Report 2020-109 All Recommendation Responses

Report 2020-109: In-Home Supportive Services Program; It Is Not Providing Needed Services to All Californians Approved for the Program, Is Unprepared for Future Challenges, and Offers Low Pay to Caregivers (Release Date: February 2021)

Recommendation for Legislative Action

To balance the need to attract a sufficient number of caregivers into the IHSS program with the need to maintain control over the State's costs, the Legislature should consider using the annual budget process to allocate additional funds to counties to enable counties to better afford increasing caregiver wages.

Description of Legislative Action

As of February 25, 2022, 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 August 25, 2021, 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 April 26, 2021, 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 these offset funds are used to best address wage disparities, the Legislature should prioritize their availability to counties where caregivers earn the least, relative to a living wage, and should exempt these wage increases from Welfare and Institutions Code 12306.16, subdivision (d), so that the amounts allocated are not included in adjustments to the county contribution.

Description of Legislative Action

AB 135 (Chapter 85, Statutes of 2021), in part, deletes subsequent county IHSS Maintenance of Effort (MOE) adjustments that otherwise would have applied when the $15 minimum wage takes effect on January 1, 2022.

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


Description of Legislative Action

As of August 25, 2021, 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 April 26, 2021, 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 limit the disincentive for counties to provide caregiver wage increases, the Legislature should modify the State's cost-sharing system to eliminate the ongoing costs that counties pay for local wage increases that are nullified by increases to the State's minimum wage.

Description of Legislative Action

AB 135 (Assembly Budget Committee), the human services omnibus budget trailer bill, expands the limitation for IHSS state-county sharing arrangements on the 10% state participation to allow no more than two three-year periods that commence before, and no more than two three-year periods that commence on or after, the date the state minimum wage reaches $15, and deletes subsequent county IHSS Maintenance of Effort (MOE) adjustments that otherwise would have applied when the $15 minimum wage takes effect on January 1, 2022. Additionally, this provision deletes subsequent MOE adjustments that otherwise would have applied when the $15 minimum wage takes effect on January 1, 2022.

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


Description of Legislative Action

As of April 26, 2021, the Legislature has not taken action to address this specific recommendation.

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


Recommendation #4 To: Social Services, Department of

To help ensure that all recipients throughout the State receive prompt approval for services and receive all approved services, by August 2021 and annually thereafter, Social Services should require counties to submit required annual plans. These plans should include, at a minimum, a description of how each county will ensure that services are promptly approved and that recipients promptly receive the approved services.

Annual Follow-Up Agency Response From December 2022

Social Services did not report a change to this recommendation's status in 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


1-Year Agency Response

No change to the previous response.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The Department of Social Services has indicated it does not have changes to provide from its previous response.


6-Month Agency Response

No change to the previous response.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The Department of Social Services has indicated it will not implement this recommendation.


60-Day Agency Response

The CDSS plans to repeal the regulation that requires counties to submit annual county plans. The requirement for county plans is an outdated regulation from when services were primarily provided by county homemakers that are employed and directed by the county. As the program evolved to a self-directed model, and recipients became responsible for the hiring and directing of the care provider, county plans were no longer meaningful as the county does not control the service provision of the program.

The CDSS plans to also repeal the regulation regarding 15 days from application to provision of services. As a self-directed program, IHSS recipients are responsible for managing their own care. Recipients sign an SOC 332 (IHSS Recipient/Employer Responsibility Checklist) at their assessment that states it is the recipient's responsibility to hire and manage their own provider and direct how and when they receive their services. Counties have no authority to hire a provider for a recipient. The county ensures recipients are assessed and authorized for services; it then becomes the recipient's responsibility to hire a provider.

Regarding the requirement to approve IHSS applications in 30 days, the CDSS is in the process of revising regulations to include the new statutory requirements for an IHSS applicant to complete a Medi-Cal eligibility determination and health care certification prior to authorization of IHSS. Both requirements allow 45 days for the applicant to complete and run concurrently.

Lastly, the CDSS has established Quality Assurance and Monitoring Units and a Program Integrity Unit which is responsible for monitoring counties in the areas which they are responsible for (application processing, assessing recipients and authorizing hours correctly, conducting reassessments timely, etc.) and will continue to do so.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

We are disappointed that the Department of Social Services has indicated that it will not require counties to comply with state law which obligates each county to ensure that services are provided to all eligible recipients during each month of the year in accordance with the county plan.


Recommendation #5 To: Social Services, Department of

To help counties prepare to meet future needs for IHSS services, Social Services should revise its regulations to require counties to include long-range projections and strategies in their annual plans.

Annual Follow-Up Agency Response From December 2022

Social Services did not report a change to this recommendation's status in 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


1-Year Agency Response

No change to previous response.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The Department of Social Services has indicated it does not have changes to provide from its previous response.


6-Month Agency Response

No change to previous response.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The Department of Social Services has indicated that it will not implement this recommendation.


60-Day Agency Response

The CDSS plans to repeal the regulation that requires counties to submit annual county plans. The requirement for county plans is an outdated regulation from when services were primarily provided by county homemakers that are employed and directed by the county. As the program evolved to a self-directed model, and recipients became responsible for the hiring and directing of the care provider, county plans were no longer meaningful as the county does not control the service provision of the program.

The CDSS plans to also repeal the regulation regarding 15 days from application to provision of services. As a self-directed program, IHSS recipients are responsible for managing their own care. Recipients sign an SOC 332 (IHSS Recipient/Employer Responsibility Checklist) at their assessment that states it is the recipient's responsibility to hire and manage their own provider and direct how and when they receive their services. Counties have no authority to hire a provider for a recipient. The county ensures recipients are assessed and authorized for services; it then becomes the recipient's responsibility to hire a provider.

Regarding the requirement to approve IHSS applications in 30 days, the CDSS is in the process of revising regulations to include the new statutory requirements for an IHSS applicant to complete a Medi-Cal eligibility determination and health care certification prior to authorization of IHSS. Both requirements allow 45 days for the applicant to complete and run concurrently.

Lastly, the CDSS has established Quality Assurance and Monitoring Units and a Program Integrity Unit which is responsible for monitoring counties in the areas which they are responsible for (application processing, assessing recipients and authorizing hours correctly, conducting reassessments timely, etc.) and will continue to do so.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

We are disappointed that the Department of Social Services has indicated that it will not require counties to comply with state law which obligates each county to ensure that services are provided to all eligible recipients during each month of the year in accordance with the county plan.


Recommendation #6 To: Social Services, Department of

To help ensure that recipients receive timely care, Social Services should, by August 2021, begin monitoring counties' compliance with the following: Approval of IHSS applications within 30 days, unless an extension for obtaining a medical certification applies. Prompt approval of IHSS applications for which the 45-day extension for a medical certification applies. Provision of services within 15 days of application approval.

Annual Follow-Up Agency Response From December 2022

Social Services did not report a change to this recommendation's status in 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


1-Year Agency Response

CDSS revised the regulations to include the new statutory requirements for an IHSS applicant to complete a Medi-Cal eligibility determination and health care certification prior to authorization of IHSS. Both requirements allow 45 days for the applicant to complete and run concurrently. Refer to Welfare and Institutions Code Section 12309.1.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

In its initial response CDSS indicated that it planned to repeal certain regulations, including one that required counties to approve IHSS applications within 30 days unless an extension related to a medical certification applies. In its one year response CDSS indicated that it has revised its regulations to reflect amendments to Welfare and Institutions code 12309.1. The agency's decision to not implement our recommendation remains unchanged.


6-Month Agency Response

No change to previous response.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The Department of Social Services has indicated that it will not implement this recommendation.


60-Day Agency Response

The CDSS plans to repeal the regulation that requires counties to submit annual county plans. The requirement for county plans is an outdated regulation from when services were primarily provided by county homemakers that are employed and directed by the county. As the program evolved to a self-directed model, and recipients became responsible for the hiring and directing of the care provider, county plans were no longer meaningful as the county does not control the service provision of the program.

The CDSS plans to also repeal the regulation regarding 15 days from application to provision of services. As a self-directed program, IHSS recipients are responsible for managing their own care. Recipients sign an SOC 332 (IHSS Recipient/Employer Responsibility Checklist) at their assessment that states it is the recipient's responsibility to hire and manage their own provider and direct how and when they receive their services. Counties have no authority to hire a provider for a recipient. The county ensures recipients are assessed and authorized for services; it then becomes the recipient's responsibility to hire a provider.

Regarding the requirement to approve IHSS applications in 30 days, the CDSS is in the process of revising regulations to include the new statutory requirements for an IHSS applicant to complete a Medi-Cal eligibility determination and health care certification prior to authorization of IHSS. Both requirements allow 45 days for the applicant to complete and run concurrently.

Lastly, the CDSS has established Quality Assurance and Monitoring Units and a Program Integrity Unit which is responsible for monitoring counties in the areas which they are responsible for (application processing, assessing recipients and authorizing hours correctly, conducting reassessments timely, etc.) and will continue to do so.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

We are disappointed that the Department of Social Services has indicated that it will not require counties to comply with state law which obligates each county to ensure that services are provided to all eligible recipients during each month of the year in accordance with the county plan.


Recommendation #7 To: Social Services, Department of

For counties that struggle to comply with its regulations regarding providing timely services, Social Services should require—and regularly follow up on—corrective action plans from these counties.

Annual Follow-Up Agency Response From December 2022

Social Services did not report a change to this recommendation's status in 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


1-Year Agency Response

No change to previous response.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

The Department of Social Services has indicated it does not have changes to provide from its previous response.


6-Month Agency Response

CDSS will not require corrective action plans regarding the annual county plans, the regulation concerning 15 days from application to provision of services, or the regulation concerning the requirement to approve IHSS applications in 30 days because CDSS plans to either repeal or is in the process of revising those regulations.

Monitoring activities are already ongoing by the Quality Assurance and Monitoring Units and Program Integrity Unit. The Program Integrity Unit Issues Quality Action Improvement Action Plans (QIAP) to the counties as needed.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

The Department of Social Services has indicated it will not implement corrective action plans for counties that are not complying with its regulations related to providing timely services. As we have previously noted, state law obligates each county to ensure that services are provided to all eligible recipients during each month of the year in accordance with the county plan.


60-Day Agency Response

The CDSS plans to repeal the regulation that requires counties to submit annual county plans. The requirement for county plans is an outdated regulation from when services were primarily provided by county homemakers that are employed and directed by the county. As the program evolved to a self-directed model, and recipients became responsible for the hiring and directing of the care provider, county plans were no longer meaningful as the county does not control the service provision of the program.

The CDSS plans to also repeal the regulation regarding 15 days from application to provision of services. As a self-directed program, IHSS recipients are responsible for managing their own care. Recipients sign an SOC 332 (IHSS Recipient/Employer Responsibility Checklist) at their assessment that states it is the recipient's responsibility to hire and manage their own provider and direct how and when they receive their services. Counties have no authority to hire a provider for a recipient. The county ensures recipients are assessed and authorized for services; it then becomes the recipient's responsibility to hire a provider.

Regarding the requirement to approve IHSS applications in 30 days, the CDSS is in the process of revising regulations to include the new statutory requirements for an IHSS applicant to complete a Medi-Cal eligibility determination and health care certification prior to authorization of IHSS. Both requirements allow 45 days for the applicant to complete and run concurrently.

Lastly, the CDSS has established Quality Assurance and Monitoring Units and a Program Integrity Unit which is responsible for monitoring counties in the areas which they are responsible for (application processing, assessing recipients and authorizing hours correctly, conducting reassessments timely, etc.) and will continue to do so.

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

Social Services provided the same response to all our recommendations, however in doing so it did not specifically respond to this recommendation. We will update this assessment based on Social Services six month response due in August 2021.


Recommendation #8 To: Butte, County of

To help ensure that recipients receive prompt approval for services and also receive all approved services, Butte County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

Annual Follow-Up Agency Response From September 2023

The California Department of Social Services (CDSS) is the oversite agency for Butte County Department of Social Services. CDSS issues All County Letters (ACLs) and All County Information Notices (ACINs) to inform counties of the implementation requirements of regulations and policies. Butte County will not implement the recommendation as CDSS has not issued a directive in the form of an ACL or ACIN that requires county IHSS programs to provide an annual county plan.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


Annual Follow-Up Agency Response From December 2022

Butte County did not report a change to this recommendation's status in 2022.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement


1-Year Agency Response

The California Department of Social Services (CDSS) is the oversite agency for Butte County Department of Social Services. CDSS issues All County Letters (ACLs) and All County Information Notices (ACINs) to inform counties of the implementation requirements of regulations and policies. Butte County has not fully implemented the recommendation in the last year following the issue date of the report because CDSS has not issued a directive in the form of an ACL or ACIN that requires county IHSS programs to provide an annual county plan.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

Butte County has indicated that it will not comply with the requirements of state law because it has not received a separate directive from CDSS requiring it to do so. We remind Butte County that the requirement to comply with state law is not dependent on the receipt of a notice or letter from a state department. However, as CDSS has indicated that it will not comply with our recommendation to require counties to submit annual plans we have assessed this response as indicating that Butte County will not implement our recommendation.


6-Month Agency Response

The California Department of Social Services (CDSS) is the oversite agency for Butte County Department of Social Services. CDSS issues All County Letters (ACLs) and All County Information Notices (ACINs) to inform counties of the implementation requirements of regulations and policies. Butte County has not fully implemented the recommendation in the sixty months following the issue date of the report because CDSS has not issued a directive in the form of an ACL or ACIN that requires county IHSS programs to provide an annual county plan.

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

In its response, Butte county did not indicate that it had taken any action towards implementing our recommendation that it conduct required county plans to help ensure that IHSS recipients receive prompt approval for services and also receive all approved services.


60-Day Agency Response

The California Department of Social Services (CDSS) is the oversite agency for Butte County Department of Social Services. CDSS issues All County Letters (ACLs) and All County Information Notices (ACINs) to inform counties of the implementation requirements of regulations and policies. Butte County has not fully implemented the recommendation in the sixty-day following the issue date of the report because CDSS has not issued a directive in the form of an ACL or ACIN that requires county IHSS programs to provide an annual county plan.

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


Recommendation #9 To: Kern County

To help ensure that recipients receive prompt approval for services and also receive all approved services, Kern County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

Annual Follow-Up Agency Response From October 2022

As part of its corrective action plan for the IHSS State Audit, Kern submitted its IHSS Annual Plan last year as directed. Upon submitting the plan, the California Department of Social Services (CDSS) informed us not to submit the plan as it was no longer required. As a result, Kern is following the most recent direction provided by CDSS regarding no longer requiring counties to submit an annual IHSS plan.

The County of Kern continues to collaborate with CDSS to ensure that they have all the necessary documentation regarding the specific actions the county takes to ensure prompt approval and receipt of IHSS services. Kern also participates in regular quality assurance monitoring conducted by the State, which includes reviewing application processing, assessing recipients and authorizing hours correctly, conducting reassessments timely, etc. Kern is currently in compliance with all state requirements and continues to seek ways to improve service delivery to the providers and recipients of the IHSS program.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Kern County has indicated that based on guidance from Social Services, it will not comply with state law requiring it to submit a plan that helps ensure provision of services to all eligible recipients each month in accordance with the county plan. We rebut Social Services' assertion that such a planning is not required on page 69 of report 2020-109.


1-Year Agency Response

Kern County did not submit a 1 year response.

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


Annual Follow-Up Agency Response From February 2022

In August of 2021, the Department submitted its annual IHSS plan to the Kern County Board of Supervisors as recommended in the State Audit. The plan was also submitted to California Department of Social Services. The plan included various measures to improve the Department's ability to provide prompt services to IHSS consumers.

Throughout the upcoming year, Kern will continue to evaluate its operations in an effort to continuously improve its promptness in providing IHSS services.

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

Kern County submitted an annual plan for review in August of 2021. A new plan will be due in August of 2022. We look forward to reviewing that plan to determine whether this recommendation is fully implemented.


6-Month Agency Response

Kern County has completed its annual plan. Kern will implement the activities listed in the plan over the next year to help improve services and to ensure that recipients promptly receive the approved services.

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

Kern County submitted an annual plan for review. We look forward to reviewing future documentation about its implementation.


60-Day Agency Response

Unless otherwise directed by the California Department of Social Services (CDSS), Kern is in the process of developing its an annual plan as recommended in the report. It will be submitted to CDSS prior to August of 2021, and annually thereafter. The plan will include a description of how we will ensure that services are promptly approved and that recipients promptly receive the approved services that recipients promptly receive the approved services.

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


Recommendation #10 To: San Diego, County of

To help ensure that recipients receive prompt approval for services and also receive all approved services, San Diego County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

Annual Follow-Up Agency Response From October 2022

An Annual Plan was implemented by the County of San Diego's Health and Human Services Agency for the IHSS program during Fiscal Year 2021-2022. An updated Annual Plan was prepared for Fiscal Year 2022-2023 and will be submitted as part of this update.

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

San Diego County provided its second annual plan for review. We appreciate the county's commitment to ensuring that IHSS recipients receive services and service approvals promptly.


1-Year Agency Response

An Annual Plan was prepared by the County of San Diego's Health and Human Services Agency for the IHSS program. The plan was implemented in July 2021 and submitted on August 25, 2021. This plan covers fiscal years 21-22 and will be updated annually.

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

San Diego County submitted an annual plan for review in August of 2021. A new plan will be due in August of 2022. We look forward to reviewing that plan to determine whether this recommendation is fully implemented.


6-Month Agency Response

An Annual Plan was prepared by the County of San Diego's Health and Human Services Agency for the IHSS program.

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

San Diego County submitted an annual plan for review. We look forward to reviewing future documentation about its implementation. We will assess whether this recommendation is complete based on implementation data, and next year's annual plan.


60-Day Agency Response

We continue to take measures to help ensure that applicants for the In-Home Supportive Services (IHSS) program receive prompt approval for services when eligible, and that those who are approved receive services to meet their assessed needs.

An IHSS Policy and Procedure Workgroup currently meets regularly to review data reports, make recommendations, and implement procedural changes to support the shortening of timeframes for intake processing and recipients in need of providers. This workgroup will develop a process for completing a comprehensive annual plan which will include specific provisions regarding how to ensure prompt approval of services and timely receipt of services.

By June 2021 a draft plan will be completed for internal review.

By August 2021 a final document will be completed.

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


Recommendation #11 To: Stanislaus County

To help ensure that recipients receive prompt approval for services and also receive all approved services, Stanislaus County should, by August 2021 and annually thereafter, complete required plans that include, at a minimum, specific provisions for how it will ensure prompt approval of services and that recipients promptly receive the approved services.

Annual Follow-Up Agency Response From November 2022

CDSS plans to repeal the regulation that requires counties to submit annual county plans. Per CDSS's response to the Audit, the requirement for counties to submit annual county plans is an outdated regulation. Based on CDSS's response to the audit, Stanislaus County will not be completing an annual plan to the State.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Stanislaus County has indicated that based on guidance from Social Services, it will not comply with state law requiring it to submit a plan that helps ensure provision of services to all eligible recipients each month in accordance with the county plan. We rebut Social Services' assertion that such a planning is not required on page 69 of report 2020-109.


1-Year Agency Response

As noted in previous responses, CDSS plans to repeal the regulation that requires counties to submit annual county plans. Per CDSS's response to the Audit, the requirement for counties to submit annual county plans is is an outdated regulation. Based on CDSS's response to the audit, Stanislaus County will not be completing an annual plan to the State.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

Stanislaus County indicates it will not implement our recommendation.


6-Month Agency Response

CDSS plans to repeal the regulation that requires counties to submit annual county plans. Per CDSS's response to the Audit, the requirement for counties to submit annual county plans is is an outdated regulation. Based on CDSS's response to the audit, Stanislaus County will not be completing an annual plan to the State.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

Stanislaus County indicates it will not implement our recommendation.


60-Day Agency Response

CDSS plans to repeal the regulation that requires counties to submit annual county plans. Per CDSS's response to the Audit, the requirement for counties to submit annual county plans is is an outdated regulation. Based on CDSS's response to the audit, Stanislaus County will not be completing an annual plan to the State.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

We are disappointed that Stanislaus County has indicated that it will not comply with state law that directly obligates it to ensure that services are provided to all eligible recipients each month in accordance with the county plan. Stanislaus County appears to have reached this decision based on an erroneous assertion from the Department of Social Services that indicates such a planning requirement is merely a component of its regulations. We rebut Social Services' assertion on page 69 of report 2020-109.


Recommendation for Legislative Action

To provide for more equitable financial participation by counties, the Legislature should revise the State's IHSS funding formula to include annual updates based on current program growth and costs and a review of specific funds available to counties. To the extent that some counties' revenues dedicated to IHSS are insufficient to cover their IHSS contributions, the Legislature should provide counties with assistance as it deems appropriate or designate additional funding sources in state law.

Description of Legislative Action

As of February 25, 2022, 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 August 25, 2021, 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 April 26, 2021, the Legislature has not taken action to address this specific recommendation.

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


All Recommendations in 2020-109

Agency responses received are posted verbatim.