SCO
City of Rancho Cucamonga
Identity Theft
Read the report at City of Rancho Cucamonga ↗
CITY OF RANCHO CUCAMONGA
Audit Report
IDENTITY THEFT PROGRAM
Chapter 956, Statutes of 2000
July 1, 2002, through June 30, 2013
M M. C
ALIA OHEN
California State Controller
November 2023
MALIA M. COHEN
CALIFORNIA STATE CONTROLLER
November 20, 2023
CERTIFIED MAIL—RETURN RECEIPT REQUESTED
Tamara Oatman, Finance Director
City of Rancho Cucamonga
10500 Civic Center Drive
Rancho Cucamonga, CA 91729
Dear Ms. Oatman:
The State Controller’s Office audited the costs claimed by the City of Rancho Cucamonga for
the legislatively mandated Identity Theft Program for the period of July 1, 2002, through
June 30, 2013.
The city claimed $500,098 for costs of the mandated program. Our audit found that $195,540 is
allowable and $304,558 is unallowable. The costs are unallowable because the city misclassified
costs, overstated the number of identity theft reports taken, misstated the time increments needed
to perform the reimbursable activities, and claimed unallowable indirect costs. The State made
no payments to the city. The State will pay $195,540, 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 city of the adjustment to its claims via a system-
generated letter for each fiscal year in the audit period.
This final audit report contains an adjustment to costs claimed by the city. If you disagree with
the audit finding, you may file an Incorrect Reduction Claim (IRC) with the Commission on
State Mandates (Commission). Pursuant to the Commission’s regulations, outlined in Title 2,
California Code of Regulations, section 1185.1, subdivision (c), an IRC challenging this
adjustment must be filed with the Commission no later than three years following the date of this
report, regardless of whether this report is subsequently supplemented, superseded, or otherwise
amended. IRC information is available on the Commission’s website at
www.csm.ca.gov/forms/IRCForm.pdf.
300 Capitol Mall, Suite 1850, Sacramento, CA 95814 | P.O. Box 942850, Sacramento, CA 94250 | Fax: 916.322.4404
sco.ca.gov
Ms. Tamara Oatman
November 20, 2023
Page 2 of 2
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/ac
cc: The Honorable L. Dennis Michael, Mayor
City of Rancho Cucamonga
Chris Hill, Principal Program Budget Analyst
Local Government Unit
California Department of Finance
Ted Doan, Finance Budget Analyst
Local Government Unit
California Department of Finance
Darryl Mar, Manager
Local Reimbursements Section
State Controller’s Office
Everett Luc, Supervisor
Local Reimbursements Section
State Controller’s Office
300 Capitol Mall, Suite 1850, Sacramento, CA 95814 | P.O. Box 942850, Sacramento, CA 94250 | Fax: 916.322.4404
sco.ca.gov
City of Rancho Cucamonga Identity Theft Program
Contents
Audit Report
Summary ............................................................................................................................ 1
Background ........................................................................................................................ 1
Audit Authority .................................................................................................................. 2
Objective, Scope, and Methodology ................................................................................. 2
Conclusion .......................................................................................................................... 4
Follow-up on Prior Audit Findings .................................................................................. 4
Views of Responsible Officials .......................................................................................... 4
Restricted Use .................................................................................................................... 5
Schedule—Summary of Program Costs .............................................................................. 6
Finding and Recommendation .............................................................................................. 12
Attachment—City’s Response to Draft Audit Report
City of Rancho Cucamonga Identity Theft Program
Audit Report
Summary The State Controller’s Office (SCO) audited the costs claimed by the City
of Rancho Cucamonga for the legislatively mandated Identity Theft
Program for the period of July 1, 2002, through June 30, 2013.
The city claimed $500,098 for costs of the mandated program. Our audit
found that $195,540 is allowable and $304,558 is unallowable. The costs
are unallowable because the city misclassified costs, overstated the
number of identity theft reports taken, misstated the time increments
needed to perform the reimbursable activities, and claimed unallowable
indirect costs. The State made no payments to the city. The State will pay
$195,540, contingent upon available appropriations.
Background Penal Code (PC) section 530.6(a), as added by the Statutes of 2000,
Chapter 956, requires a local law enforcement agency to take a police
report and begin an investigation when a complainant residing within its
jurisdiction reports suspected identity theft.
On March 27, 2009, the Commission on State Mandates (Commission)
found that this legislation mandates a new program or higher level of
service for local law enforcement agencies within the meaning of service
for local law enforcement agencies within the meaning of Article XIII B,
section 6 of the California Constitution, and imposes costs mandated by
the State pursuant to Government Code (GC) section 17514.
The Commission determined that each claimant is allowed to claim and be
reimbursed for the following ongoing activities identified in the
parameters and guidelines (Section IV., “Reimbursable Activities”):
1. Either a) or b) below:
a) Take a police report supporting a violation of Penal Code
section 530.5 which includes information regarding the
personal identifying information involved and any uses of that
personal identifying information that were non-consensual and
for an unlawful purpose, including, if available, information
surrounding the suspected identity theft, places where the
crime(s) occurred, and how and where the suspect obtained and
used the personal identifying information. This activity
includes drafting, reviewing, and editing the identity theft
police report; or
b) Reviewing the identity theft report completed on-line by the
identity theft victim.
2. Begin an investigation of the facts, including the gathering of facts
sufficient to determine where the crime occurred and what pieces of
personal identifying information were used for an unlawful purpose. The
purpose of the investigation is to assist the victims in clearing their
names. Reimbursement is not required to complete the investigation for
purposes of criminal prosecution.
The Commission also determined that reimbursable activities do not
include providing a copy of the report to the complainant, or referring the
-1-
City of Rancho Cucamonga Identity Theft Program
matter to the law enforcement agency in the location where the suspected
crime was committed for further investigation.
The program’s parameters and guidelines establish the state mandate and
define the reimbursement criteria. 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.
Audit Authority We conducted this performance audit in accordance with GC
sections 17558.5 and 17561, which authorize the SCO to audit the city’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 for payment.
Objective, Scope, The objective of our audit was to determine whether claimed costs
represent increased costs resulting from the legislatively mandated
and Methodology
Identity Theft Program. Specifically, we conducted this audit to determine
whether claimed costs were supported by appropriate source documents,
were not funded by another source, and were not unreasonable and/or
excessive.
Unreasonable and/or excessive costs include ineligible costs that are not
identified in the program’s parameters and guidelines as reimbursable
costs.
The audit period was July 1, 2002, through June 30, 2013.
To achieve our objective, we performed the following procedures.
• We analyzed the annual mandated cost claims filed by the city 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. We also reviewed the claimed activities to determine whether
they adhered to the SCO’s Mandated Cost Manual and the program’s
parameters and guidelines.
• We completed an internal control questionnaire by interviewing key
city staff. We discussed the claim preparation process with city staff
members to determine what information was obtained, who obtained
it, and how it was used.
• We obtained system-generated lists of identity-theft cases with
jurisdiction codes for the City of Rancho Cucamonga from the
San Bernardino County Sheriff’s Department’s (SBCSD) computer-
aided dispatch (CAD) system to verify the existence, completeness,
and accuracy of unduplicated case counts for each fiscal year in the
audit period. We recalculated the costs based on the allowable number
of cases for each of the reimbursable activities.
• We designed a statistical sampling plan to test approximately 25-50%
of claimed costs, based on a moderate level of detection (audit) risk.
-2-
City of Rancho Cucamonga Identity Theft Program
We judgmentally selected the city’s filed claims for fiscal year
(FY) 2010-11 through FY 2012-13 for testing, which comprised
claimed costs totaling $138,470 (or 27.7%) of the total costs claimed
($500,098). The sampling plan is described in the Finding and
Recommendation section.
• We used a random number table to select 264 out of 695 identity theft
reports from the three fiscal years sampled. We tested the identity theft
report as follows:
o We determined whether a contemporaneously prepared and
approved police report supported that a violation of PC
section 530.5 occurred.
o We determined whether the initial police reports were courtesy
reports from other law enforcement agencies that had been
forwarded to SBCSD’s Rancho Cucamonga Patrol Station for
further investigation.
o We determined whether the victim of identity theft contacted the
SBCSD to initiate the law enforcement investigation.
o We obtained employee numbers, names, and classifications from
sampled police reports documenting who performed the
reimbursable activities. We compared the employee
classifications obtained from the police reports to those claimed
by the city.
o We obtained system-generated time stamps from SBCSD’s CAD
system for the “Time On Scene” and “Time Closed” associated
with each report to determine the time spent to begin an
investigation. For reports with unreasonable and excessive time
spent, we reviewed the detailed history of time stamps from the
CAD system for the incident number related to the sampled police
report, and adjusted for ineligible time spent on arrests and other
incident numbers.
• We interviewed sworn and non-sworn county employees who
performed the mandated activities, as documented in the sampled
police reports, about their time spent performing reimbursable
activities not captured by the CAD system.
• As no city staff members performed the reimbursable activities, we
used copies of the city’s annual law enforcement services contracts
with the county during the audit period to obtain the annual contract
services costs incurred by the city. The contract services costs
included salary and benefit costs for various employee classifications,
administrative costs, and various other additional costs related to
providing law enforcement services for the city.
• We projected the audit results of the three years tested by multiplying
the allowable case counts by the audited average time increments
needed to perform the reimbursable activities, and multiplying the
product by the contract hourly rates of county employees who
performed them. Due to the homogeneity of the population, we
applied the weighted three-year average error rate that we derived
from testing our samples to the remaining eight years of the audit
period.
-3-
City of Rancho Cucamonga Identity Theft Program
• We reviewed the city’s Single Audit Reports to identify potential
sources of offsetting savings or reimbursements from federal or pass-
through programs applicable to the Identity Theft Program. We did
not identify any applicable offsetting revenues. The city certified in its
claims that it did not receive such offsetting revenues applicable to this
mandated program.
We did not audit the city’s financial statements.
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.
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 city did not claim costs that are funded by another source;
however, we did find that it claimed unsupported and ineligible costs, as
quantified in the Schedule and described in the Finding and
Recommendation section of this audit report.
For the audit period, the City of Rancho Cucamonga claimed $500,098 for
costs of the legislatively mandated Identity Theft Program. Our audit
found that $195,540 is allowable and $304,558 is unallowable. The State
made no payments to the city. The State will pay $195,540, contingent
upon available appropriations.
Following issuance of this audit report, the SCO’s Local Government
Programs and Services Division will notify the city 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 City of Rancho
Cucamonga’s legislatively mandated Identity Theft Program.
Prior Audit
Findings
Views of We issued a draft audit report on April 19, 2023. The City of Rancho
Responsible Cucamonga’s representative responded by letter dated June 28, 2023,
disagreeing with the audit results. This final audit report includes the city’s
Officials
response as an attachment.
-4-
City of Rancho Cucamonga Identity Theft Program
Restricted Use This audit report is solely for the information and use of the City of Rancho
Cucamonga, 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
November 20, 2023
-5-
City of Rancho Cucamonga Identity Theft Program
Schedule—
Summary of Program Costs
July 1, 2002, through June 30, 2013
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2002, through June 30, 2003
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 20,587 $ - $ (20,587)
Beginning an investigation of facts 7,356 - (7,356)
Total salaries 27,943 - (27,943)
Contract services:
Taking police report on a violation of PC §530.5 - 10,999 10,999
Beginning an investigation of facts - 9,057 9,057
Total contract services - 20,056 20,056
Total direct costs 27,943 20,056 (7,887)
Indirect costs 26,267 - (26,267)
Total program costs $ 54,210 20,056 $ (34,154)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 20,056
July 1, 2003, through June 30, 2004
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 20,865 $ - $ (20,865)
Beginning an investigation of facts 7,456 - (7,456)
Total salaries 28,321 - (28,321)
Contract services:
Taking police report on a violation of PC §530.5 - 11,098 11,098
Beginning an investigation of facts - 9,161 9,161
Total contract services - 20,259 20,259
Total direct costs 28,321 20,259 (8,062)
Indirect costs 24,838 - (24,838)
Total program costs $ 53,159 20,259 $ (32,900)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 20,259
-6-
City of Rancho Cucamonga Identity Theft Program
Schedule (continued)
-7-
C o s t E le m e n ts
J u ly 1 , 2 0 0 4 , th r o u g h J u n e 3 0 , 2 0 0 5
D ir e c t c o s ts :
S a la r ie s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l s a la r ie s
C o n tr a c t s e r v ic e s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l c o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
I n d ir e c t c o s ts
T o ta l p r o g r a m c o s ts
2 L e s s a m o u n t p a id b y th e S ta te
A llo w a b le c o s ts c la im e d in e x c e s s o f a m
J u ly 1 , 2 0 0 5 , th r o u g h J u n e 3 0 , 2 0 0 6
D ir e c t c o s ts :
S a la r ie s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l s a la r ie s
C o n tr a c t s e r v ic e s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l c o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
I n d ir e c t c o s ts
T o ta l p r o g r a m c o s ts
2 L e s s a m o u n t p a id b y th e S ta te
A llo w a b le c o s ts c la im e d in e x c e s s o f a m
f P
f P
o u
f P
f P
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5
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3 0
3 0
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3 0
3 0
id
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.5
.5
A c tu a l C o s ts
C la im e d
$ 2 7 ,0 9 3
9 ,6 8 8
3 6 ,7 8 1
-
-
-
3 6 ,7 8 1
2 9 ,4 9 9
$ 6 6 ,2 8 0
$ 2 8 ,6 5 0
1 0 ,1 4 7
3 8 ,7 9 6
-
-
-
3 8 ,7 9 6
3 1 ,5 4 2
$ 7 0 ,3 3 8
A llo w a b le
p e r A u d it
$ -
-
-
1 2 ,9 1 0
1 0 ,6 7 4
2 3 ,5 8 4
2 3 ,5 8 4
-
2 3 ,5 8 4
-
$ 2 3 ,5 8 4
$ -
-
-
1 4 ,2 4 1
1 1 ,5 6 9
2 5 ,8 1 0
2 5 ,8 1 0
-
2 5 ,8 1 0
-
$ 2 5 ,8 1 0
A u d
A d ju s tm
$ ( 2
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City of Rancho Cucamonga Identity Theft Program
Schedule (continued)
-8-
C o s t E le m e n ts
J u ly 1 , 2 0 0 6 , th r o u g h J u n e 3 0 , 2 0 0 7
D ir e c t c o s ts :
S a la r ie s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l s a la r ie s
C o n tr a c t s e r v ic e s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l c o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
I n d ir e c t c o s ts
T o ta l p r o g r a m c o s ts
2 L e s s a m o u n t p a id b y th e S ta te
A llo w a b le c o s ts c la im e d in e x c e s s o f a m
J u ly 1 , 2 0 0 7 , th r o u g h J u n e 3 0 , 2 0 0 8
D ir e c t c o s ts :
S a la r ie s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l s a la r ie s
C o n tr a c t s e r v ic e s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l c o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
I n d ir e c t c o s ts
T o ta l p r o g r a m c o s ts
2 L e s s a m o u n t p a id b y th e S ta te
A llo w a b le c o s ts c la im e d in e x c e s s o f a m
f P
f P
o u
f P
f P
o u
C
C
n
C
C
n
§
§
t p
§
§
t p
5
5
a
5
5
a
3 0
3 0
id
3 0
3 0
id
.5
.5
.5
.5
A c tu a l C o s ts
C la im e d
$ 1 8 ,0 6 5
6 ,4 4 3
2 4 ,5 0 8
-
-
-
2 4 ,5 0 8
1 9 ,3 1 2
$ 4 3 ,8 2 0
$ 1 1 ,8 5 9
4 ,2 1 8
1 6 ,0 7 7
-
-
-
1 6 ,0 7 7
1 2 ,7 1 8
$ 2 8 ,7 9 5
A llo w a b le
p e r A u d it
$ -
-
-
8 ,6 9 6
7 ,1 2 4
1 5 ,8 2 0
1 5 ,8 2 0
-
1 5 ,8 2 0
-
$ 1 5 ,8 2 0
$ -
-
-
5 ,9 9 3
4 ,8 8 4
1 0 ,8 7 7
1 0 ,8 7 7
-
1 0 ,8 7 7
-
$ 1 0 ,8 7 7
A u d it
A d ju s tm e n
$ ( 1 8 ,0
( 6 ,4
( 2 4 ,5
8 ,6
7 ,1
1 5 ,8
( 8 ,6
( 1 9 ,3
$ ( 2 8 ,0
$ ( 1 1 ,8
( 4 ,2
( 1 6 ,0
5 ,9
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( 5 ,2
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$ ( 1 7 ,9
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City of Rancho Cucamonga Identity Theft Program
Schedule (continued)
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2008, through June 30, 2009
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 8,615 $ - $ (8,615)
Beginning an investigation of facts 3,060 - (3,060)
Total salaries 11,675 - (11,675)
Contract services:
Taking police report on a violation of PC §530.5 - 4,473 4,473
Beginning an investigation of facts - 3,629 3,629
Total contract services - 8,102 8,102
Total direct costs 11,675 8,102 (3,573)
Indirect costs 9,282 - (9,282)
Total program costs $ 20,957 8,102 $ (12,855)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 8,102
July 1, 2009, through June 30, 2010
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 9,803 $ - $ (9,803)
Beginning an investigation of facts 3,480 - (3,480)
Total salaries 13,283 - (13,283)
Contract services:
Taking police report on a violation of PC §530.5 - 5,557 5,557
Beginning an investigation of facts - 4,508 4,508
Total contract services - 10,065 10,065
Total direct costs 13,283 10,065 (3,218)
Indirect costs 10,786 - (10,786)
Total program costs $ 24,069 10,065 $ (14,004)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 10,065
-9-
City of Rancho Cucamonga Identity Theft Program
Schedule (continued)
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2010, through June 30, 2011
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 12,662 $ - $ (12,662)
Beginning an investigation of facts 4,495 - (4,495)
Total salaries 17,157 - (17,157)
Contract services:
Taking police report on a violation of PC §530.5 - 5,948 5,948
Beginning an investigation of facts - 4,150 4,150
Total contract services - 10,098 10,098
Total direct costs 17,157 10,098 (7,059)
Indirect costs 12,697 - (12,697)
Total program costs $ 29,854 10,098 $ (19,756)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 10,098
July 1, 2011, through June 30, 2012
Direct costs:
Salaries:
Taking police report on a violation of PC §530.5 $ 21,912 $ - $ (21,912)
Beginning an investigation of facts - - -
Total salaries 21,912 - (21,912)
Contract services:
Taking police report on a violation of PC §530.5 - 7,385 7,385
Beginning an investigation of facts - 6,803 6,803
Total contract services - 14,188 14,188
Total direct costs 21,912 14,188 (7,724)
Indirect costs 16,214 - (16,214)
Total program costs $ 38,126 14,188 $ (23,938)
Less amount paid by the State2 -
Allowable costs claimed in excess of amount paid $ 14,188
-10-
City of Rancho Cucamonga Identity Theft Program
Schedule (continued)
-11-
C o s t E le m e n ts
J u ly 1 , 2 0 1 2 , th r o u g h J u n e 3 0 , 2 0 1 3
D ir e c t c o s ts :
S a la r ie s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l s a la r ie s
C o n tr a c t s e r v ic e s :
T a k in g p o lic e r e p o r t o n a v io la tio n o
B e g in n in g a n in v e s tig a tio n o f fa c ts
T o ta l c o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
I n d ir e c t c o s ts
T o ta l p r o g r a m c o s ts
2 L e s s a m o u n t p a id b y th e S ta te
A llo w a b le c o s ts c la im e d in e x c e s s o f a m
S u m m a r y : J u ly 1 , 2 0 0 2 , th r o u g h J u n e 3
D ir e c t c o s ts
S a la r ie s
C o n tr a c t s e r v ic e s
T o ta l d ir e c t c o s ts
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_________________________
1 See the Finding and Recommendation section.
2 Payment amount current as of September 12, 2023.
City of Rancho Cucamonga Identity Theft Program
Finding and Recommendation
FINDING— The City of Rancho Cucamonga claimed $500,098 ($276,391 in salary
costs and $223,707 in related indirect costs) for the Identity Theft
Overstated Identity
Program. We found that $195,540 is allowable and $304,558 is
Theft Program costs
unallowable. The costs are unallowable primarily because the city claimed
misclassified costs, overstated the number of identity theft reports taken,
misstated the time increments needed to perform the reimbursable
activities, and claimed unallowable indirect costs.
The city used the correct methodology to calculate its salary costs. It
multiplied the number of identity theft police reports by the time required
to perform the reimbursable activities, and it multiplied the product by the
hourly rates obtained from the city’s contracts with SBCSD. The
SBCSD’s contracts included costs for salaries and benefits, as well as
additional administrative costs.
However, the city should have classified its salary costs as contract
services costs, because no city staff members performed the reimbursable
activities. The city contracted with San Bernardino County to have the
SBCSD perform all of its law enforcement services during the audit
period. Therefore, the city did not incur any salary costs—or indirect costs
related to salary costs—but rather incurred contract services costs. We
reallocated the costs to the appropriate cost category of Contract Services.
The following table summarizes the claimed, allowable, and audit
adjustment amounts by fiscal year:
(A) (B) (C) (D)=(A)+(B)+(C)
Salaries Related Contract Total
Fiscal Amount Amount Audit Indirect Cost Services Audit
Year Claimed 1 Allowable Adjustment Adjustment Adjustment Adjustment
2002-03 $ 27,943 $ - $ (27,943) $ (26,267) $ 2 0,056 $ ( 34,154)
2003-04 2 8,321 - (28,321) (24,838) 20,259 (32,900)
2004-05 3 6,781 - (36,781) (29,499) 23,584 (42,696)
2005-06 3 8,796 - (38,796) (31,542) 25,810 (44,528)
2006-07 2 4,508 - (24,508) (19,312) 15,820 (28,000)
2007-08 1 6,077 - (16,077) (12,718) 10,877 (17,918)
2008-09 1 1,675 - (11,675) (9,282) 8,102 (12,855)
2009-10 1 3,283 - (13,283) (10,786) 10,065 (14,004)
2010-11 1 7,157 - (17,157) (12,697) 10,098 (19,756)
2011-12 2 1,912 - (21,912) (16,214) 14,188 (23,938)
2012-13 3 9,938 - (39,938) (30,552) 36,681 (33,809)
Total $ 276,391 $ - $ (276,391) $ ( 223,707) $ 195,540 $ (304,558)
1 Amounts claimed for FY 2004-05, FY 2007-08, FY 2010-11, and FY 2011-12 adjusted by $1 due to claim
rounding errors
Contract Services Costs
The city contracted with San Bernardino County to have the SBCSD
provide all of its law enforcement services during the audit period. These
-12-
City of Rancho Cucamonga Identity Theft Program
services included reimbursable activities claimed for the mandated
program. The city contracted for various SBCSD staff positions each fiscal
year and paid the SBCSD annual contract billing rates for the positions.
These positions included, but were not limited to, Deputy Sheriffs, Office
Specialists, Service Specialists, and Sergeants. No city staff members
performed any of the reimbursable activities under this program; therefore,
the city did not incur salary and related indirect costs as claimed, but rather
incurred contract services costs. We reallocated the costs to the appropriate
cost category of Contract Services.
Identity Theft Incident Reports
The city stated in its claims that it took 2,749 identity theft incident reports
during the audit period. We found that the city overstated the number of
reports taken by 715, and that allowable reports totaled 2,034.
The following table summarizes the counts of claimed, supported, and
allowable identity theft cases, and the audit adjustment by fiscal year:
(A) (B) (C) (D)=(C)-(A)
Fiscal Claimed Audited Allowable Audit
Year Reports Population Reports Adjustment
2002-03 370 3 86 269 (101)
2003-04 375 3 76 262 (113)
2004-05 397 3 93 274 (123)
2005-06 404 4 08 284 (120)
2006-07 232 2 28 159 (73)
2007-08 144 1 48 103 (41)
2008-09 103 1 09 76 (27)
2009-10 120 1 35 94 (26)
2010-11 155 1 56 96 (59)
2011-12 163 1 81 113 (50)
2012-13 286 3 58 304 18
Total 2,749 2,878 2,034 (715)
For each fiscal year, the SBCSD provided Excel spreadsheets, generated
from its CAD system, to support the claimed number of initial police
reports for violations of PC section 530.5. This list of police reports
identified the county jurisdiction code, the year of the report, and the report
number. The SBCSD also provided a Jurisdiction Reference Chart, which
disclosed county jurisdiction codes and jurisdiction codes for the cities that
contract with the county for law enforcement services. The spreadsheets
supported 2,878 identity theft police reports filed for the City of Rancho
Cucamonga during the audit period.
We verified the accuracy of the unduplicated counts of initial police
reports recorded in the CAD system by determining whether:
• Each identity theft case was supported by a contemporaneously
prepared and approved police report; and
• The police report supported a violation of PC section 530.5.
-13-
City of Rancho Cucamonga Identity Theft Program
Our audit plan called for testing 25% of claimed costs at a minimum. We
selected FY 2010-11 through FY 2012-13 for testing purposes, as claimed
salaries for these three fiscal years totaled $79,007 ($17,158, $21,911, and
$39,938, respectively), which represents 28.6% of the $276,391 amount
claimed for salaries during the audit period.
For the three years, we selected a statistical sample from the documented
number of identity theft incident reports (the population) based on a 95%
confidence level, a precision rate of ±8%, and an expected error rate
of 50%. We used statistical samples in order to project the results to the
population for each fiscal year. We randomly selected 264 out of 695
identity theft incident reports for review.
Our review of sample incident reports disclosed the following:
• For FY 2010-11, we found that 29 out of 76 identity theft incident
reports were unallowable because:
o Seven reports did not meet the requirements of PC
section 530.6(a), because the victim(s) of identity theft did not
initiate the investigation by contacting the local law enforcement
agency;
o Two reports were not for violations of PC section 530.5;
o One report did not indicate that a crime occurred; and
o Nineteen reports were courtesy reports (police reports taken and
prepared by other law enforcement agencies).
Therefore, we calculated an error rate of 38.16% for FY 2010-11.
• For FY 2011-12, we found that 31 out of 82 identity theft incident
reports were unallowable because:
o Nine reports did not meet the requirements of PC section 530.6(a),
because the victim(s) of identity theft did not initiate the
investigation by contacting the local law enforcement agency;
o Two reports did not indicate that a crime occurred;
o Two reports were incident reports that did not specify violation of
any specific code section;
o Four reports did not include violations of PC section 530.5 as an
offense;
o Two reports were for victims who did not reside in the City of
Rancho Cucamonga; and
o Twelve reports were courtesy reports.
Therefore, we calculated an error rate of 37.80% for FY 2011-12.
• For FY 2012-13, we found that 16 out of 106 identity theft incident
reports were unallowable because:
o Two reports were not for violations of PC section 530.5;
o Three reports did not indicate that a crime occurred;
o Five reports were for victims who did not reside in the City of
Rancho Cucamonga; and
-14-
City of Rancho Cucamonga Identity Theft Program
o Six reports were courtesy reports.
Therefore, we calculated an error rate of 15.09% for FY 2012-13.
The following table shows the average error rates for FY 2010-11 through
FY 2012-13:
-15-
2
2
2
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Y
0
0
0
is c a l
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1 0 - 1 1
1 1 - 1 2
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( A )
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C a s e s
S a m p le d
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e r o f f is c a l y e
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te
6 %
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5 %
5 %
)
3
We extrapolated the average error rate to the audited population of reports
for FY 2002-03 through FY 2009-10, and applied the actual audited error
rate for each of the other fiscal years to determine the allowable and
unallowable number of incident reports taken.
The following table shows the number of allowable and unallowable
incident reports by fiscal year:
(A) (B) (C)=(A)×(B) (D)=(A)-(C)
Average Total Total
Fiscal Audited Error Error Unallowable Allowable
Year Population Rate Rate Reports Reports
2002-03 386 N/A 30.35% 117 269
2003-04 376 N/A 30.35% 114 262
2004-05 393 N/A 30.35% 119 274
2005-06 408 N/A 30.35% 124 284
2006-07 228 N/A 30.35% 69 159
2007-08 148 N/A 30.35% 45 103
2008-09 109 N/A 30.35% 33 76
2009-10 135 N/A 30.35% 41 94
2010-11 156 38.16% N/A 60 96
2011-12 181 37.80% N/A 68 113
2012-13 358 15.09% N/A 54 304
Total 2,878 844 2 ,034
Time Increments
The parameters and guidelines identify the following reimbursable
activities:
• Activity 1a – Taking a police report on a violation of PC section 530.5;
• Activity 1b – Reviewing an online identity theft report completed by
a victim; and
• Activity 2 – Beginning an investigation.
City of Rancho Cucamonga Identity Theft Program
The parameters and guidelines specify that Activity 1a “includes drafting,
reviewing, and editing the identity theft police report.”
For convenience, we separated Activity 1a into two sub-activities:
• Activity 1a.1 – Taking a police report; and
• Activity 1a.2 – Reviewing, editing, and approving a police report.
The city claimed the following time increments for Activity 1a.1 during
the audit period:
• 55 minutes for a Deputy Sheriff for FY 2002-03 through FY 2010-11;
• 74 minutes for a Deputy Sheriff for FY 2011-12 and FY 2012-13; and
• 15 minutes for an Office Specialist to provide related clerical support
for FY 2011-12 and FY 2012-13.
The city claimed the following time increments for Activity 1a.2 during
the audit period:
• 12 minutes for a Sergeant for FY 2002-03 through FY 2010-11; and
• 16.5 minutes for a Sergeant for FY 2011-12 and FY 2012-13.
The city claimed 25 minutes for a Deputy Sheriff to perform Activity 2 for
FY 2002-03 through FY 2010-11. It did not claim costs related to this
activity for FY 2011-12 and FY 2012-13.
The city based its time increments for FY 2002-03 through FY 2010-11
on a 2011 phone interview with an SBCSD Sergeant, who estimated the
amount of time required to perform the mandated activities. The city also
included a time log signed on October 9, 2011, by a Service Specialist for
an unspecified activity that took place from March 9 through May 20,
presumably in 2011, although the year is unspecified. The activity is
described only as “PC 530.5,” with time increments ranging from “2” to
“4.5” and no indication whether those are minutes or hours.
For FY 2011-12 and FY 2012-13, an SBCSD Office Specialist estimated
that staff members in the Office Specialist classification spent 15 minutes
per case providing clerical support related to Activity 1a.1 – taking or
editing a police report. In addition, the city conducted a time study in 2012
and provided two summary time logs containing time entries for 16 cases.
The entries were dated from January 5, 2012, through August 21, 2012,
and were completed by various employees performing Activity 1a.1 –
taking or editing a police report and Activity 1a.2 – reviewing and
approving a police report. An SBCSD Office Specialist signed and dated
the summary time log for Activity 1a.1 – taking or editing a police report,
certifying the accuracy of the entries. An SBCSD Sergeant signed and
dated the summary time log for Activity 1a.2 – reviewing and approving
a police report, certifying the accuracy of the results.
However, the city did not provide any contemporaneously prepared
documentation supporting the time log entries, such as the related police
reports or information from the SBCSD’s CAD system. In addition, the
city did not provide a time study plan or any other information explaining
-16-
City of Rancho Cucamonga Identity Theft Program
how it acquired and analyzed this data. Therefore, we could not determine
whether the city based these time entries on actual time or on estimates.
Allowable Time Increments
The county’s CAD system did not record time on Activity 1a.1, taking a
police report on a violation of PC section 530.5; or on Activity 1a.2,
reviewing and approving a police report. We interviewed various SBCSD
employees, who provided testimonial evidence of the approximate time
spent on reimbursable activities not recorded by the CAD system. We
found that this information provided a reasonable representation of the
time needed to perform these reimbursable activities.
For Activity 1a.1, we interviewed three Deputy Sheriffs, three Service
Specialists, and one Sergeant about drafting and editing identity theft
police reports taken by Officers. Based on these interviews, we determined
that SBCSD staff members spent an average of 35 minutes drafting and
editing identity theft police reports taken by SBCSD Deputies.
For Activity 1a.2, we interviewed three Detectives and three Sergeants
about reviewing identity theft police reports. Based on these interviews,
we determined that SBCSD staff members spent an average of 13 minutes
reviewing police reports.
For Activity 2, the SBCSD’s Rancho Cucamonga Patrol Station provided,
at our request, copies of CAD reports for the same police reports that we
sampled for FY 2010-11, FY 2011-12, and FY 2012-13. These reports
provided time stamps detailing when an Officer arrived on scene and
departed, and the time spent on the specific incident. The reports also
identified the employee classification (Deputy Sheriff or Service
Specialist) that performed the activity of beginning an investigation by
interviewing the victim to determine where the crime occurred and what
pieces of personal identifying information were used for an unlawful
purpose. We used these contemporaneously prepared time reports as
support for the time spent on beginning an investigation.
Based on our analysis, we determined the following time increments for
each allowable police report that originated in the City of Rancho
Cucamonga:
• 35 minutes (0.58 hours) for Deputy Sheriffs or Service Specialists to
perform Activity 1a.1 – taking a police report on violations of PC
section 530.5;
• 13 minutes (0.22 hours) for Sergeants to perform Activity 1a.2 –
reviewing and approving a police report; and
• 44 minutes (0.73 hours) for Deputy Sheriffs or Service Specialists to
begin an investigation (Activity 2) for FY 2002-03 through
FY 2009-10, 38 minutes (0.63 hours) for FY 2010-11, 50 minutes
(0.83 hours) for FY 2011-12, and 43 minutes (0.72 hours) for
FY 2012-13.
-17-
City of Rancho Cucamonga Identity Theft Program
The following table summarizes the time increments claimed and
allowable for the reimbursable activities by fiscal year:
-18-
F
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is
22222222222
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AFf
A c tiv ity 1 a .1
T a k in g a
R e p o r t
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0 2 - 0 3 5 5
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0 4 - 0 5 5 5
0 5 - 0 6 5 5
0 6 - 0 7 5 5
0 7 - 0 8 5 5
0 8 - 0 9 5 5
0 9 - 1 0 5 5
1 0 - 1 1 5 5
1 1 - 1 2 7 4
1 2 - 1 3 7 4
s s ta te d in th e n a r r a tiv
Y 2 0 0 2 - 0 3 th r o u g h F Y
o r 2 6 % o f c a s e s f o r F Y
C la im e
A c tiv ity 1 a .1
C le r ic a l
S u p p o r t
O f f ic e
S p e c ia lis t
-
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-
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1 5
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e , D e p u ty S h e r if f
2 0 1 0 - 1 1 , 7 5 % f o
2 0 0 2 - 0 3 th r o u g h
d M in u te s A llo w a b le M in u te
A c tiv ity 1 a .2 A c tiv ity 2 A c tiv ity 1 a .1 A c tiv ity 1 a .2
R e v iw in g a B e g in n in g a n T a k in g a P o lic e R e v iw in g a
P o lic e R e p o r t I n v e s tig a tio n R e p o r t * P o lic e R e p o r t
D e p u ty S h e r if f a n d
S e r g e a n t D e p u ty S h e r if f S e r v ic e S p e c ia lis t S e r g e a n t
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 2 2 5 3 5 1 3
1 6 .5 - 3 5 1 3
1 6 .5 - 3 5 1 3
s to o k p o lic e r e p o r ts a n d b e g a n in v e s ty g a tio n s f o r 7 4 % o f c a s e s d u r in g
r F Y 2 0 1 1 - 1 2 , a n d 7 2 % f o r F Y 2 0 1 2 - 1 3 . S e r v ic e S p e c ia lis ts to o k p o lic e r e p
F Y 2 0 1 0 - 1 1 , 2 5 % f o r F Y 2 0 1 1 - 1 2 , a n d 2 8 % f o r F Y 2 0 1 2 - 1 3 .
s
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A c tiv ity 2
B e g in n in g a n
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ts
Claimed Job Classifications
As noted previously, the city claims for FY 2002-03 through FY 2010-11
included costs for Deputy Sheriffs to perform Activity 1a.1 – taking or
editing a police report, for Sergeants to perform Activity 1a.2 – review and
approve a police report, and for Deputy Sheriffs to perform Activity 2 –
beginning an investigation. The city’s claims for FY 2011-12 and
FY 2012-13 only included costs for Deputy Sheriffs and Office Specialists
to perform Activity 1a.1 and for Sergeants to perform Activity 1a.2.
However, the city did not claim any costs for Activity 2 in its claims for
FY 2011-12 and FY 2012-13.
Allowable Staff
In order to clarify which SBCSD staff members performed the mandated
activities, we:
• Prepared a schedule of the police reports selected for testing;
• Reviewed the police reports for each case to determine the actual
employee classification of the staff member who prepared each report;
and
• Calculated the extent (percentage of involvement) that staff members
in various employee classifications performed the mandated activities
for the sampled identity theft cases.
Although the city claimed time for Deputy Sheriffs, Office Specialists, and
Sergeants to perform the mandated activities, we found that Deputy
Sheriffs and Sheriff Service Specialists prepared and edited police
reports (actions included in Activity 1a.1) and began investigations
(Activity 2). We also found that Sergeants reviewed and approved the
City of Rancho Cucamonga Identity Theft Program
police reports (Activity 1a.2). We based this conclusion on our review of
the copies of the uniform crime reports (police reports) that SBCSD’s
Rancho Cucamonga Patrol station provided for our sample selections of
identity theft cases from FY 2010-11 through FY 2012-13. Using this
information, we analyzed the extent to which staff members in these
employee classifications performed the mandated activities and reached
the following conclusions:
• Sheriff Deputies performed Activity 1a.1 and Activity 2 at an average
of 74% for FY 2002-03 through FY 2010-11, while Service Specialists
averaged 26% performing these activities;
• For FY 2011-12, Sheriff Deputies performed Activity 1a.1 and
Activity 2 at an average of 75%, while Service Specialists averaged
25% performing these activities;
• For FY 2012-13, Sheriff Deputies performed Activity 1a.1 and
Activity 2 at an average of 72%, while Service Specialists averaged
28% performing these activities;
• Sergeants performed 100% of Activity 1a.2 for all years of the audit
period; and
• We found no corroborating evidence that SBCSD Office Specialists
provided clerical support for Activity 1a.1.
Contract Hourly Rates
The city’s claims included copies of its annual contract that it negotiated
with the SBCSD for each year of the audit period. Each contract specifies
the level of service performed for the city, indicating the number of various
employee classifications involved in the city’s law enforcement (the level
of service) and the county’s cost for providing these employees. The
county uses this contract to indicate the authorized SBCSD staffing level
for each year of the audit period. However, none of the contracts identified
the total annual hours per service level. As a result of recalculating contract
hourly rates, we determined that the city used 1,800 annual productive
hours, as specified in the SCO’s Mandated Cost Manual, for all SBCSD
employees.
We used this information to determine the contract hourly billing rates for
various employee classifications by using the total contract cost for each
employee classification divided by the number of personnel that the
county provided. For example, the city’s contract for FY 2012-13 indicates
that 96.75 Deputy Sheriffs (including one Deputy Sheriff who provided
law enforcement services for the city during nine months of FY 2012-13,
or 75 percent of the fiscal year), and 12 Sergeants provided law
enforcement for the city during the year.
The following table shows the contract hourly rate calculation for Deputy
Sheriffs and Sergeants during FY 2012-13:
Employee Annual Level of Cost per Productive Hourly
Classification Cost Service Employee Hours Rate
Deputy Sheriff $ 1 4,351,923 96.75 $ 148,340 1,800 $ 82.41
Sergeant $ 2,250,050 12.00 $ 187,504 1,800 $ 104.17
-19-
City of Rancho Cucamonga Identity Theft Program
The city used the same methodology to calculate hourly billing rates in all
of its claims for the audit period.
The city’s contracts with SBCSD also include additional employee
classifications and items—such as vehicles, dispatch services, and
equipment—that are part of the direct costs incurred to provide law
enforcement for the city. However, the city explained during the audit that
its contracts also include items that are clearly administrative in nature.
During the audit, we discussed with city representatives the issue of
recovering these administrative costs. The city believes that it should be
able to prepare Indirect Cost Rate Proposals to recover these costs.
However, OMB A-87 Office of Management and Budget guidance does
not allow for the recovery of administrative costs using contract services
as a base and classifying the administrative costs as indirect costs. The
administrative costs included within the city’s contracts for law
enforcement services do not fit the definition of indirect costs.
The SCO’s Mandated Cost Manual states that the costs of contract
services are allowable. Costs for contract services can be claimed using an
hourly billing rate. However, the manual does not provide specific
guidance on how to calculate an hourly billing rate. Generally speaking,
an hourly rate for a specific employee classification would be determined
by dividing the contract cost for an individual employee by 1,800 annual
productive hours. However, this approach does not allow claimants to
recover any additional contract costs, such as administrative costs, that
could be reimbursable. For additional guidance, we reviewed law
enforcement service contracts for cities contracting with Los Angeles
County. Having previously audited a number of these cities, we noted that
the county’s billing rates included the costs for various employee
classifications. However, the total costs for those classifications included
salaries and benefits plus an additional “liability percentage,” which was
added to the contract hourly rate at a specific percentage amount. It is our
understanding that this liability percentage covers costs for administrative
items, such as various forms of insurance and amounts for countywide cost
allocation plans. We did not audit these billing rates.
However, San Bernardino County does not structure its contracts this way
and, instead, includes administrative costs and indirect costs as separately
billed line items in its contracts for law enforcement services. In order to
be equitable with other California cities contracting for law enforcement
services, we concluded that it was appropriate to allow the city to claim
costs for line items included in San Bernardino County’s contracts that are
clearly administrative in nature.
We calculated an administrative cost percentage for each fiscal year of the
audit period based on the city’s Law Enforcement Services Contract. To
calculate the percentage, we divided the cost of the following line items
by the total contract cost:
• Administrative support
• Office automation
• Vehicle insurance
• Personnel liability and bonding
-20-
City of Rancho Cucamonga Identity Theft Program
• TRU – Telephone Reporting Unit (FY 2002-03 through FY 2004-05)
• County-wide Cost Allocation Plan (COWCAP) – Administrative and
Indirect Costs
• Board approved COWCAP subsidy (one-time for FY 2012-13 only)
• Startup costs (FY 2002-03 through FY 2009-10)
The following table shows the allowable administrative cost percentage
for each fiscal year during the audit period:
-21-
2
2
2
2
2
2
2
2
2
2
2
F
0
0
0
0
0
0
0
0
0
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0
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0
0
0
0
0
0
0
0
1
1
1
c
2
3
4
5
6
7
8
9
0
1
2
a l Y
- 0 3
- 0 4
- 0 5
- 0 6
- 0 7
- 0 8
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- 1 1
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e a r A d m in is tr a
9
6
5
4
4
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5
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5
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%
%
%
%
%
%
%
%
%
%
%
C o s t R a te
As mentioned previously, we added all of the items within each contract
that we determined to be administrative in nature (based on the
descriptions provided in the contracts) and then divided the total by each
year’s total contract cost to determine the extent that administrative costs
were represented in each year’s contract. The following table shows this
calculation for FY 2012-13:
Cost Contract
Category Amount
Administrative support $ 124,976
Office automation 6 5,223
Vehicle insurance 110,792
Personnel liability & bonding 407,133
Countywide administrative cost plan (COWCAP) 1,270,734
Board approved COWCAP subsidy ( 254,147)
Startup costs 6,987
Total administrative costs $ 1 ,731,698
Divided by total contract amount 2 8,209,685
Administrative cost percentage 6.14%
Therefore, claimed hourly rates for Deputy Sheriffs and Sergeants for
FY 2012-13 increased as follows:
Employee Hourly Administrative Revised
Classification Rate Percentage Rate
Deputy Sheriff $ 82.41 6.14% $ 87.47
Sergeant $ 104.17 6.14% $ 110.57
City of Rancho Cucamonga Identity Theft Program
The following table summarizes the claimed and allowable contract hourly
billing rates for Deputy Sheriffs during the audit period, and the difference
between those rates:
-22-
2
2
2
2
2
2
2
2
2
2
2
F is c a l
Y e a r
0 0 2 - 0 3
0 0 3 - 0 4
0 0 4 - 0 5
0 0 5 - 0 6
0 0 6 - 0 7
0 0 7 - 0 8
0 0 8 - 0 9
0 0 9 - 1 0
0 1 0 - 1 1
0 1 1 - 1 2
0 1 2 - 1 3
D e
C la im e d
H o u r ly
R a te
$ 4 7 .7
4 7 .7
5 8 .5
6 0 .2
6 6 .6
7 0 .3
7 1 .3
6 9 .6
6 9 .6
7 8 .9
8 2 .4
p
2
2
7
8
5
1
1
0
0
8
1
u ty S h e r if f
A llo w a b le
H o u r ly
R a te
$ 4 7 .7
5 1 .1
5 6 .9
6 0 .2
6 6 .6
7 0 .3
7 1 .3
6 9 .6
7 5 .0
7 8 .9
8 2 .4
2
4
7
8
5
0
1
0
3
8
3
R a te
D if f e r e n c e
$ -
3 .4 2
( 1 .6 0
-
-
( 0 .0 1
-
-
5 .4 3
-
0 .0 2
)
)
A d
P
m
e
in
r c
is tr a tiv
e n ta g e
9 .4 5 %
6 .1 8 %
5 .1 8 %
4 .5 6 %
4 .8 6 %
5 .5 1 %
5 .3 9 %
8 .1 9 %
5 .3 3 %
5 .4 2 %
6 .1 4 %
e
R e v is e
H o u r ly
R a te
$ 5 2
5 4
5 9
6 3
6 9
7 4
7 5
7 5
7 9
8 3
8 7
d
.1
.3
.9
.0
.8
.1
.1
.3
.0
.2
.4
0
0
2
3
9
7
5
0
3
6
9
R e v is e d
R a te
D if f e r e n c
$ 4 .3
6 .5
1 .3
2 .7
3 .2
3 .8
3 .8
5 .7
9 .4
4 .2
5 .0
e
8
8
5
5
4
6
4
0
3
8
8
The following table summarizes the claimed and allowable contract hourly
billing rates for Service Specialists during the audit period, and the
difference between those rates:
Service Specialists
Claimed Allowable Revised Revised
Fiscal Hourly Hourly Rate Administrative Hourly Rate
Year Rate Rate Difference Percentage Rate Difference
2002-03 $ - $ 25.81 $ 25.81 9.45% $ 28.25 $ 2.44
2003-04 - 28.25 28.25 6.18% 3 0.00 1 .75
2004-05 - 32.42 32.42 5.18% 34.10 1 .68
2005-06 - 33.13 33.13 4.56% 34.64 1 .51
2006-07 - 34.80 34.80 4.86% 36.49 1 .69
2007-08 - 36.12 36.12 5.51% 38.11 1 .99
2008-09 - 35.18 35.18 5.39% 37.08 1 .90
2009-10 - 34.87 34.87 8.19% 37.73 2 .86
2010-11 - 35.74 35.74 5.33% 37.64 1 .90
2011-12 - 37.16 37.16 5.42% 39.17 2 .01
2012-13 - 38.34 38.34 6.14% 40.69 2 .35
City of Rancho Cucamonga Identity Theft Program
The following table summarizes the claimed and allowable contract hourly
billing rates for Sergeants during the audit period, and the difference
between those rates:
Sergeant
Claimed Allowable Revised Revised
Fiscal Hourly Hourly Rate Administrative Hourly Rate
Year Rate Rate Difference Percentage Rate Difference
2002-03 $ 59.50 $ 59.50 $ - 9.45% $ 63.18 $ 3.68
2003-04 5 9.50 63.52 4 .02 6.18% 67.45 7 .95
2004-05 7 2.80 70.77 (2.03) 5.18% 74.44 1 .64
2005-06 7 8.31 78.31 - 4.56% 81.88 3 .57
2006-07 8 3.83 83.83 - 4.86% 87.90 4 .07
2007-08 8 9.50 89.52 0 .02 5.51% 94.45 4 .95
2008-09 9 1.35 91.35 - 5.39% 96.27 4 .92
2009-10 8 9.44 89.44 - 8.19% 96.77 7 .33
2010-11 8 9.44 96.99 7 .55 5.33% 102.16 12.72
2011-12 101.63 101.63 - 5.42% 107.14 5 .51
2012-13 104.17 104.17 - 6.14% 110.57 6 .40
For the audit period, we calculated allowable contract services costs based
on the audited counts of PC section 530.5 identity theft reports, audited
time increments, audited contract hourly billing rates, and the additional
allowable percentage to allow for administrative costs.
The following table shows the calculation of allowable contract services
costs for FY 2012-13:
-23-
P
T
R
T
B
T
T
E m p lo y e e
C la s s if ic a tio n
r e p a r e a r e p o r t:
D e p u ty S h e r if f
S e r v ic e S p e c ia lis t
o ta l, p r e p a r e a r e p o r t
e v ie w a r e p o r t:
S e r g e a n t
o ta l, r e v ie w a r e p o r t
e g in a n in v e s tig a tio n :
D e p u ty S h e r if f
S e r v ic e S p e c ia lis t
o ta l, b e g in a n in v e s tig a tio n
o ta l a llo w a b le c o n tr a c t s e r v ic e s c o s ts
C o n tr a c t N u m b e r
P H R o f c a s e s M in u te s
[ a ] [ b ] [ c ]
$ 8 7 .4 9 3 0 4 3 5
4 0 .6 9 3 0 4 3 5
1 1 0 .5 7 3 0 4 1 3
$ 8 7 .4 9 3 0 4 4 3
4 0 .6 9 3 0 4 4 3
H o u r s
[ d = ( b * g ) /6 0
1 7 7 .3
1 7 7 .3
6 5 .8
2 1 7 .8
2 1 7 .8
]
33
7
77
A c tiv ity
%[
e ]
7 2 .0 %
2 8 .0 %
1 0 0 .0 %
7 2 .0 %
2 8 .0 %
A llo w a b le
c o s ts
[ f = a * i* k ]
1 1 ,1 7 1
2 ,0 2 0
$ 1 3 ,1 9 1
7 ,2 8 3
$ 7 ,2 8 3
1 3 ,7 2 4
2 ,4 8 2
$ 1 6 ,2 0 6
$ 3 6 ,6 8 1
We performed similar calculations of allowable contract services costs for
all the other fiscal years of the audit period.
City of Rancho Cucamonga Identity Theft Program
Indirect Costs
For the audit period, the city included copies of its Indirect Cost Rate
Proposals with its mandated cost claims. The city claimed related indirect
costs totaling $223,707 for the audit period, based on $276,393 in claimed
salaries. We found that the entire amount is unallowable, because no city
staff member performed any of the reimbursable activities under this
program during the audit period. Instead, the city contracted with the
county to have the SBCSD perform all of its law enforcement services
during the audit period. Therefore, the city did not incur any direct salary
costs or related indirect costs.
Furthermore, none of the costs that the city incurred for law enforcement
services provided by the SBCSD were indirect costs. The parameters and
guidelines (Section V.B., “Indirect Cost Rates”) provide that indirect costs
are “incurred for a common or joint purpose, benefiting more than one
program, and . . . not directly assignable to a particular department or
program.” In this instance, there is only one program (law enforcement
services provided by a contractor) and there are no city departments.
The following table summarizes the claimed, allowable, and audit
adjustment amounts for indirect costs by fiscal year:
(A) (B) (C)=(B)-(A)
Claimed Indirect
Fiscal Salaries Indirect Indirect Costs Audit
Year Claimed Cost Rate Costs 1 Allowable Adjustment
2002-03 $ 27,943 94.00% $ 26,267 $ - $ (26,267)
2003-04 2 8,321 87.70% 24,838 - ( 24,838)
2004-05 3 6,781 80.20% 29,499 - ( 29,499)
2005-06 3 8,796 81.30% 31,542 - ( 31,542)
2006-07 2 4,508 78.80% 19,312 - ( 19,312)
2007-08 1 6,077 79.10% 12,718 - ( 12,718)
2008-09 1 1,675 79.50% 9,282 - (9,282)
2009-10 1 3,283 81.20% 10,786 - ( 10,786)
2010-11 1 7,158 74.00% 12,697 - ( 12,697)
2011-12 2 1,912 74.00% 16,214 - ( 16,214)
2012-13 3 9,938 76.50% 30,552 - ( 30,552)
Total $ 276,392 $ 2 23,707 $ - $ (223,707)
1 Differences in Indirect Costs column are due to rounding.
Criteria
Section III, “Period of Reimbursement,” of the parameters and guidelines
states, “Actual costs for one fiscal year shall be included in each claim.”
Section IV, “Reimbursable Activities,” of the parameters and guidelines
begins:
To be eligible for mandated cost reimbursement for any given 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 to 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
-24-
City of Rancho Cucamonga Identity Theft Program
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 sheet, invoices, and receipts.
Section IV continues:
For each eligible claimant, the following ongoing activities are eligible
for reimbursement:
1. Either a) or b) below:
a) Take a police report supporting a violation of Penal Code
section 530.5 which includes information regarding the
personal identifying information involved and any uses of that
personal information that were non-consensual and for an
unlawful purpose, including, if available, information
surrounding the suspected identity theft, places where the
crime(s) occurred, and how and where the suspect obtained and
used the personal identifying information. This activity
includes drafting, reviewing, and editing the identity theft
police report; or
b) Reviewing the identity theft report completed on-line by the
identity theft victim.
2. Begin an investigation of the facts, including the gathering of facts
sufficient to determine where the crime(s) occurred and what pieces
of personal identifying information were used for an unlawful
purpose. The purpose of the investigation is to assist the victims in
clearing their names. Reimbursement is not required to complete the
investigation for purposes of criminal prosecution.
Providing a copy of the report to the complainant is not reimbursable
under this program.
Referring the matter to the law enforcement agency where the
suspected crime was committed for further investigation of the facts
is also not reimbursable under this program.
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 these
activities.
Section V.B, “Indirect Cost Rates,” of the parameters and guidelines
states, in part:
Indirect costs are costs that are incurred for a common or joint purpose,
benefiting more than one program, and are not directly assignable to a
particular department or program without efforts disproportionate to the
result achieved. Indirect costs may include: (1) the overhead costs of the
unit performing the mandate; and (2) the costs of the central government
services distributed to the other departments based on a systematic and
rational basis through a cost allocation plan.
Compensation for indirect costs is eligible for reimbursement utilizing
the procedure provided in [Title 2, Code of Federal Regulations]
Part 225 (Office of Management and Budget (OMB) Circular A-87).
Claimants have the option of using 10% of labor, excluding fringe
-25-
City of Rancho Cucamonga Identity Theft Program
benefits, or preparing an Indirect Cost Rate Proposal (ICRP) if the
indirect cost rate exceeds 10%.
The SCO’s Mandated Cost Manual (“Filing a Claim,” part 7.3, “Contract
Services”), dated July 1, 2013, states:
The cost of contract services is allowable if the local agency lacks the
staff resources or necessary expertise, or it is economically feasible to
hire a contractor to perform the mandated activity. The claimant must
keep documentation on hand to support the name of the contractor,
explain the reason for having to hire a contractor, describe the mandated
activities performed, give the dates when the activities were performed,
the number of hours spent performing the mandate, the hourly billing
rate, and the total cost. The hourly billing rate must not exceed the rate
specified in the P’s & G’s for the mandated program. The contractor's
invoice or statement must include an itemized list of costs for activities
performed. A copy of the contract must be included with the
submitted claim.
Recommendation
The California State Legislature suspended the Identity Theft Program in
the FY 2013-14 through FY 2022-23 Budget Acts. If the program becomes
active again, we recommend that the city:
• Adhere to the program’s parameters and guidelines and the SCO’s
Mandated Cost Manual when claiming reimbursement for mandated
costs; and
• Ensure that claimed costs include only eligible costs, are based on
actual costs, and are properly supported.
City’s Response
The City of Rancho Cucamonga’s disagreement with the DAR [Draft
Audit Report] findings lies in the denial of various necessary costs within
our contract with the San Bernardino County Sheriff’s Department,
including cost for our administrative command staff (our Police Chief
and departmental supervisory staff), cost for our patrol cars and other
vehicles, cost for our clerical staff, and cost for our city’s share of
dispatch support costs billed by the County.
As you know State mandate law and procedures were created to satisfy
the requirements of Article XIII B of the California Constitution which
state that, “Whenever the Legislature or any state agency mandates a new
program or higher level of service on any local government, the State
shall provide a subvention of funds to reimburse that local government
for the costs of the program or increased level of service.”
Government Code (GC) sections 17500 through 17617 provide for the
reimbursement of costs incurred by local agencies for costs mandated by
the State. Parameters and Guidelines (Ps and Gs) and Claiming
Instructions assure that all actual costs – both direct and indirect related
to the performance of the mandate be reimbursed to local agencies.
It is clear that this audit did not result in a fair reimbursement of those
necessary costs as all that the State Controller’s Office (SCO) staff
recommends for reimbursement is the direct costs of Deputies and
-26-
City of Rancho Cucamonga Identity Theft Program
Sergeants working specifically/directly on mandated activities (salaries
and benefits) plus an average of a 6% “Administrative Allocation Rate.”
We were told the Indirect Cost Rate Proposal (ICRP) or overhead rate
cannot be used because SCO audit staff contends that indirect costs are
not eligible for reimbursement in our situation. Our situation being that
we are a city that contracts for law enforcement services and that our
service provider, San Bernardino County Sheriff’s Department
(SBCSD), charges us for overhead costs on a detailed basis within our
contract; thus, making it impossible according to SCO audit staff, for us
to use the existing Indirect Cost Rate Proposal (ICRP) methodology
prescribed in claiming instructions, claiming manuals and the Federal
CFR/OMB guidelines to compute an overhead rate as other local
agencies can.
SCO staff stated in the audit that they were sympathetic to our plight of
not being able to recover any overhead costs, so they created a new
methodology they named the “Administrative Cost Rate” (we’ll refer to
this new type of rate as the “ACR”) to allow the recovery of some costs
that they could identify as “clearly administrative” in nature. Thus,
instead of allowing us the overhead rates that would have been allowed
under existing Ps and Gs and Claiming Instructions which averaged
about 70%, we were granted the “ACR” rate that averaged about 6%.
The primary activity that this State mandate program requires is that law
enforcement personnel take an Identity Theft Report and begin an
investigation of the facts, including the gathering of facts sufficient to
determine where the crime(s) occurred and what pieces of personal
identifying information were used for an unlawful purpose.
We agreed that this activity was performed by the Deputy Sheriff
positions we pay for through our contract with the San Bernardino
County Sheriff’s Department (SBCSD). The City has no in-house Police
Department other than the one it has purchased through its contract with
the SBCSD. This contract includes all direct sworn staff, indirect support
and administrative personnel, and overhead costs – such as vehicle
expenses, and other costs associated with operating a police department.
Schedule A of our contract lists all costs charged in detail by type of cost
- similar to how a full- service city would account for these costs in an
expenditure report.
SCO audit staff determined that the direct costs incurred through our
contract -- the salary and benefits costs of the Deputies we purchase
though our contract for service with the San Bernardino County Sheriff’s
Department (SBCSD) positions -- were eligible for reimbursement,
however, not the vast majority of other necessary overhead costs billed
within that contract. For example:
The mandate requires that our Deputy drive to the scene to take a report
from the victim – yet SCO audit findings include no reimbursement of
costs for the actual vehicles, fuel, and maintenance. A Deputy needs a
vehicle to perform their law enforcement duties. Our Deputy would not
be able to perform the mandate as they typically drive to the victim’s
location to take their Identity Theft Reports. This is a reasonable and
necessary cost to perform the mandate, yet the DAR findings only allow
costs for vehicle insurance but omit the cost of the vehicles themselves.
The mandate requires that our communications/dispatch staff transmit
information about the call for service to the Deputy so that they are aware
-27-
City of Rancho Cucamonga Identity Theft Program
of what the nature of the call is and where the victim is located. Yet SCO
staff reimbursement allows for no dispatch/communications staff to take
the phone calls from the public and relay the request for service to the
sworn Deputies who perform the direct law mandated enforcement
duties.
The mandate requires that the Identity Theft report be typed, entered, and
maintained in our records and computer system – yet there is no
allotment of costs to reimburse us for the clerical personnel to do this
activity that is required as a result of this mandate.
The mandate requires employment of sworn personnel to perform this
activity. In order for an agency to provide sworn staff, it must supervise
them and provide administrative support; yet no departmental support
costs such as our departmental command staff costs were allowed
(including our Captain, who functions as our Department’s Police Chief,
his Lieutenant or second-in-command, or administrative time of
Sergeants who are the first line supervisors).
It is clear that the Audit Report Findings are not reasonable, nor would
they satisfy the intent of the State or Federal laws and guidelines. No
reasonable person would agree that a Deputy could perform their law
enforcement duties or perform the mandated activities without a vehicle,
administrative/command staff support, or clerical and dispatch service
support.
City staff and our consultant have spent many hours and numerous
correspondences back and forth trying to resolve this issue. However, to
avoid this correspondence from becoming overly lengthy or repetitive,
we will only touch on a few main points in this response, and will include
our past communications as an attachment to our future Incorrect
Reduction Claim (IRC) to serve as back up and to provide greater detail
to the Commission on State Mandates (Commission) when they review
this matter.
CLARITY, DISCLOSURE, AND TRANSPARENCY IS NEEDED
FROM THE SCO AND CLAIMING INSTRUCTIONS TO
EXPLAIN WHICH ENTITY IS ELIGIBLE TO CLAIM WHAT
REIMBURSABLE COST
[The Audit Manager’s] May 12, 2023 email attempts to explain to us
why the indirect costs/ICRP costs we incurred are not eligible for
reimbursement: “Those [our contract] salary and benefit costs belong
solely to San Bernardino County, not the City of Rancho Cucamonga.”
And “Just because the county incurs indirect costs and bills the city for
them does not mean that these are also indirect costs incurred by Rancho
Cucamonga.”
It appears that the crux of the argument to deny our city (and if audit
precedent applies, all contract cities) law enforcement overhead costs is
because SCO staff believes that technically the contracting entity (in this
case San Bernardino County Sheriff’s Department or SBCSD) whose
employees perform the administrative and support tasks paid for in our
contract [in our case the Captains, Lieutenants, Sergeants, Office
Specialists, Secretaries, etc.] and support costs [such as vehicles, walkie-
talkies, dispatch center charges, etc.] don’t “belong” to us (the city who
contracts for and pays for them) -- but to the agency that “provides” those
personnel and services.
-28-
City of Rancho Cucamonga Identity Theft Program
It was our understanding (and common accounting practice), that if you
bought and paid for something (if you “incurred” that cost), then that
cost/product becomes “yours”, and that the agency “incurring” the costs
should be the one to claim for State Reimbursement since you were the
agency that ultimately “lost” that money from your budget to pay for the
State Mandate program.
Since both direct and indirect costs are all a part of the same contract
with SBCSD then it would stand to reason that both types of costs would
be treated consistently – either the city is eligible to claim and receive
reimbursement for both – or neither.
However, Page 24 of the Draft Audit Report states, “We found that the
entire amount [of indirect costs claimed] is unallowable because no
city staff member performed any of the reimbursable activities…”
How can this logic hold: that indirect costs are somehow not allowable
“because no city staff member performed any of the reimbursable
activities”, when the opposite conclusion was arrived at regarding direct
costs and activities. SCO Audit allows reimbursement for the direct
contract staff performed by SBCSD Deputies and Sergeants, even
though those positions are also not “city staff members” and their costs
are charged and incurred through the same exact contract.
When the city requested clarification, [The Audit Manager’s] May 12,
2023 email response explains, “the city did not incur any indirect
overhead costs within its contract with San Bernardino County”.
Then he goes on to say, seemingly contradicting himself, “[j]ust
because the county incurs indirect costs and bills the city for them
doesn’t mean that these are also indirect costs incurred by Rancho
Cucamonga.”
How does this make sense? SCO staff agrees that the costs are indirect
when they “belonged” to the County; but if the county who incurs those
indirect costs, bills the city for them, then they are no longer indirect
costs or costs “incurred” by the city?
If contract cities do not “incur” indirect costs and cannot claim indirect
costs billed within their contracts – does this mean that the counties that
provide/incur those cost are eligible for the reimbursement of those
costs? In this case, would SBCSD receive reimbursement for those
costs?
Prior State Controller audits have found this is not the case. The
following is a quote from page 19 of the SCO’s June 2022 audit of San
Bernardino County’s Interagency Child Abuse and Neglect Investigation
Reports (ICAN)):
“…we [SCO] found that the county included costs for providing
services to contract cities as part of its mandated cost claims for
all activities. The parameters and guidelines state that any
county, city, or city and county is eligible to submit a mandate
reimbursement claim. Therefore, all counties and cities—
including contract cities—are eligible to submit mandate
reimbursement claims. Because contract cities are eligible to
submit reimbursement claims, and the county received fees for
law enforcement services from its contract cities, we
determined that the county should only claim costs associated
with the unincorporated areas of the county. We determined
-29-
City of Rancho Cucamonga Identity Theft Program
that the costs incurred by contract cities are unallowable
because the county had already been compensated by contract
fees. The county did not report offsetting reimbursements for
the contract city cases in its mandated cost claims. Therefore,
we found that the county overstated these claimed costs because
it did not offset costs that were funded by other sources.”
This audit is not unique. There are numerous other audits of county law
enforcement claims where the SCO comes to the same conclusion: that
the contracting entity - the city, not the county -- is eligible to request or
receive reimbursement of mandated costs because those costs are
incurred/paid for by the contracting cities. A sampling of other similar
audits includes San Bernardino County April 2022, Identity Theft
Program, Los Angeles County September 2019, Crime Statists Reports
for the Department of Justice Program, and Los Angeles County
November 2019, Domestic Violence Arrest Policies and Standards
Program.
So, which is it? Who is entitled to claim the costs –the city that pays for
the service, or the county that provides the service? Based on this audit
analysis, neither the contract city nor the county would be able to obtain
reimbursement of indirect costs charged to cities.
State instructions say indirect costs that are incurred by the agency
incurring the direct costs are to submit the claims for reimbursement. The
SCO requirement that “a city staff member perform reimbursable
activities” in order to obtain reimbursement of both direct and indirect
costs is contrary to the plain language of the Ps & Gs and would mean
that no contract city would be able to obtain reimbursement for mandate
overhead costs.
Since counties did not receive any State Mandate reimbursement for
indirect costs that were paid for via city contracts and now this Audit
indicates that contracting cities cannot claim for the indirect costs, this
creates a loophole where only the State gains unfairly by not having to
pay either party for those State Mandated costs. Claimants deserve clear,
written guidelines/instructions provided to them prior to claim
preparation and submission, and consistent treatment/interpretation of
those rules. The State Controller’s Office cannot use different metrics
and methodologies from audit to audit.
DID THESE ISSUES ARISE DUE TO A DEFICIENCY IN STATE
CLAIMING FORMS?
Early in this audit in August of 2022, SCO auditor, [name redacted],
issued her first set of findings which stated that indirect costs could not
be claimed because the Claiming Instructions “Form 1” and “Form 2”
precluded reimbursement of indirect costs because those forms
“differentiate contract services” from salaries or (direct labor) for
purposes of calculating indirect costs.”
Our responds to this was if the SCO didn’t like the way forms looked or
how costs were displayed or presented on those forms, that they had the
authority to format the forms to their liking. However, having an issue
with form format or how costs should be presented/displayed was not a
legitimate reason for the SCO to ignore the underlying principles and
direction of the Parameters and Guidelines and Claiming Instructions
and deny reimbursement of eligible costs.
-30-
City of Rancho Cucamonga Identity Theft Program
SCO audit report on page 20 notes that “The SCO’s Mandated Cost
Manual states that costs of contract services are allowable. Costs for
contract services can be claimed using an hourly billing rate.” However,
the Manual does not provide specific guidelines on how to calculate an
hourly billing rate.
The issue in this audit was not how direct salary costs were computed.
The City of Rancho Cucamonga used the prescribed method allowed in
instructions by dividing total salaries and benefits by 1,800 annual
productive hours – which the SCO auditor agreed was appropriate.
The issue was how the indirect cost component should be calculated.
[The Audit Manager] informed us in his January 5th email that “[o]ur
position has always been that using the A-87 methodology contained in
Subpart E to claim administrative costs using contract services as a base
is a non-starter for our office.” And in the May 13th email, “Indirect costs
cannot be claimed against contract services.”
Our consultant provided him with evidence that this was not the case
citing the 2017 City of San Marcos Crime Statistics Reporting Audit.
In the City of San Marcos audit (which contracts with the San Diego
Sheriff’s Office (SDSO) for law enforcement services, the following
indirect costs were allowed (See City of San Marcos 2017 – Crime
Statistics Reporting Audit Report on page 23). State Controller’s Office
auditors recognized there were additional indirect/overhead costs and
those costs were allowed as valid overhead charges. Below is an extract
from the Audit Report on page 23 that addressed the Contract Indirect
Costs:
“Contract Indirect Costs
We reviewed the contract agreements between the city and the
SDSO. For FY 2007-08 through FY 2011-12, the SDSO
contract agreements provided schedules and identified
supplemental contracted labor costs and contracted overhead
costs. We determined that overhead costs identified in the
contract were appropriate as they related to the performance of
mandated activities. We computed indirect cost rates for
contract services for these years by dividing total contract
overhead costs, station support staff costs, and Sergeant Admin
position costs, by the contracted labor costs identified in the
contract supplemental schedules.”
In the allowable ICRP/ “contract overhead costs”, the audit
permitted:
1) proration of support/admin costs including Station Level
Staff Support including: Captain, Admin Secretary, Lieutenant,
Sergeants, Volunteer Coordinator, Senior Clerk, Department
Aide, Receptionist, Intermediate Clerk.
3) Law Enforcement Support including Station Detectives,
Communication Center (Central Dispatch support), Crime
Prevention, Juvenile Intervention, Regional Services
4) Services and Supplies Costs
5) Support Costs including Vehicles, Facilities/Space, County
Management Support (Admin, Fiscal, Data Services, Personnel
& Other)
6) Liability (charged separately)
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City of Rancho Cucamonga Identity Theft Program
The items we included in our ICRP are all similar, if not identical items:
Administrative support, such as Captains, Lieutenants, and Sergeants;
Clerical support; Vehicles; and Communication Center (Central
Dispatch Services, etc.) but in our case they were NOT allowed as
indirect costs.
In addition, in the case of San Marcos’ Audit, the prescribed ICRP
format/computational methodology was employed; using contract
salaries and benefits as the denominator for determining the overhead
rate, and not total contract costs as the SCO uses in their new “ACR”
methodology rate computation.
Please explain why Rancho Cucamonga is being treated differently and
why the interpretations and methodologies are different for two similar
contract cities.
EXISTING PARAMETERS AND GUIDELINES AND CLAIMING
INSTRUCTIONS PERMIT CITIES THAT CONTRACT FOR
LAW ENFORCEMENT SERVICES TO OBTAIN
REIMBURSEMENT FOR THEIR FULL INDIRECT COSTS AS
DEFINED UNDER FEDERAL CFR/OMB STANDARDS.
Existing claiming instructions and claiming manuals under Contract
Services state that “all costs charged” can be claimed.
Identity Theft Claiming Instructions
Section V. A. 3. Contracted Services:
“Report the name of the contractor and services performed to
implement the reimbursable activities and attach a copy of the
contract to the claim. If the contractor bills for time and
materials, report the number of hours spent on the activities and
all costs charged. If the contract is a fixed price, report the
dates when services were performed and itemize all costs for
those services during the period covered by the reimbursement
claim. If the contract services were also used for purposes other
than the reimbursable activities, only the pro-rata portion of the
services used to implement the reimbursable activities can be
claimed. Submit contract consultant and invoices with the claim
and a description of the contract scope of services.”
The Claiming Manual adds that the claimant should provide: “… the
mandated activities performed, the number of hours spent performing the
mandate, the hourly billing rate, and the total cost.”
The City complied with these instructions and provided a copy of the
contract and detailed costs related to the reimbursable activities, time
studies to show number of hours spent performing the mandate, the
hourly billing rates – including how direct and indirect/overhead costs
were computed. We accounted for all costs charged. Total costs include
the necessary overhead [vehicles, dispatch support, command staff,
clerical staff, etc.] to perform the mandated activities.
There is nothing in the Ps and Gs, Claiming Instructions, or the Claiming
Manual that would suggest that the Commission intended that cities that
contract for law enforcement would not be eligible for indirect costs or
that contract cities would have to use a different set of rules or standards
to compute allowable indirect costs. We see nothing that would indicate
that Federal CFR/OMB guidelines would not apply.
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City of Rancho Cucamonga Identity Theft Program
USE OF A NEW METHODOLOGY TO COMPUTE
OVERHEAD/ICRP COSTS IS NOT SUPPORTED BY CLAIMING
INSTRUCTIONS, PARAMETERS AND GUIDELINES, OR THE
CLAIMING MANUAL
In our correspondence, SCO staff provided many reasons why our
Indirect Cost Rate Proposals (ICRPs) – rates derived using the exact
format and guidelines prescribed by the Claiming Manual, Parameters
and Guidelines, and in compliance with Federal CRF Guidelines - could
not be used and instead why audit staff had to create and apply a new
alternate methodology and format to compute indirect costs, which you
have entitled: “The Allowable Administrative Percentage” or the
“Administrative Cost Rate” (see page 21 of SCO Draft Audit Report).
One of the issues with this “new methodology” is that it does not allow
for the inclusion of all the costs that would have been allowable under
existing claiming instructions and Federal CFR/OMB Guidelines. Cost
such as vehicle usage costs, command staff administrative costs,
secretarial support, etc. [The Audit Manager] tried to explain why
CFR/OMB Guidelines do not apply, but his explanations do not seem to
be grounded in established written guidelines. Denying that existing
written rules apply and then creating and applying new, unwritten
methodologies without any prior notice or explanation in fact creates
new rules that have not been vetted by the Commission and other
interested parties.
Page 20 of the Audit narrative explains that this new methodology
developed by the SCO’s staff, the “Administrative Cost Percentage,”
was calculated by…dividing the costs of the following items
“Administrative Support, Office Automation, Services and Supplies,
Vehicle Insurance, Personnel Liability and Bonding, Telephone
Reporting Unit, County Administrative Cost (COWCAP), COWCAP
subsidy, and Start-up Costs” by the total contract cost.
Claiming Instructions pages 4-5 and the Claiming Manual on pages
11-12 states:
A. Indirect Cost Rate Proposal Method
If a local agency elects not to utilize the 10% fixed rate
method but wants to claim indirect costs, it must
prepare an ICRP for the program. The proposal must
follow the provisions of the OMB Circular 2 CFR,
Chapter I and Chapter II, Part 200 et al., formerly OMB
Circular A-87, Cost Principles for State, Local, and Indian
Tribal Governments. The development of the indirect cost
rate proposal requires that the indirect cost pool include
only those costs which are incurred for a common or joint
purpose that benefit more than one cost objective. The
indirect cost pool may include only costs that can be
shown to provide benefits to the program. In addition,
total allocable indirect costs may include only costs that
cannot be directly charged to an identifiable cost center
(i.e., program).
A method for preparing a departmental indirect cost
rate proposal for programs is presented as Table 6.
Only this format is acceptable under the SCO
reimbursement requirements. If more than one
department is involved in the reimbursement program,
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City of Rancho Cucamonga Identity Theft Program
each department must have its own indirect cost rate
proposal for the program.
We followed these rules and guidelines in preparing overhead/ICRP
rates, and find no language in the Claiming Manual, the Claiming
Instructions, Parameters and Guidelines, or Federal CFR Guidelines to
describe or support SCO staff’s alternate and newly created
“Administrative Cost Percentage” method of computing overhead costs.
There is no distinction made in the instructions or alternate methodology
described for cities that contract for law enforcement services.
There is no reason why the existing instructions and ICRP format
presented in Table 6 of the Claiming Manual cannot be used and that
would necessitate the creation of an alternate indirect cost rate
methodology (as we have demonstrated by preparing and submitted
ICRPs in the required format with our claims – and numerous other
contract city claims - over the last twenty years with no issue). Our law
enforcement contract with SBCSD (See Schedule A) clearly lists and
segregates all direct and indirect costs in a level of detail which is similar
to how a full-service city’s Actual Expenditure Report is organized and
how the example in Table 6 is presented.
This new approach proposed by staff is flawed in a number of aspects.
First, and most importantly, it is not described in any manual or
instructions provided to us at the time of filing of these claims. How is a
local agency expected to be able to compute allowable overhead costs
correctly and in a consistent, uniform manner if those methods and
guidelines are not described or provided in advance in any documents or
manuals? Why are there different rules of eligibility for determining
indirect costs for contract cities?
Creating a new procedure and methodology, after the fact, without any
notice to local agencies or review by the Commission on State Mandates
violates Due Process guidelines and has not been properly vetted through
the State’s required procedures. In addition, by creating a new
methodology just for agencies that contract for Law Enforcement
Services and saying they are not entitled to use the same, existing
Instructions and Parameters and Guidelines constitutes “Underground
Rule Making”. We request that you comply with written Claiming
Instructions and Guidelines and use the same ICRP methodology
prescribed in the existing Parameters and Guidelines and the Federal
CFR/OMB standards to audit our claims’ overhead rates.
Secondly, SCO’s new “Allowable Administrative Cost Percentage” or
“Administrative Cost Rate” methodology which uses total contract
services costs as the denominator instead of salaries and wages, is flawed
because it does NOT exclude capital expenditures (see all the equipment
usage charges in our contract) and other distorting items such as pass-
through funds (See Countywide Cost Allocation or COWCAP costs in
the contract).
The Claiming Manual states:
“The distributions base may be: (1) total direct costs (excluding
capital expenditures and other distorting items, such as pass-
through funds, major subcontracts, etc.); (2) direct salaries and
wages; or (3) another base which results in an equitable
distribution.
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City of Rancho Cucamonga Identity Theft Program
Claiming Manual, Section 8. Indirect Costs (Example)
“ f) Distribution base for the computation of the indirect cost
rate is total salaries and wages.
ICRP = Allowable
Indirect Costs = $300,000 = 30.00%
Total Salaries and Wages $1,000,000
The contract with SBCSD itemized salaries and benefits separately, so
there is no reason why this could not have been used as the base for
distributing indirect costs as is required in the Claiming Instructions.
The “administrative cost rate” methodology proposed appears to
contradict SCO Audit’s own statements on page 20 which says,
“OMB-A-87… does not allow for the recovery of administrative costs
using contract services as a base”. Yet it appears that is exactly what
SCO staff’s newly created “ACR” “rate” does. Page 21 of the Audit
report states, “…we divided the cost of the following line
items…[administrative support, office automation, etc.] that we
identified as being “clearly administrative” by the “total contract
amount”.
We thought using total contract costs as a base not allowed. Our rate was
prepared using total actual salaries and benefits, as specified in the
instructions.
FY 2012-13 Rate Comparison
City computed ICRP = $12,167,160 = Total Allowable Indirect Costs = 76.5%
$15,907,114 Total Direct Salaries & Benefits
SCO computed “ACR” = $1,731,698, = Total “Allowable Admin. Costs” = 6.1%
$28,209,685 TOTAL CONTRACT SERVICE AMOUNT
SCO JUSTIFICATION FOR DENYING INDIRECT COSTS ARE
FLAWED
We agree with SCO staff’s statement that there are clearly
administrative costs in the contract, but why didn’t you include our
administrative command and clerical staff, who are clearly
administrative and clerical, in SCO’s version of the ICRP or their
“Administrative Cost Rate”?
2 CFR Ch. II Part 200 Appendix IV:
(4) General administration and general expenses. The expenses
under this heading are those that have been incurred for the
overall general executive and administrative offices of the
organization and other expenses of a general nature which do
not relate solely to any major function of the organization. This
category must also include its allocable share of fringe benefit
costs, operation and maintenance expense, depreciation, and
interest costs. Examples of this category include central offices,
such as the director’s office, the office of finance, business
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City of Rancho Cucamonga Identity Theft Program
services, budget and planning, personnel, safety and risk
management, general counsel, management information
systems, and library costs.
2 CFR Ch. II
“The salaries and wages of administrative and pooled clerical
staff should normally be treated as indirect costs. Direct
charging of these costs may be appropriate where a major
project or activity explicitly requires and budgets for
administrative or clerical services and other individuals
involved can be identified with the program or activity.”
Command/administrative staff. Can you please explain why none of
our command staff costs, including our Captain, who is our city’s Police
Chief; the Lieutenants who oversee administration and operations of the
entire unit; and our Sergeants, who are the first line supervisors of the
Deputies; were not included in SCO overhead rate computations? These
staff perform the “executive and administrative” functions of the
department.
Every Deputy requires command staff oversight – supervisors must
perform annual reviews of employee performance, deal with disciplinary
issues, decide on pay increases, schedule time off and ensure there is
always adequate coverage and staffing, perform department budgeting
functions, schedule training, offer guidance and support on difficult
cases, etc. In prior correspondence we provided copies of the job
descriptions for these positions so you can confirm that their duties are
indeed administrative and necessary support to the entire department.
(https://www.governmentjobs.com/careers/sanbernardino/promotionalj
obs)
1) Captain – serves as our department Police Chief. The job
description for this position (attached) states under “Distinguishing
Characteristics: Sheriff’s Captain is characterized by the
administrative responsibility for an assigned major division, facility
or station.”
2) Lieutenant - is also an administrative position, whose job description
states, “Positions in this class are characterized by their status as
second in command with authority to assume full administrative and
supervisory responsibilities during the absence of the commanding
officer.”
3) Sergeants - “The class of Sheriff’s Sergeant represents the first full
level of supervision.”
Clerical staff all are costs incurred for a common or joint purpose
(supporting the entire department and law enforcement staff), and they
provide necessary administrative, supervisory and clerical support that is
necessary to operate a police department. They provide benefits to more
than one cost objective, benefit the program, and cannot be directly
charged to an identifiable cost center (i.e., program). Secretaries and
dispatchers don’t provide direct law enforcement service. 2 CFR Ch. II
§200.414 (c) specifically identifies clerical staff as an administrative
cost: The salaries of administrative and clerical staff should normally
be treated as indirect (F&A) costs.”
OMB/CFR guidelines also specify that clerical staff are a part of the
administrative function. Thus, our Secretaries, Office Specialists, and
Supervising Office Specialists should have also been included in the
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City of Rancho Cucamonga Identity Theft Program
SCO computation as they provide necessary clerical support to the
department. Please explain the rational for excluding these necessary
clerical staff both directly and indirectly from our claims.
How are these positions not administrative? Except for a portion of the
Sergeant positions (who review and approve Identity Theft reports
directly), these individuals are not providing direct law enforcement
services, but supporting and administering the department. These
positions oversee not just one program, but the entire law enforcement
department and all staff. This is no different from the function of
command staff in a full-service (non-contracting city) which the SCO
office has routinely allowed to be included in the computation of their
overhead rates. These same positions were allowed by the SCO in the
SBCSD’s audited Identity Theft claims overhead ICRP rates.
We previously provided SCO staff with the full job descriptions for these
positions to support our contention that these are administrative positions
that support the entire department (and not just one program) and are
necessary administrative support to the entire department. Your staff
declined numerous offers to schedule a meeting with county command
staff to answer any questions your staff may have about these positions’
duties so they could feel confident that these positions do indeed perform
eligible administrative functions that support the entire department.
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City of Rancho Cucamonga Identity Theft Program
Below we have provided the citation from Federal 2 CFR Part 225
Guideline that supports allowability of the indirect costs the City of
Rancho Cucamonga incurred through our contract with SBCSD – not
just the eight items SCO staff included in their “ACR” rate:
Contract Cost Items NOT Included by Federal CFR Citation supporting the allowability
SCO as allowable Indirect cost of the cost
Captain, Lieutenant, Sergeants 2 CFR Ch. II §200.414 (c) ”The salaries of administrative and
clerical staff should normally be treated as indirect (F&A) costs.”
2 CFR Ch. II Pt. 200, App. IV B. ALLOCATION OF INDIRECT
COSTS AND DETERMINATION OF INDIRECT COST RATES
The salaries and wages of administrative and pooled clerical staff
should normally be treated as indirect costs. Direct charging of
these costs may be appropriate where a major project or activity
explicitly requires and budgets for administrative or clerical
services and other individuals involved can be identified with the
program or activity.
Office Specialists & Secretaries 2 CFR Ch. II §200.414 (c) ”The salaries of administrative and
clerical staff should normally be treated as indirect (F&A)
costs.” (See additional narrative above)
Dispatch Support Appendix B to Part 225—Selected Items of Cost
7. Communication costs. Costs incurred for telephone services, local
and long distance telephone calls, telegrams, postage, messenger,
electronic or computer transmittal services and the like are allowable.
[the County charges a share of the dispatch/communications division
costs with contracting cities]
Also see above- 2 CFR Ch. II Pt. 200, App. IV B. ALLOCATION OF
INDIRECT COSTS AND DETERMINATION OF INDIRECT COST RATES
The salaries and wages of administrative and pooled clerical staff
should normally be treated as indirect costs.
Vehicle Usage Charges: Multiple Sections of OMB/CFR Guidelines address
eligibility of equipment charges and usage:
Marked units, Unmarked Units, Marked Citizen
Patrol Sedan, Pickup Trucks, & Motorcycles
Appendix B to Part 225—Selected Items of Cost
11. Depreciation and use allowances. a) use allowances are
means of allocating the cost of fixed assets to periods benefiting
Also, Handheld Talkies (HTs), Radar Units, Tasers
from asset use.
Compensation for the use of fixed assets on hand may be made
through depreciation or use allowances. A combination of the
two methods may not be used in connection with a single class of
fixed assets (e.g., buildings, office equipment, computer
equipment, etc.)
15. Equipment and other capital expenditures.
(2)‘‘Equipment’’ means an article of nonexpendable, tangible
personal property having a useful life of more than one year and
an acquisition cost which equals or exceeds the lesser of the
capitalization level established by the governmental unit for
financial statement purposes, or $5000.
43. Travel costs.
a. General. Travel costs are the expenses for transportation,
lodging, subsistence, and related items incurred by employees
who are in travel status on official business of the governmental
unit. Such costs may be charged on an actual cost basis, on a per
diem or mileage basis in lieu of actual costs incurred,
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City of Rancho Cucamonga Identity Theft Program
OTHER ALLOWABLE AND NECESSARY SUPPORT COSTS
PURSUANT TO CFR / OMB
2 CFR §200.403 Factors affecting allowability of costs.
Except where otherwise authorized by statute, costs must meet
the following general criteria in order to be allowable under
Federal awards:
Be necessary and reasonable for the performance of the Federal
award and be allocable thereto under these principles
CFR Guidelines do not limit indirect costs to only “administrative”
items. The language is written broadly to take various programs into
account. For example, if a “program” requires waste pick up and disposal
(like in the Los Angeles County Municipal Storm Water Claim), then in
addition to the direct costs of staff who do the waste pickups, the
departmental support and equipment usage (garbage truck usage costs),
would be considered necessary and reasonable and allowable in the
overhead rate.
Similarly, in a mandate that requires “law enforcement” services – then
the departmental costs that are needed to ensure a Deputy can provide
law enforcement services are eligible for inclusion in the overhead rate.
Those eligible overhead costs include:
Necessary Support Costs
Without vehicles, radios, and dispatch services the Deputies could not
provide law enforcement services. They could not receive any calls for
service or communicate with either the public or with the department
command staff; they could not drive to the scene of any call for service;
and there would be no clerical support to process, store, and access any
of the police reports (including these mandated Identity Theft Reports)
and records as required by law. No law enforcement agency could
function without these support functions.
SCO ACTIONS TO DENY APPLICABILITY OF OMB/CFR
GUIDELINES AND ESTABLISH NEW CLAIMING
METHODOLOGIES (Administrative Cost Rates in lieu of Indirect
Cost Rates) CONSTITUTES UNDERGROUND RULE MAKING.
If it is the SCO’s position that in order for a contracting city to be able to
obtain full reimbursement of all direct and indirect overhead costs, a
County Sheriff’s Department MUST show a billable rate that includes
all overhead in its direct staff’s (Deputy Rate) cost – then shouldn’t that
be stated very clearly somewhere in the instructions? It would be very
easy for the SBCSD to alter their format and show all charged costs in
the direct staff/Deputy Rate, similar to how Los Angeles County does.
Since SCO staff interpretation makes a very material difference in
reimbursement amounts – this should have been very explicitly stated in
the claiming manuals and instructions. By having our costs presented by
San Bernardino County individually vs. aggregately, as Los Angeles
County did, we stand to be denied over $200,000 in indirect costs which
would have been eligible if we were allowed to use existing claiming
instructions and OMB/CFR guidelines.
Local agencies which contract for law enforcement services have been
claiming overhead costs computed based on OMB/CFR standards for
over 25 years now with no issue, but suddenly this has become a new
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City of Rancho Cucamonga Identity Theft Program
avenue for SCO staff to think it is a legitimate way of cutting State costs.
SCO appears to be making up rules as you go and doing so inconsistently
for that matter from audit to audit.
In the SCO’s audits of Los Angeles County contract cities, overhead
costs built into the Deputy hourly rates (as well as liability charges) were
allowed. In the SCO audit of San Marcos (San Diego County Sheriff
contracting agency) most overhead costs were allowed and computed
“using contract services costs improperly identified as salaries and
benefits as a base for claiming indirect costs” – the exact same method
we used and that you are now saying is invalid. Each of these audits show
inconsistent treatment of overhead costs in cities that contract for law
enforcement services and failure to adhere to written State and Federal
instructions and guidelines.
The DAR states (on page 20) that the SCO acknowledged that different
counties include different costs in their rates – for example, Los Angeles
(LA) County contract cities include overhead in their hourly billing rates,
plus a percentage for insurance and liability charges. SCO narrative
stated the desire to “be equitable with other California cities contracting
for law enforcement services” so allowed us an average 6%
“administrative cost rate”. However, that “ACR” rate is vastly lower than
what the true ICRP rate prepared in compliance with CFR/OMB standard
(76.5% for FY 12-13) would have been. It is evident from the table below
how “fair” the “administrative allocation rate” is.
SCO approved rate for LA County contract cities was $124/hour vs.
$87/hour for us and other contract cities in San Bernardino County, a rate
that is substantially lower than was approved for cities in LA County and
even more than the city of Rialto (a comparable full-service city in our
same county).
FY 2012-13 Deputy Sheriff Hourly Rate Comparison
LA COUNTY CONTRACT CITIES HOURLY RATE
CITY REQUESTED* $136.40*
(Including additional 10% overhead requested, but denied by SCO) *
LA COUNTY CONTRACT CITIES AUDITED SCO HOURLY
RATE $124.00*
SCO APPROVED*
SAN BERNARDINO COUNTY CONTRACT CITIES HOURLY
RATE $145.45
CITY REQUESTED
(including “ICRP/OMB A-87” rate)
CITY OF RIALTO AUDITED OFFICER HOURLY RATE
SCO APPROVED** $126.84**
(including “ICRP/OMB A-87” rate)
SAN BERNARDINO COUNTY CONTRACT CITIES SCO
HOURLY RATE SCO RECOMMENDED PER PRELIM. AUDIT $87.47
REPORT
(including SCO new “ACR” Rate)
*See City of West Hollywood Identity Theft Audit and City of Palmdale Child Abuse and Neglect Audits
**This is the FY 11-12 SCO Officer audited hourly rate for the City of Rialto, a full-service city in the same
county.
These hourly rates were computed in the following manner – first, just
as SCO staff computed them on page 21 of the SCO DAR, and, second,
just as we computed for the claims we originally submitted.
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City of Rancho Cucamonga Identity Theft Program
FY 2012-13: Billable Hourly Rate Computation for the San Bernardino
County Deputy Sheriff:
SCO Allowed Hourly Billing Rate using SCO created
“Administrative Cost Rate” (ACR)
FY 12-13 based rate with only salaries and benefits per contract = $82.41
+ overhead per SCO allowed “ACR” = $82.41 x 6.14% rate = + $5.06
SCO allowed hourly billing rate = $87.47
vs
City Claimed Hourly Billing Allowed Rate using existing ICRP
Methodology/Claiming Instructions
FY 12-13 based rate with only salaries and benefits per contract = $82.41
+ overhead per Ps&Gs ICRP guidelines = $82.41 x 76.5% ICRP rate = + $63.04
Actual hourly billing rate = $145.45
If the SCO wishes to change the rules, head in this new direction, and
apply this new interpretation – that OMB A-87/CFR methodology does
not apply for computation of law enforcement overhead/Indirect Cost
Rate Proposal (ICRP) rates paid through contracts with county law
enforcement agencies – then this should be explicitly stated in the written
rules and guidelines and all parties should be able to review and
participate in the adoption of those rules. Further, it is not fair to
retroactively apply new standards and impose new rules on local
agencies without providing advanced notice to them.
If OMB/CFR guidelines are inapplicable and SCO’s newly developed
“ACR” methodology must be used, there is no written explanation of
how this new overhead/”ACR” rate is to be computed and how to
determine which costs are “clearly administrative in nature”. It may be
“clear” to SCO staff what costs apply, but we would also have included
our command staff as we believe the costs are clearly administrative in
nature: costs for our “Captains, Lieutenants, and Sergeants, as well as
various other line- item charges” which SCO auditors concede “may
[emphasis added] or may not be administrative in nature dependent on
the functions that each classification performs” can qualify for inclusion
in the overhead rate.
Finally, we believe SCO staff actions violate “Due Process” requirements
by creating new rules and standards that are not enumerated in written
claiming manuals, parameters and guidelines, claiming instructions, and
the OMB/CFR Guidelines. There is no statement that Ps and Gs do not
apply to cities contracting for law enforcement services: that contract
cities don’t qualify for reimbursement of indirect costs. There is no
explanation that indirect costs are not allowable if they are itemized in
the contract with the county; but are allowable if they are already built
into direct staff (Deputy) hourly billing rates. There is no description,
explanation, or examples provided in any manual of how local agencies
that contract for law enforcement services are supposed to claim their
allowable indirect or “administrative”/“ACR”costs in a manner
acceptable to the SCO.
Given SCO staff response that 1) OMB/CFR Guidelines do not apply to
the computation of indirect costs for cities that contract for law
enforcement agencies with county agencies; 2) that indirect costs for
contract cities are in fact completely unallowable costs or are subject to
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City of Rancho Cucamonga Identity Theft Program
some alternate, non-written standards that only SCO staff can determine
or dictate at their sole discretion, 3) that there is no explanation or
written guidelines provided to claimants in the instructions that explain
what costs are and are not eligible; 4) that SCO findings that city contract
agencies (like those in LA County) can obtain reimbursement for all
direct and indirect charges included in their hourly rates, but those
contracts that do not already have overhead pre-built into their Deputy
rates forfeit their right to obtain indirect costs computed in the same
manner suggests that the SCO is engaged in underground rule making.
THERE ARE NO SEPARATE RULES AND GUIDELINES FOR
CONTRACT CITIES (CITIES WHO PURCHASE THEIR LAW
ENFORCEMENT SERVICES VIA A CONTRACT) TO CLAIM
ALLOWABLE OVERHEAD COSTS:
On page 13 of the SCO’s DAR that correctly states “the city contracts
with San Bernardino County to have the SBCSD (San Bernardino
County Sheriff’s Department) to provide all its law enforcement
services.” The City website (https://www.cityofrc.us/RCPD) states,
“Police Department: Since incorporation in 1977, law enforcement
services in the City have been provided through a contract with the San
Bernardino County Sheriff's Department. Rancho Cucamonga continues
to be one of Southern California's most family-oriented, safe, and
prosperous cities. The low crime rate that the City continues to enjoy, is
a direct result of not only the hard work and dedication of the men and
women of the Police Department, but the positive interaction and
participation by the community in crime prevention activities.”
The agreements and the annual Schedule of Costs shows that the city is
purchasing all the components of a Police Department, including direct
and indirect (overhead) costs. The expenditures listed in the contract
under Schedule A is in a similar level of detail and format to a full-
service city’s departmental expenditure report. San Bernardino County
segregates each line item of cost separately and the billing rates of each
position ONLY include salary and benefit costs (see Contract, Schedule
A, Footnote 1). All necessary overhead is included separately in the
contract and is described in detail. Many of those costs are eligible
indirect costs that are necessary to support the function of the department
and to allow the Deputies to perform their primary duty of providing law
enforcement services.
There are no alternate or separate guidelines for computing overhead
rates in claiming instructions or in Federal CFR Guidelines, to be used
for contract cities, as you are proposing. The city calculated and
provided Departmental Indirect Cost rates, computed exactly as shown
in the State’s guidelines and in compliance with Federal CFR/OMB
Guidelines.
We agree with the Parameters and Guidelines (Ps and Gs), Claiming
Instructions, and the Claiming Manual where it explains how indirect
costs are to be prepared; however, the instructions must be read in their
entirety to determine their intent.
Parameters and Guidelines V.B. Indirect Cost Rates:
Indirect costs are costs that are incurred for a common or joint
purpose, benefiting more than one program, and are not directly
assignable to a particular department or program without efforts
disproportionate to the result achieved. Indirect costs may
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City of Rancho Cucamonga Identity Theft Program
include: (1) the overhead costs of the unit performing the
mandate; and (2) the costs of the central government services
distributed to the other departments based on a systematic and
rational basis through a cost allocation plan.
In this case the UNIT performing the mandate is the law enforcement
unit purchased by the City of Rancho Cucamonga from the San
Bernardino County Sheriff’s Department (SBCSD) as outlined in detail
in their contract showing all cost components charged to the city. The
Schedule A shows that in addition to the Direct Salaries and Benefits of
Law Enforcement Personnel, salaries of support and administrative staff
for positions such as Captain, Lieutenants, Clerical Support positions, as
well as other necessary and eligible (compliant with CFR guidelines)
overhead costs such as vehicle and equipment usage charges which were
billed to the city.
Claiming Manual, Section 8 states,
Indirect costs are (a) Incurred for a common or joint purpose
benefiting more than one cost objective, and (b) not readily
assignable to the cost objectives specifically benefited without
effort disproportionate to the results achieved. Indirect costs can
originate in the department performing the mandate or in
departments that supply the department performing the
mandate with goods, services, and facilities. To be allowable,
a cost must be allocable to a particular cost objective. Indirect
costs must be distributed to benefiting cost objectives on bases,
which produce an equitable result, related to the benefits
derived by the mandate.
DAR states on page 24 that “none of the costs that the city incurred for
law enforcement services provided by the SBCSD were indirect costs”
and appears to argue that because ALL costs in the contract are
assignable to the law enforcement contract or City Police Department,
then ALL costs must be direct.
If SCO staff interpretation was correct, there would be no such thing as
a Departmental Indirect Cost Rate as shown in State claiming manuals,
examples, and instructions because every cost “assignable” to that
department would be a direct cost. Nothing would be indirect except for
costs outside of that department that were allocated to the department
through the City or County-wide cost allocation plans. That is clearly not
the case as “Departmental” Indirect Cost rates are the standard.
Staff’s statement “if it’s assignable to the department, then it’s direct” is
disproved by SCO’s own analysis as you acknowledged that over eight
items “assigned” to our “Department”/ law enforcement services
contract were indeed allowable indirect (administrative) costs and
included in SCO staff’s “Administrative Cost Rate”. Since these costs
were also “assignable to the department”, then that would make those
costs also direct costs by SCO’s definition.
The wording in the instructions and guidelines shows that the
terminology between: “program”, “department”, and “cost objective” are
used interchangeably to allow maximum flexibility to apply to various
situations. The entire instructions must be read in context, not
abbreviated and cherry picked. Claiming Manual, 8. Indirect Costs
states: “Indirect costs can originate in the department performing the
mandate or in departments that supply the department performing
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City of Rancho Cucamonga Identity Theft Program
the mandate with goods, services, and facilities.” Clearly indirect costs
can originate in the law enforcement unit purchased from SBCSD.
COMMISSION ON STATE MANDATES PRIOR DECISIONS
SUPPORT THE VALIDITY OF EXISTING PARAMETERS AND
GUIDELINES AND EXISTING METHODOLOGY IN
COMPUTATION OF OVERHEAD/ICRP RATES FOR
CONTRACT CITIES:
Prior Commission on State Mandates (CSM) decisions also provided
insight on the topic of overhead for cities contracting for law
enforcement services.
In the City of Palmdale’s Incorrect Reduction Claim (IRC) of the SCO’s
2016 Audit of their Interagency Child Abuse and Neglect Reporting
claims (See November, 2018 CSM meeting transcript) the Commission
reviewed whether the City of Palmdale, which contracted with Los
Angeles County for law enforcement services, was entitled to the 10%
default overhead rate they claimed in their requests for reimbursement.
The Commission staff concluded that while it was not appropriate for a
contracting agency to use the default 10% ICRP rate when computing
overhead costs since this rate was designed specifically for application
to only salaries (not salaries and benefits); a contract city would have
been eligible for indirect cost reimbursement if the city prepared their
own ICRP rate demonstrating valid indirect costs. The city did prepare
and submit their ICRPs showing overhead cost computations.
Commissioner Alex stated during the meeting (Page 46 of transcript,
Lines 5-8 of hearing transcript) that he agreed that “…there is overhead
associated with a contract and I think that’s typical.”
Mr. Jones of the Commission staff noted that “...the Parameters and
Guidelines say you can – you can prepare an indirect cost rate proposal
if the indirect cost rate exceeds 10%.” (Page 44 lines 24-25 and page 45,
lines 1-2 of hearing transcript)
Commission Member Adams asked, “And under Parameters –
Parameters and Guidelines, would there have been an appropriate
way to claim these indirect costs?” (Page 38 lines 14-21 of hearing
transcript)
Mr. Jones of the Commission staff responds, “Staff’s position is that,
yes, there was an appropriate way, and it was to develop an indirect
cost rate proposal with documentation that the Controller could
review.” (Page 38 lines 24-25 and Page 39 lines 1-2)
Ms. Shelton of the Commission noted that, “…you have to follow the
plain language of the Parameters and Guidelines.” (Page 47,
lines 21-23 of hearing transcript). The plain language being that indirect
costs were eligible for inclusion in the reimbursement claims under the
language and rules established in the Parameters and Guidelines.
SCO FINDINGS THAT OUR ADMINISTRATIVE STAFF
(CAPTAINS, LIEUTENANTS, SERGEANTS); SUPPORT STAFF
(STATION CLERKS, SECRETARIES, AND SHERIFF’S
SERVICE SPECIALISTS); AND SUPPORT COSTS (DISPATCH
SERVICES, VEHICLE AND EQUIPMENT USAGE CHARGES)
ARE NOT ALLOWABLE ARE INCONSISTENT WITH PRIOR
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City of Rancho Cucamonga Identity Theft Program
AUDITS OF BOTH OTHER CONTRACT SERVICE CITIES AND
FULL SERVICE CITIES:
We already cited the City of San Marcos Audit, another contract city in
a similar situation. But there are many examples of full-service (non-
contract) cities SCO audited where identical indirect costs (Captains,
Lieutenants, Sergeants, Clerical Support, Vehicle and Equipment usage,
etc.) were found to be allowable overhead/indirect costs. This list is only
a small sample, listing audits our consultant was directly involved in and
has personal information of:
- County of San Bernardino: Identity Theft Audit
- City of Rialto: Child Abuse and Neglect Reporting Audit
- City of South Lake Tahoe: Child Abuse and Neglect Reporting
Audit
- City of Fresno: Administrative License Suspension Audit
- City of Fresno: Domestic Violence Audit
- City of Fresno: Identity Theft Audit
- City of Fresno: Peace Officer Bill of Rights Audits
Please let us know if you’d like us to send you a copy of the audits or
ICRPs allowed in these reviews.
Like costs must be treated consistently to have a fair and non-arbitrary
audit.
1) SCO audits of San Bernardino County Sheriff’s Department:
The SCO has already audited and approved indirect cost rates for the San
Bernardino County Sheriff’s Department (our contracting agency) for
this same program (Identity Theft) and for the same years. Since SCO
approved indirect cost rates for this same organization, for activities
which were performed by the same class of employees, paid at the same
rates, for the same program and for the same years, our allowable
overhead rates which are sourced from the same agency should not be
less than those approved rates.
San Bernardino County: Identity Theft Audit Report, Release April
2022
Allowable Direct Indirect Approved
ICRP Rate:
2002-03 $34,330 $24,543 =$24,543/$34,330= 71.5%
2003-04 $34,123 $20,965 = 61.4%
2004-05 $44,177 $27,142 = 61.4%
2005-06 $44,188 $20,875 = 47.2%
2006-07 $49,011 $21,727 = 46.2%
2007-08 $50,876 $27,743 = 54.5%
2008-09 $43,288 $20,596 = 47.6%
2009-10 $34,516 $15,770 = 45.7%
2010-11 $30,836 $14,215 = 46.1%
2011-12 $38,594 $16,468 = 42.7%
2012-13 $34,115 $14,335 = 42.0%
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City of Rancho Cucamonga Identity Theft Program
Allowing the City only an average of 6% overhead or “administrative
cost allocation rate” when SCO audit of the San Bernardino County
Sheriff’s Department that provides us with law enforcement services is
about 7 to 10 times that, shows the inequity and erroneous basis of staff
computations.
CFR guidelines state in Section 200.306 (f) of 2 CFR Part 200:
(f) When a third-party organization furnishes the services of an
employee, these services must be valued at the employee’s regular rate
of pay plus an amount of fringe benefits that is reasonable, necessary,
allocable, and otherwise allowable, and indirect costs at either the third-
party organization’s approved federally negotiated indirect cost rate or,
a rate in accordance with § 200.414 Indirect (F&A) costs,
paragraph (d), provided these services employ the same skill(s) for
which the employee is normally paid.
OMB/CFR clearly states that in addition to third-party salaries and
benefits (which you properly allowed), indirect costs, at either the third-
party organizations approved federally negotiated indirect cost rate, or a
rate in accordance with 2 CFR Part 200 § 200.414 are eligible.
OMB A-87/CFR guidelines do not distinguish or provide alternate
indirect cost rate methodologies between first- and third-parties. The
same rules would apply.
If SCO staff believe Federal CFR/(prior OMB A-87 methodology) does
not apply to or allow for the recovery of full indirect costs for contract
cities, or that some alternate methodology exists for contract cities,
please provide evidence and references to the pertinent sections of
Claiming Instructions, Parameters and Guidelines, or OMB/CFR
Guidelines that support this. Other than State and Federal CFR
guidelines, we are not aware of any alternate rules or guidelines that
dictate how indirect costs are to be computed for contract cities.
Therefore, we believe the existing rules would be applicable in the
computation of our ICRP rates.
IF COSTS ARE DIRECT, AS THE DAR IMPLIES, THEN WHY
DOESN’T THE SCO PAY FOR THOSE COSTS DIRECTLY?
Page 20 of the DAR narrative states, “The city’s contracts with the
SBCSD also includes additional employee classifications and items –
such as vehicles, dispatch services, and equipment – that are all a part of
the direct costs incurred to provide law enforcement for the city.”
If it is SCO’s position that these costs are not allowable in the Indirect
Cost Rate, or in the SCO’s newly created “Allowable Cost Rate” (ACR),
then because a portion of these costs were legitimately necessary to
perform the mandate program these costs should be reimbursed. Simply
brushing them off and saying that they are all a part of the direct costs to
provide law enforcement to the city does not satisfy mandate law or
parameters and guidelines which state all direct and indirect costs must
be reimbursed.
Under Section 5 of the Claiming Manual, it states:
Allowable costs are those direct and indirect costs, less
applicable credits, considered eligible for reimbursement. In
order for costs to be allowable and thus eligible for
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City of Rancho Cucamonga Identity Theft Program
reimbursement, the costs must meet the following general
criteria:
1. The cost is necessary and reasonable for proper and
efficient administration of the mandate and not a general
expense required in carrying out the overall responsibilities
of government;
2. The cost is allocable to a particular cost objective identified
in the Ps & Gs; and
3. The cost is net of any applicable credits that offset or
reduce expenses of items allocable to the mandate
It would not be possible to provide law enforcement services or comply
with the mandate without vehicles, dispatch services, and equipment.
Vehicles, equipment and dispatch services meet these criteria. The State
Mandate Claiming Manual in the ICRP Example Table 6, page 13 states
that “(Each line item should be reviewed to see if it benefits the mandate
to insure a fair and equitable distribution.)”
Vehicle/Equipment Use: SCO proposed “ACR” rates do not include
costs for the actual vehicles/ transportation costs. Also, handheld ratios
or talkies were also omitted. Deputies would not be able to get the
information from Dispatch without their handheld radios (HTs) or drive
to the scene of the Identity Theft case. Both travel and vehicle/equipment
usage are allowable as direct or indirect costs based on the instructions,
so they could be claimed either way.
Appendix E to Part 225—State and Local Indirect Cost Rate
Proposals Section A. 4. states:
… typical examples of indirect costs may include certain
State/local-wide central service costs, general administration of
the grantee department or agency, accounting and personnel
services performed within the grantee department or agency,
depreciation or use allowances on buildings and equipment,
the costs of operating and maintaining facilities, etc.
The State Controller Claiming Manual in Section 7. Direct Costs, (6)
Travel Expenses states:
Travel expenses are normally reimbursable in accordance with
the travel rules and regulations of the local jurisdiction...
Based on these State and Federal Guidelines, we felt it was more
appropriate to include the vehicle/equipment usage and related travel
expenses in the overhead rate/ICRP. However, it could be claimed
directly as you seem to be suggesting.
The City could be provided with a reimbursement for these costs using
the allowable Federal vehicle mileage reimbursement rates by fiscal
year, for example, in FY 2012-13 the rate was $.555 per mile. We could
compute the total mileage for all ID Theft cases and apply this rate to
reimburse us for our travel expenses. For example, if each ID Theft
victim is an average of 10 miles from the station, that would be 20 miles
round trip per case (304 cases) x $.555 per mile, or $3,374
reimbursement for travel costs in FY 2012-13.
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City of Rancho Cucamonga Identity Theft Program
Dispatch Services. The Audit report state that dispatch services are a
direct function. Clearly the dispatcher/communications function
“benefits the mandate” and is necessary support to the entire law
enforcement function of the department. As dispatch support is
necessary support to the Deputies for this mandate and for all law
enforcement services, the “fair and equitable distribution” (see Claiming
Instructions Manual, ICRP Example, Table 6, page 13) of costs related
to this mandated program must be allowed.
We could take the total number of calls for service in a year, then, using
the total number of Identity Theft cases, charge that same percentage of
“Dispatch Services” costs to the mandate.
Administrative and Clerical Support. A similar computation can be
performed to distribute a fair allocable share of administrative support
costs directly. We can take the total number of Deputies (the staff who
provides the direct services of the law enforcement department) and then
distribute the costs of the Captain/Police Chief and other administrative
personnel for their necessary supervision and support.
Direct costing can certainly be done, but in the SCO audit, the city was
not reimbursed for the cost either directly or indirectly. This omission
violates the California Constitution and Parameters and Guidelines by
denying us actual, increased costs that were necessary to perform the
mandate.
“ALL COSTS SUBMITTED TO THE SCO ARE SUBJECT TO
REVIEW TO DETERMINE IF THE COSTS ARE RELATED TO
THE MANDATE”:
Page 2 of Mandated Cost Manual, Section: Audit of Costs, “All claims
submitted to the SCO are subject to review to determine if costs are
related to the mandate…and are prepared in accordance with SCO’s
Claiming Instructions.” We believe we have complied with the
instructions and shown that the items we requested reimbursement for
were necessary and are supported by Parameters and Guidelines, State
Instructions, and Federal CFR Guidelines.
Not allowing reimbursement of those costs for vehicles, administrative
personal such as our Police Chief, clerical staff, and the dispatch charges
billed to us from the county when they are clearly necessary for the
provision of the mandated services would be contrary to Claiming
Instructions, Parameters and Guidelines, as well as Federal CFR-200
standards which all specifically allow for the inclusion and
reimbursement of both direct AND indirect costs. To simply exclude or
not allow legitimate costs is contrary to State and Federal rules, and also
would be inconsistent with SCO’s own office’s prior audit
determinations.
Please let us know if we you have any questions or if we can provide any
additional information. We believe that the costs shown by the city are
the proper and allowable costs, in compliance with State and Federal
rules and guidelines.
SCO’s Comments
The finding and recommendation remain unchanged.
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City of Rancho Cucamonga Identity Theft Program
In its response, the city did not respond to the portion of the finding related
to overstated identity theft reports or the misstated time increments
required to perform the reimbursable activities. The city’s response
focuses on unallowable indirect costs ($223,707) and its belief that the
additional allowable costs we calculated for administrative costs ($9,487)
within the city’s law enforcement services contracts are insufficient. The
city also refers to SCO audits of other claimants; however, the
Commission has affirmed in prior Incorrect Reduction Claim decisions
that audits of other claimants are not relevant to the SCO’s audit here, as
each audit depends on the documentation and evidence provided by the
claimant to show increased costs mandated by the State.
The city’s response comprises an explanation for why it is eligible to claim
indirect costs against contract services costs. However, the arguments it
raises suggest a complete misunderstanding of indirect costs, when they
apply, and what they represent.
The city did not claim allowable indirect/overhead costs by virtue of its
law enforcement services contracts with San Bernardino County because
the city did not incur any indirect costs as defined by the parameters and
guidelines. The parameters and guidelines define indirect costs as:
…costs that are incurred for a common or joint purpose benefitting more
than one program, and are not directly assignable to a particular
department or program without efforts disproportionate to the results
achieved. Indirect costs may include: (1) the overhead costs of the unit
performing the mandate; and (2) the costs of the central government
services distributed to other departments based on a systematic and
rational basis through a cost allocation plan.
According to the parameters and guidelines, allowable indirect costs
include “the overhead costs of the unit performing the mandate.” The City
of Rancho Cucamonga contracts out its law enforcement services with the
SBCSD. The unit performing the work related to the mandate is the
SBCSD, not the city. The overhead costs for SBCSD are included in its
billing rate, and our audit determined that those costs were allowable. The
only indirect costs incurred by the City of Rancho Cucamonga for law
enforcement services are its internal costs incurred by various city
departments for negotiating and administering its contracts with San
Bernardino County, however, the city did not claim these costs
San Bernardino County includes its indirect costs as separate line items in
its contracts for law enforcement services; however, that does not also
make those costs indirect costs incurred by the City of Rancho Cucamonga
just because the city reimburses the county for these costs. There is a clear
distinction. We refer to these line item costs as “administrative costs” in
order to differentiate them from indirect costs.
The city’s contention that it “purchased salaries and benefits” from San
Bernardino County is inconsistent with Generally Accepted Accounting
Principles. The costs that the city incurred are contract services costs. The
city’s additional contention that the unit performing the mandate is “the
law enforcement unit purchased by the city” is not supportable. The city
did not purchase the SBCSD, it purchased the contracted services that the
SBCSD provided.
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City of Rancho Cucamonga Identity Theft Program
That said, we responded to an argument raised by the city’s mandated cost
consultant during the audit related to the methodology that another county
uses to bill its contract cities for law enforcement services. That county
includes administrative costs within the productive hourly rate
calculations for county personnel in its law enforcement services
contracts. The consultant’s argument correctly noted that San Bernardino
County does not structure its law enforcement services contracts in the
same manner. We discussed this argument internally and agreed that there
is no methodology for the city to recover these “administrative costs”
included as specific line item costs within its contracts with San
Bernardino County. As we did not audit any of the individual line item
costs within San Bernardino County’s contracts, we have no way of
knowing whether the county included a factor for indirect costs in its
calculations of rates for personnel and equipment.
Although we were under no obligation to do so, we determined that it is
appropriate to calculate an allowable administrative percentage and add it
to the productive hourly rate calculations for county staff in this instance.
This is similar to the methodology noted by the city’s mandated cost
consultant. We based our determination that certain contract costs are
“clearly” administrative costs on our judgment that such costs are not
directly related to providing law enforcement services for the city. Our
report spells out exactly which costs we included. We believe that the line
item descriptions describe various types of indirect costs that San
Bernardino County incurred to provide law enforcement services pursuant
to its contracts with the city. As stated previously, just because the city is
reimbursing the county for its indirect costs, Generally Accepted
Accounting Principles dictates that this does not also make those indirect
costs incurred by the City of Rancho Cucamonga.
Our determination of calculating additional allowable costs based on
administrative costs within the city’s contracts is unrelated to OMB
Circular A-87 cost principles. Instead, we used a basic mathematical
construct to allocate the mandated portion of administrative costs based on
each year’s total contract amount. The city states that certain other costs
within its law enforcement contracts should be included in the
calculations, such as costs for Lieutenants and certain Sergeants, because
they perform an administrative function for the SBCSD. While activities
performed by certain SBCSD law enforcement staff may be for an
administrative function, the costs are still direct contract services costs
incurred by the city for law enforcement services. The administrative costs
that we identified in the audit are not for law enforcement services.
In its response, the city refers to Title 2, Code of Federal Regulations,
part 200 (2 CFR 200), section 200.306(f) as justification for claiming
indirect costs using the same indirect cost rates that San Bernardino
County included in its mandated cost claims for this program. However,
Section 200.306(f) is included within Subpart D of 2 CFR 200, which
provides guidance for recipients of federal awards to account for cost
sharing amounts. This guidance is not applicable to the calculation of
indirect costs, nor is it applicable to mandated cost claims.
The parameters and guidelines for the Identity Theft Program identify
2 CFR 225, Appendix A and B (OMB Circular A-87) as the controlling
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City of Rancho Cucamonga Identity Theft Program
requirements for claiming indirect costs. The Commission adopted the
parameters and guidelines for the Identity Theft Program in 2011. Several
years later, the federal government re-codified 2 CFR 225 within
2 CFR 200 as Subpart E, along with the applicable appendices.
We used a methodology here to include the costs we identified as
administrative costs within the city’s contracts and re-calculated allowable
productive hourly rates for county staff. This resulted in additional
allowable contract services costs of $9,487 for the city, which is not a
reduction of costs.
The reductions of costs claimed in the audit are for overstated identity theft
reports, misstated time increments to perform the reimbursable activities,
and unallowable indirect costs. The city is responding only to the portion
of the finding related to the reduction of claimed indirect costs. The city
used an incorrect methodology to claim indirect costs, in violation of the
parameters and guidelines. As a result, the costs are unallowable. The
Commission previously agreed to this conclusion within prior Incorrect
Reduction Claims; however, the city has the option to file an Incorrect
Reduction Claim with the Commission and have the matter adjudicated
again.
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City of Rancho Cucamonga Identity Theft Program
Attachment—
City’s Response to Draft Audit Report
State Controller’s Office
Division of Audits
Post Office Box 942850
Sacramento, CA 94250
www.sco.ca.gov
S22-MCC-0009