State Hospitals should create a policy requiring the facility's filing official to be appropriately trained in the collection of Form 700s. In particular, this training should cover the identification of designated individuals and the requirement to collect a Form 700 upon individuals assuming designated positions, annually thereafter, and upon their leaving their designated positions.
In June 2016 State Hospitals reported that the facility had issued a new policy to its staff. Our review of the policy determined that it had created a comprehensive policy that identified the facility's filing officers, the training the filing officers were required to complete, and set specific timelines for the completion of each training requirement. It also set specific requirements regarding how completion of the required training should be documented. Further, the policy clearly stated that filing officers should ensure that all designated employees are required to complete a Form 700 upon assuming a designated position, annually thereafter, and upon leaving their designated positions.
State Hospitals reported in March 2016 that the facility prepared an initial draft policy that had been reviewed and was undergoing revisions. It did not estimate a completion date for the facility's policy.
In addition, in January 2016 State Hospitals issued a memorandum to all Form 700 filing officials that details the responsibilities and training requirements for its filing officials. In March 2016, it reported that all of its filing officials attended training taught by the Fair Political Practices Commission regarding the collection of Form 700s.