SCO
CIty of Long Beach
Domestic Violence Arrest Policies and Standards
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CITY OF LONG BEACH
Audit Report
DOMESTIC VIOLENCE ARREST POLICIES AND
STANDARDS PROGRAM
Chapter 246, Statutes of 1995
July 1, 2019, through June 30, 2023
M M. C
ALIA OHEN
C
ALIFORNIA
S
TATE
C
ONTROLLER
September 2025
MALIA M. COHEN
CALIFORNIA STATE CONTROLLER
September 2, 2025
CERTIFIED MAIL—RETURN RECEIPT REQUESTED
Mr. Kevin Riper, Director
Financial Management Department
City of Long Beach
411 West Ocean Boulevard
Long Beach, CA 90802
Dear Director Riper:
The State Controller’s Office audited the costs claimed by the City of Long Beach (the city) for
the legislatively mandated Domestic Violence Arrest Policies and Standards Program for the
period of July 1, 2019, through June 30, 2023.
The city claimed and was paid $465,699 for costs of the mandated program. Our audit found that
$409,118 is allowable and $56,581 is unallowable. The costs are unallowable because the city
overstated salary and benefit costs, and related indirect costs.
Following issuance of this 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.
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/am
.
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. Kevin Riper
September 2, 2025
Page 2 of 2
Copy: The Honorable Rex Richardson, Mayor
City of Long Beach
Shawna Stevens, Chief of Staff
City of Long Beach
Christian Cambridge, Financial Services Officer
City of Long Beach
Rebecca Bernstorff, Budget Manager
Financial Management Department
City of Long Beach
Geraldine Alejo, Revenue Management Officer
Financial Management Department
City of Long Beach
Wally Hebeish, Chief
Long Beach Police Department
Julissa Jose-Murray, Chief
Business Operations Bureau
Long Beach Police 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
City of Long Beach Domestic Violence Arrest Policies and Standards Program
Contents
Audit Report
Summary ............................................................................................................................ 1
Background ........................................................................................................................ 1
Audit Authority.................................................................................................................. 1
Objective, Scope, and Methodology ................................................................................. 1
Conclusion .......................................................................................................................... 3
Follow-up on Prior Audit Findings .................................................................................. 4
Views of Responsible Officials .......................................................................................... 4
Restricted Use .................................................................................................................... 4
Schedule—Summary of Program Costs .............................................................................. 5
Findings and Recommendations ........................................................................................... 7
Attachment—City’s Response to Draft Audit Report
City of Long Beach Domestic Violence Arrest Policies and Standards Program
Audit Report
Summary The State Controller’s Office (SCO) audited the costs claimed by the City
of Long Beach (the city) for the legislatively mandated Domestic Violence
Arrest Policies and Standards Program for the period of July 1, 2019,
through June 30, 2023.
The city claimed and was paid $465,699 for costs of the mandated
program. Our audit found that $409,118 is allowable and $56,581 is
unallowable. The costs are unallowable because the city overstated salary
and benefit costs, and related indirect costs.
Background Penal Code (PC) section 13701, subdivision (b) (added by Chapter 246,
Statutes of 1995), required local law enforcement agencies to develop,
adopt, and implement written arrest policies for domestic violence
offenders by July 1, 1996. The legislation also required local law
enforcement agencies to obtain input from local domestic violence
agencies in developing the arrest policies. Under previous law, local law
enforcement agencies were required to develop, adopt, and implement
written policies for response to domestic violence calls and were
encouraged, but not obligated, to consult with domestic violence experts.
On September 25, 1997, the Commission on State Mandates determined
that Chapter 246, Statutes of 1995, imposed a state mandated program
reimbursable under Government Code (GC) section 17561.
The program’s parameters and guidelines establish the state mandate and
define the reimbursement criteria. The Commission on State Mandates
adopted the parameters and guidelines on August 20, 1998, and amended
them on October 30, 2009. In compliance with GC section 17758, the SCO
issues the Mandated Cost Manual for Local Agencies (Mandated Cost
Manual) to assist local agencies in claiming mandated program
reimbursable costs.
We conducted this performance audit in accordance with GC
Audit Authority
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
Domestic Violence Arrest Policies and Standards 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 unsupported and ineligible costs that are not
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City of Long Beach Domestic Violence Arrest Policies and Standards Program
identified in the program’s parameters and guidelines as reimbursable
costs.
The audit period was July 1, 2019, through June 30, 2023.
To achieve our objective, we performed the following procedures:
• We reviewed the annual mandated cost claims filed by the city for the
audit period and identified the significant cost components of each
claim as salaries and benefits, and related indirect costs. We then
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
city staff members. We discussed the claim preparation process with
city staff to determine what information was obtained, who obtained
it, and how it was used. We determined which controls were
significant to the audit objective, and the effect of the identified
internal control weaknesses on the audit objective.
• We assessed the reliability of the data (payroll, revenue and
expenditure records) generated from the city’s information
management system and the city’s record management system,
Central Square Records Enterprise, by interviewing city staff
members and examining supporting documentation. We determined
that the data was sufficiently reliable to address the audit objective.
• We verified that the city used the uniform time allowance and applied
it properly.
• We reviewed and analyzed the claimed domestic violence incident
report counts and verified that these counts were supported by the
city’s Central Square Records Enterprise.
• We used simple random sampling to select the following statistical
samples from the audited population of incident reports:
o We sampled 140 of 1,998 incident reports for fiscal year
(FY) 2019-20.
o We sampled 139 of 1,924 incident reports for FY 2020-21.
o We sampled 140 of 2,094 incident reports for FY 2021-22.
o We sampled 140 of 2,107 incident reports for FY 2022-23.
• We determined whether the sampled incident reports included
interviews with both parties involved in the domestic violence
incident, and whether the officer considered the 17 factors listed in the
parameters and guidelines to identify the primary aggressor. We
identified the following errors:
o Of the 140 sampled incident reports for FY 2019-20, 44 were
partially reimbursable.
o Of the 139 sampled incident reports for FY 2020-21, 50 were
partially reimbursable and two were non-mandate-related.
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City of Long Beach Domestic Violence Arrest Policies and Standards Program
o Of the 140 sampled incident reports for FY 2021-22, 47 were
partially reimbursable and one was non-mandate-related.
o Of the 140 sampled incident reports for FY 2022-23, 58 were
partially reimbursable and one was non-mandate-related.
Errors found were projected to the intended (total) population; see
Finding 1.
• We recalculated the allowable costs using the audited incident report
counts.
• We interviewed city staff members to determine what employee
classifications were involved in performing the mandated activities
during the audit period.
• We traced the average productive hourly rate calculations for the
claimed employee classification to supporting information in the
city’s payroll system.
• We verified the indirect costs claimed by the city for the audit period.
We found that the city had overstated the indirect cost rate claimed for
FY 2022-23; see Finding 2.
• We traced the benefit rate calculations for the claimed employee
classification to supporting information in the city’s cost allocation
plans.
• We verified that the city’s claimed costs were not funded by any other
sources.
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
did not find that the city claimed costs that were funded by other sources;
however, we found that it claimed unsupported and ineligible costs as
quantified in the Schedule and described in the Findings and
Recommendations section.
For the audit period, the city claimed and was paid $465,699 for costs of
the legislatively mandated Domestic Violence Arrest Policies and
Standards Program. Our audit found that $409,118 is allowable and
$56,581 is unallowable.
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.
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City of Long Beach Domestic Violence Arrest Policies and Standards Program
Follow-up on We have not previously conducted an audit of the city’s legislatively
mandated Domestic Violence Arrest Policies and Standards Program.
Prior Audit
Findings
Views of We issued a draft audit report on June 3, 2025. The ctiy’s representatives
Responsible responded by letter dated June 12, 2025, agreeing with the audit findings.
This final audit report includes the city’s response as an attachment.
Officials
Restricted Use This audit report is solely for the information and use of the city, 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 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
September 2, 2025
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City of Long Beach Domestic Violence Arrest Policies and Standards Program
Schedule—
Summary of Program Costs
July 1, 2019, through June 30, 2023
Actual Costs Allowable Audit
Cost Elements Claimed per Audit Adjustment Reference ¹
July 1, 2019, through June 30, 2020
Direct costs:
Salaries and benefits $ 79,681 $ 73,034 $ (6,647) Finding 1
Indirect costs 27,460 25,169 ( 2,291) Finding 1
Total direct and indirect costs 107,141 98,203 ( 8,938)
Less offsetting revenues and reimbursements2 - - -
Total program costs $ 1 07,141 98,203 $ (8,938)
Less amount paid by the State3 (107,141)
Amount paid in excess of allowable costs claimed $ (8,938)
July 1, 2020, through June 30, 2021
Direct costs:
Salaries and benefits $ 78,548 $ 68,681 $ (9,867) Finding 1
Indirect costs 27,413 23,968 ( 3,445) Finding 1
Total direct and indirect costs 105,961 92,649 (13,312)
Less offsetting revenues and reimbursements2 - - -
Total program costs $ 1 05,961 92,649 $ (13,312)
Less amount paid by the State3 (105,961)
Amount paid in excess of allowable costs claimed $ (13,312)
July 1, 2021, through June 30, 2022
Direct costs:
Salaries and benefits $ 88,391 $ 79,158 $ (9,233) Finding 1
Indirect costs 31,464 28,178 ( 3,286) Finding 1
Total direct and indirect costs 119,855 107,336 (12,519)
Less offsetting revenues and reimbursements2 - - -
Total program costs $ 1 19,855 107,336 $ (12,519)
Less amount paid by the State3 (119,855)
Amount paid in excess of allowable costs claimed $ (12,519)
-5-
City of Long Beach Domestic Violence Arrest Policies and Standards Program
Schedule (continued)
-6-
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_________________________
1 See the Findings and Recommendations section.
2 We determined the claimed costs were not funded by any other sources.
3 Payment amount current as of July 28, 2025.
City of Long Beach Domestic Violence Arrest Policies and Standards Program
Findings and Recommendations
FINDING 1— The city claimed non-reimbursable salaries and benefits totaling $37,702.
The related indirect costs total $13,603, for a total finding of $51,305.
Non-reimbursable
costs
The reimbursable activities for this cost component consist of interviewing
both parties involved in the domestic violence incident and considering
the 17 factors identified in the program’s parameters and guidelines to
identify the primary aggressor.
To calculate the claimed costs, the city multiplied the number of reported
responses to incidents by the average productive hourly rate, including the
applicable indirect costs, then multiplied the resulting amount by the
standard time of 29 minutes (0.48 of an hour).
For each fiscal year, we selected a statistical sample from the documented
number of domestic violence incident reports (the audited population)
based on a 95% confidence level, a precision rate of ± 8%, and an expected
error rate of 50%. We used statistical samples so that the results could be
projected to the population for each fiscal year.
For testing purposes, we selected a random sample of 559 incident reports
(140 for FY 2019-20, 139 for FY 2020-21, 140 for FY 2021-22, and
140 for FY 2022-23). We reviewed the sample incident reports to
determine whether the city performed the required mandated program
activities.
We documented the results of our review of sample incident reports as
follows:
• Allowable – 356 incident reports were fully reimbursable under the
mandated program. These reports are reimbursable at 29 minutes
(0.48 hours) per report.
• Partially reimbursable – 199 incident reports were partially
reimbursable, because the officers did not interview both parties
involved in the domestic violence incident. These reports are
reimbursable at 20.5 minutes (0.34 hours) per report, based on
8.5 minutes to interview one party and 12 minutes to consider the
various factors identified in the program’s parameters and guidelines.
• Unallowable – Four incident reports were ineligible for
reimbursement or were non-mandate-related. Non-mandate-related
incidents were those that did not meet the definition of domestic
violence as provided in PC section 13700; the incidents relate to no
interviews documented or provided, verbal altercation, or false
accusation.
During testing, we found that the city claimed the entire standard time of
29 minutes for incident reports that were only partially reimbursable and
claimed reimbursement for ineligible and unsupported incident reports.
The city overstated these costs because it did not claim costs in accordance
-7-
City of Long Beach Domestic Violence Arrest Policies and Standards Program
with the program’s parameters and guidelines or the SCO’s Mandated
Cost Manual.
The following table summarizes the results of the statistical samples:
-8-
A
P
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T
llo w a b le in c id e n
a r tia lly r e im b u r s
( o n ly o n e p a r
n a llo w a b le in c id
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t r e p o r ts
a b le in c id e n
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p le d
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2 0 1 9 - 2 0
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4 4
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8 1
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T o ta l
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4
5 5 9
The following table summarizes the unallowable hours based on the
results of the statistical samples by fiscal year:
Fiscal Year
2019-20 2020-21 2021-22 2022-23 Total
Allowable incident reports 9 6 8 7 9 2 8 1 3 56
Standard time allowance (hours) × 0.48 × 0.48 × 0.48 × 0.48
Subtotal [A] 4 6 4 2 4 4 3 9
Partially reimbursable incident reports
(only one party interviewed) 4 4 5 0 4 7 5 8 1 99
Allowable standard time allowance (hours) × 0.34 × 0.34 × 0.34 × 0.34
Subtotal [B] 1 5 1 7 1 6 2 0
Total reimbursable hours
for sampled reports [C] = [A] + [B] 6 1 5 9 6 0 5 9
Statistical sample size ÷ 140 ÷ 139 ÷ 140 ÷ 140
Reimbursable hours per report 0.44 0.42 0.43 0.42
Documented number of domestic
violence incident reports × 1,998 × 1,924 × 2,094 × 2,107
Total reimbursable hours 879 808 900 885
Hours per documented number of domestic
violence incident reports + ( 959) + ( 924) + (1,005) + (1,011)
Total unallowable hours (80) ( 116) ( 105) ( 126)
City of Long Beach Domestic Violence Arrest Policies and Standards Program
The following table summarizes the unallowable costs based on the
unallowable hours identified from the statistical samples by fiscal year:
-9-
1
U n a llo w a b le h o u rs
C la im e d a v e ra g e P H R (s a la ry o n ly )
U n a llo w a b le s a la rie s [A ]
C la im e d b e n e fit ra te [B ]
R e la te d u n a llo w a b le b e n e fit c o s ts [C ] = [A
T o ta l u n a llo w a b le s a la rie s a n d b e n e fits
[D ] = [A ] + [C ]
C la im e d in d ire c t c o s t ra te [E ]
1 R e la te d in d ire c t c o s ts [F ] = [D ] x [E ]
A u d it a d ju s tm e n t [G ] = [D ] + [F ]
In d ire c t c o s ts w e re c o m p u te d u s in g s a la rie
] x
s a
[B ]
n d b e n
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(8
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Criteria
Section IV, “Reimbursable Activities,” of the parameters and guidelines
begins:
To be eligible for mandated cost reimbursement for any fiscal year, only
actual costs may be claimed. Actual costs are those costs actually
incurred to implement the mandated activities. Actual costs must be
traceable and supported by source documents that show the validity of
such costs, when they were incurred, and their relationship to the
reimbursable activities. A source document is a document created at or
near the same time the actual cost was incurred for the event or activity
in question. Source documents may include, but are not limited to,
employee time records or time logs, sign-in sheets, invoices, and
receipts. . . .
Section IV, “Reimbursable Activities,” of the parameters and guidelines
continues:
The claimant is only allowed to claim and be reimbursed for increased
costs for reimbursable activities. . . . Increased cost is limited to the cost
of an activity that the claimant is required to incur as a result of the
mandate.
Section IV.E, “Uniform Cost Allowance,” of the parameters and guidelines
states:
Pursuant to Government Code section 17557, the Commission on State
Mandates has adopted a uniform cost allowance for reimbursement in
lieu of payment of total actual costs incurred. The uniform cost
allowance is applied only to Section IV, Reimbursable Activities,
Component D (Implementation of the New Domestic Violence Arrest
Policies to Identify the Primary Aggressor) and covers all costs (direct
and indirect) of performing activities described under Component D. The
uniform cost allowance provides the following:
A standard time of twenty-nine (29) minutes may be claimed to
identify the primary aggressor in any domestic violence incident.
City of Long Beach Domestic Violence Arrest Policies and Standards Program
The standard time of twenty-nine (29) minutes is broken down as
follows:
• Seventeen (17) Minutes – Interview of both parties
• Twelve (12) Minutes – Consideration of the factors listed
[under Component D]
The total cost will be determined by multiplying the number of reported
responses × the average productive hourly rate, including applicable
indirect costs as specified in section V., paragraph B, herein, × .48
(29 minutes divided by 60 minutes).
Recommendation
We recommend that the city:
• Follow the program’s parameters and guidelines and the SCO’s
Mandated Cost Manual when preparing its reimbursement claims;
• Claim costs for only those reports that document incidents meeting the
definition of domestic violence by PC section 13700; and
• Claim only the portion of the standard time allowance that is
attributable to the mandated activities performed.
City’s Response:
The city concurred with the audit finding.
FINDING 2— For the audit period, the city claimed indirect costs based on indirect cost
rate proposals (ICRP) prepared for the police department. We found that
Overstated indirect
the city overstated its indirect costs for FY 2022-23 by $5,276. The costs
cost rates
were overstated because the city used the incorrect Cost Allocation Plans,
and used costs incurred in the fiscal period of October through September
instead of July through June.
During testing, we requested, and the city provided, expenditure reports
and Cost Allocation Plans with the correct fiscal period of July through
June for FY 2019-20 through FY 2022-23. We found that by using the
incorrect fiscal period, the city overstated the indirect costs rate for
FY 2022-23. We applied the error rate to allowable salaries and benefits
to calculate the overstated indirect costs for FY 2022-23, a total finding of
$5,276. The city overstated these costs because it did not claim costs in
accordance with the program’s parameters and guidelines or the SCO’s
Mandated Cost Manual.
The following table summarizes the claimed, allowable, and adjusted
indirect cost rates:
Claimed Allowable
Fiscal Indirect Cost Indirect Cost Audit
Year Rate Rate Adjustment
2022-23 38.32% 32.04% (6.28)%
-10-
City of Long Beach Domestic Violence Arrest Policies and Standards Program
The following table summarizes the adjustment to the indirect costs:
Fiscal Year
2022-23 Total
Allowable indirect cost rate 32.04%
Claimed indirect cost rate + (38.32)%
Error rate (6.28)%
Allowable salaries and benefits × 84,010
Audit adjustment $ ( 5,276) $ ( 5,276)
Criteria
Section IV, “Reimbursable Activities,” of the parameters and guidelines
begins:
To be eligible for mandated cost reimbursement for any fiscal year, only
actual costs may be claimed. Actual costs are those costs actually
incurred to implement the mandated activities. Actual costs must be
traceable and supported by source documents that show the validity of
such costs, when they were incurred, and their relationship to the
reimbursable activities. A source document is a document created at or
near the same time the actual cost was incurred for the event or activity
in question. Source documents may include, but are not limited to,
employee time records or time logs, sign-in sheets, invoices, and
receipts. . . .
Section IV, “Reimbursable Activities,” of the parameters and guidelines
continues:
The claimant is only allowed to claim and be reimbursed for increased
costs for reimbursable activities. . . . Increased cost is limited to the cost
of an activity that the claimant is required to incur as a result of the
mandate.
Section V.B., “Indirect Costs,” of the parameters and guidelines states:
Indirect costs are defined as costs which are incurred for common or joint
purpose, benefiting more than one program and are not directly
assignable to a particular department of program without efforts
disproportionate to the result achieved. Indirect costs may include both
(1) overhead costs of the unit performing the mandate; and (2) the costs
of central government services distributed to other departments based on
a systematic and rational basis through a cost allocation plan.
Compensation for indirect costs is reimbursable utilizing the procedure
provided in the [Office of Management and Budget Circular] A-87.
Claimants have the option of using 10% of direct labor, excluding fringe
benefits, or preparing a departmental Indirect Cost Rate Proposal (ICRP)
for the department if an indirect cost in excess of 10% is claimed. If more
than one department is claiming indirect costs for the mandated program,
each department must have its own ICRP prepared in accordance with
[Office of Management and Budget Circular] A-87. An ICRP must be
submitted with the claim when the indirect cost rate is in excess of 10%.
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City of Long Beach Domestic Violence Arrest Policies and Standards Program
Recommendation
We recommend that the city:
• Follow the program’s parameters and guidelines and the SCO’s
Mandated Cost Manual when preparing its reimbursement claims;
• Ensure that the correct fiscal year costs are used to calculate indirect
cost rates applicable to the corresponding fiscal year; and
• Ensure that the correct fiscal period of July through June is used to
calculate indirect cost rates.
City’s Response:
The city concurred with the audit finding.
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City of Long Beach Domestic Violence Arrest Policies and Standards 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
S25-MCC-0005