To comply with the reform act, the benefit committee for San Diego County should review staff responsibilities to ensure that its conflict code requires all individuals participating in or making governmental decisions to disclose reportable interests.
IGLCBC has re-adopted the conflict of interest code as a formal part of the bylaws on February 11, 2015 to include specific references to members, alternates, and including staff. Committee Staff and members will complete 2015 Form 700s by the April 2015 deadline. A protocol is now in place for updates to the membership roster to coordinate with the County of San Diego's Clerk of the Board of Supervisors.
This Audit Finding is listed as Pending. The IGLCBC requires all members and alternates of the IGLCBC complete form 700 documents, per the attached conflict of interest codes. The IGLCBC has had the practice of including staff related to the committee, and has included them on Committee Rosters, however the Committee will consider modifications to the conflict of interest codes to include staff responsibilities. The County of San Diego County of San Diego, through the Clerk of the Board, has a process to monitor FPPC training and filing Statements of Economic Interest for all members. This will be considered further prior to the one year final response for this audit, in response to the findings. Those revisions will be provided to the California State Auditor when they are completed.
The audit finding is directed at members of the IGLCBC who either did not file a Form 700 or did not file on time. The IGLCBC has a process in place that requires staff and the filing officers to attend required training and shares this training information with the IGLCBC members. The IGLCBC will formalize these procedures in its the bylaws. However even without the formal change, the IGLCBC members have all filled appropriately in 2014, and IGLCBC staff will follow up with the filing and training requirements in future years. IGLCBC staff has and will continue to file Form 700 documents, as required for involvement in the operations and preparation of materials for the IGLCBC. These records are availalble upon request.
San Diego County's response indicates that the benefit committee will formalize the procedures in its bylaws. We have assessed the response as pending until the benefit committee updates its bylaws and provides documentation to substantiate its claim of full implementation.
†Response Type refers to the interval in which the auditee is providing the State Auditor with their status in implementing recommendations made in an audit report. Auditees must submit a response 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 or subsequent to one year.
*Agency responses received after June 2013 are posted verbatim.