Report 2019-114 All Recommendation Responses

Report 2019-114: California State University: The Mandatory Fees Its Campuses Charge Receive Little Oversight Yet They Represent an Increasing Financial Burden to Students (Release Date: May 2020)

Recommendation for Legislative Action

To ensure that all funding that students and the Legislature provide to the CSU system to pay for its core functions receives the same oversight, the Legislature should do the following:

- Direct the Chancellor's Office to review mandatory fee expenditures across all 23 campuses and, by December 2020, report to the Legislature how much campuses spent of those fees on faculty and academic support staff, classroom and laboratory improvements, educational equipment and software, student trips and events, instruction-related facility improvements, and athletics in fiscal year 2018-19. The Chancellor's Office should also report the proportions and dollar amounts of these fee expenditures that directly support the CSU's core functions—namely, instructing and graduating students who are prepared to succeed.

- Using this information, determine and implement the most effective centralized way to fund the core functions for which mandatory fees currently pay.

- Upon implementing the new funding approach, prohibit CSU campuses from charging and using revenue from mandatory fees—including student success fees; instructionally related activities fees; and materials, services, and facilitates fees—to pay for any of the identified core functions. This prohibition should also apply to any mandatory fees campuses create in the future.

Description of Legislative Action

As of June 23, 2022, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

As of June 23, 2022, the Legislature has not taken action to address this specific recommendation.

Description of Legislative Action

As of May 14, 2021, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 1-Year Status: No Action Taken

Description of Legislative Action

As of November 14, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of July 14, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation for Legislative Action

To ensure that CSU students have a strong voice regarding the mandatory fees they must pay, the Legislature should amend state law to require campuses to hold binding student votes when seeking to establish or increase any mandatory fee. The Legislature should require the Chancellor's Office to verify the results of all student votes before the chancellor approves fee changes.

Description of Legislative Action

As of June 23, 2022, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

As of June 23, 2022, the Legislature has not taken action to address this specific recommendation.

Description of Legislative Action

As of November 14, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 6-Month Status: No Action Taken

Description of Legislative Action

As of July 14, 2020, the Legislature has not taken action to address this specific recommendation.

California State Auditor's Assessment of 60-Day Status: No Action Taken

Recommendation #3 To: University, California State

To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should revise its fee policy to require campuses to justify amounts for new or increasing fees by providing supporting documentation demonstrating the need for the fees, how they calculated the fee amounts, and how they determined that no other source of funding could pay for the needed services.

Annual Follow-Up Agency Response From September 2023

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees. CSU management believes that these steps are sufficient and will not take any further action.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. Because the fee policy does not contain meaningful requirements in these areas, the response from the Chancellor's Office that its audits did not identify issues with campus processes does not address our concern.

Annual Follow-Up Agency Response From October 2022

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation.

As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. For example, as we discuss on pages 28-32, the vague requirements in the fee policy allowed the campuses we reviewed to impose or increase mandatory fees without justifying specific fee amounts. Further, the fee policy does not require campuses to demonstrate that they have no other way to pay for their needs, and the campuses we reviewed consistently failed to do so.

Because the fee policy does not contain meaningful requirements in these areas, the conclusions CSU reaches based on its recent audits are not relevant and CSU's response does not address the deficiencies we found in the policy. The Chancellor's Office's planned approach is also concerning because it did not dispute any of our conclusions in its response to the audit report and, in fact, on page 53 stated its intention to implement our recommendations to improve its policies and practices. Therefore, we stand by our recommendation that the Chancellor's Office revise its policy to require campuses to justify amounts for new or increasing fees.

Annual Follow-Up Agency Response From October 2021

At the May 2021 meeting, the Board of Trustees approved audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees. The first of these audits started on September 27, 2021, and two more are currently planned.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

As with its previous responses, the Chancellor's Office's reported action does not address our recommendation.

As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. For example, as we discuss on pages 28-32, the vague requirements in the fee policy allowed the campuses we reviewed to impose or increase mandatory fees without justifying specific fee amounts. Further, the fee policy does not require campuses to demonstrate that they have no other way to pay for their needs, and the campuses we reviewed consistently failed to do so.

Because the fee policy does not contain meaningful requirements in these areas, the described action regarding internal audit activities to ensure adherence to CSU policy is not relevant and will not address the deficiencies we found in the policy. The Chancellor's Office's planned approach is also concerning because it did not dispute any of our conclusions in its response to the audit report and, in fact, on page 53 stated its intention to implement our recommendations to improve its policies and practices. Therefore, we stand by our recommendation that the Chancellor's Office revise its policy to require campuses to justify amounts for new or increasing fees.

1-Year Agency Response

At the May 2021 meeting, the Board of Trustees is expected to approve audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The Chancellor's Office's response does not address our recommendation.

As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. For example, as we discuss on pages 28-32, the vague requirements in the fee policy allowed the campuses we reviewed to impose or increase mandatory fees without justifying specific fee amounts. Further, the fee policy does not require campuses to demonstrate that they have no other way to pay for their needs, and the campuses we reviewed consistently failed to do so.

Because the fee policy does not contain meaningful requirements in these areas, the described plan to conduct internal audit activities to ensure adherence to CSU policy is not relevant and will not address the deficiencies we found in the policy. The Chancellor's Office's planned approach is also concerning because it did not dispute any of our conclusions in its response to the audit report and, in fact, on page 53 stated its intention to implement our recommendations to improve its policies and practices. Therefore, we stand by our recommendation that the Chancellor's Office revise its policy to require campuses to justify amounts for new or increasing fees.

6-Month Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services is developing its 2021-22 audit plan and will include at least one fee audit in the audit plan it submits to the Board of Trustees for approval in May 2021.

California State Auditor's Assessment of 6-Month Status: No Action Taken

The Chancellor's Office's response does not address our recommendation.

As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. For example, as we discuss on pages 28-32, the vague requirements in the fee policy allowed the campuses we reviewed to impose or increase mandatory fees without justifying specific fee amounts. Further, the fee policy does not require campuses to demonstrate that they have no other way to pay for their needs, and the campuses we reviewed consistently failed to do so.

Because the fee policy does not contain meaningful requirements in these areas, the Chancellor's Office's plan to increase internal audit activities to ensure adherence to CSU policy is not relevant and will not address the deficiencies we found in the policy. The Chancellor's Office's planned approach is also concerning because it did not dispute any of our conclusions in its response to the audit report and, in fact, on page 53 stated its intention to implement our recommendations to improve its policies and practices. Therefore, we stand by our recommendation that the Chancellor's Office revise its policy to require campuses to justify amounts for new or increasing fees.

60-Day Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services plans to begin these reviews in 2021, after the audit plan is approved by the Board of Trustees.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The Chancellor's Office's response does not address our recommendation.

As we conclude throughout the audit report, the current fee policy does not ensure adequate accountability to students. For example, as we discuss on pages 28-32, the vague requirements in the fee policy allowed the campuses we reviewed to impose or increase mandatory fees without justifying specific fee amounts. Further, the fee policy does not require campuses to demonstrate that they have no other way to pay for their needs, and the campuses we reviewed consistently failed to do so.

Because the fee policy does not contain meaningful requirements in these areas, the Chancellor's Office's plan to increase internal audit activities to ensure adherence to CSU policy is not relevant and will not address the deficiencies we found in the policy. The Chancellor's Office's planned approach is also concerning because it did not dispute any of our conclusions in its response to the audit report and, in fact, on page 53 stated its intention to implement our recommendations to improve its policies and practices. Therefore, we stand by our recommendation that the Chancellor's Office revise its policy to require campuses to justify amounts for new or increasing fees.

Recommendation #4 To: University, California State

To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should extend its review responsibilities to include increases to existing mandatory fees.

Annual Follow-Up Agency Response From September 2023

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees. CSU management believes that these steps are sufficient and will not take further action.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Our review found that campuses violated fee policy requirements related to increasing existing fees, including those related to making expenditure projections consulting with students before implementing a fee increase. However, the Chancellor's Office does not review campuses' processes for increasing fees to ensure that those processes comply with the policy before allowing a fee to go into effect. Further, we called out the violations mentioned above in the report and the Chancellor's Office did not dispute those findings, despites its statement now that its audits did not identify issues. Finally, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, the actions taken by the Chancellor's Office do not implement our recommendation.

Annual Follow-Up Agency Response From October 2022

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Our review found that campuses violated fee policy requirements related to increasing existing fees. As we explain on page 30 of our report, two campuses failed to make required expenditure projections for proposed fee increases. For other fee increases, campuses also violated fee policy requirements related to consulting with students before implementing a fee increase, as we discuss on pages 33 and 34. However, the Chancellor's Office currently does not review proposed fee increases to ensure that those campuses' processes comply with the policy.

As we have stated in previous assessments, CSU's approach to addressing the issues we found through additional internal audits is not sufficient. In the event those audits identify issues with campuses' fee processes, it will be after mandatory fee increases are already in place and students have been paying them. Further, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, notwithstanding CSU's statements about the conclusions of its recent audits, we stand by our recommendation that the Chancellor's Office should extend its review responsibilities to include proposed increases to existing mandatory fees .

Annual Follow-Up Agency Response From October 2021

At the May 2021 meeting, the Board of Trustees approved audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees. The first of these audits started on September 27, 2021, and two more are currently planned.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

As with its previous responses, the Chancellor's Office's reported actions do not address our recommendation. Our review found that campuses violated fee policy requirements related to increasing existing fees. As we explain on page 30 of our report, two campuses failed to make required expenditure projections for proposed fee increases. For other fee increases, campuses also violated fee policy requirements related to consulting with students before implementing a fee increase, as we discuss on pages 33 and 34. However, the Chancellor's Office currently does not review campuses' processes for increasing fees to ensure that those processes comply with the policy.

Even if the Chancellor's Office's actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. Further, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office should extend its review responsibilities to include proposed increases to existing mandatory fees so that CSU campuses adequately identify the need for their proposed mandatory fee amounts.

1-Year Agency Response

At the May 2021 meeting, the Board of Trustees is expected to approve audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Our review found that campuses violated fee policy requirements related to increasing existing fees. As we explain on page 30 of our report, two campuses failed to make required expenditure projections for proposed fee increases. For other fee increases, campuses also violated fee policy requirements related to consulting with students before implementing a fee increase, as we discuss on pages 33 and 34. However, the Chancellor's Office currently does not review campuses' processes for increasing fees to ensure that those processes comply with the policy.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. Further, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office should extend its review responsibilities to include proposed increases to existing mandatory fees so that CSU campuses adequately identify the need for their proposed mandatory fee amounts.

6-Month Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services is developing its 2021-22 audit plan and will include at least one fee audit in the audit plan it submits to the Board of Trustees for approval in May 2021.

California State Auditor's Assessment of 6-Month Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Rather, the response mischaracterizes our audit results by stating that it will "ensure campuses continue to adhere to CSU policy." In fact, our review found that campuses violated fee policy requirements related to increasing existing fees. As we explain on page 30 of our report, two campuses failed to make required expenditure projections for proposed fee increases. For other fee increases, campuses also violated fee policy requirements related to consulting with students before implementing a fee increase, as we discuss on pages 33 and 34. However, the Chancellor's Office currently does not review campuses' processes for increasing fees to ensure that those processes comply with the policy.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. The fact that the Chancellor's Office does not plan to begin this work until 2021 further delays any potential indication and suggests the Chancellor's Office is not serious about addressing the problems we identified. Further, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office should extend its review responsibilities to include proposed increases to existing mandatory fees so that CSU campuses adequately identify the need for their proposed mandatory fee amounts.

60-Day Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services plans to begin these reviews in 2021, after the audit plan is approved by the Board of Trustees.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Rather, the response mischaracterizes our audit results by stating that it will "ensure campuses continue to adhere to CSU policy." In fact, our review found that campuses violated fee policy requirements related to increasing existing fees. As we explain on page 30 of our report, two campuses failed to make required expenditure projections for proposed fee increases. For other fee increases, campuses also violated fee policy requirements related to consulting with students before implementing a fee increase, as we discuss on pages 33 and 34. However, the Chancellor's Office currently does not review campuses' processes for increasing fees to ensure that those processes comply with the policy.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. The fact that the Chancellor's Office does not plan to begin this work until 2021 further delays any potential indication and suggests the Chancellor's Office is not serious about addressing the problems we identified. Further, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. Therefore, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office should extend its review responsibilities to include proposed increases to existing mandatory fees so that CSU campuses adequately identify the need for their proposed mandatory fee amounts.

Recommendation #5 To: University, California State

To ensure that CSU campuses adequately identify the need for their proposed mandatory fee amounts, the Chancellor's Office should increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

Annual Follow-Up Agency Response From September 2023

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees. CSU management believes that these steps are sufficient and will not take any further action.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Specifically, the planned approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. For the reasons we raised in our responses to previous Chancellor's Office updates, audits after the fact are not a replacement for appropriate oversight of proposed fees.

Annual Follow-Up Agency Response From October 2022

Audit and Advisory Services (A&AS) completed three campus-based mandatory student fees audits as part of its annual audit plan for 2021-2022. The audits were completed in December 2021, May 2022, and August 2022. In general, A&AS noted that the campuses had appropriate frameworks for the administration of student fees.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Specifically, the planned approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. As we discuss on pages 33 and 34 of the audit report, we identified several instances in which campuses' processes violated student consultation requirements. However, the Chancellor's Office did not intervene to enforce the requirements in any of those cases. Instead, the Chancellor's Office approved these mandatory fees and students have been paying them since.

As we have stated in previous assessments, CSU's approach to addressing the issues we found through additional internal audits is not sufficient. In the event those audits identify issues with campuses' fee processes, it will be after mandatory fee increases are already in place and students have been paying them. For this reason, increased audits after the fact do not relieve the Chancellor's Office of its responsibility to thoroughly review campuses' proposed mandatory fees before campuses implement those fees. Finally, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. As such, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, notwithstanding CSU's statements about the conclusions of its recent audits, we stand by our recommendation that the Chancellor's Office increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

Annual Follow-Up Agency Response From October 2021

At the May 2021 meeting, the Board of Trustees approved audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees. The first of these audits started on September 27, 2021, and two more are currently planned.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

As with its previous responses, the Chancellor's Office's reported actions do not address our recommendation. Specifically, its approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. As we discuss on pages 33 and 34 of the audit report, we identified several instances in which campuses' processes violated student consultation requirements. However, the Chancellor's Office did not intervene to enforce the requirements in any of those cases. Instead, the Chancellor's Office approved these mandatory fees and students have been paying them since.

Even if the Chancellor's Office's actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. For this reason, performing additional audits after the fact do not relieve the Chancellor's Office of its responsibility to thoroughly review campuses' proposed mandatory fees before campuses implement those fees. Finally, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. As such, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations during these reviews. Therefore, we stand by our recommendation that the Chancellor's Office increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

1-Year Agency Response

At the May 2021 meeting, the Board of Trustees is expected to approve audits of campus-based mandatory fees as part of the division of Audit and Advisory Services annual audit plan for 2021-2022. The audits will assess whether the campuses adhered to CSU policy with regard to the establishment, assessment, and implementation of the fees.

California State Auditor's Assessment of 1-Year Status: No Action Taken

The Chancellor's Office's response does not address our recommendation. Specifically, the planned approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. As we discuss on pages 33 and 34 of the audit report, we identified several instances in which campuses' processes violated student consultation requirements. However, the Chancellor's Office did not intervene to enforce the requirements in any of those cases. Instead, the Chancellor's Office approved these mandatory fees and students have been paying them since.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. For this reason, increased audits after the fact do not relieve the Chancellor's Office of its responsibility to thoroughly review campuses' proposed mandatory fees before campuses implement those fees. Finally, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. As such, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

6-Month Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services is developing its 2021-22 audit plan and will include at least one fee audit in the audit plan it submits to the Board of Trustees for approval in May 2021.

California State Auditor's Assessment of 6-Month Status: No Action Taken

The Chancellor's Office's response does not address our recommendation and mischaracterizes our audit results by stating that it will "ensure campuses continue to adhere to CSU policy." Specifically, the planned approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. As we discuss on pages 33 and 34 of the audit report, we identified several instances in which campuses' processes violated student consultation requirements. However, the Chancellor's Office did not intervene to enforce the requirements in any of those cases. Instead, the Chancellor's Office approved these mandatory fees and students have been paying them since.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. For this reason, increased audits after the fact do not relieve the Chancellor's Office of its responsibility to thoroughly review campuses' proposed mandatory fees before campuses implement those fees. Finally, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. As such, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

60-Day Agency Response

The Chancellor has asked the division of Audit and Advisory Services to conduct more frequent periodic reviews of campus-based mandatory fees to ensure that campuses continue to adhere to CSU policy with regard to their establishment, assessment, and implementation. The division of Audit and Advisory Services plans to begin these reviews in 2021, after the audit plan is approved by the Board of Trustees.

California State Auditor's Assessment of 60-Day Status: No Action Taken

The Chancellor's Office's response does not address our recommendation and mischaracterizes our audit results by stating that it will "ensure campuses continue to adhere to CSU policy." Specifically, the planned approach does not address the shortcomings we identified with the Chancellor's Office's review of proposed mandatory fees at CSU campuses, particularly in the area of student consultation. As we discuss on pages 33 and 34 of the audit report, we identified several instances in which campuses' processes violated student consultation requirements. However, the Chancellor's Office did not intervene to enforce the requirements in any of those cases. Instead, the Chancellor's Office approved these mandatory fees and students have been paying them since.

Even if the Chancellor's Office's planned actions succeed in identifying such violations in the future, it will be after mandatory fee increases are already in place and students have been paying them, rather than before the increases are imposed. For this reason, increased audits after the fact do not relieve the Chancellor's Office of its responsibility to thoroughly review campuses' proposed mandatory fees before campuses implement those fees. Finally, although we called out the above violations in the report and the Chancellor's Office did not dispute those findings, it has not indicated that it intervened to address the violations, nor that it intends to do so. As such, we question whether the Chancellor's Office will take any action if and when its own staff identify similar violations after the fact. Therefore, we stand by our recommendation that the Chancellor's Office increase the rigor of its fee proposal review and approval process to better ensure that it detects campuses' violations of the fee policy.

All Recommendations in 2019-114

Agency responses received are posted verbatim.