Report 2019-111 Recommendations

To reduce the risk of unidentified health and safety violations, HCD should by January 2021 use its existing authority to develop written policies and procedures for selecting parks for its park inspections that consider for all parks the number and severity of recent complaints as well as the length of time since HCD conducted any type of park visit.

To reduce health and safety risks in parks, HCD should by September 2020 develop written guidance that specifies what constitutes a field monitoring visit, how inspectors should choose parks for field monitoring, and how inspectors will document these visits.

To reduce health and safety risks in parks, HCD should by September 2020 document facility IDs and dates for all inspections and field monitoring visits in CASAS so that staff can readily determine the length of time since each park's last inspection or field monitoring visit and the type of inspection or visit that HCD conducted.

To improve consistency in inspections, HCD should by July 2021 develop and implement procedures to specify the factors that inspectors should consider when deciding whether to cite common types of violations.

To improve consistency in inspections, HCD should by July 2021 develop and implement procedures to implement and begin providing periodic refresher training to its inspectors to reinforce inspection policies.

To improve consistency in inspections, HCD should by July 2021 develop and implement procedures to require a secondary review of a selection of inspection reports to ensure that staff members follow key legal and HCD policy requirements. These procedures should specify how often secondary reviewers will review reports, how many reports they will review, what to look for during these reviews, and how to document the secondary review.

To ensure that park owners and residents have sufficient information to understand HCD's inspection process, HCD should by September 2020 establish procedures for promptly mailing notices to park owners and residents and consistently document when it mails notices.

To ensure that park owners and residents have sufficient information to understand HCD's inspection process, HCD should by September 2020 establish a process to document its reviews of compliance with time frames for mailing required notices.

To ensure that park owners and residents have sufficient information to understand HCD's inspection process, HCD should by September 2020 establish procedures to ensure that it invites residents to all live preinspection conferences it conducts.

To ensure that complaints alleging potential health and safety violations are inspected in a timely manner, HCD should by September 2020 begin periodically monitoring its compliance with time requirements for conducting complaint inspections.

To demonstrate that it is making reasonable efforts to consult with complainants before inspectors perform complaint inspections, HCD should by January 2021 develop procedures to require inspectors to document a reasonable number of attempts to contact complainants before conducting the inspection of the complaint.

To demonstrate that it is making reasonable efforts to inform complainants of the results, HCD should by January 2021 develop procedures to require staff to notify complainants in writing of the results of the inspection and document the notification.

To demonstrate that it is making reasonable efforts to notify complainants of options available if their allegations are not health and safety violations or fall outside HCD jurisdiction, HCD should by January 2021 develop procedures to verify that inspectors include information about complainants' right to pursue private civil or other action when applicable.

To ensure that HCD promptly communicates all required information to park owners and residents, HCD should by September 2020 review and revise the notices it issues to ensure that they comply with statutory requirements, such as providing information regarding the right to appeal inspectors' decisions and a list of local agencies that offer home rehabilitation or repair programs.

To ensure that HCD promptly communicates all required information to park owners and residents, HCD should by September 2020 establish a process to review notifications annually for compliance with any changes in its inspection procedures.

To ensure that HCD appropriately uses the revenue from fees it collects for the parks program activities only for the fees' intended purposes, HCD should by September 2020 require staff, including inspectors, in the codes and standards division to charge hours that accurately reflect the work they perform.

To ensure that HCD appropriately tracks the time inspectors spend on each program activity, HCD should by September 2020 rescind the time reporting guidance in the August 2015 memorandum and issue new guidance in accordance with HCD policy. It should then require managers to verify the accuracy of inspector timesheets.

To ensure that HCD is able to determine its anticipated workload needs, HCD should by September 2020 establish procedures that ensure that staff accurately record each inspector's time spent on program activities in CASAS.

To prevent misuse of state time and state vehicles by inspectors, HCD should by September 2020 establish a formal process to routinely monitor vehicle usage, including specifics on how and when managers should review inspectors' GPS data, such as information on location and mileage use, to ensure that inspectors use state vehicles and state time only for their official duties.

To ensure that it is aware of any potential conflicts of interest that its inspectors may have, HCD should by September 2020 develop procedures to review the annual and assuming-position Form 700s of all inspectors with reportable financial interests to identify potential conflicts of interest.

To ensure that it is aware of any potential conflicts of interest that its inspectors may have, HCD should by September 2020 develop procedures to ensure that staff promptly notify the Form 700 filing officer of all inspectors hired or leaving HCD employment.

To ensure that it is aware of any potential conflicts of interest that inspectors may have involving real property, HCD should by January 2021 amend its conflict-of-interest code to require inspectors to disclose financial interests in real property.

To ensure that it complies with state law regarding reporting requirements for Form 700s, by August 2020 HCD should notify inspectors with missing Form 700s of their responsibility to file and the potential penalties that may be assessed if they fail to do so. HCD should notify the Fair Political Practices Commission about any inspectors who do not submit the forms as required after notification was sent as well as those who should have submitted Form 700s but who cannot be located as of August 2020.

To demonstrate that it appropriately addresses all complaints alleging inspector misconduct, HCD should by September 2020 establish policies to document all complaints against inspectors and the steps it takes to address those complaints.

To demonstrate that it appropriately addresses all complaints alleging inspector misconduct, HCD should by September 2020 refer all complaints against inspectors alleging misconduct to its equal employment opportunity officer or other individual specified in policy.

To ensure that HCD evaluates LEA oversight of mobile home parks effectively, by January 2021 HCD should continue its efforts to finalize its policies and procedures for evaluating LEAs and ensure that staff members follow its procedures for handling complaints it forwards to those LEAs.

To ensure that HCD evaluates LEA oversight of mobile home parks effectively, by January 2021 HCD should develop a formalized schedule to evaluate an adequate number of LEAs each year. HCD could establish a risk-based approach for selecting LEAs to evaluate.

To ensure that HCD evaluates LEA oversight of mobile home parks effectively, by January 2021 HCD should develop formal training for its inspectors in the use of its inspection checklist when conducting LEA evaluations.