2024-109 California Department of Housing and Community Development
Increased Support is Critical for Local Jurisdictions to Complete Timely Housing Plans
Published: January 15, 2026
Audit Recommendations Disclosure
When an audit is completed and a report is issued, auditees must provide the State Auditor with information regarding their progress in implementing recommendations from our reports at three intervals from the release of the report: 60 days, six months, and one year. Additionally, Senate Bill 1452 (Chapter 452, Statutes of 2006), requires auditees who have not implemented recommendations after one year, to report to us and to the Legislature why they have not implemented them or to state when they intend to implement them. Below is a listing of each recommendation the State Auditor made in the report referenced and a link to the most recent response from the auditee addressing their progress in implementing the recommendation and the State Auditor’s assessment of auditee’s response based on our review of the supporting documentation.
Recommendations to the Legislature
Recommendation 1
To reduce the spike in HCD’s workload that occurs when many local jurisdictions submit their revised housing elements contemporaneously, the Legislature should consider amending the housing element law to further stagger these submissions by doing the following:
Assigning housing element due dates based on smaller regional groupings and local jurisdiction size. Such an amendment should allow local jurisdictions within larger COGs to have different due dates, such as separating ABAG and SCAG deadlines by three years.
Agency response status:
Pending
Recommendation 2
To reduce the spike in HCD’s workload that occurs when many local jurisdictions submit their revised housing elements contemporaneously, the Legislature should consider amending the housing element law to further stagger these submissions by doing the following:
Establishing incentives, such as priority access to housing-related grants or streamlined review by HCD, for local jurisdictions that submit their housing element revisions, including subsequent submittals, ahead of schedule.
Agency response status:
Pending
Recommendation 3
To ensure that local jurisdictions and HCD have time to adjust to any new or updated housing element laws without disrupting current planning cycles, the Legislature should consider including a transition period, such as a delay in the effective date of a law passed during a planning cycle.
Agency response status:
Pending
Recommendations to the California Department of Housing and Community Development
Recommendation 4
To ensure that local jurisdictions have the assistance and guidance necessary to update their revised housing elements, HCD should immediately create or revise polices to do the following:
Ensure that it offers scheduled meetings to local jurisdictions following their receipt of a findings letter.
Agency response status:
Fully implemented
Date of implementation:
March 2026
State Auditor assessment status:
Fully implemented
60-Day Agency Response
HCD has updated its business processes and standard operating procedures to routinely offer jurisdictions the opportunity to meet with HCD staff within two weeks of receiving a housing element findings letter.
The letter template language has been revised to include this offer, and standard language in transmittal emails accompanying findings letters has been updated to reflect this change.
On February 19, 2026, staff received training on the new procedure to ensure consistent implementation.
Public Reasoning Behind State Auditor 60-Day Assessment
HCD provided a copy of its updated Housing Element Review Process, which includes a step for the primary reviewer to offer to provide follow up technical assistance such as informal reviews within two weeks.
Recommendation 5
To ensure that local jurisdictions have the assistance and guidance necessary to update their revised housing elements, HCD should immediately create or revise polices to do the following:
Ensure that it uses consistent language in its findings letters to distinguish between a requirement and a suggestion.
Agency response status:
Not fully implemented
Date of implementation:
6/1/2026
State Auditor assessment status:
Pending
60-Day Agency Response
On March 5, 2026, HCD held a training session with review staff on the appropriate use of requirement versus suggestive language in findings letters. HCD is currently in the process of reviewing and updating its internal review matrices, standard findings, and templated letters. HCD management will provide ongoing feedback and training (as needed) to staff to ensure consistencies between the statute, the required analysis, and recommendations. Furthermore, HCD will review and revise the existing matrices and letter templates by April 30, 2026. Standard finding language will be updated by June 1, 2026. HCD will also ensure that any future updates to standard language and template documents will adhere to these protocols.
Recommendation 6
To ensure that local jurisdictions have the assistance and guidance necessary to update their revised housing elements, HCD should immediately create or revise polices to do the following:
Establish timelines to ensure that it issues guidance for new legal requirements before those requirements take effect.
Agency response status:
Not fully implemented
Date of implementation:
7/1/26
State Auditor assessment status:
Pending
60-Day Agency Response
HCD is currently in the process of developing its Standard Operating Procedures (SOPs) for preparing technical assistance memorandums for local jurisdictions when new legislation related to housing element requirements is enacted.
These SOPs will consider two key criteria:
1. the effective date of the new law, and
2. the complexity of the legislation.
Based on these criteria, HCD will implement a two-pronged approach to releasing technical assistance on new laws.
First, for legislation with an implementation/effective date occurring within three months of the bill’s signing, HCD will issue a simplified document outlining the changes
Second, HCD will provide more comprehensive technical assistance as follows: a) For simple statutory changes, HCD will release updated technical assistance within a six-month timeframe, and b) For more complex statutory changes, HCD will release updated technical assistance within a one-year timeframe.
For legislation that has a delayed effectuation date per recommendation 3 of the CSA report, HCD will be able to provide technical assistance guidance ahead of that effective date under the farmwork above.
Recommendation 7
To ensure that local jurisdictions have the assistance and guidance necessary to update their revised housing elements, HCD should immediately create or revise polices to do the following:
Provide each local jurisdiction or group of local jurisdictions within a COG with a proposed timeline that identifies significant milestones such as expected dates for the submission of initial and revised draft housing elements and that allows adequate time for the department’s review and feedback.
Agency response status:
Not fully implemented
Date of implementation:
7/1/26
State Auditor assessment status:
Pending
60-Day Agency Response
HCD is currently in the process of developing projected timeline frameworks tailored to each COG’s statutory deadline. The framework will include key milestones jurisdictions should attempt to meet to be found in substantial compliance. The initial timeline framework will be developed by July 2026 but then the information will be tailored and distributed when regional housing needs determinations are shared to all local jurisdictions respective to their COG. A copy of the general framework timeline will also be available on HCD’s website.
Recommendation 8
To ensure that it has sufficient staffing to conduct timely and thorough housing element reviews and to provide local jurisdictions with individualized assistance as necessary, HCD should complete a comprehensive workforce analysis. This analysis should assess current and projected workload, include both primary and secondary reviewers, and specifically address times of significantly increased workload. This analysis should also include a review of the compensation offered to primary and secondary reviewers and their competitiveness to other, comparable positions.
Agency response status:
Not fully implemented
Date of implementation:
9/30/26
State Auditor assessment status:
Pending
60-Day Agency Response
HCD is currently scoping a workforce analysis
The analysis will focus on three key areas:
1. Timely Review of Housing Elements: Assess the gap between current staffing levels and projected needs to ensure sufficient resources during peak review periods. This will include estimating hours required per housing element and the volume of elements under review during high-demand years.
2. Provision of Technical Assistance: Evaluate staffing hours needed to provide technical assistance at three stages: a) Before housing element development, b) During initial draft preparation, and c) During review and subsequent resubmittals.
3. Reviewer Classifications: Determine the number of second-level reviewers required for oversight and timely feedback. This includes ensuring adequate Housing and Community Development Specialist II positions to support primary reviewers and maintain responsiveness to jurisdictions.
Proposed Timeline:
– March 31, 2026 – Complete scoping and methodology
– June 30, 2026 – Complete primary analysis and recommendations
