Report 2017-116 Recommendation 1 Responses

Report 2017-116: Community Child Care Council of Santa Clara County: Because It Disadvantaged Some Families and Misused State Funds, It Could Benefit From Increased Monitoring by the California Department of Education (Release Date: April 2018)

Recommendation #1 To: Community Child Care Council of Santa Clara County

To ensure that families have sufficient time to respond to notices regarding eligibility, 4Cs should establish specific controls in its child-care data system by July 2018 to prevent staff from backdating the notification dates of the notices, and it should begin conducting periodic reviews of notification dates in the data system by October 2018 to ensure that the controls are effective.

1-Year Agency Response

In addition to the previous tracking and monitoring tools implemented to ensure families have sufficient time to respond to notices regarding eligibility, and reported in the October 4, 2018 Response date, the following practices have been established:

1. Development of NOA tracking spreadsheet. Case managers are responsible to notate all NOAs issued for the month and acknowledge that NOAs are mailed on the same date as stated in the case notes. Case Manager submits NOA tracking spreadsheet to supervisor for review. (Implemented September 2018)

2. Conduct periodic reviews by random sampling of files from each case manager's caseload to assure that all NOAs issued are reported accurately on the submitted spreadsheet. (Implemented December 2018)

3. Revised staff training materials on NOA process

Attachments:

1) Staff Training Materials: Proper Letter & NOA Usage

2) Case Manager Tracking NOAs (February 2019)

3) NOA Tracking Audit Log Randomized Samples (December 2018, January 2019 & February 2019)

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

4Cs provided documentation of a policy for conducting periodic reviews on an ongoing basis along with the documentation referenced in its response addressing past periodic reviews it conducted.

6-Month Agency Response

Agency has developed Tracking and Monitoring NOA tool to record Date NOA issued, Family ID, Family Name, How NOA was distributed, Reason for NOA, Recording of NOA activity in software case notes. Each staff who issues NOA is responsible for recording on spreadsheet which is reviewed and verified by Supervisor and Manager. Staff have received multiple trainings on proper issuance and tracking of NOAs. Supporting Documentation: Bi-Weekly Case Manager Discussion Sign-In Sheet_9_10_2018_11am; Bi-Weekly Cse Manager Discussion Sign In Sheet_September 10_430pm; NOA Steps to Complete Before Sending NOA; Tracking NOAs Month; NOA Tracking_Documenting Case Notes_Staff Training; Tracking NOAs Case Manager Spreadsheet_October 2018.

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

4Cs provided documentation of the controls it has implemented and subsequently informed us that it plans to begin periodic reviews in December 2018 to ensure those controls are effective.

60-Day Agency Response

On December 9, 2017, 4Cs Director of Compliance contacted the NoHo software vendor to inquire about "locking" the NoHo date generated field. Doing this would prevent a user from changing the date a Notice of Action (NOA) is created. NoHo software vendor informed the 4Cs that the NOA lock feature was "broken" and their programmers would fix it. As of February 13, 2018, the lock feature was fixed and the NOA date generated field was "locked" to prevent a user from changing the date when a NOA is created. The date the NOA is created is the default date. It cannot be changed. (Supporting documentation submitted of NoHo Screen Shot "Field is Locked - Date Integrity".)

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

4Cs provided evidence that it implemented controls to prevent the backdating of notification dates for notices of action. However, its response did not address whether it plans to conduct periodic reviews of these dates in the data system to ensure that the controls are effective.

All Recommendations in 2017-116

Agency responses received are posted verbatim.