SCO
Orange County
Racial and Identity Profiling
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ORANGE COUNTY
Audit Report
RACIAL AND IDENTITY PROFILING PROGRAM
Chapter 466, Statutes of 2015;
and Chapter 328, Statutes of 2017
July 1, 2018, through June 30, 2023
M M. C
ALIA OHEN
C
ALIFORNIA
S
TATE
C
ONTROLLER
October 2025
MALIA M. COHEN
CALIFORNIA STATE CONTROLLER
October 17, 2025
CERTIFIED MAIL—RETURN RECEIPT REQUESTED
Mr. Salvador Lopez, Chief Deputy Auditor-Controller
Orange County
1770 North Broadway
Santa Ana, CA 92706
Dear Mr. Lopez:
The State Controller’s Office audited the costs claimed by Orange County (the county) for the
legislatively mandated Racial and Identity Profiling Program for the period of July 1, 2018,
through June 30, 2023.
The county claimed and was paid $757,738 for costs of the mandated program. Our audit found
that $307,902 is allowable and $449,836 is unallowable. The costs are unallowable primarily
because the county overstated costs for collecting and reporting stop data, overstated costs for
training, and claimed unallowable related indirect costs.
Following issuance of this audit report, the Local Government Programs and Services Division
of the State Controller’s Office will notify the county of the adjustment to its claims via a
system-generated letter for each fiscal year in the audit period.
If you have any questions regarding this report, please contact Lisa Kurokawa, Chief,
Compliance Audits Bureau, by telephone at 916-327-3138. Thank you.
Sincerely,
Original signed by
Kimberly A. Tarvin, CPA
Chief, Division of Audits
KAT/ac
MAILING ADDRESS P.O. Box 942850, Sacramento, CA 94250
SACRAMENTO 3301 C Street, Suite 700, Sacramento, CA 95816 | 916.324.8907
LOS ANGELES 901 Corporate Center Drive, Suite 200, Monterey Park, CA 91754 | 323.981.6802
Mr. Salvador Lopez
October 17, 2025
Page 2 of 2
Copy: The Honorable Doug Chaffee, Chairman
Orange County Board of Supervisors
Noma Crook, Director
Financial/Administrative Services Division
Orange County Sheriff’s Department
Linh Vuong, Audit Manager
Financial/Administrative Services Division
Orange County Sheriff’s Department
Tobin Anderson, Sergeant
Strategy, Accountability, Focus, and Evaluation Division
Orange County Sheriff’s Department
Chris Hill, Principal Program Budget Analyst
Local Government Unit
California Department of Finance
Kaily Yap, 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
MAILING ADDRESS P.O. Box 942850, Sacramento, CA 94250
SACRAMENTO 3301 C Street, Suite 700, Sacramento, CA 95816 | 916.324.8907
LOS ANGELES 901 Corporate Center Drive, Suite 200, Monterey Park, CA 91754 | 323.981.6802
Orange County Racial and Identity Profiling Program
Contents
Audit Report
Summary ............................................................................................................................ 1
Background ........................................................................................................................ 1
Audit Authority .................................................................................................................. 2
Objective, Scope, and Methodology ................................................................................. 3
Conclusion .......................................................................................................................... 4
Follow-up on Prior Audit Findings .................................................................................. 5
Views of Responsible Officials .......................................................................................... 5
Restricted Use .................................................................................................................... 5
Schedule—Summary of Program Costs .............................................................................. 6
Finding and Recommendation .............................................................................................. 9
Attachment—Orange County Sheriff’s Department’s Response to Draft Audit Report
Orange County Racial and Identity Profiling Program
Audit Report
Summary The State Controller’s Office (SCO) audited the costs claimed by Orange
County (the county) for the legislatively mandated Racial and Identity
Profiling Program for the period of July 1, 2018, through June 30, 2023.
The county claimed and was paid $757,738 for costs of the mandated
program. Our audit found that $307,902 is allowable and $449,836 is
unallowable. The costs are unallowable primarily because the county
overstated costs for collecting and reporting stop data, overstated costs for
training, and claimed unallowable related indirect costs.
Background Government Code (GC) section 12525.5, as added and amended by the
Statutes of 2015, Chapter 466 and the Statutes of 2017, Chapter 328; and
Title 11, California Code of Regulations, sections 999.224 through
999.229 established the state-mandated Racial and Identity Profiling
Program.
The program requires a local law enforcement agency that employs peace
officers—or that contracts for peace officers from another city or county
for police protection services—to electronically report to the Attorney
General, on an annual basis, data on all “stops” conducted within its
jurisdiction. For purposes of the program, “peace officer” does not include
probation officers or officers in custodial settings.
On May 22, 2020, the Commission on State Mandates found that GC
section 12525.5 constitutes a reimbursable state-mandated program,
beginning November 7, 2017, for local law enforcement agencies.
The Commission on State Mandates determined that each claimant is
allowed to claim and be reimbursed for the following activities identified
in the parameters and guidelines (Section IV., “Reimbursable Activities”):
A. One-Time Activities
1. One-time training per peace officer employee and supervisor
assigned to perform the reimbursable activities listed in section
IV.B. of these Parameters and Guidelines.
2. One-time installation and testing of software necessary to
comply with the state-mandated requirements for the collection
and reporting of data on all applicable stops.
B. Ongoing Activities
1. Identification of the peace officers required to report stops, and
maintenance of a system to match individual officers to their
Officer I.D. number. . . .
2. Collection and reporting data on all stops, as defined, conducted
by that agency’s peace officers for the preceding calendar year
in accordance with sections 999.226(a) and 999.227 of the
regulations. . . .
3. Electronic submission of data to DOJ and retention of stop data
collected. . . .
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Orange County Racial and Identity Profiling Program
4. Audits and validation of data collected. . . .
5. For stop data collected, ensure that the name, address, social
security number, or other unique personally identifiable
information of the individual stopped, searched, or subjected to
property seizure, and the badge number or other unique
identifying information of the peace officer involved is not
transmitted to the Attorney General in an open text field. . . .
The parameters and guidelines describe the 16 types of stop data and all
applicable data elements, data fields, and narrative explanation fields that
peace officers must collect for every stop.
The following stops are not reportable:
• Interactions with passengers in a stopped vehicle who have not been
observed or suspected of violating the law;
• Stops made during public safety mass evacuations;
• Stops made during active shooter incidents;
• Stops resulting from routine security screenings to enter a building or
special event;
• Interactions during traffic control of vehicles due to a traffic accident
or emergency, crowd control requiring pedestrians to remain in a fixed
location for public safety reasons, persons detained at residences so
that officers can check for proof of age while investigating underage
drinking, and checkpoints and roadblocks where officers detain a
person as the result of regulatory activity that is general and not based
on individualized suspicion or personal characteristics;
• Interactions with a person who is subject to a warrant or search
condition at his or her residence;
• Interactions with a person who is subject to home detention or house
arrest;
• Stops in a custodial setting; and
• Stops that occur while an officer is off-duty.
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
county’s records to verify the actual amount of the mandated costs. In
addition, GC section 12410 provides the SCO with general authority to
audit the disbursement of state money for correctness, legality, and
sufficient provisions of law for payment.
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Orange County Racial and Identity Profiling Program
Objective, Scope, The objective of our audit was to determine whether claimed costs
represent increased costs resulting from the legislatively mandated Racial
and Methodology
and Identity Profiling 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.
The audit period was July 1, 2018, through June 30, 2023.
To achieve our objective, we performed the following procedures:
• We reviewed the annual mandated cost claims filed by the county for
the audit period and identified the significant cost components of each
claim as salaries, benefits, and indirect costs. We determined whether
there were any errors or unusual or unexpected variances from year to
year. We 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
county staff. We discussed the claim preparation process with county
staff to determine what information was obtained, who obtained it, and
how it was used.
• We assessed the reliability of data (stop data, productive hourly rate
[PHR] support, and expenditure records) generated by the county’s
records management system by interviewing key county staff
members and examining the supporting documentation. We
determined that the data provided was sufficiently reliable to address
the audit objective.
• We obtained the county’s system-generated lists of stop data—which
the county had collected and reported to the Department of Justice
(DOJ)—from its Racial and Identity Profiling Act (RIPA) application
to verify the existence, completeness, and accuracy of counts for each
fiscal year of the audit period. We recalculated the costs based on the
allowable number of stops reported for each fiscal year in the audit
period.
• We designed a statistical sampling plan to test salary and benefit costs
claimed under the collection and reporting of data cost category of the
county’s claims for each year of the audit period, based on a moderate
level of detection (audit) risk. We describe the sampling plan in the
Finding and Recommendation section.
• We used a random number table to select 295 out of 35,093 stops
reported by the county for the two fiscal years sampled. We tested the
stop data as follows:
o We determined whether each stop included all of the required
elements to be reported to the DOJ according to the program’s
parameters and guidelines.
o We determined whether stops were performed by peace officers
who were covered by a law enforcement services agreement, other
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Orange County Racial and Identity Profiling Program
memorandum of understanding, or funded by an outside funding
source.
o We determined whether any stops occurred at the residence of a
known felon with an outstanding arrest warrant; and
o We obtained employee ID numbers and ranks of peace officers
from the stop data documenting who performed the reimbursable
activities. We then compared the employee classifications
obtained from the stop data to those that the county claimed.
• We obtained updated average time spent performing the reimbursable
activities calculated from the county’s RIPA application.
• We projected the audit results of the two years tested by multiplying
the allowable count of stops by the audited average time increments
needed to perform the reimbursable activities and multiplied the
product by the PHRs of the county employees who performed them.
• We reviewed the county’s Single Audit Reports to identify any
offsetting savings or reimbursements from federal or pass-through
programs applicable to the Racial and Identity Profiling Program. We
identified several such programs and discussed them with the county.
A county representative confirmed that the county did not receive
offsetting revenues applicable to this mandated program during the
audit period.
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 an instance of
noncompliance with the requirements described in our audit objective. We
did not find that the county claimed costs that were funded by other
sources; 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 county claimed and was paid $757,738 for costs
of the legislatively mandated Racial and Identity Profiling Program. Our
audit found that $307,902 is allowable and $449,836 is unallowable.
Following issuance of this audit report, the SCO’s Local Government
Programs and Services Division will notify the county of the adjustment
to its claims via a system-generated letter for each fiscal year in the audit
period.
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Orange County Racial and Identity Profiling Program
Follow-up on We have not previously conducted an audit of the county’s legislatively
mandated Racial and Identity Profiling Program.
Prior Audit
Findings
Views of We issued a draft audit report on August 29, 2025. The county’s
Responsible representative responded by letter dated September 5, 2025, agreeing with
the audit results. This final audit report includes the county’s response as
Officials
an attachment.
Restricted Use This audit report is solely for the information and use of the county, the
California Department of Finance, and the SCO; it is not intended to be,
and should not be, used by anyone other than these specified parties. This
restriction is not intended to limit distribution of this audit report, which is
a matter of public record and is available on the SCO website at
www.sco.ca.gov.
Original signed by
Kimberly A. Tarvin, CPA
Chief, Division of Audits
October 17, 2025
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Orange County Racial and Identity Profiling Program
Schedule—
Summary of Program Costs
July 1, 2018, through June 30, 2023
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2018, through June 30, 2019
Direct costs:
Salaries and benefits:
I Tnsrtaainll apneda ctee sot fsfoicfetwrsa arend supervisors $ 4 0,246 $ 12,898 $ (27,348)
Collect and report data 63,217 3 1,226 (31,991)
Submit to DOJ and retain data collected - - -
Audit and validate data - - --
Subtotal: salaries and benefits 1 03,463 4 4,124 (59,339)
Contract services:
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected - - -
Total direct costs 1 03,463 4 4,124 (59,339)
Indirect costs 33,356 1 4,226 (19,130)
Total program costs $ 136,819 5 8,350 $ (78,469)
Less amount paid by the State2 ( 136,819)
Allowable costs claimed in excess of amount paid $ ( 78,469)
July 1, 2019, through June 30, 2020
Direct costs:
Salaries and benefits:
T Trraainin p peeaaccee o offfficiceerrss a anndd s suuppeerrvvisisoorrss $ 2,728 $ 2 ,491 (237)
Collect and report data 50,300 2 5,026 (25,274)
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 5,299 1,766 ( 3,533)
C Aoulldeict ta anndd v raelpidoartte d daatata - 1,766 1 ,7 6 6-
SSuubbttoottaall: ssaallaarriieess aanndd bbeenneeffiittss 58,327 3 1,049 (27,278)
Contract services:
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected - - -
Total direct costs 58,327 3 1,049 (27,278)
Indirect costs 28,656 1 5,254 (13,402)
Total program costs $ 8 6,983 4 6,303 $ (40,680)
Less amount paid by the State2 (86,983)
Allowable costs claimed in excess of amount paid $ ( 40,680)
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Orange County Racial and Identity Profiling Program
Schedule (continued)
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2020, through June 30, 2021
Direct costs:
Salaries and benefits:
T Trraainin p peeaaccee o offfficiceerrss a anndd s suuppeerrvvisisoorrss $ 2,203 $ 2 ,081 $ (122)
Collect and report data 1 01,846 4 6,996 (54,850)
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 13,800 3,460 (10,340)
C Aoulldeict ta anndd v raelpidoartte d daatata 8,344 2,504 ( 5,840)
SSuubbttoottaal l:s asalalarireies sa anndd b beenneefiftists 1 26,193 5 5,041 (71,152)
Contract services:
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 1,882 - ( 1,882)
Total direct costs 1 28,075 5 5,041 (73,034)
Indirect costs 60,421 2 6,354 (34,067)
Total program costs $ 188,496 8 1,395 $ (107,101)
Less amount paid by the State2 ( ( 118087,,419061))
Allowable costs claimed in excess of amount paid $ (107,101)
July 1, 2021, through June 30, 2022
Direct costs:
Salaries and benefits:
T Trraainin p peeaaccee o offfficiceerrss a anndd s suuppeerrvvisisoorrss $ 1 5,329 $ - $ (15,329)
Collect and report data 71,749 3 5,681 (36,068)
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 9,203 1,852 ( 7,351)
C Aoulldeict ta anndd v raelpidoartte d daatata 15,798 878 (14,920)
SSuubbttoottaal l:s asalalarireies sa anndd b beenneefiftists 1 12,079 3 8,411 (73,668)
Contract services:
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 1,648 - ( 1,648)
Total direct costs 1 13,727 3 8,411 (75,316)
Indirect costs 52,599 1 8,026 (34,573)
Total program costs $ 166,326 5 6,437 $ (109,889)
Less amount paid by the State2 ( ( 116069,,382869))
Allowable costs claimed in excess of amount paid $ (109,889)
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Orange County Racial and Identity Profiling Program
Schedule (continued)
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment1
July 1, 2022, through June 30, 2023
Direct costs:
Salaries and benefits:
TTrraainin ppeeaaccee oofffficiceerrss aanndd ssuuppeerrvvisisoorrss $ 1 8,615 $ - $ (18,615)
Collect and report data 82,295 4 0,639 (41,656)
SIunbstmalilt aton dD tOesJt asnodft wreatarein data collected 8,968 4,336 ( 4,632)
ACuodlliet catn adn vda rliedpaotert ddaattaa 15,221 922 (14,299)
SSuubbttoottaall: ssaallaarriieess aanndd bbeenneeffiittss 1 25,099 4 5,897 (79,202)
Contract services:
I Snsutbamll iat ntod DteOst Js oafntdw raerteain data collected 8 10 - (810)
Total direct costs 1 25,909 4 5,897 (80,012)
Indirect costs 53,205 1 9,520 (33,685)
Total program costs $ 179,114 6 5,417 $ (113,697)
Less amount paid by the State2 ( ( 117193,,161947))
Allowable costs claimed in excess of amount paid $ (113,697)
Summary: July 1, 2018, through June 30, 2023
Direct costs:
Salaries and benefits $ 525,161 $ 214,522 $ (310,639)
Contract services 4,340 - ( 4,340)
-
Total direct costs 5 29,501 214,522 (314,979)
Indirect costs 2 28,237 9 3,380 ( 1 3 4 ,8 5 7-)
Total program costs $ 757,738 307,902 $ (449,836)
Less amount paid by the State2 ( 757,738)
Allowable costs claimed in excess of amount paid $ (449,836)
_________________________
1 See the Finding and Recommendation section.
2 Payment amount current as of September 15, 2025.
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Orange County Racial and Identity Profiling Program
Finding and Recommendation
FINDING— The county claimed and was paid $757,738 for the mandated program. We
found that $307,902 is allowable and $449,836 is unallowable.
Overstated Racial and
Identity Profiling
The costs are unallowable primarily because the county overstated costs
Program costs
for collecting and reporting stop data, overstated costs for training, and
claimed unallowable related indirect costs.
The following table summarizes the claimed, allowable, and audit
adjustment amounts by fiscal year for the audit period:
Direct Costs Related Total
Fiscal Amount Amount Audit Indirect Cost Audit
Year Claimed Allowable Adjustment Adjustment Adjustment
2018-19 $ 103,463 $ 44,124 $ (59,339) $ (19,130) $ (78,469)
2019-20 5 8,327 3 1,049 (27,278) ( 13,402) (40,680)
2020-21 128,075 5 5,041 (73,034) ( 34,067) (107,101)
2021-22 113,727 3 8,411 (75,316) ( 34,573) (109,889)
2022-23 125,909 4 5,897 (80,012) ( 33,685) (113,697)
Total $ 529,501 $ 214,522 $ (314,979) $ (134,857) $ (449,836)
One-time Activities
The parameters and guidelines identify the following one-time activities:
• Activity A.1. – One-time training for each peace officer employee and
supervisor assigned to perform the reimbursable activities; and
• Activity A.2. – One-time installation and testing of software necessary
to comply with the requirements for collecting and reporting stop data.
Training
The county claimed salary and benefit costs totaling $79,121 for one-time
staff training. We found that $17,470 is allowable and $61,651 is
unallowable. The costs are unallowable because the county claimed
training costs that are either unsupported or duplicated.
Patrol Station Training
The county’s claims included training that occurred at Orange County
Sheriff’s Department (OCSD) patrol stations. The county claimed that its
officers were trained on the requirements of the RIPA at 43 briefing
sessions which were documented on watchlists. During the audit, the
OCSD provided 17 patrol station watchlists for fiscal year (FY) 2018-19
that supported 30 minutes of RIPA training for 72 peace officers
(18 Sergeants, 51 Deputy Sheriffs, and three Investigators).
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Orange County Racial and Identity Profiling Program
The county did not provide the remaining 26 patrol station watchlists to
support RIPA training costs during FY 2018-19 for 60 peace officers
(25 Sergeants, 33 Deputy Sheriffs, and two Investigators). As these
training sessions were all unsupported by documentation, they are
unallowable.
One-on-One Training
The county’s claims also included one-on-one RIPA training sessions,
which occurred while officers were in the field. As there were no
watchlists available to support the claimed costs for one-on-one RIPA
training with a Field Training Officer, we requested the following
additional information:
• Employee ID numbers of the trainers and trainees;
• Assigned patrol station;
• Unincorporated or contract city assignment within patrol station;
• Type of training received (briefing at patrol station or one-on-one with
Field Training Officer); and
• Job classification of trainer.
The county provided the requested information that supported its claim of
30-minute training for 98 OCSD employees in the Deputy Sheriff II (DSII)
classification—16 in FY 2018-19, 46 in FY 2019-20, and 36 in
FY 2020-21. We found that 92 DSIIs were eligible for training and six
were ineligible for training. The ineligible training included sessions in
FY 2019-20 for four DSIIs who were employed in custody operations, and
sessions in FY 2020-21 for two DSIIs previously identified as trainers.
The OCSD also provided the requested information to support FY 2021-22
and FY 2022-23 training costs for 261 DSIIs (119 in FY 2021-22 and
142 in FY 2022-23). However, the names of the trainees had been redacted
and the training time claimed had been increased from 30 minutes to
60 minutes. The county did not provide an explanation or support for
doubling the time claimed for training. Due to the redacted trainee names,
we also could not verify whether the OCSD staff listed had already
received the one-time RIPA training.
Preparation of Training Video
The county claimed costs for preparing a short RIPA training video. The
OCSD provided a summary recap of hours spent to support its claim of
333 hours for RIPA training video production (160 hours for the video
producer, 148 hours for six DSIIs, and 25 hours for five Deputy Sheriff
Trainees [DST] as actors). However, the supporting document claimed
293 of the 333 total hours using the same date, July 11, 2018, as follows:
• Five hours for each of the five DSTs (25 hours total),
• 20 hours for each of the five DSIIs (100 hours total),
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Orange County Racial and Identity Profiling Program
• 48 hours for one DSII; and
• 120 hours for the video producer.
The remaining 40 hours claimed were for a video producer on August 6,
2018.
We asked county representatives how they determined the number of
hours claimed and requested actual dates when the mandated activities
were performed to support the total hours claimed. Instead, we received
the same summary information on three occasions that the county had
previously provided to us. Therefore, we determined that the time claimed
was based on estimates of time spent performing the mandated activities.
In the meantime, we verified the existence of the RIPA training video by
watching it and noted that it has a duration of 6.5 minutes. Based on this
evidence, we determined that eight hours for each of the DSIIs (40 hours
total), 16 hours for the video producer, and 25 hours for the DSTs are
allowable. Therefore, 81 hours are allowable, and 252 hours are
unsupported.
The following table presents the claimed, allowable, and audit adjustment
amounts for Activity A.1. by fiscal year:
-11-
2
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2
2
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-
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Ongoing Activities
The parameters and guidelines identify the following ongoing activities:
• Activity B.1. – Identifying the peace officers required to report stops,
and maintaining a system to match individual officers to their
Officer ID numbers;
• Activity B.2. – Collecting and reporting data on all reportable stops;
• Activity B.3. – Submitting electronic stop data to the DOJ and
retaining collected stop data;
• Activity B.4. – Audits and validation of data collected; and
• Activity B.5. – Ensuring that personally identifiable information of the
individuals stopped, and unique identifying information of the peace
officers involved are not transmitted to the DOJ in an open text field.
Orange County Racial and Identity Profiling Program
Collecting and Reporting Data
The county claimed salary and benefit costs totaling $369,407 for
collecting and reporting stop data (Activity B.2.). We found that $179,568
is allowable and $189,839 is unallowable. The costs are unallowable
because the county claimed costs based on unsupported time increments
to report stops; and claimed stops performed by officers assigned in
jurisdictions covered by law enforcement services agreements or funded
by federal or state grants, as well as stops performed at residences of
known felons with outstanding arrest warrants, which are unallowable.
We reviewed the county’s claims to determine whether the claimed salary
and benefit costs were related to the mandate and were properly supported.
Number of Stops Reported
The county reported 35,865 stops in its claims during the audit period
(6,573 stops during FY 2018-19; 5,089 stops during FY 2019-20;
9,986 stops during FY 2020-21; 6,684 stops during FY 2021-22; and
7,533 stops during FY 2022-23).
During the audit we requested, and the county generated, Excel
spreadsheets showing stop data downloaded from its RIPA application to
support the number of stops. These spreadsheets contained the following
information:
• Stop ID number,
• Stop date and time,
• Officer ID number, and
• City where the stop occurred.
The spreadsheets supported 35,093 stops during the audit period
(6,573 stops during FY 2018-19; 5,089 stops during FY 2019-20;
9,214 stops during FY 2020-21; 6,684 stops during FY 2021-22; and
7,533 stops during FY 2022-23).
We verified the accuracy of the stop data recorded in the RIPA application
by determining whether each stop:
• Included all required elements according to the program’s parameters
and guidelines;
• Was not performed by a peace officer in a jurisdiction covered by a
law enforcement-services agreement or other agreement, or funded by
outside funding sources such as federal grants; and
• Did not occur at the residence of a known felon with an outstanding
arrest warrant.
For FY 2020-21 and FY 2022-23, we selected a statistical sample of stop
data from the documented number of stops reported by the county (the
adjusted unduplicated population) based on a 95% confidence level, a
-12-
Orange County Racial and Identity Profiling Program
precision rate of ±8%, and an expected error rate of 50%. We used
statistical sampling in order to project the results to the population for each
fiscal year. We randomly selected 295 out of 16,747 reported stops for
those two years.
Our review of the sampled stop data disclosed the following
circumstances.
FY 2020-21
We found that seven of 148 reported stops occurred in an adjacent county,
just over the county line. However, an OCSD representative explained that
these stops began in Orange County and that the officers involved crossed
the county line in order to complete the stops. Therefore, we did not
identify these seven stops as exceptions. However, 772 of the stops
claimed for FY 2020-21 are unallowable due to the difference between the
9,986 stops claimed and the audited population of 9,214 stops.
FY 2022-23
We found that two of 147 reported stops are unallowable for the following
reasons:
• One stop was performed in Imperial County, which is not a county
adjacent to Orange County; and
• One stop occurred at the residence of a known felon with an
outstanding arrest warrant.
We calculated an error rate of 1.36% for FY 2022-23 and multiplied the
audited population of 7,533 by the error rate to arrive at 102 unallowable
stops and 7,431 allowable stops.
The following table summarizes the count of claimed, supported, and
allowable stops, and the audit adjustment by fiscal year:
-13-
T
2
2
2
2
2
o
F is c a l
Y e a r
0 1 8 - 1
0 1 9 - 2
0 2 0 - 2
0 2 1 - 2
0 2 2 - 2
ta l s to
9
0
1
2
3
p s
( A )
C la im e
S to p s
6 ,5 7
5 ,0 8
9 ,9 8
6 ,6 8
7 ,5 3
3 5 ,8 6
d
3
9
6
4
3
5
( B )
S to p s
C o n d u c te d
p e r D O J
6 ,5 7 3
5 ,0 8 9
9 ,2 1 4
6 ,6 8 4
7 ,5 3 3
3 5 ,0 9 3
( C
A llo w
S to
6
5
9
6
7
3 4
)
a
p
,5
,0
,2
,6
,4
,8
b
s
2
5
1
3
3
6
le
8
4
4
9
1
6
( D ) = ( C ) − ( A
A u d it
A d ju s tm e n
( 4
( 3
( 7 7
( 4
( 1 0
( 9 9
)
t
5 )
5 )
2 )
5 )
2 )
9 )
Time Increments
The county reported in its claims that officers spent an average of
five minutes per stop during the audit period.
Orange County Racial and Identity Profiling Program
During the audit, the county provided an email from an OCSD
Commander stating that a Captain verbally notified him on March 5, 2021,
that five minutes was the average time for the completion of a RIPA stop.
He further stated that another Captain had looked for physical
documentation to support this assertion but was not successful.
The county also provided a time-study prepared on October 4, 2024, which
disclosed an average of three minutes to collect and report stop data. The
county recorded time spent collecting and reporting stop data for
36 undated stops. Eight of the stops occurred in an OCSD jurisdiction (six
from the North Patrol station and two in the county’s unincorporated area);
the other 28 stops occurred in contract cities. The RIPA time study was
prepared after the initiation of this audit and the time study’s results can
only be applied prospectively.
The test claim for this mandated program identified a DOJ field study
conducted by eight Southern California law enforcement agencies—
including OCSD—and the California Highway Patrol. The field study
concluded that 2.5 minutes was the appropriate average time to complete
a RIPA data form. We asked an OCSD representative about the field study;
the representative agreed that 2.5 minutes is the correct average time to
use for the county’s stops. Therefore, we applied 2.5 minutes to the
population of audited stops for the audit period.
Job Classifications
The county’s claims indicated that the employee classification of DSII
performed Activity B.2. The program’s parameters and guidelines state
that sworn peace officers are required to perform the reimbursable
activities. To determine which employee classifications performed the
reimbursable activities, we:
• Reviewed the lists of allowable stop data from our sample selections
to determine the actual rank and job classification of the peace officers
who performed Activity B.2.; and
• Calculated the percentage of involvement for each peace officer
employee classification that performed Activity B.2.
Our review revealed that the county’s DSIIs performed a significant
majority of the reimbursable activities, as the number of stops performed
by other employee classifications were immaterial. Therefore, we agree
that 100% of this mandated activity was performed by the county’s DSIIs.
We obtained the PHRs and related benefit rates for the county’s DSIIs for
all years of the audit period to calculate allowable salary and benefit costs.
We then multiplied the audited counts of stops by the allowable PHRs and
benefit rates for the county’s DSIIs and multiplied the product by the
average time required to perform Activity B.2.
-14-
Orange County Racial and Identity Profiling Program
The following table summarizes how we calculated allowable costs for
Activity B.2. by fiscal year:
-15-
FD
FD
FD
FD
FD
Ye
Ye
Ye
Ye
Ye
E m p lo y e e
C la s s ific a tio n
2 0 1 8 - 1 9
p u ty S h e riff II
2 0 1 9 - 2 0
p u ty S h e riff II
2 0 2 0 - 2 1
p u ty S h e riff II
2 0 2 1 - 2 2
p u ty S h e riff II
2 0 2 2 - 2 3
p u ty S h e riff II
P H(a
$ 6 1
6 3
6 5
6 7
6 9
R
)
.3 8
.1 9
.1 2
.4 7
.7 2
N u m b
o f S to
(b )
6 ,5
5 ,0
9 ,2
6 ,6
7 ,4
ep
2
5
1
3
3
r
s
8
4
4
9
1
In
T im e
c re m e n
(c )
2 .5
2 .5
2 .5
2 .5
2 .5
t
T o ta l
M in u te s
(d ) = (b ) × (c )
1 6 ,3 2 0
1 2 ,6 3 5
2 3 ,0 3 5
1 6 ,5 9 8
1 8 ,5 7 8
H o u rs
(e ) = (d ) ÷
2
2
3
2
3
6 0
7 2
1 1
8 4
7 7
1 0
A llo w a b le
S a la rie s
(f) = (a ) × (e
$ 1 6 ,6 9 5
1 3 ,3 3 3
2 5 ,0 0 6
1 8 ,6 8 9
2 1 ,6 1 3
)
B e n e fit
R a te s
(g )
8 7 .0 4 %
8 7 .7 0 %
8 7 .9 4 %
9 0 .9 2 %
8 8 .0 3 %
A llo w a b le
B e n e fits
(h ) = (f) × (g
$ 1 4 ,5 3 1
1 1 ,6 9 3
2 1 ,9 9 0
1 6 ,9 9 2
1 9 ,0 2 6
)
T o ta l
A llo w a b le
C o s ts
(i) = (f) + (h )
$ 3 1 ,2 2 6
2 5 ,0 2 6
4 6 ,9 9 6
3 5 ,6 8 1
4 0 ,6 3 9
The following table presents the claimed and allowable amounts for
salaries and benefits and the audit adjustment by fiscal year:
2
2
2
2
2
F
Y
0
0
0
0
0
T
is c a l
e a r
1 8 - 1 9
1 9 - 2 0
2 0 - 2 1
2 1 - 2 2
2 2 - 2 3
o ta ls
S a la
$ 3
2
5
3
4
$ 1 9
r
3
6
4
7
3
5
ie
,6
,7
,1
,5
,7
,9
s
2
9
9
8
6
5
1
8
1
1
7
8
C la
B e n
$ 2
2
4
3
3
$ 1 7
im
e
9
3
7
4
8
3
e d
f its
,5 9 6
,5 0 2
,6 5 5
,1 6 8
,5 2 8
,4 4 9
T o
$ 6
5
1 0
7
8
$ 3 6
ta l
3 ,2
0 ,3
1 ,8
1 ,7
2 ,2
9 ,4
1
0
4
4
9
0
7
0
6
9
5
7
S a la
$ 1 6
1 3
2 5
1 8
2 1
$ 9 5
r ie s
,6 9 5
,3 3 3
,0 0 6
,6 8 9
,6 1 3
,3 3 6
A llo w
B e n e f
$ 1 4 ,5
1 1 ,6
2 1 ,9
1 6 ,9
1 9 ,0
$ 8 4 ,2
a b
its
3 1
9 3
9 0
9 2
2 6
3 2
le
T o
$ 3
2
4
3
4
$ 1 7
ta l
1 ,2
5 ,0
6 ,9
5 ,6
0 ,6
9 ,5
2
2
9
8
3
6
6
6
6
1
9
8
A u d
A d ju s tm
$ ( 3 1
( 2 5
( 5 4
( 3 6
( 4 1
$ ( 1 8 9
it
e n
,9 9
,2 7
,8 5
,0 6
,6 5
,8 3
t
1
4
0
8
6
9
)
)
)
)
)
)
Electronic Submission to the DOJ and Retention of Stop Data Collected
The county claimed $37,270 ($19,755 in salary costs and $17,515 in
related benefits) for electronic submission of stop data to the DOJ and the
retention of stop data collected (Activity B.3.). We found that $11,413 is
allowable and $25,857 is unallowable. The costs are unallowable because
the county claimed costs based on unsupported time.
The county provided the following documentation with its claims to
support the costs for submitting electronic stop data to the DOJ and
retaining collected stop data:
• For FY 2019-20, the IT Supervisor’s declaration of time for 42 hours
spent by date describing the activities performed.
• For FY 2020-21, FY 2021-22, and FY 2022-23, lists of estimated time
spent by month and year by the IT Supervisor and the Applications
Developer.
Orange County Racial and Identity Profiling Program
During the audit, the county provided system-generated contemporaneous
data submission logs for the audit period. These logs provided the
following information:
• Start date and end date of stop reports;
• Status (“Resubmit,” “Pending Fixes,” or “Finished”);
• Log file date (electronic submission);
• Total processed;
• Total success;
• Total rejected;
• Total with errors; and
• Total HTTP errors.
We used these logs to test the validity of the dates and times claimed for
the electronic submission of data to the DOJ. Allowable costs are for those
instances when the dates on the data transmission logs matched the dates
on the supporting documentation provided.
The following table presents the claimed and allowable hours and amounts
for salaries and benefits and the audit adjustment by fiscal year.
-16-
2
2
2
2
F
Y
0
0
0
0
T
is c a l
e a r
1 9 - 2 0
2 0 - 2 1
2 1 - 2 2
2 2 - 2 3
o t a l
C
H
la im
o u r
4
9
6
5
2 5
eC
s
2
5
3
9
9
d la
S
im e d
a la r ie
B e n e
$ 5
1 3
9
8
$ 3 7
s a n
f it s
,2 9 9
,8 0 0
,2 0 3
,9 6 8
,2 7 0
d
H o u r
1
2
1
2
8
A
s
4
5
3
9
1
llo
S
w a b le
a la r ie
B e n e
$ 1
3
1
4
$ 1 1
s a n
f it s
,7 6 6
,4 6 0
,8 5 2
,3 3 5
,4 1 3
d
A
$
$
A u
d ju s
(
( 1
(
(
( 2
d
t m
3
0
7
4
5
it
e
,5 3
,3 4
,3 5
,6 3
,8 5
n
3
0
1
3
7
t
)
)
)
)
)
Audits and Validation of Data Collected
The county claimed $39,363 ($20,810 in salary costs and $18,553 in
related benefits) for audits and validation of data collected (Activity B.4.).
We found that $6,070 is allowable and $33,293 is unallowable. The costs
are unallowable because the county claimed costs based on unsupported
time.
The county provided the following documentation with its claims to
support the costs for audits and validation of data collected:
• For FY 2019-20, the county did not claim any costs for this activity.
• For FY 2020-21 and FY 2021-22, emails from a Sergeant in OCSD’s
Strategy, Accountability, Focus, and Evaluation (SAFE) Division that
listed estimated “RIPA time,” described as Senate Bill 90 qualifying
hours spent by two Deputies and a Sergeant performing Activity B.4.
Orange County Racial and Identity Profiling Program
• For FY 2022-23, a declaration of estimated time spent by two
Deputies, a Sergeant, and a Research Analyst performing Activity B.4
for OCSD, which was certified by an OCSD Captain and a Sergeant.
However, the descriptions of the activities performed were for
designing and reviewing audit graphs for RIPA reports; updating
RIPA policies; and drafting, entering data, and auditing the reports.
The Research Analyst stated clearly that the hours declared were based
on her best estimates of time spent on RIPA policies and reports.
OCSD’s SAFE Division publishes an annual RIPA Report, a current
version of which can be seen at www.ocsheriff.gov/sites/ocsd/files/2025-
05/2024%20OCSD%20Annual%20RIPA%20Statistical%20Report_0.pd
f. The report is neither a mandated report nor a reimbursable activity for
this program. Therefore, all hours estimated for SAFE Division staff
claimed as “RIPA time” were potentially not related to the mandated
activity of audits and validation of errors in stop data that had been
electronically transmitted to the DOJ.
During the audit, the county provided additional support for the time spent
by an IT Supervisor to correct and resubmit errors from previous
submissions of stop data sent to the DOJ. Based on the time spent and the
number of errors corrected, we determined an average of 1.93 minutes to
resubmit each stop report that had errors. We applied that time increment
based on the resubmitted stop reports for all years of the audit period.
The following table presents the claimed and allowable costs for salaries
and benefits and the audit adjustment by fiscal year:
-17-
2
2
2
2
F is c a
Y e a r
0 1 9 - 2
0 2 0 - 2
0 2 1 - 2
0 2 2 - 2
T o t a
l
0
1
2
3
l
$
$
A m o
C la im
8
1 5
1 5
3 9
u n
e
,3
,7
,2
,3
t
d
-
4 4
9 8
2 1
6 3
A
$
$
A m o
llo w
1
2
6
u
a
,7
,5
8
9
,0
n
b
6
0
7
2
7
t
le
6
4
8
2
0
A
$
$
A u d it
d ju s t m e
1 ,7 6
( 5 ,8 4
( 1 4 ,9 2
( 1 4 ,2 9
( 3 3 ,2 9
n
6
0
0
9
3
t
)
)
)
)
Indirect Costs
The county’s Indirect Cost Rate Proposals adequately supported its
indirect cost rates for the audit period. Using those rates, the county
claimed related indirect costs totaling $228,237 for the audit period, based
on $425,161 in claimed salaries and benefits. We found that $93,380 is
allowable and $134,857 is unallowable. The costs are unallowable because
they are based on unallowable salaries and benefits for each year of the
audit period. To recalculate indirect costs, we applied the claimed indirect
cost rates to the corresponding eligible direct costs.
Orange County Racial and Identity Profiling Program
The following table summarizes the claimed, allowable, and audit
adjustments for indirect costs by fiscal year:
-18-
2
2
2
2
2
F is c a l
Y e a r
0 1 8 - 1 9
0 1 9 - 2 0
0 2 0 - 2 1
0 2 1 - 2 2
0 2 2 - 2 3
T o ta ls
S a la r ie
a n d B e n e
C la im e
$ 1 0 3 ,4
5 8 ,3
1 2 6 ,1
1 1 2 ,0
1 2 5 ,0
sfd
6
2
9
7
9
its
3
7
3
9
9
S a la r ie s
a n d B e n e f its
A llo w a b le
$ 4 4 ,1 2 4
3 1 ,0 4 9
5 5 ,0 4 1
3 8 ,4 1 1
4 5 ,8 9 7
I n d ir e c
C o s t
R a te
3 2 .2 4
4 9 .1 3
4 7 .8 8
4 6 .9 3
4 2 .5 3
t
%
%
%
%
%
I n d ir e c t
C o s ts
C la im e d
$ 3 3 ,3 5
2 8 ,6 5
6 0 ,4 2
5 2 ,5 9
5 3 ,2 0
$ 2 2 8 ,2 3
6
6
1
9
5
7
I n d ir e c t
C o s ts
A llo w a b le
$ 1 4 ,2 2 6
1 5 ,2 5 4
2 6 ,3 5 4
1 8 ,0 2 6
1 9 ,5 2 0
$ 9 3 ,3 8 0
A u
A d ju s
$ ( 1
( 1
( 3
( 3
( 3
$ ( 1 3
d it
tm e
9 ,1 3
3 ,4 0
4 ,0 6
4 ,5 7
3 ,6 8
4 ,8 5
n
0
2
7
3
5
7
t
)
)
)
)
)
)
Criteria
Section II, “Eligible Claimants,” of the parameters and guidelines states,
in part:
. . . Cities and counties may not claim the costs of their peace officer
employees that are incurred while they are assigned out to work for other
government or private entities based on a contract or memorandum of
understanding.
Item 1 of Section III., “Period of Reimbursement,” of the parameters and
guidelines states that “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 fiscal year, only
actual costs may be claimed. Actual costs are those costs actually
incurred to implement the mandated activities. Actual costs must be
traceable and supported by source documents that show the validity of
such costs, when they were incurred, and their relationship to the
reimbursable activities. A source document is a document created at or
near the same time the actual cost was incurred for the event or activity
in question. Source documents may include, but are not limited to,
employee time records or time logs, sign-in sheet, invoices, and receipts.
Section V.A.1., “Salaries and Benefits,” of the parameters and guidelines
states:
Report each employee implementing the reimbursable activities by
name, job classification, and productive hourly rate (total wages and
related benefits divided by productive hours). Describe the specific
reimbursable activities performed and the hours devoted to each
reimbursable activity performed.
Section V.A.5, “Training,” of the parameters and guidelines states, in part:
Report the cost of training an employee to perform the reimbursable
activities, as specified in Section IV of this document. Report the name
Orange County Racial and Identity Profiling Program
and job classification of each employee preparing for, attending, and/or
conducting training necessary to implement the reimbursable activities.
Provide the title, subject, and purpose (related to the mandate of the
training session), dates attended, and location. . . .
Section V.B., “Indirect Cost Rates,” of the parameters and guidelines
states, in part:
. . . Indirect costs may include both: (1) 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. . . .
Section VII, “Offsetting Revenues and Reimbursements,” of the
parameters and guidelines states:
Any offsetting revenue the claimant experiences in the same program as
a result of the same statutes or executive orders found to contain the
mandate shall be deducted from the costs claimed. In addition,
reimbursement for this mandate from any source, including but not
limited to, service fees collected, federal funds, and other applicable state
funds, shall be identified and deducted from any claim submitted for
reimbursement.
Recommendation
We recommend that the county:
• 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.
County’s Response
The Orange County Sheriff Department (OCSD) received the Racial and
Identity Profiling Act (RIPA) Program Draft Audit Report on August 29,
2025, and acknowledges the findings presented in the draft report.
In response to the draft audit report, OCSD would like to note that the
RIPA program existed prior to reimbursement being allowed. In
April 2021, OCSD submitted claims for FY 2018-19 through
FY 2020-21. OCSD was made aware of State’s approval for cost
reimbursement on the RIPA program after services had been rendered.
Therefore, the claims submitted were based on the best information
available at that time. OCSD concurs with the audit findings and will
implement processes to ensure that allowable claim activities are
properly supported. Below are OCSD’s plan for corrective action:
• A course outline with list of attendees will be provided for all RIPA
trainings
• Provide a job number for RIPA activities coding
• Conduct periodic time studies on repetitive activities
-19-
Orange County Racial and Identity Profiling Program
Attachment—
Orange County Sheriff’s Department’s
Response to Draft Audit Report
State Controller’s Office
Division of Audits
Post Office Box 942850
Sacramento, CA 94250
www.sco.ca.gov
S24-MCC-0006