Suspected Child Abuse Report (Form 8572), conducting initial interviews with parents, victims, suspects, or witnesses, where applicable, and making a report of the findings of those interviews, which may be reviewed by a supervisor. Reimbursement is not required in the following circumstances: i. Investigative activities conducted by a mandated reporter to complete the Suspected Child Abuse Report (Form SS 8572) pursuant to Penal Code section 11166(a). ii. In the event that the mandated reporter is employed by the same child protective agency required to investigate and submit the "Child Abuse Investigation Report" Form SS 8583 or subsequent designated form to the Department of Justice, pursuant to Penal Code section 11169(a), reimbursement is not required if the investigation required to complete the Form SS 8572 is also sufficient to make the determination required under section 11169(a), and sufficient to complete the essential information items required on the Form SS 8583, pursuant to Code of Regulations, title 11, section 903 (Register 98, No. 29). ii. Investigative activities undertaken subsequent to the determination whether a report of suspected child abuse is substantiated, inconclusive, or unfounded, as defined in Penal Code section 11165.12, for purposes of preparing the Form SS 8583…. -22- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Section IV, subsection B.3 of the parameters and guidelines also states: b. Beginning January 1, 2012, county welfare departments, or county probation departments where designated by the county to receive mandated reports shall: 1) Complete an investigation Complete an investigation to determine whether a report of suspected child abuse or severe neglect is unfounded, substantiated or inconclusive, as defined in Penal Code section 11165.12, for purposes of preparing and submitting the state “Child Abuse Investigation Report” Form SS 8583, or subsequent designated form, to the Department of Justice. Except as provided in paragraph below, this activity includes review of the initial Suspected Child Abuse Report (Form 8572), conducting initial interviews with parents, victims, suspects, or witnesses, where applicable, and making a report of the findings of those interviews, which may be reviewed by a supervisor. Reimbursement is not required in the following circumstances: i. Investigative activities conducted by a mandated reporter to complete the Suspected Child Abuse Report (Form SS 8572) pursuant to Penal Code section 11166(a). ii. In the event that the mandated reporter is employed by the same child protective agency required to investigate and submit the "Child Abuse Investigation Report" Form SS 8583 or subsequent designated form to the Department of Justice, pursuant to Penal Code section 11169(a), reimbursement is not required if the investigation required to complete the Form SS 8572 is also sufficient to make the determination required under section 11169(a), and sufficient to complete the essential information items required on the Form SS 8583, pursuant to Code of Regulations, title 11, section 903 (Register 98, No. 29). iii. Investigative activities undertaken subsequent to the determination whether a report of suspected child abuse is substantiated, inconclusive, or unfounded, as defined in Penal Code section 11165.12, for purposes of preparing the Form SS 8583. Section V, subparagraph A.1, “Salaries and Benefits,” of the parameters and guidelines states: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims, and -23- Madera County Interagency Child Abuse and Neglect Investigation Reports Program  Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported. County’s Response The county agreed with the audit finding. The county claimed $47,702 in salaries and benefits for the Forward FINDING 3— Reports to the Department of Justice cost component during the audit Unallowable salaries period. We found that $19,517 is allowable and $28,185 is unallowable. and benefits – Unallowable related indirect costs total $1,820, for a total finding of Reporting to the State $30,005. Department of Justice: Forward This component provides reimbursement for costs associated with Reports to the preparing and submitting the Form SS 8583 to the DOJ. A Form SS 8583 Department of Justice is prepared and submitted for every investigated case of known or cost component suspected child abuse or severe neglect that is determined to be suUbstantiated or inconclusive. Beginning January 1, 2012, only substantiated referrals are eligible for reimbursement. n a To calculate the claimed salaries and benefits, the county multiplied the l ATI by the number of Form SS 8583s forwarded to the DOJ, then l multiplied the resulting hours by a PHR and related benefit rate. o Dwuring testing, we found that the county overstated the number of referrals foar which a Form SS 8583 was forwarded to the DOJ, misstated the PHRs, anbd overstated the benefit rates and related indirect costs. The county ovlerstated these costs because it did not claim costs in accordance with the preo gram’s parameters and guidelines or the SCO’s Mandated Cost Msanual. a The following table summarizes the claimed, allowable, and adjusted l costs for the Forward Reports to the Department of Justice cost component a by fiscal year: r Fiscal Aimount Amount Audit Unallowable Total Audit Year Celaimed Allowable Adjustment Indirect Costs Adjustment 1999-2000 $ s 3 ,270 $ 1,149 $ (2,121) $ (131) $ ( 2,252) 2000-01 a 3 ,533 1,345 (2,188) (133) ( 2,321) 2001-02 3 ,070 1,068 (2,002) (125) ( 2,127) n 2002-03 3 ,341 1,334 (2,007) (124) ( 2,131) d 2003-04 3 ,164 1,347 (1,817) (116) ( 1,933) 2004-05 b 2 ,897 1,329 (1,568) (103) ( 1,671) 2005-06 e 3 ,883 1,438 (2,445) (167) ( 2,612) 2006-07 3 ,356 1,746 (1,610) (112) ( 1,722) n 2007-08 2 ,835 1,208 (1,627) (111) ( 1,738) e 2008-09 2 ,796 1,383 (1,413) (97) ( 1,510) 2009-10 f 2 ,903 1,382 (1,521) (108) ( 1,629) 2010-11 i 2 ,502 1,350 (1,152) (81) ( 1,233) 2011-12 2 ,453 1,370 (1,083) (75) ( 1,158) t 2012-13 3 ,331 833 (2,498) (171) ( 2,669) s 2013-14 3 ,065 615 (2,450) (166) ( 2,616) 2014-15 – 1 ,303 620 (683) - ( 683) Total $ R 4 7,702 $ 19,517 $ (28,185) $ (1,820) $ ( 30,005) e p o -24- r t Madera County Interagency Child Abuse and Neglect Investigation Reports Program Number of Reports Forwarded to the DOJ For FY 1999-2000 through FY 2013-14, the claimed number of referrals for which a Form SS 8583 was prepared and forwarded to the DOJ was obtained from the CWS/CMS via online access to the California Child Welfare Indicators Project. For FY 2014-15, the DSS obtained the claimed number of referrals for which a Form SS 8583 was prepared and forwarded to the DOJ directly from the CWS/CMS. The county provided a detailed referral listing generated by the CWS/CMS. During our review, we found that the listing included duplicate referrals; referrals initiated by DSS staff members as the mandated reporter, and then investigated by the CWS staff; referrals that were “evaluated out”; and general neglect referrals. Referrals that were initiated by the DSS staff members as the mandated reporter, and then investigated by CWS staff; referrals that were “evaluated out” and not investigated; and general neglect referrals are not mandate-related activities. Therefore, we determined that the costs claimed for these referrals are ineligible for reimbursement. Duplicate referrals are also unallowable. We recalculated the number of supported referrals for the audit period. For testing purposes, we relied on the results of our review of the 250 referrals that were judgementally selected as a non-statistical sample (discussed in Finding 2). Prior to January 1, 2012, both substantiated and inconclusive reports were eligible for reimbursement; as of January 1, 2012, forwarding inconclusive reports to DOJ is not reimbursable. Based on our review, we found that 216 (45 out of 50 in FY 2000-01; 45 out of 50 in FY 2004-05; 45 out of 50 in FY 2007-08; 36 out of 50 in FY 2011-12; and 45 out of 50 in FY 2014-15) of the sampled 250 referrals were eligible. We also determined that a Form SS 8583 was prepared and sent to the DOJ for 167 (26 out of 45 in FY 2000-01; 28 out of 45 in FY 2004-05; 36 out of 45 in FY 2007-08; 32 out of 36 in FY 2011-12; and all 45 in FY 2014-15) out of 216 referrals. Consistent with AU-C section 530, we calculated a weighted average based on the results of our testing. We projected the results by applying the weighted average of 77% to the total eligible number of referrals for which DSS staff members prepared and submitted a Form SS 8583 to the DOJ during the audit period. We determined that for the Forward Reports to the Department of Justice cost component, the allowable number of referrals totals 4,278. We recalculated the costs based on the allowable number of referrals. -25- Madera County Interagency Child Abuse and Neglect Investigation Reports Program The following table summarizes the claimed, allowable, and adjusted number of referrals for the Forward Reports to the Department of Justice cost component by fiscal year: Fiscal Claimed Allowable Audit Year Referrals Referrals Adjustment 1999-2000 639 363 (276) 2000-01 680 394 (286) 2001-02 582 350 (232) 2002-03 624 391 (233) 2003-04 582 349 (233) 2004-05 525 316 (209) 2005-06 693 303 (390) 2006-07 590 323 (267) 2007-08 491 216 (275) 2008-09 477 229 (248) 2009-10 498 237 (261) 2010-11 424 238 (186) 2011-12 403 225 (178) 2012-13 549 142 (407) 2013-14 495 102 (393) 2014-15 210 100 (110) Total 8,462 4,278 (4,184) Productive Hourly Rate The DSS provided actual salary and benefit cost data generated by the county’s payroll system for the DSS staff members responsible for performing the mandate-related activities during the audit period. We used this actual salary cost data to calculate the average annual salary amount for employees in the Social Worker I through IV classifications. To calculate the PHR, we divided the amount by 1,800 productive hours. As explained in Finding 5, we found that the county misstated the claimed PHRs for FY 1999-2000 through FY 2006-07, FY 2008-09, FY 2010-11, FY 2012-13, and FY 2013-14. Benefit Rate The DSS provided the General Ledger Budgets and Actuals with Encumbrances reports identifying the actual departmental salary and benefit costs for the audit period. We used the actual benefits from these reports to calculate the department-wide benefit rates for the audit period. To calculate the benefit rates, we divided the total actual departmental benefits by the total actual departmental salaries. As explained in Finding 6, we found that the county overstated the claimed benefit rates in FY 1999-2000 through FY 2008-09. Criteria Section IV, “Reimbursable Activities,” of the parameters and guidelines begins: To be eligible for mandated cost reimbursement for any fiscal year, only actual costs may be claimed. -26- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Actual costs are those costs actually incurred to implement the mandated activities. Actual costs must be traceable and supported by source documents that show the validity of such costs, when they were incurred, and their relationship to the reimbursable activities. A source document is a document created at or near the same time the actual cost was incurred for the event or activity in question. Source documents may include, but are not limited to, employee time records or time logs, sign in sheets, invoices, and receipts…. The claimant is only allowed to claim and be reimbursed for increased costs for reimbursable activities….Increased cost is limited to the cost of an activity that the claimant is required to incur as a result of the mandate. Section IV, subsection B.3, of the parameters and guidelines states, in part: a. From July 1, 1999 to December 31, 2011, city and county police or sheriff’s departments, county probation departments if designated by the county to receive mandated reports, and county welfare departments shall:…. 2) Forward reports to the Department of Justice Prepare and submit to the Department of Justice a report in writing of every case it investigates of known or suspected child abuse or severe neglect which is determined to be substantiated or inconclusive, as defined in Penal Code section 11165.12. Unfounded reports, as defined in Penal Code section 11165.12, shall not be filed with the Department of Justice. If a report has previously been filed which subsequently proves to be unfounded, the Department of Justice shall be notified in writing of that fact. The reports required by this section shall be in a form approved by the Department of Justice (currently form 8583) and may be sent by fax or electronic transmission. This activity includes costs of preparing and submitting an amended report to DOJ, when the submitting agency changes a prior finding of substantiated or inconclusive to a finding of unfounded or from inconclusive or unfounded to substantiated. Reimbursement is not required for the costs of the investigation required to make the determination to file an amended report. b. Beginning January 1, 2012, county welfare departments, or county probation departments where designated by the county to receive mandated reports shall: …. 2) Forward reports to the Department of Justice Prepare and submit to the Department of Justice a report in writing of every case it investigates of known or suspected child abuse or severe neglect which is determined to be substantiated, as defined in Penal Code section 11165.12. Unfounded or inconclusive reports, as defined in Penal Code section 11165.12, shall not be filed with the Department of Justice. If a report has previously been filed which subsequently proves to be unfounded, the Department of Justice shall be notified in writing of that fact. The reports required by this section shall be in a form approved by the Department of Justice and may be sent by fax or electronic transmission. This activity includes costs of preparing and submitting an amended report to DOJ, when the submitting agency changes a prior finding of substantiated to a finding of inconclusive or -27- Madera County Interagency Child Abuse and Neglect Investigation Reports Program unfounded, or from inconclusive or unfounded to substantiated, or when other information is necessary to maintain accuracy of the CACI. Reimbursement is not required for the costs of the investigation required to make the determination to file an amended report. Section V.A.1, “Salaries and Benefits,” of the parameters and guidelines states: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims, and  Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported. County’s Response The county agreed with the audit finding. The county claimed $29,814 in salaries and benefits for the Notifications FINDING 4— Following Reports to the Child Abuse Central Index cost component Unallowable salaries during the audit period. We found that $10,459 is allowable and $19,355 and benefits – is unallowable. Unallowable related indirect costs total $1,261, for a total Notifications finding of $20,616. Following Reports to the Child Abuse The reimbursable activity for this cost component consists of notifying, in Central Index cost writing, the known or suspected child abuser that he or she has been component reported to CACI, in any form approved by the DOJ, at the time the FoUrm SS 8583 is filed with the DOJ. n ToU calculate the claimed salaries and benefits, the county multiplied the ATI by the number of referrals in which a CACI notification was sent to n the suspected child abuser, then multiplied the resulting hours by a PHR a and related benefit rate. l l During testing, we found that the county overstated the number of referrals o for which a CACI notification was sent to the suspected child abuser, mwisstated the PHRs, and overstated the benefit rates and related indirect coasts. The county overstated these costs because it did not claim costs in acbcordance with the program’s parameters and guidelines or the SCO’s Mlandated Cost Manual. e s a -28- l a Madera County Interagency Child Abuse and Neglect Investigation Reports Program The following table summarizes the claimed, allowable, and adjusted costs for the Notifications Following Reports to the Child Abuse Central Index cost component by fiscal year: Fiscal Amount Amount Audit Unallowable Total Audit Year Claimed Allowable Adjustment Indirect Costs Adjustment 1999-2000 $ 2,044 $ 615 $ (1,429) $ (91) $ (1,520) 2000-01 2,208 721 (1,487) (93) (1,580) 2001-02 1,919 572 (1,347) (86) (1,433) 2002-03 2,089 714 (1,375) (87) (1,462) 2003-04 1,978 722 (1,256) (81) (1,337) 2004-05 1,810 713 (1,097) (73) (1,170) 2005-06 2,427 771 (1,656) (113) (1,769) 2006-07 2,097 935 (1,162) (81) (1,243) 2007-08 1,772 646 (1,126) (77) (1,203) 2008-09 1,748 744 (1,004) (69) (1,073) 2009-10 1,814 740 (1,074) (77) (1,151) 2010-11 1,564 724 (840) (59) (899) 2011-12 1,533 734 (799) (55) (854) 2012-13 2,082 444 (1,638) (112) (1,750) 2013-14 1,915 331 (1,584) (107) (1,691) 2014-15 814 333 (481) - (481) Total $ 29,814 $ 10,459 $ (19,355) $ (1,261) $ (20,616) Number of CACI Notifications For FY 1999-2000 through FY 2013-14, the claimed number of referrals for which a CACI notification was sent was obtained from the CWS/CMS via online access to the California Child Welfare Indicators Project. For FY 2014-15, the DSS obtained the claimed number of referrals for which a CACI notification was sent directly from the CWS/CMS. The county provided a detailed referral listing generated by the CWS/CMS. During our review, we found that the listing included duplicate referrals; referrals initiated by DSS staff members as the mandated reporter, and then investigated by the CWS staff; referrals that were “evaluated out”; and general neglect referrals. Referrals that were initiated by the DSS staff members as the mandated reporter, and then investigated by CWS staff; referrals that were “evaluated out” and not investigated; and general neglect referrals are not mandate-related activities. Therefore, we determined that the costs claimed for these referrals are ineligible for reimbursement. Duplicate referrals are also unallowable. We recalculated the number of supported referrals for the audit period. For testing purposes, we relied on the results of our review of the 250 referrals judgementally selected as a non-statistical sample (discussed in Finding 2). Prior to January 1, 2012, both substantiated and inconclusive reports were eligible for reimbursement; as of January 1, 2012, forwarding inconclusive reports to DOJ is not reimbursable. Based on our review, we found that 216 (45 out of 50 in FY 2000-01; 45 out of 50 in FY 2004-05; 45 out of 50 in FY 2007-08; 36 out of 50 in FY 2011-12; and 45 out of 50 in FY 2014-15) of the sampled 250 referrals were eligible. -29- Madera County Interagency Child Abuse and Neglect Investigation Reports Program We also determined that a CACI notification was sent for 143 (21 out of 45 in FY 2000-01; 20 out of 45 in FY 2004-05; 33 out of 45 in FY 2007-08; 29 out of 36 in FY 2011-12; and 40 out of 45 in FY 2014-15) out of 216 referrals. Consistent with AU-C section 530, we calculated a weighted average based on the results of our testing. We projected the results by applying the weighted average of 66% to the total eligible number of referrals for which CACI notifications were sent to suspected child abusers by the DSS staff members during audit period. We determined that, for the Notifications Following Reports to the Child Abuse Central Index cost component, the allowable number of referrals totals 3,668. We recalculated the costs based on the allowable number of referrals. The following table summarizes the claimed, allowable, and adjusted number of CACI notifications sent to suspected child abusers by fiscal year: Fiscal Claimed Allowable Audit Year Referrals Referrals Adjustment 1999-2000 639 311 (328) 2000-01 680 338 (342) 2001-02 582 300 (282) 2002-03 624 335 (289) 2003-04 582 299 (283) 2004-05 525 271 (254) 2005-06 693 260 (433) 2006-07 590 277 (313) 2007-08 491 185 (306) 2008-09 477 197 (280) 2009-10 498 203 (295) 2010-11 424 204 (220) 2011-12 403 193 (210) 2012-13 549 121 (428) 2013-14 495 88 (407) 2014-15 210 86 (124) Total 8,462 3,668 (4,794) Productive Hourly Rate The DSS provided actual salary and benefit cost data generated by the county’s payroll system for the DSS staff members responsible for performing the mandate-related activities during the audit period. We used this actual salary cost data to calculate the average annual salary amount for employees in the Social Worker I through IV classifications. We divided the average annual salary amount by 1,800 productive hours to calculate the PHR. As explained in Finding 5, we found that the county misstated the claimed PHRs for FY 1999-2000 through FY 2006-07, FY 2008-09, FY 2010-11, FY 2012-13, and FY 2013-14. Benefit Rate The DSS provided the General Ledger Budgets and Actuals with Encumbrances reports identifying the actual departmental salary and benefit costs for the audit period. We used the actual benefits from these -30- Madera County Interagency Child Abuse and Neglect Investigation Reports Program reports to calculate the department-wide benefit rates for the audit period. To calculate the benefit rates, we divided the total actual departmental benefits divided by the total actual departmental salaries. As explained in Finding 6, we found that the county overstated the claimed benefit rates in FY 1999-2000 through FY 2008-09. Criteria Section IV, “Reimbursable Activities,” of the parameters and guidelines begins: To be eligible for mandated cost reimbursement for any fiscal year, only actual costs may be claimed. Actual costs are those costs actually incurred to implement the mandated activities. Actual costs must be traceable and supported by source documents that show the validity of such costs, when they were incurred, and their relationship to the reimbursable activities. A source document is a document created at or near the same time the actual cost was incurred for the event or activity in question. Source documents may include, but are not limited to, employee time records or time logs, sign in sheets, invoices, and receipts…. The claimant is only allowed to claim and be reimbursed for increased costs for reimbursable activities.…Increased cost is limited to the cost of an activity that the claimant is required to incur as a result of the mandate. Section IV, subsection B.4, “Notifications Following Reports to the Child Abuse Central Index,” of the parameters and guidelines states: a. City and county police or sheriff’s departments, county probation departments if designated by the county to receive mandated reports, and county welfare departments shall: 1) Notify in writing the known or suspected child abuser that he or she has been reported to the Child Abuse Central Index, in any form approved by the Department of Justice, at the time the “Child Abuse Investigation Report” is filed with the Department of Justice. This activity includes, where applicable, completion of the Notice of Child Abuse Central Index Listing form (SOC 832), or subsequent designated form. For law enforcement agencies only, this activity is eligible for reimbursement from July 1, 1999 until December 31, 2011, pursuant to Penal Code section 11169(b), as amended by Statutes 2011, chapter 468 (AB 717), which ends the mandate to report to DOJ for law enforcement agencies. Section V, subparagraph A.1, “Salaries and Benefits,” of the parameters and guidelines states: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. -31- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims, and  Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported. County’s Response The county agreed with the audit finding. The DSS claimed salaries for employees in the Social Worker I through FINDING 5— IV classifications for FY 1999-2000 through FY 2013-14, and for the Misstated productive Social Worker IV classification in FY 2014-15. hourly rates M For FY 2009-10 through FY 2013-14, the DSS calculated salaries for i employees in the Social Worker I through IV classifications using the total s cumulative actual annual salary costs for each of these classifications. To s determine the average actual annual salary costs, the DSS divided the total cutmulative actual annual salary costs for these classifications by the total nuamber of DSS staff members assigned to these classifications. To cotmpute the PHRs, the DSS divided the average actual salary costs for theese classifications by 1,800 productive hours. d For FY 1999-2000 through FY 2008-09, DSS did not use the total p cumulative actual annual salary costs for each of these classifications to r calculate the salaries. Instead, the county estimated the PHRs by reducing o the computed PHR in FY 2009-10 by a cost-of-living adjustment equal to d 1.5%, and applied this methodology to the preceding fiscal years. u c For FY 2014-15, the DSS calculated salaries for the Social Worker IV cltassification using the total cumulative actual annual salary cost for this cliassification. To determine the average annual salary cost, the DSS divvided by the number of DSS staff members assigned to this clea ssification. To compute the PHR, the DSS divided the average annual sahlary cost for this classification by 1,800 productive hours. o During testing, the DSS provided actual salary cost data from the county’s u payroll system for DSS staff members responsible for performing the r mandate-related activities during the audit period. We reviewed the actual l salary cost data and recalculated the PHRs based on the actual salary costs. y We found that the county misstated the PHRs for FY 1999-2000 through r FY 2006-07, FY 2008-09, FY 2010-11, FY 2012-13, and FY 2013-14. We reacalculated allowable costs based on the allowable PHRs. t e s U n U n -32- a l Madera County Interagency Child Abuse and Neglect Investigation Reports Program The following table summarizes the claimed, allowable, and adjusted PHRs for the fiscal years that resulted in an audit adjustment: Fiscal Claimed Allowable Audit Year PHR PHR Adjustment 1999-2000 $ 2 6.63 $ 19.76 $ (6.87) 2000-01 2 7.03 21.30 (5.73) 2001-02 2 7.44 18.83 (8.61) 2002-03 2 7.86 20.64 (7.22) 2003-04 2 8.29 22.31 (5.98) 2004-05 2 8.72 23.34 (5.38) 2005-06 2 9.15 25.17 (3.98) 2006-07 2 9.60 28.16 (1.44) 2008-09 3 0.51 31.80 1 .29 2010-11 3 1.24 30.04 (1.20) 2012-13 3 1.07 30.08 (0.99) 2013-14 3 1.55 30.74 (0.81) Criteria Section V, subparagraph A.1, “Salaries and Benefits,” of the parameters and guidelines states: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. Section 2, part 7, sub-part (1)(a), “Productive Hourly Rate Options,” of the SCO’s Mandated Cost Manual (July 1, 2015) states: A local agency may use one of the following methods to compute productive hourly rates:  Actual annual productive hours for each employee;  The weighted-average annual productive hours for each job title; or  1,800* annual productive hours for all employees. If actual annual productive hours or weighted-average annual productive hours for each job title is chosen, the claimant must maintain documentation of how these hours were computed. *1,800 annual productive hours excludes the following employee time:  Paid holidays;  Vacation earned;  Sick leave taken;  Informal time off;  Jury duty; and  Military leave taken. -33- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims; and  Calculate the PHRs based on the classifications of the employees who perform the mandated activities, using the documentation for the corresponding fiscal year. County’s Response The county agreed with the audit finding. For the audit period, the county claimed benefits for employees in the FINDING 6— Social Worker I through IV classifications. For FY 2009-10 through Overstated benefit rates FY 2014-15, the benefit costs for these classifications were calculated M using the total actual departmental benefit costs from the DSS payroll i system. The total actual departmental benefit costs were divided by the s total departmental salary costs to compute the benefit rates. For s FY 1999-2000 through FY 2008-09, the DSS did not use the total actual detpartmental salary and benefit costs to compute the benefit rates claimed. Inastead, the DSS computed an average estimated benefit rate totaling 44t.14%, based on the calculated benefit rates for FY 2009-10 therough FY 2013-14. d During testing, the DSS provided the General Ledger Budgets and Actuals p with Encumbrances reports identifying the total actual departmental salary r and benefit costs for the audit period. We reviewed the reports and o recalculated the benefit rates based on the total actual departmental salary d and benefit costs. We found that the county overstated the benefit rates in u FY 1999-2000 through FY 2008-09. We calculated allowable costs based c on the allowable benefit rates. t Thie following table summarizes the claimed, allowable, and adjusted bevnefit rates for the fiscal years that resulted in an audit adjustment: e Fiscal Claimed Allowable Audit h Year Benefit Rate Benefit Rate Adjustment o 1999-2000 44.14% 20.17% (23.97)% u 2000-01 44.14% 20.22% (23.92)% r 2001-02 44.14% 21.50% (22.64)% l 2002-03 44.14% 24.01% (20.13)% 20y0 3-04 44.14% 29.78% (14.36)% 20r04-05 44.14% 35.21% (8.93)% 20a05-06 44.14% 41.39% (2.75)% 20t06-07 44.14% 43.92% (0.22)% 2007-08 44.14% 39.62% (4.52)% e 2008-09 44.14% 42.45% (1.69)% s U n U n -34- a l Madera County Interagency Child Abuse and Neglect Investigation Reports Program Criteria Section V, subparagraph A.1, “Salaries and Benefits,” of the parameters and guidelines states, in part: Report each employee implementing the reimbursable activities by name, job classification, and productive hourly rate (total wages and related benefits divided by productive hours). Describe the specific reimbursable activities performed and the hours devoted to each reimbursable activity performed. Section 2, part 7, sub-part (2)(d), “Employer’s Benefit Contribution,” of the SCO’s Mandated Cost Manual states, in part: A local agency has the option of claiming actual employer’s fringe benefit contributions or computing an average fringe benefit cost for the employee’s job classification and claiming it as a percentage of direct labor. The same time base should be used for both salary and fringe benefits when computing a percentage. Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims; and  Calculate the benefit rates based on the classifications of the employees who perform the mandated activities, using the documentation for the corresponding fiscal year. County’s Response The county agreed with the audit finding. The county reported $817,519 in offsetting revenues for the audit period. FINDING 7— We found that the county overstated offsetting revenues by $539,844. Overstated offsetting revenues The county reported the mandate-related ratio of funding it received based M on the total annual costs claimed. As a result of the adjustments identified i in Findings 1 through 6, we recalculated the offsetting revenues based on thse allowable costs using the 35% offset ratio provided by the DSS for the ausdit period. t a t e d p r o d u c t -35- i v Madera County Interagency Child Abuse and Neglect Investigation Reports Program The following table summarizes the audit adjustment related to offsetting revenues by fiscal year: Reported Actual Fiscal Offsetting Offsetting Audit Year Revenues Revenues Adjustment 1999-2000 $ (39,425) $ (10,350) $ 29,075 2000-01 (45,664) (12,714) 32,950 2001-02 (44,600) (8,953) 35,647 2002-03 (50,411) (11,480) 38,931 2003-04 (52,333) (13,557) 38,776 2004-05 (50,678) (15,112) 35,566 2005-06 (50,320) (14,070) 36,250 2006-07 (57,080) (20,354) 36,726 2007-08 (48,483) (15,777) 32,706 2008-09 (47,705) (17,652) 30,053 2009-10 (52,922) (17,479) 35,443 2010-11 (61,153) (22,737) 38,416 2011-12 (68,605) (29,330) 39,275 2012-13 (64,220) (26,354) 37,866 2013-14 (56,261) (20,311) 35,950 2014-15 (27,659) (21,445) 6,214 Total $ (817,519) $ (277,675) $ 539,844 Criteria Section VII, “Offsetting Revenues and Reimbursements,” of the parameters and guidelines states: Any offsetting revenue the claimant experiences in the same program as a result of the same statutes or executive orders found to contain the mandate shall be deducted from the costs claimed. In addition, reimbursement for this mandate from any source, including, but not limited to, service fees collected, federal funds, and other state funds, shall be identified and deducted from this claim. Recommendation The ICAN Investigation Reports Program was suspended in the FY 2015-16 through FY 2021-22 Budget Acts. If the program becomes active again, we recommend that the county:  Follow the parameters and guidelines and the SCO’s Mandated Cost Manual when preparing its reimbursement claims; and  Ensure that all offsetting revenues are identified and deducted from claimed costs. County’s Response The county agreed with the audit finding. -36- Madera County Interagency Child Abuse and Neglect Investigation Reports Program Attachment— County’s Response to Draft Audit Report State Controller’s Office Division of Audits Post Office Box 942850 Sacramento, CA 94250 http://www.sco.ca.gov S20-MCC-0008