Report 2016-104 Recommendation 15 Responses

Report 2016-104: California Public Utilities Commission: It Should Reform Its Rules to Increase Transparency and Accountability, and Its Contracting Practices Do Not Align With Requirements or Best Practices (Release Date: September 2016)

Recommendation #15 To: Public Utilities Commission

The CPUC should update and follow its retention policy for economic interest disclosures so that it is aligned with state law.

Annual Follow-Up Agency Response From October 2019

CPUC had established a Records Retention Policy and implemented a Partially completed- CPUC-wide process that has resulted in 100% compliance with the annual Form 700 filings.(See attached written policy). The Form 700s and Ethics certifications are currently collected by designated staff and tracked via a manual, non-automated system that is also designed to meet the requirements for the retention of disclosures of economic interests. To streamline this manual process, the CPUC is reviewing options for electronic storage of disclosures of economic interests in an effective and efficient manner. CPUC is working on an electronic solution no later than September 2019 and will submit substantiation of full implementation

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

The CPUC updated its records retention policy, and it now aligns with the requirements of state law. Provided that it follows this policy, the CPUC will have fully addressed our recommendation.

Annual Follow-Up Agency Response From October 2018

The CPUC has a retention policy and is working to ensure compliance with DGS requirements. The PUC was in 100 % compliance with all annual form 700s this year. In addition, PUC is working to procure software that will allow automatic electronic software will be able to document and store all the Form 700s and Ethics certifications enabling better tracking and electronic filing.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

The CPUC did not provide evidence of its document retention policy that aligns with the requirements in state law for the retention of disclosures of economic interests.

Annual Follow-Up Agency Response From November 2017

The CPUC has a document retention policy in draft format and is now working with the Divisions to establish compliance with the the requirements for form 700s so our policy aligns with best practices.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

1-Year Agency Response

The CPUC is currently adopting an agency wide document retention policy which will include the requirements for form 700s so our policy aligns with best practices.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

CPUC is retaining all documents completed regarding statements of economic interest.

California State Auditor's Assessment of 6-Month Status: Pending

As stated in our report, the required retention period for statements of economic interests is seven years.The CPUC did not submit evidence to support its statement that it is now retaining all documents related to completed statements of economic interest. Further, it did not provide evidence that it updated its retention policy.

60-Day Agency Response

The Legal Office is currently reviewing the requirement for filing statements of economic interests and verifying what the requirement is for the CPUC employees. This will include updating the retention policy for economic interest disclosures so it aligns to state law.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2016-104

Agency responses received are posted verbatim.