San Bernardino County

SAN BERNARDINO COUNTY Final Audit Report RACIAL AND IDENTITY PROFILING PROGRAM July 1, 2017, through June 30, 2023 M ALIA M. C OHEN C S C ALIFORNIA TATE ONTROLLER March 2026 S24-MCC-0012 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 5, 2026 CERTIFIED MAIL—RETURN RECEIPT REQUESTED The Honorable Ensen Mason, CPA, CFA, Auditor-Controller San Bernardino County 268 West Hospitality Lane San Bernardino, CA 92415 Dear Auditor-Controller Mason: The State Controller’s Office audited the costs claimed by San Bernardino County (the county) for the legislatively mandated Racial and Identity Profiling Program for the period of July 1, 2017, through June 30, 2023. The county claimed and was paid $1,676,005 for costs of the mandated program. Our audit found that $1,421,078 is allowable and $254,927 is unallowable. The costs are unallowable primarily because the county overstated salaries and benefits, and 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. 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. Ensen Mason March 5, 2026 Page 2 of 3 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 Copy: Mima Ugbo, Chief Deputy Controller San Bernardino County Auditor-Controller’s Office Alejandra Villalobos, Manager Management Services Section San Bernardino County Auditor-Controller’s Office The Honorable Dawn Rowe, Chair San Bernardino County Board of Supervisors Carolina Mendoza, Chief Deputy Director Bureau of Administration San Bernardino County Sheriff’s Department Eric Patrick, Financial Manager Bureau of Administration San Bernardino County Sheriff’s Department Tiffany Escosio, Finance Officer Bureau of Administration San Bernardino County Sheriff’s Department Chris Hill, Principal Program Budget Analyst Local Government Unit California Department of Finance 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. Ensen Mason March 5, 2026 Page 3 of 3 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 | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 CONTENTS SUMMARY 1 BACKGROUND 1 AUDIT AUTHORITY 4 OBJECTIVE, SCOPE, AND METHODOLOGY 4 CONCLUSION 8 FOLLOW-UP ON PRIOR AUDIT FINDINGS 8 VIEWS OF RESPONSIBLE OFFICIALS 8 RESTRICTED USE 9 SCHEDULE—SUMMARY OF PROGRAM COSTS 10 FINDINGS AND RECOMMENDATIONS 15 ATTACHMENT—SAN BERNARDINO COUNTY’S RESPONSE TO DRAFT AUDIT REPORT 30 Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 SUMMARY The State Controller’s Office (SCO) audited the costs claimed by San Bernardino County (the county) for the legislatively mandated Racial and Identity Profiling Program for the period of July 1, 2017, through June 30, 2023. The county claimed and was paid $1,676,005 for costs of the mandated program. Our audit found that $1,421,078 is allowable and $254,927 is unallowable. The costs are unallowable primarily because the county overstated salaries and benefits, and 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 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. -1- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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 [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. . . . -2- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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 situation that requires that vehicles are stopped for public safety purposes; any type of crowd control in which pedestrians are made to remain in a location or routed to a different location for public safety purposes; interactions during which persons are detained at a residence so that the officer may check for proof of age for purposes of investigating underage drinking; and checkpoints and roadblocks in which an officer detains 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. -3- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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 the county in claiming reimbursable costs. AUDIT AUTHORITY We conducted this 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. OBJECTIVE, SCOPE, AND METHODOLOGY Our audit objective was to determine whether claimed costs represent increased costs resulting from the legislatively mandated Racial and Identity Profiling Program during the period of July 1, 2017, through June 30, 2023. Specifically, we conducted this audit to determine whether claimed costs were supported by appropriate source documents, not funded by another source, and not unreasonable and/or excessive. Unreasonable and/or excessive costs include ineligible costs that are not identified in the program’s parameters and guidelines as reimbursable costs. 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 and benefits, and indirect costs. We determined whether there were any errors, or unusual or unexpected variances from year to year. We also reviewed the claimed activities to determine whether they adhered to the SCO’s Mandated Cost Manual and the program’s parameters and guidelines. -4- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • We completed an internal control questionnaire by interviewing the county’s key staff members. We discussed the claim preparation process with the county’s staff members to determine what information was obtained, who obtained it, and how it was used. • We assessed the reliability of data (stop data, payroll, revenue, and expenditure records) generated by the county’s information management system and the county’s record management system by interviewing the county’s staff members and examining the supporting documentation. We determined that the data provided was sufficiently reliable to address the audit objective. • We reviewed and analyzed the claimed one-time training costs to verify that the costs were properly supported and were mandate-related. We verified that the claimed costs did not include duplicate employees and that the Racial and Identity Profiling Act (RIPA) training course was completed by all employees (see Finding 1). • We reviewed and analyzed the claimed costs for the identification of peace officers required to report stops, and the maintenance of a system to match individual officers to their Officer ID number. We determined that the claimed costs were reasonable. • We obtained the county’s system-generated lists of stop data—which the county had collected and reported to the DOJ—from its RIPA application to verify the existence, completeness, and accuracy of counts for each fiscal year of the audit period. We found several reported stops with a duration of negative or zero minutes that were identified as “glitches” within the county’s RIPA application. 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 for the collection and reporting of stop data for fiscal year (FY) 2018-19 through FY 2022-23, based on a moderate level of detection (audit) risk. The sampling plan is described in the Findings and Recommendations section. -5- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • We used a random number table to select 745 out of 128,509 stops from the five fiscal years sampled. We tested the stop data as follows: o We determined whether data collected for 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 sampled stops tested were performed by peace officers who were covered by a law enforcement services agreement, other 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. o We obtained employee ID numbers and ranks of peace officers from the sampled 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 reviewed and analyzed the county’s average time increments claimed to verify that the hours spent performing the reimbursable activities by each job classification were reasonable and properly supported. Based on our discussion with the county’s personnel, we determined that the county overstated the average time increments that it used to calculate its costs for collecting and reporting stop data. • We traced a sample of the county’s average productive hourly rate (PHR) calculations for the claimed job classifications to supporting information in the county’s payroll system. We determined that the claimed PHRs were reasonable. • We projected the audit results for each of the five fiscal years tested by multiplying the allowable count of stops by the allowable average time increments needed to perform the reimbursable activities and multiplying the product by the PHRs of the county employees who performed them (see Finding 1). -6- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • We reviewed and analyzed the claimed costs for electronic submission of data to the DOJ and retention of stop data collected. We determined that the claimed costs were reasonable. • We obtained the county’s system-generated lists for the audits and validation of data collected from its RIPA application to verify the total time spent for each job classification claimed. We verified that the claimed costs did not include stops with a duration of negative or zero minutes from its collection and reporting of stop data (see Finding 1). • We reviewed and analyzed the claimed costs for stop data collected, to ensure that the identities of the individual and the peace officer involved were not transmitted to the Attorney General in an open text field. We determined that the claimed costs were reasonable. • We verified that the claimed indirect costs for each fiscal year of the audit period were for common or joint purposes and that indirect cost rates were properly calculated, supported, and applied. However, the county did not allocate the appropriate percent allocation between direct and indirect costs for FY 2021-22 (see Finding 2). • We inquired with the county’s staff members and reviewed the county’s Single Audit Reports and revenue reports to identify potential sources of offsetting savings or reimbursements from federal or pass-through programs applicable to the Racial and Identity Profiling Program. We identified several programs and discussed those with the county. A county representative confirmed that it did not receive offsetting revenues applicable to the 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. -7- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 CONCLUSION As a result of performing the audit procedures, we found instances of noncompliance with the requirements described in our audit objective. We found that the county claimed costs that are ineligible, unsupported, and funded by another source, as quantified in the Schedule and described in the Findings and Recommendations section. For the audit period, the county claimed and was paid $1,676,005 for costs of the legislatively mandated Racial and Identity Profiling Program. Our audit found that $1,421,078 is allowable and $254,927 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. FOLLOW-UP ON PRIOR AUDIT FINDINGS We have not previously conducted an audit on the county’s legislatively mandated Racial and Identity Profiling Program. VIEWS OF RESPONSIBLE OFFICIALS We issued a draft audit report on October 30, 2025. The county’s representative responded by letter dated November 7, 2025, agreeing with the audit results. This final audit report includes the county’s response as an attachment. -8- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 RESTRICTED USE This report is solely for the information and use of the county, the California Department of Finance, and 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 March 5, 2026 -9- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 SCHEDULE—SUMMARY OF PROGRAM COSTS July 1, 2017, through June 30, 2023 For every fiscal year of the audit period, we found salaries and benefits that were reimbursed to the county through contracts or grants. Rather than reporting the applicable amounts as offsetting revenues, we have accounted for them in audit adjustments for direct and indirect costs related to Activity B.2., collecting and reporting stop data. Please see Finding 1 for the specifics of this adjustment. Payment amounts shown below are current as of December 3, 2025. GC section 17568 stipulates that the State will not reimburse any claim more than one year after the filing deadline specified in the SCO’s claiming instructions. That deadline has expired for FY 2021-22. Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference July 1, 2017, through June 30, 2018 Direct costs: Salaries and benefits: Train peace officers and supervisors $17,582 $17,582 $0 Intentionally left blank Total direct costs 17,582 17,582 0 Intentionally left blank Indirect costs 9,254 9,254 0 Intentionally left blank Total direct and indirect costs 26,836 26,836 0 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Total program costs $26,836 26,836 $0 Intentionally left blank Less amount paid by the state -26,836 Intentionally left blank Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank Intentionally left blank -10- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference July 1, 2018, through June 30, 2019 Direct costs: Salaries and benefits: Train peace officers and supervisors $2,489 $2,369 -$120 Finding 1 Collect and report data 268,666 171,501 -97,165 Finding 1 Audit and validate data 81,856 81,775 -81 Finding 1 Total direct costs 353,011 255,645 -97,366 Intentionally left blank Indirect costs 187,519 135,798 -51,721 Finding 1 Total direct and indirect costs 540,530 391,443 -149,087 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Total program costs $540,530 391,443 -$149,087 Intentionally left blank Less amount paid by the state -540,530 Intentionally left blank Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$149,087 Intentionally left blank Intentionally left blank Intentionally left blank July 1, 2019, through June 30, 2020 Direct costs: Salaries and benefits: Collect and report data $166,065 $133,964 -$32,101 Finding 1 Audit and validate data 50,553 50,147 -406 Finding 1 Total direct costs 216,618 184,111 -32,507 Intentionally left blank Indirect costs 116,107 98,682 -17,425 Finding 1 Total direct and indirect costs 332,725 282,793 -49,932 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Total program costs $332,725 282,793 -$49,932 Intentionally left blank Less amount paid by the state -332,725 Intentionally left blank left blank Intentionally Intentionally left blank Amount paid in excess of allowable costs -$49,932 Intentionally left blank Intentionally left blank Intentionally left blank -11- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference July 1, 2020, through June 30, 2021 Direct costs: Salaries and benefits: Train peace officers and supervisors $99 $67 -$32 Finding 1 Collect and report data 120,395 106,418 -13,977 Finding 1 Audit and validate data 54,243 54,055 -188 Finding 1 Total direct costs 174,737 160,540 -14,197 Intentionally left blank Indirect costs 83,087 76,337 -6,750 Finding 1 Total direct and indirect costs 257,824 236,877 -20,947 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Total program costs $257,824 236,877 -$20,947 Intentionally left blank Less amount paid by the state -257,824 Intentionally left blank Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$20,947 Intentionally left blank Intentionally left blank Intentionally left blank July 1, 2021, through June 30, 2022 Direct costs: Salaries and benefits: Train peace officers and supervisors $573 $480 -$93 Finding 1 Collect and report data 145,757 113,444 -32,313 Finding 1 Audit and validate data 70,880 70,880 0 Finding 1 Total direct costs 217,210 184,804 -32,406 Intentionally left blank Indirect costs 34,819 71,223 36,404 Findings 1, 2 Total direct and indirect costs 252,029 256,027 3,998 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Less allowable costs that exceed costs claimed 0 -3,998 -3,998 Intentionally left blank -12- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference Total program costs $252,029 252,029 $0 Intentionally left blank Less amount paid by the state -252,029 Intentionally left blank Intentionally left blank Intentionally left blank Allowable costs claimed in excess of amount paid $0 Intentionally left blank Intentionally left blank Intentionally left blank July 1, 2022, through June 30, 2023 Direct costs: Salaries and benefits: Identification of peace officers/Maintenance of system $8,158 $8,158 $0 Intentionally left blank Collect and report data 107,320 82,629 -24,691 Finding 1 Electronic submission of data 4,079 4,079 0 Intentionally left blank Audit and validate data 52,038 52,038 0 Intentionally left blank Ensure identities are not transmitted in open text field 16,315 16,315 0 Intentionally left blank Total direct costs 187,910 163,219 -24,691 Intentionally left blank Indirect costs 78,151 67,881 -10,270 Finding 1 Total direct and indirect costs 266,061 231,100 -34,961 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Total program costs $266,061 231,100 -$34,961 Intentionally left blank Less amount paid by the state -266,061 Intentionally left blank Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$34,961 Intentionally left blank Intentionally left blank Intentionally left blank Summary: July 1, 2017, through June 30, 2023 Direct costs: Salaries and benefits: Train peace officers and supervisors $20,743 $20,498 -$245 Finding 1 Identification of peace officers/Maintenance of system 8,158 8,158 0 Intentionally left blank Collect and report data 808,203 607,956 -200,247 Finding 1 Electronic submission of data 4,079 4,079 0 Intentionally left blank -13- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Actual Costs Allowable Audit Cost Elements Claimed per Audit Adjustment Reference Audit and validate data 309,570 308,895 -675 Finding 1 Ensure identities are not transmitted in open text field 16,315 16,315 0 Intentionally left blank Total direct costs 1,167,068 965,901 -201,167 Intentionally left blank Indirect costs 508,937 459,175 -49,762 Findings 1, 2 Total direct and indirect costs 1,676,005 1,425,076 -250,929 Intentionally left blank Less offsetting revenues and other reimbursements 0 0 0 Intentionally left blank Less allowable costs that exceed costs claimed 0 -3,998 -3,998 Intentionally left blank Total program costs $1,676,005 1,421,078 -$254,927 Intentionally left blank Less amount paid by the state -1,676,005 Intentionally left blank Intentionally left blank Intentionally left blank Amount paid in excess of allowable costs -$254,927 Intentionally left blank Intentionally left blank Intentionally left blank -14- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 FINDINGS AND RECOMMENDATIONS Finding 1—Overstated Salaries and Benefits The county claimed $1,167,068 in salaries and benefits for the audit period. We found that $965,901 is allowable and $201,167 is unallowable. Unallowable related indirect costs total $91,361, for a total adjustment of $292,528. The costs are unallowable because the county overstated the number of employees that attended or completed the one-time training, overstated the number of stops conducted, overstated the average time increments needed to perform the collection and reporting of data on all stops, overstated the number of hours claimed for audits and validation, and overstated related indirect costs. The county overstated these costs because it did not claim costs in accordance with the program's parameters and guidelines or the SCO's Mandated Cost Manual. The following table summarizes the audit adjustment by fiscal year for salaries and benefits: Salaries and Salaries and Salaries and Unallowable Benefits Benefits Benefits Related Indirect Total Audit Fiscal Claimed Allowable Audit Adjustment Costs Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [C] + [D] 2017-18 $17,582 $17,582 $0 $0 $0 2018-19 353,011 255,645 -97,366 -51,721 -149,087 2019-20 216,618 184,111 -32,507 -17,425 -49,932 2020-21 174,737 160,540 -14,197 -6,750 -20,947 2021-22 217,210 184,804 -32,406 -5,195 -37,601 2022-23 187,910 163,219 -24,691 -10,270 -34,961 Total $1,167,068 $965,901 -$201,167 -$91,361 -$292,528 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 -15- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • 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 salaries and benefits costs totaling $20,743 for one-time staff training. We found that $20,498 is allowable and $245 is unallowable. Unallowable related indirect costs total $94, for a total adjustment of $339. The costs are unallowable for the following reasons: • The county inadvertently claimed six employees (five in FY 2018-19 and one in FY 2020-21) who attended a RIPA training course more than once. • The county claimed six employees who did not complete their RIPA training course for FY 2021-22. During fieldwork, these six employees showed a status of “P” on the county’s POST (Peace Officer Standards and Training) roster. The “P” status indicated that the course was “In-Progress.” Therefore, the county confirmed that the records are based on transcripts and that training has not been completed for those individuals. The county overstated its claimed RIPA training time by 4.8 minutes (0.08 hours) per employee. The San Bernardino County Sheriff’s Department stated that the time allocated for training was 10.2 minutes (0.17 hours) per trainee. However, when the claims were prepared, the total hours worked were rounded to 0.25-hour increments. The following table summarizes the audit adjustment by fiscal year for one-time staff training: Salaries and Salaries and Salaries and Unallowable Total Benefits Benefits Benefits Related Audit Fiscal Claimed Allowable Audit Adjustment Indirect Costs Adjustment Year [A] [B] ([C] = [B] − [A]) [D] ([E] = [C] + [D]) 2017-18 $17,582 $17,582 $0 $0 $0 2018-19 2,489 2,369 -120 -64 -184 2020-21 99 67 -32 -15 -47 2021-22 573 480 -93 -15 -108 Total $20,743 $20,498 -$245 -$94 -$339 -16- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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. Collecting and Reporting Data The county claimed $808,203 in salaries and benefits for collecting and reporting stop data. We found that $607,956 is allowable and $200,247 is unallowable. Unallowable related indirect costs total $90,916, for a total adjustment of $291,163. The costs are unallowable because the county overstated the number of stops conducted, claimed stops performed by officers who were covered by law enforcement services agreements or funded by federal or state grants, and overstated its average time increments for collecting and reporting stop data. The following table summarizes the audit adjustment by fiscal year for collecting and reporting data: Salaries and Salaries and Unallowable Salaries and Benefits Benefits Audit Related Total Audit Fiscal Benefits Claimed Allowable Adjustment Indirect Costs Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [C] + [D] 2018-19 $268,666 $171,501 -$97,165 -$51,614 -$148,779 2019-20 166,065 133,964 -32,101 -17,207 -49,308 2020-21 120,395 106,418 -13,977 -6,645 -20,622 -17- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Salaries and Salaries and Unallowable Salaries and Benefits Benefits Audit Related Total Audit Fiscal Benefits Claimed Allowable Adjustment Indirect Costs Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [C] + [D] 2021-22 145,757 113,444 -32,313 -5,180 -37,493 2022-23 107,320 82,629 -24,691 -10,270 -34,961 Total $808,203 $607,956 -$200,247 -$90,916 -$291,163 Number of Stops Reported The county reported 133,619 stops in its claims during the audit period. We found that the county overstated the number of stops reported by 9,257, and that 124,362 stops are allowable. The following table summarizes the counts of claimed, supported, and allowable stops, and the audit adjustment by fiscal year: Claimed Stops Audited Population Allowable Stops Audit Adjustment Fiscal Year [A] [B] [C] [D] = [C] − [A] 2018-19 37,526 32,728 31,409 -6,117 2019-20 31,752 31,497 30,439 -1,313 2020-21 23,808 23,751 22,953 -855 2021-22 23,549 23,549 22,918 -631 2022-23 16,984 16,984 16,643 -341 Total 133,619 128,509 124,362 -9,257 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 date and time, • Stop case number, • San Bernardino County Sheriff’s Department’s station name, • Officer ID number, -18- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • Officer classification, and • Duration of stop (in minutes). After reviewing the county’s stop data listing for each fiscal year, we found that the county inadvertently claimed 321 stops that had a duration time of negative or zero minutes each: eight stops in FY 2018-19, 255 stops in FY 2019-20, 57 stops in FY 2020-21, and one stop in FY 2022-23. The county indicated that these stops were errors caused by system clock inaccuracies, time zone mismanagement, and incorrect time calculation logic on the client side of their web application. Therefore, we removed the stops with negative or zero minutes from our audited population. We verified the accuracy of the stop data recorded in the county’s 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 federal or state grants; and • Did not occur at the residence of a known felon with an outstanding arrest warrant. For FY 2018-19 through FY 2022-23, we selected a statistical sample from the documented number of stops reported by peace officers (the population) based on a 95 percent confidence level, a precision rate of plus or minus eight percent, and an expected error rate of 50 percent. We used statistical samples in order to project the results to the population for each fiscal year. We selected for review a total random sample of 745 out of 128,509 reported stops. Our review of the sampled stop data disclosed the following: • For FY 2018-19, we found that six out of 149 reported stops were unallowable. All six stops were conducted by officers whose salaries were partially funded by a federal or state grant. Therefore, we calculated an error rate of 4.03 percent for FY 2018-19. -19- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 • For FY 2019-20, we found that five out of 149 reported stops were unallowable. Three of the five stops were conducted by officers whose salaries were partially funded by a federal or state grant. The remaining two stops were conducted by an officer under contract to provide law enforcement services to a school district. Therefore, we calculated an error rate of 3.36 percent for FY 2019-20. • For FY 2020-21, we found that five out of 149 reported stops were unallowable. Four of the five stops were conducted by officers under contract to provide law enforcement services to a school district. The remaining stop was conducted by an officer whose salary was partially funded by a federal or state grant. Therefore, we calculated an error rate of 3.36 percent for FY 2020-21. • For FY 2021-22, we found that four out of 149 reported stops were unallowable. All four stops were conducted by officers whose salaries were partially funded by a federal or state grant. Therefore, we calculated an error rate of 2.68 percent for FY 2021-22. • For FY 2022-23, we found that three out of 149 reported stops were unallowable. All three stops were conducted by officers whose salaries were partially funded by a federal or state grant. Therefore, we calculated an error rate of 2.01 percent for FY 2022-23. In order to determine the allowable and unallowable stops for each fiscal year, we multiplied the audited population of stops by the error rates for FY 2018-19 through FY 2022-23. The following table summarizes the number of allowable and unallowable stops by fiscal year: Fiscal Audited Population Error Rate Total Unallowable Stops Total Allowable Stops Year [A] [B] [C] = [A] × [B] [D] = [A] − [C] 2018-19 32,728 4.03% 1,319 31,409 2019-20 31,497 3.36% 1,058 30,439 2020-21 23,751 3.36% 798 22,953 2021-22 23,549 2.68% 631 22,918 2022-23 16,984 2.01% 341 16,643 Total 128,509 4,147 124,362 Intentionally left blank -20- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Time Increments The county claimed its average time increments for collecting and reporting stop data based on each job classification that conducted a RIPA stop. The county stated that their RIPA application has an internal tracking system that captures both the start and end times for each stop. The RIPA application enforces a maximum report time of 15 minutes to prevent excessive time inflation, such as an officer stepping away briefly before submitting their RIPA form. After reviewing the county’s RIPA data listing for each fiscal year of the audit period, none of the reported stops took longer than 10 minutes. Also, a majority of the 10-minute stops that were part of our statistical sample only involved one or two persons per stop. Therefore, we excluded the 10-minute stops from the average time increment calculation, as these stops may have been incidences where the officers stepped away briefly before submitting their RIPA form. The following table shows the calculation of the allowable average minutes to conduct stops by job classification for FY 2018-19: Average Total Minutes Worked Number of Stops Minutes per Stop Job Classification [A] [B] ([C] = [A] ÷ [B]) Deputy Sheriff 33,194 10,193 3.26 Deputy Sheriff 12 Hr/80 41,363 12,936 3.20 Deputy Sheriff 12 Hr/84 5,360 1,675 3.20 Deputy Sheriff Resident 2,401 648 3.71 Lieutenant 175 35 5.00 Sergeant 4,002 980 4.08 Sergeant 12 Hr/80 & 84 385 81 4.75 Detective/Corporal 7,954 2,093 3.80 -21- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Job Classifications The county claimed various job classifications for collecting and reporting stop data based on the system-generated list from its RIPA application. These classifications included, but were not limited to, Deputy Sheriff, Deputy Sheriff Resident, Sergeant, and Detective/Corporal. To determine which job classifications performed the reimbursable activities, we: • Reviewed the stop data from our statistical sample; and • Calculated the percentage of involvement for each job classification that performed Activity B.2. We calculated allowable salaries and benefits for each job classification based on the percentage of involvement from our statistical sample, total allowable stops, allowable average time increments, and PHRs. -22- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 The following table shows the calculation of allowable salaries and benefits for each job classification for FY 2018-19: Salaries Total Average Total Total Productive and Stops Time Minutes Hours Hourly Benefits Stops Percentage Allowable Increment Worked Worked Rate Allowable Allowable Sampled ([C] = [A] × Allowable ([E] = [C] × ([F] = [E] ÷ Allowable ([H] = [F] × Job Classification [A] [B] [B]) [D] [D]) [60]) [G] [G]) Deputy Sheriff 31,409 33.55% 10,537 3.26 34,350.62 572.51 $104.10 $59,598 Deputy Sheriff 12 Hr Shift - 80 31,409 51.01% 16,022 3.20 51,270.40 854.51 85.60 73,146 Deputy Sheriff 12 Hr Shift - 84 31,409 5.37% 1,687 3.20 5,398.40 89.97 139.86 12,583 Deputy Sheriff Resident 31,409 1.34% 421 3.71 1,561.91 26.03 124.50 3,241 Sheriff's Sergeant 31,409 3.36% 1,055 4.08 4,304.40 71.74 138.89 9,964 Sheriff's Detective/Corporal 31,409 5.37% 1,687 3.80 6,410.60 106.84 121.39 12,969 Total $171,501 Intentionally left blank Intentionally left blank Intentionally left blank Intentionally left blank Intentionally left blank Intentionally left blank Intentionally left blank -23- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 The following table shows the percentage of involvement for each job classification (based on our statistical sample) for FY 2018-19: Number of Stops Percentage Conducted Sample Size Sampled Job Classification [A] [B] ([C] = [A] ÷ [B]) Deputy Sheriff 50 149 33.55% Deputy Sheriff 12 Hr Shift - 80 76 149 51.01% Deputy Sheriff 12 Hr Shift - 84 8 149 5.37% Deputy Sheriff Resident 2 149 1.34% Sheriff's Sergeant 5 149 3.36% Sheriff's Detective/Corporal 8 149 5.37% Total 149 100.00% Intentionally left blank Audits and Validation of Data Collected The county claimed $309,570 in salaries and benefits for the audits and validation of data collected. We found that $308,895 is allowable and $675 is unallowable. Unallowable related indirect costs total $351, for a total adjustment of $1,026. The costs are unallowable because the county overstated the number of stops subject to audits and validation. During fieldwork, the county provided a system-generated list that supports the total number of hours worked for the audits and validation of data collected. We found stops that had a duration of negative or zero minutes in the audits and validation file. As the reported stops with negative or zero minutes were caused by inaccuracies within the county’s RIPA application system, we removed those stops from the overall audits and validation listing. The following table summarizes the audit adjustment by fiscal year for audits and validation of data collected: Unallowable Salaries and Salaries and Related Total Benefits Benefits Audit Indirect Audit Fiscal Claimed Allowable Adjustment Costs Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [C] + [D] 2018-19 $81,856 $81,775 -$81 -$43 -$124 2019-20 50,553 50,147 -406 -218 -624 -24- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 Unallowable Salaries and Salaries and Related Total Benefits Benefits Audit Indirect Audit Fiscal Claimed Allowable Adjustment Costs Adjustment Year [A] [B] [C] = [B] − [A] [D] [E] = [C] + [D] 2020-21 54,243 54,055 -188 -90 -278 2021-22 70,880 70,880 0 0 0 2022-23 52,038 52,038 0 0 0 Total $309,570 $308,895 -$675 -$351 -$1,026 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. 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 IV.A.1., "One-Time Activities," of the parameters and guidelines states: 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. -25- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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 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 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. -26- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 County’s Response The Sheriff’s Department (Department) acknowledges the finding that certain costs were overstated due to deviations from the program’s parameters, guidelines, and the SCO Mandated Cost Manual. We are implementing the following corrective actions to ensure full compliance with all applicable requirements. Corrective Actions: • Compliance with Guidelines: The Department will provide comprehensive training to all personnel involved in the preparation and review of mandated cost claims to ensure full compliance with the program’s parameters, guidelines, and the SCO Mandated Cost Manual. • Accuracy and Documentation: The Department will strengthen its internal review procedures to verify that only eligible and actual costs are claimed, and that all claimed costs are properly supported with appropriate documentation. • Ongoing Monitoring: The Department will periodically review and update its cost- claiming processes to maintain compliance and prevent future misstatements. Finding 2—Understated Indirect Cost Rate The county understated its indirect cost rate for FY 2021-22, which resulted in understated costs totaling $41,599. The understatement occurred because the county changed the percent allocation between direct and indirect costs. -27- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 The following table summarizes the calculation of the indirect cost rate adjustment for FY 2021-22: Error Indirect Cost Rate Indirect Cost Rate Rate Salaries and Benefits Audit Claimed Allowable [C] = [B] − Allowable Adjustment [A] [B] [A] [D] [E] = [C] × [D] 16.03% 38.54% 22.51% $184,804 $41,599 Criteria Section IV., “Reimbursable Activities,” of the parameters and guidelines states, “Actual costs must be traceable and supported by source documents that show the validity of such costs. . . .” Section V.B., “Indirect Cost Rates,” of the parameters and guidelines begins: Indirect costs are costs that are incurred for a common or joint purpose, benefiting more than one program, and are not directly assignable to a particular department or program without efforts disproportionate to the result achieved. Indirect costs may include 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. Compensation for indirect costs is eligible for reimbursement utilizing the procedure provided in 2 Code of Federal Regulations (CFR) part 225 (Office of Management and Budget [OMB] Circular A-87). . . . Section V.B. of the parameters and guidelines continues: If the claimant chooses to prepare an ICRP [Indirect Cost Rate Proposal], both the direct costs (as defined and described in 2 CFR part 225, appendices A and B [OMB Circular A-87 attachments A & B]) and the indirect costs shall exclude capital expenditures and unallowable costs (as defined and described in 2 CFR part 225, appendices A and B [OMB Circular A-87 attachments A & B]). . . . -28- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 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; • Ensure that claimed costs include only eligible costs, are based on actual costs, and are properly supported; and • Allocate expenditures between direct, indirect, and unallowable costs based on the guidance in 2 CFR part 225 when calculating ICRPs. County’s Response The Department acknowledges the finding regarding the understatement of the indirect cost rate for FY 2021–22, which resulted in understated reimbursable costs. The Department notes that while the cost allocation methodology was modified during this period, we believe the revised approach remains consistent with the cost principles outlined in 2 CFR part 225 for [ICRPs]. Corrective Actions: • Compliance with Guidelines: The Department will continue to ensure adherence to the program’s parameters, guidelines, and the SCO Mandated Cost Manual when preparing and submitting mandated cost claims. • Accurate and Supported Costs: The Department will confirm that all claimed costs are eligible, based on actual expenditures, and fully supported by appropriate documentation. • Ongoing Review of Cost Allocation: The Department will periodically review its cost allocation methodology to ensure continued compliance with 2 CFR part 225 and to prevent potential misstatements in future claims. -29- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 ATTACHMENT—SAN BERNARDINO COUNTY’S RESPONSE TO DRAFT AUDIT REPORT -30- Office of the State Controller | San Bernardino County Racial and Identity Profiling Program Final Audit Report March 2026 End of report -31-