To improve its enforcement actions in order to effectively address health and safety violations by child care facilities, the department should ensure that regional office staff consult with legal division staff early in the process when circumstances warrant it by clarifying its policies as necessary and following up to determine that the policies are complied with.
The department reported that the legal divisionís early consultation pilot project in Southern California was well received, yet significant operational changes were made because of staff turnover. It reevaluated areas of assignment and sent legal staff to regional offices to be readily available for consultation. However, the department stated that it was doubtful it would expand the pilot project to Northern California, in part because the diversion of legal counsel to full-time consultation did not seem likely. Still, the department stated that it has continued to stress the need for early legal consultation. Finally, the department indicated that it requires monthly legal consultation on all cases that may result in an administrative action. (2008-406, p. 192)
Agency responses received after June 2013 are posted verbatim.