City of Moreno Valley

CITY OF MORENO VALLEY Review Report RACIAL AND IDENTITY PROFILING PROGRAM Chapter 466, Statutes of 2015; and Chapter 328, Statutes of 2017 July 1, 2017, through June 30, 2024 M ALIA M. C OHEN C S C ALIFORNIA TATE ONTROLLER March 2026 S25-MCC-9015 STATE CONTROLLER’S OFFICE | DIVISION OF AUDITS Post Office Box 942850 | Sacramento, CA 94250 Sacramento Office: 3301 C Street, Suite 700 | Sacramento, CA 95816 | 916-324-8907 Monterey Park Office: 901 Corporate Center Drive, Suite 200 | Monterey Park, CA 91754 | 323-981-6802 www.sco.ca.gov MALIA M. COHEN CALIFORNIA STATE CONTROLLER March 6, 2026 CERTIFIED MAIL—RETURN RECEIPT REQUESTED Ms. Dena Heald, Chief Financial Officer City of Moreno Valley 14177 Frederick Street Moreno Valley, CA 92552 Dear Ms. Heald: The State Controller’s Office reviewed the costs claimed by the City of Moreno Valley (the city) for the legislatively mandated Racial and Identity Profiling Program for the period of July 1, 2017, through June 30, 2024. We conducted our review under the authority of Government Code sections 12410, 17558.5, and 17561. Our review was limited to validating the claimed contract services costs and hourly rates. The city claimed $682,158 for costs of the mandated program. Our review found that $589,168 is allowable and $92,990 is unallowable ($88,982 plus a $4,008 penalty for filing a late claim). The costs are unallowable because the city claimed costs for collecting and reporting stop data for fiscal year 2017-18, which was before the required reporting period began. The State paid the city $678,150. 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 Ms. Dena Heald March 6, 2026 Page 2 of 2 If you have any questions regarding this report, please contact Lisa Kurokawa, Chief, Compliance Audits Bureau, by telephone at 916-327-3138 or email at lkurokawa@sco.ca.gov. Thank you. Sincerely, Original signed by Kimberly A. Tarvin, CPA Chief, Division of Audits Attachments: Attachment 1—Summary of Program Costs Attachment 2—Review Results Copy: The Honorable Ulises Cabrera, Mayor City of Moreno Valley 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 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 ATTACHMENT 1—SUMMARY OF PROGRAM COSTS July 1, 2017, through June 30, 2024 Payment amounts shown below are current as of December 31, 2025. The city amended its fiscal year 2018-19 claim after the due date. Pursuant to Government Code section 17568, the State assessed a late filing penalty equal to 10 percent of allowable costs that exceed the timely filed claim amount, with no maximum penalty amount. Actual Costs Allowable Review Cost Elements Claimed per Review Adjustments July 1, 2017, through June 30, 2018 Direct costs: Salaries and benefits: Collect and report data $88,982 $0 -$88,982 Total program costs $88,982 0 -$88,982 Less: amount paid by the State -88,982 Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$88,982 Intentionally left blank Intentionally left blank July 1, 2018, through June 30, 2019 Direct costs: Salaries and benefits: Collect and report data $137,298 $0 -$137,298 Contract services: Collect and report data 0 137,298 137,298 Total direct costs 137,298 137,298 0 Less: late filing penalty 0 -4,008 -4,008 Total program costs $137,298 133,290 -$4,008 Less: amount paid by the State -133,290 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank Page 1 of 3 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 Actual Costs Allowable Review Cost Elements Claimed per Review Adjustments July 1, 2019, through June 30, 2020 Direct costs: Salaries and benefits: Collect and report data $77,737 $0 -$77,737 Contract services: Collect and report data 0 77,737 77,737 Total program costs $77,737 77,737 $0 Less: amount paid by the State -77,737 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank July 1, 2020, through June 30, 2021 Direct costs: Salaries and benefits: Collect and report data $121,229 $0 -$121,229 Contract services: Collect and report data 0 121,229 121,229 Total program costs $121,229 121,229 $0 Less: amount paid by the State -121,229 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank July 1, 2021, through June 30, 2022 Direct costs: Salaries and benefits: Collect and report data $121,098 $0 -$121,098 Contract services: Collect and report data 0 121,098 121,098 Total program costs $121,098 121,098 $0 Less: amount paid by the State -121,098 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank Page 2 of 3 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 Actual Costs Allowable Review Cost Elements Claimed per Review Adjustments July 1, 2022, through June 30, 2023 Direct costs: Salaries and benefits: Collect and report data $89,414 $0 -$89,414 Contract services: Collect and report data 0 89,414 89,414 Total program costs $89,414 89,414 $0 Less: amount paid by the State -89,414 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank July 1, 2023, through June 30, 2024 Direct costs: Salaries and benefits: Collect and report data $46,400 $0 -$46,400 Contract services: Collect and report data 0 46,400 46,400 Total program costs $46,400 46,400 $0 Less: amount paid by the State -46,400 Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank Summary: July 1, 2017, through June 30, 2024 Direct costs: Salaries and benefits Collect and report data $682,158 $0 -$682,158 Direct costs: Contract services Collect and report data 0 593,176 593,176 Total direct costs 682,158 593,176 -88,982 Less: late filing penalty 0 -4,008 -4,008 Total program costs $682,158 589,168 -$92,990 Less: amount paid by the State -678,150 Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$88,982 Intentionally left blank Intentionally left blank Page 3 of 3 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 ATTACHMENT 2—REVIEW RESULTS Background Government Code (GC) section 12525.5, as added and amended by Chapter 466, Statutes of 2015; Chapter 328, Statutes of 2017; 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 and 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. Page 1 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 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 [Department of Justice] and retention of stop data collected. . . . 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; Page 2 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 • Interactions occurring during traffic control of vehicles in response 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 when an officer is off duty. Finding—Overstated Racial and Identity Profiling Program Costs The City of Moreno Valley (the city) claimed $88,982 in costs for collecting and reporting stop data to the DOJ for fiscal year (FY) 2017-18. The costs are unallowable because the requirement to report the city’s stop data did not begin until FY 2018-19. We also found that the city misclassified its contract services costs as salary and benefit costs. The city contracts with the Riverside County Sheriff’s Department (RCSD) for its law enforcement services; therefore, the city did not incur any salary and benefit costs, but rather incurred contract services costs. We reallocated these costs to the appropriate cost category of contract services. The city used the correct methodology to calculate its salary and benefit costs: it multiplied the number of stops by the average time required to perform the reimbursable activity, then multiplied the total by the hourly rate obtained from the city’s contract with the RCSD. However, because no city staff members performed the reimbursable activities, these costs should have been classified as contract services costs, not as salary and benefit costs. Page 3 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 The following table summarizes the claimed, allowable, and review adjustment amounts by fiscal year: Salaries and Salaries and Allowable Benefits Benefits Review Contract Total Review Fiscal Claimed Allowable Adjustment Services Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [D] − [C] 2017-18 $88,982 $0 -$88,982 $0 -$88,982 2018-19 137,298 0 -137,298 137,298 0 2019-20 77,737 0 -77,737 77,737 0 2020-21 121,229 0 -121,229 121,229 0 2021-22 121,098 0 -121,098 121,098 0 2022-23 89,414 0 -89,414 89,414 0 2023-24 46,400 0 -46,400 46,400 0 Total $682,158 $0 -$682,158 $593,176 -$88,982 Contract Services Costs The city contracted with the RCSD to perform its law enforcement services during the review period. The “Police Department” page of the city’s website states, in part: The Moreno Valley Police Department provides law enforcement services including patrol, traffic enforcement, crime prevention and community engagement, detective services, and special enforcement. Law-enforcement services are contracted by the Riverside County. These services included the reimbursable activities claimed for the mandated program. Each fiscal year, the city contracted with the RCSD for various staff positions; however, only the Sheriff’s Patrol (Supported Undedicated Productive – Blended) classification performed the reimbursable activities. No city staff member performed any of the reimbursable activities under this program; therefore, the city did not incur salary and benefit costs as claimed, but rather incurred contract services costs. We reallocated the costs to the appropriate cost category of contract services. Page 4 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 Ongoing Activity B.2 – Collecting and Reporting Data The city claimed a total of $682,158 for collecting and reporting data on all stops during the review period. We found that $593,176 is allowable and $88,982 is unallowable. The costs are unallowable because the city claimed costs for collecting and reporting stop data for FY 2017-18. During discussions with a representative of the RCSD, we found that the RCSD advised the city that it had submitted data for 9,287 city stops to the DOJ for FY 2017-18. This was in error, as the RCSD was in its implementation and testing phase for the Racial and Identity Profiling Program during that fiscal year. The RCSD began reporting city stops to the DOJ beginning on July 1, 2018. Therefore, all costs claimed for FY 2017-18 are unallowable. Contract Hourly Rates The city’s claims included copies of Attachment A from the RCSD’s Law Enforcement Services Contract, which lists the RCSD’s contract law enforcement rates for each fiscal year of the review period. We found that the claimed contract hourly rates for the classification of Sheriff’s Patrol Officer were properly applied to calculate the costs for the collection and reporting of data for all stops for each fiscal year of the review period. The following table summarizes the calculation of allowable contract services costs for each fiscal year: Number of Average Time Allowable Allowable Increment Total Allowable Contract Total Allowable Fiscal Stops (in minutes) Hours Worked Hourly Rate Costs Year [A] [B] [C] = ([A] × [B]) ÷ 60 [D] [E] = [C] × [D] 2017-18 0 3.20 0.00 $179.65 $0 2018-19 14,335 3.13 747.81 183.60 137,298 2019-20 9,605 2.57 411.41 188.95 77,737 2020-21 14,191 2.59 612.58 197.90 121,229 2021-22 13,112 2.69 587.85 206.00 121,098 2022-23 9,218 2.78 427.10 209.35 89,414 2023-24 6,152 2.11 216.35 214.47 46,400 Total Intentionally left blank Intentionally left blank 3,003.10 Intentionally left blank $593,176 Page 5 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 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. Item 2.a.(1) of Section IV.B., “Ongoing Activities,” of the parameters and guidelines states: An agency that employs 1,000 or more peace officers shall begin collecting data on or before July 1, 2018, and shall issue its first round of reports on or before April 1, 2019. Section V.A.3., “Contracted Services,” of the parameters and guidelines states: Report the name of the contractor and services performed to implement the reimbursable activities. 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 services that were performed during the period covered by the reimbursement claim. If the contract services are 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 attorney invoices with the claim and a description of the contract scope of services. Page 6 of 7 Office of the State Controller | City of Moreno Valley Racial and Identity Profiling Program Review Report March 2026 Recommendation We recommend that the city: • Adhere to the Racial and Identity Profiling Program's parameters and guidelines and the SCO’s Mandated Cost Manual for Local Agencies when claiming reimbursement for mandated costs; and • Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported. End of report Page 7 of 7