Report 2015-030 All Recommendation Responses

Report 2015-030: State Bar of California: It Has Not Consistently Protected the Public Through Its Attorney Discipline Process and Lacks Accountability (Release Date: June 2015)

Recommendation #1 To: Bar of California, State

To ensure that its backlog does not adversely affect the quality of the discipline it imposes on attorneys who fail to fulfill their professional responsibilities, the State Bar should adhere to its quality control processes. Further, it should take steps to prevent its management or staff from circumventing those processes, such as requiring the presentation to the board of any proposed changes to quality control.

6-Month Agency Response

At its November 20, 2015, meeting, the Board of Trustees adopted a policy amending the charter of its Regulation and Discipline Committee (RAD) to specify that approval of RAD is required in order to implement any material changes to policy-level quality control measures in the Office of the Chief Trial Counsel, the Client Security Fund, or the Office of Probation. The meeting agenda and relevant item report are being submitted via email.

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

60-Day Agency Response

The State Bar will be presenting appropriate oversight policies for the Board of Trustees to adopt to implement this recommendation and to prevent a repetition of the situation identified in the report when prior Office of Chief Trial Counsel (OCTC) management eliminated OCTC's Audit and Review Unit in 2010 and its quality control processes were circumvented without the knowledge of the board or this committee.

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

Recommendation for Legislative Action

To ensure that it consistently counts and reports its backlog of disciplinary cases, the State Bar and the Legislature should work together to determine what cases the State Bar should include in its backlog. For example, one method of calculating the backlog would be to include every case that affects public protection that the State Bar does not resolve within six months from the time it receives a complaint. The Legislature should then amend the state law that currently defines how the State Bar should present the backlog in its discipline report.

Description of Legislative Action

Senate Bill 387 (Chapter 537, Statutes of 2015), in part provides that, in addition to written complaints received by the California State Bar, its Annual Discipline Report on backlog of cases must include other matters opened in the Office of the Chief Trial Counsel and pending beyond six months after receipt without the filing of notices of disciplinary charges, or the initiation of other disciplinary proceedings in the State Bar Court for the purpose of seeking the imposition of discipline against a member of the State Bar. The bill also requires the State Bar's Annual Discipline Report to include the number, average pending time, and other specified information related to disciplinary cases and complaints.

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

Recommendation #3 To: Bar of California, State

To ensure that it consistently counts and reports its backlog of disciplinary cases, the State Bar and the Legislature should work together to determine what cases the State Bar should include in its backlog. For example, one method of calculating the backlog would be to include every case that affects public protection that the State Bar does not resolve within six months from the time it receives a complaint. Until the Legislature determines what cases the State Bar should include in its backlog, the State Bar should comply with our 2009 recommendation to fully disclose the types of cases it includes and excludes from its backlog calculation, as well as any methodology changes from the prior year.

6-Month Agency Response

Business and Professions Code sections 6086.15(a)(1)-(9) specify the backlog reporting requirements that will be used to prepare the 2015 Annual Discipline Report. B&P section 6086.15(a)(1) specifically addresses backlog; because the specific types of matters to be included in the backlog count are not specified in that section, the State Bar has sought feedback from the State Auditor and the Legislature on a proposed outline for the 2015 ADR report which delineates the specific matters to be included in the backlog count. The estimated completion date for this item reflects the due date for the 2015 report.

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

60-Day Agency Response

The State Bar has worked with the Legislature and as a result there is a pending amendment to Business and Professions Code section 6086.15, subdivision (a)(1), which defines the types of cases that are included in the annual discipline report. (Sen. Bill No. 387 (2014-2915 Reg. Sess.) as amended July 15, 2015, section 1.) The amendment would require that in addition to written complaints of a lawyer's misconduct, the backlog report shall include other matters opened in the Office of Chief Trial Counsel and pending beyond six months after receipt without the filing of notices of disciplinary charges, or the initiation of other disciplinary proceedings in the State Bar Court for the purpose of seeking the imposition of discipline against a member of the State Bar. Information, including average pending time, about other cases that affect public protection, as identified in Table 8 of the audit report, will be included in other parts of the annual discipline report, but not as part of the backlog as defined. The State Bar will conform its annual discipline report for 2015 to these provisions.

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

Recommendation #4 To: Bar of California, State

To provide clear and reliable information to the Legislature, the governor, and the public, the State Bar should define how it calculates case-processing speeds in its discipline report and should report this metric using the same method each year. If the State Bar elects to continue presenting the median case-processing time, it should also present the average case-processing time. Finally, it should fully disclose any methodology changes from the methodology used in the prior year.

1-Year Agency Response

See attached Annual Discipline Report which addresses definition for case processing speeds, provides both mean and median times, and discloses changes in methodology from prior year.

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

6-Month Agency Response

Business and Professions Code sections 6086.15(a)(5)-(9)specifies the methodology to be used for calculating case-processing speed; this methodology will be used to complete the 2015 Annual Discipline Report. The estimated completion date for this item reflects the due date for the 2015 Report.

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

60-Day Agency Response

Beginning with its annual discipline report for 2015, the State Bar will begin including the average or "mean" case processing time to provide more information to stakeholders. The State Bar will also continue to present its case-processing times using the positional measurements of median and 90th percentile in order to provide a more complete picture of the time for handling cases. Average is a useful measurement when the distribution is normal. However, the processing times of discipline cases is not normal; instead there are typically "outliers," with the time taken to conclude these cases creating a "long tail" in the distribution curve that dramatically affects the average. In this situation, the average time will be above the "typical" value and well below the "long tail." For this reason, the State Bar had reported both the median (a standard and widely used statistic for long-tailed distributions) and the 90th percentile (an indicator of the "long tail"). Including average with median and 90th percentile will provide more complete information. When enacted, Senate Bill No. 387 will include an amendment to Business and Professions Code section 6086.15, subdivision (a)(5) to provide that speed of handling and disposition of cases be measured by both median and average time.

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

Recommendation #5 To: Bar of California, State

To assure the Legislature and the public that the data in the State Bar's discipline reports are accurate, the board should implement controls over the accuracy, consistency, and sufficiency of the data gathered and methods used to compute the information included in the report. For example, the board could expand the role of an existing board committee—such as the regulation and discipline committee—to include a review of the discipline report and the underlying discipline statistics

1-Year Agency Response

The Board of Trustees adopted an amendment to the charter of its Regulation and Discipline (RAD) Committee providing authority to RAD for oversight of the Annual Discipline Report process and underlying discipline statistics.

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

6-Month Agency Response

The Regulation and Discipline Committee will consider Charter amendments designed to formalize its role over review and approval of the Annual Discipline Report, including the underlying statistics, at its January 31, 2016, meeting.

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

60-Day Agency Response

The State Bar is reviewing the methodology for gathering and reporting the information in the annual discipline report. It will document and report to the Regulation and Discipline Committee and the board controls, data collection methods and data validation methods in producing the annual discipline report. In addition, the State Bar will expressly add oversight of the annual discipline report process and underlying discipline statistics to the charge of RAD.

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

Recommendation #6 To: Bar of California, State

To align its staffing with its mission, the State Bar should engage in workforce planning for its discipline system. The workforce planning should include the development and formal adoption of an appropriate backlog goal, an assessment of the staffing needed to achieve that goal while ensuring that the discipline process is not compromised, and the creation of policies and procedures sufficient to provide adequate guidance to the staff of each unit within the discipline system.

1-Year Agency Response

See May 10, 2016 Workforce Planning Report and May 13, 2016, State Bar Backlog Report.

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

The State Bar contracted with the National Center for State Courts to conduct workforce planning. The report, issued in May 2016, is extensive and contains numerous recommendations to streamline and improve the State Bar's discipline process. In addition, the State Bar developed a backlog report, which contains an estimate of how many staff the State Bar will need to meet backlog targets.

6-Month Agency Response

Workforce Planning proposals submitted pursuant to competitive solicitation on December 14, 2015, are now being reviewed. A vendor will be selected by January 8, 2016. The solicitation can be found at: http://www.calbar.ca.gov/Portals/0/documents/rfp/2015/2015_RFP-WorkforcePlanning.pdf

In addition, a working group comprised of representative staff from the Office of the Chief Trial Counsel has been established to begin developing a recommended backlog goal. That group had its first meeting on December 17, 2015, and will meet again the first week of January, with the goal of having a viable and vetted recommendation developed in conjunction with the initial work of the workforce planning consultant.

Pursuant to statutory directive, this Recommendation will be fully completed by May 15, 2016.

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

60-Day Agency Response

The request for proposals procedure required by Business and Professions Code section 6008.6 begins this month. In working with the Legislature, the recommendation has been added to Senate Bill No. 387, which includes a deadline, has been set for the State Bar to submit a report on its workforce plan to the Legislature by May 15, 2016.

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

Recommendation #7 To: Bar of California, State

To ensure that the audit and review unit's random audits of closed case files provide an effective oversight mechanism, the State Bar should follow its policy to conduct and record meetings and trainings related to the audit report's recommendations.

Annual Follow-Up Agency Response From August 2019

A review and analysis of audit data determined that an analysis of trends was not useful. The audit findings are case- and fact-specific; detailed comments are provided for each file that is reviewed. The Office of Research and Institutional Accountability recommends continuing to use the full audit report in the Office of Chief Trial Counsel staff training.

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

The State Bar's analysis of trends would have been an additional enhancement to this recommendation, but was unneeded for full implementation. Because the State Bar had previously taken steps that would have implemented this recommendation (refer to its response in March 2018) and it does not have additional steps to take, we consider this recommendation fully implemented.

Annual Follow-Up Agency Response From October 2018

The systemic review of audit data is underway, and will be completed by the end of the year.

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

Annual Follow-Up Agency Response From March 2018

OCTC conducts trainings after each random audit report, and began recording these trainings in February 2015; these recordings are available to OCTC staff on the Bar's intranet. The most recent training related to the random audits of closed cases took place on June 5, 2017, and trainings for the most recently completed audit are scheduled for 12/21/2017. OCTC will continue to present trainings based on random audit findings within the timeframe required by policy. In addition to those trainings, OCTC plans to analyze the cumulative results of all audits to address trends and ongoing issues in ways that makes the members of OCTC more mindful of the random audit feedback. For example, OCTC will develop a list of "common mistakes to avoid," that will be posted on OCTC intranet site; this list will be updated after each successive audit.

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

The State Bar indicated that while all of the steps identified in its March 2018 response have been implemented, it has not yet completed the systemic review of audit data. The State Bar estimated that this review will be completed by September 30th. Thus, this recommendation is pending completion of the review.

Annual Follow-Up Agency Response From November 2017

Significant progress has been made regarding this recommendation, although the Bar does not believe it has been fully implemented and institutionalized.

During 2017 the State Bar contracted with an additional auditor to review casefiles and enter data into the new audit database. As a result of this additional effort, at the end of October, data from four bi-annual audits had been entered into the new audit database which will allow for the tracking of compliance with policy and procedure in the Office of the Chief Trial Counsel (OCTC). Staff in the Office of Research and Institutional Accountability will be working through the end of 2017 and early 2018 with OCTC staff to review the data and determine whether patterns in the data can be used to inform the training of OCTC attorneys and Investigators.

Absent this more systemic review of the data, "lessons learned" from the audits are being summarized and conveyed to staff in a way that maximizes impact and reduces the chances that they continue to make the same errors.

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

The State Bar confirmed that it conducts and records meetings and trainings related to the audit and review unit's random audit report's recommendations. However, as indicated by the State Bar, it does not believe this recommendation will be fully implemented or institutionalized until staff in the Office of Research and Institutional Accountability have reviewed new data and determined whether patterns in the data can be used to inform the training of OCTC attorneys and Investigators.

Annual Follow-Up Agency Response From October 2016

Prior to fully implementing this recommendation it was necessary to reorganize the random audit process so that data could be compiled systematically regarding the findings of the audit. In June, 2016, the State Bar created a database to capture information from the random audit. During July and August of 2016, the audit process was moved from a paper-based system - in which findings from each case were returned to individual case files - to an automated process in which data from each case-file review are captured and stored in the new database. These data are now being analyzed and will be evaluated in conjunction with the auditor to identify patterns of problems that will be used to inform future trainings.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2016

To fully implement this recommendation, the State Bar developed a database in June to capture information from the random audit so that the audit findings may be systematically analyzed and used for training purposes. During July and August of 2016, the audit process was moved from a paper-based system - in which findings from each case were returned to individual case files - to an automated process in which data from each case-file review are captured and stored in the new database. These data are currently being analyzed and will be evaluated in conjunction with the auditor to identify patterns of problems that will be used to inform future trainings.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

The Bar has modified the contract for the audit and review function. The first report prepared pursuant to modified contract terms will be submitted to the Bar by 9/1/16. Executive Office staff will work with the Office of the Chief Trial Counsel to ensure that training occurs with respect to specific findings and recommendations included in the 9/1/16 report.

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

6-Month Agency Response

The State Bar's new leadership team is reviewing the audit and review function, and has transitioned management of the contract for the random audit function from the Office of the Chief Trial Counsel to the Chief Operating Officer. As part of the transition, the contract will be modified to expand both the scope and depth of the audit. These modifications will also address the need to systemize the dissemination of audit findings, and the development and delivery of training to address those findings.

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

60-Day Agency Response

OCTC is reviewing the processes of its audit and review unit and will take steps to ensure compliance with its policy to conduct and record meetings and trainings related to the audit report's recommendations.

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

Recommendation #8 To: Bar of California, State

To ensure that the audit and review unit's random audits of closed case files provide an effective oversight mechanism, the audit and review unit should oversee the retrieval of case files for audit.

6-Month Agency Response

The Audit and Review Unit is now responsible for overseeing the identification and retrieval of case files for audit purposes.

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

60-Day Agency Response

OCTC is reviewing the processes of its audit and review unit and will take steps to ensure that retrieval of case files that have been randomly selected for audit is overseen by the audit and review unit.

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

Recommendation #9 To: Bar of California, State

To ensure that the review function within the audit and review unit continues to provide a means for complainants to appeal the State Bar's decisions on closed cases, the State Bar should implement a policy that prohibits the chief trial counsel from dissolving the review function of the audit and review unit. Alternatively, at a minimum, it should require board approval for such an action.

6-Month Agency Response

As stated in the response to Recommendation 1, the Board of Trustees adopted an amendment to the Charter of the Regulation and Discipline Committee addressing this issue at its November 20, 2015, meeting; the Chief Trial Counsel is precluded from dissolving the Audit and Review Unit or function absent explicit RAD approval.

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

60-Day Agency Response

As stated in the response to recommendation no. 1, the State Bar is pursuing board action to adopt appropriate oversight policies and prevent a repetition of what occurred in 2010 when OCTC eliminated quality control processes without the knowledge of the board.

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

Recommendation #10 To: Bar of California, State

To provide independent oversight of the Office of the Chief Trial Counsel and assurance that it properly closes its case files, the audit and review unit should report to an individual or body that is separate from the chief trial counsel, such as the executive director or the board.

Annual Follow-Up Agency Response From October 2016

A new unit for managing the audit and review process was established in the Office of the General Counsel (OGC), a department that is separate and independent of the Office of the Chief Trial Counsel. Effective July 1, 2016, requests for an audit and review of an OCTC decision to close a file are sent to the new Complaint Review Unit (CRU) in OGC.

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

1-Year Agency Response

The Audit and Review Unit will transition to the Office of the General Counsel effective July 1, 2016.

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

6-Month Agency Response

On November 12, 2015, State Bar staff discussed the status of this Recommendation with State Auditor staff; the State Bar suggested an alternative approach to realizing the objectives and intent of the Recommendation, while retaining the existing reporting structure for the Audit and Review Unit. State Auditor staff indicated that they would provide feedback regarding the Bar's proposal; on December 17, 2015, a reminder regarding the need for that feedback was sent to the State Auditor. The estimated completion date for this Recommendation is tbd given the Bar's proposal to retain the existing reporting structure for the Unit.

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

We discussed this matter with the State Bar to give it feedback on the options for implementing the recommendation. According to the State Bar, the Audit and Review unit will be transitioning to the Office of the General Counsel (OGC). Work is underway to prepare for the transition.

60-Day Agency Response

The State Bar will study options to reorganize the audit and review unit to provide greater independence of some its major functions. A separate, bar-wide audit unit, which conducts analysis and internal audits of the Office of Chief Trial Counsel and other State Bar operations, may be a more appropriate mechanism for providing oversight. However, housing this function in the office of the executive director and including the authority to conduct "second-looks" at closed complaints to direct that they be reopened is problematic. Under existing law, the chief trial counsel serves under the regulation and discipline oversight committee of the board and not under the direction of the chief executive officer. The procedure of the State Bar's former complainants grievance panel and later discipline audit panel, both of which had independent authority to review and recommend the reopening of closed files, proved to be ineffective, creating instead more delays and frustrations for complainants. In 2001, the Legislature repealed the provision requiring an independent panel and permitted the State Bar to adopt Rule 2601 of the Rules of Procedure delegating the discretion to reopen cases back to the Office of Chief Trial Counsel.

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

Our recommendation is intended to ensure independence of the audit and review unit. The State Bar's proposal of a separate, bar-wide unit, would likely satisfy our recommendation as long as the unit does not report to the chief trial counsel.

Recommendation #11 To: Bar of California, State

To ensure that it spends revenues from the membership fee appropriately, the State Bar needs to implement policies and procedures to restrict its ability to transfer money between funds that its board or state law has designated for specific purposes.

60-Day Agency Response

At its July 2015 meeting, the board adopted policies and procedures to restrict the transfer or loan of money between funds that the board or state law has designated for specific purposes. (Agenda Item 146 JULY 13 2015.)

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

Recommendation #12 To: Bar of California, State

To ensure that it can justify future expenditures that exceed a certain dollar level, such as capital or IT projects that cost more than $2 million, the State Bar should implement a policy that requires accurate cost-benefit analyses comparing relevant cost estimates. The policy should include a requirement that the State Bar present the analyses to the board to ensure that it has the information necessary to make appropriate and cost-effective decisions. In addition, the State Bar should be clear about the sources of funds it will use to pay for each project.

60-Day Agency Response

At its July 2016 meeting, the board adopted a policy that for all contracts, projects, and expenditures reasonably expected to exceed $2,000,000, State Bar staff must develop and present a written cost-benefit analysis to the board. The policy requires action by the board or the relevant board committee to affirmatively approve the contract, project, or expenditure. All such cost-benefit analyses must discuss a recommended course of action and alternatives. (Agenda Item 147 JULY 13 2015.)

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

Recommendation #13 To: Bar of California, State

To justify any future special assessment that the State Bar wants to add to the annual membership fee, the State Bar should first present the Legislature with the planned uses for those funds and cost estimates for the project for which the State Bar intends to use the special assessment.

Annual Follow-Up Agency Response From October 2016

On May 13, 2016, in compliance with Business and Professions Code 6140.16, the State Bar submitted a Spending Plan to the Legislature. The Spending Plan includes a thorough analysis of the Bar's priorities and necessary operating costs. The Plan also provides details on the Bar's fund balances to determine a reasonable amount for the annual membership fee. Finally, the Plan calculates the additional amount of funding needed to reduce the backlog in the Office of the Chief Trial Counsel and implement the Bar's workforce plan. The Spending Plan is available on the State Bar's web site at:

http://www.calbar.ca.gov/LinkClick.aspx?fileticket=0c49c3RnO_U%3d&tabid=224&mid=1534

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

1-Year Agency Response

In the event that the State Bar seeks a special assessment in the future, the planned use of the funds, and cost estimates for the related project/s will be provided to the Legislature. Staff will bring a policy to the Board to that effect at its July meeting.

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

6-Month Agency Response

In the event that the State Bar seeks a special assessment in the future, the planned use of the funds, and cost estimates for the related project/s will be provided to the Legislature.

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

60-Day Agency Response

The State Bar agrees with this recommendation. But, at the moment, the State Bar is not seeking any new special assessments to which this would apply. Thus, we are unable to take the action recommended at this time. The State Bar will conform to this in the event that it seeks a special assessment in the future. However, the State Bar will add a requirement to its budget control policy.

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

Recommendation #14 To: Bar of California, State

To ensure that it adequately informs the Legislature about the status of the IT projects in its strategic plan, the State Bar should annually update the projects' cost estimates, their respective status, and the funds available for their completion.

6-Month Agency Response

At its July 24, 2015, meeting, the Board of Trustees adopted a policy requiring that a written cost-benefit analysis be submitted to the Board of Trustees before committing to, or making a binding agreement as related to, a project or other initiative that is expected to cost in excess of $2,000,000. The report supporting the Board action is being submitted via email.

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

60-Day Agency Response

The State Bar will include the update of this information in its annual report on the status of the implementation of its strategic plan, which is submitted with its final proposed budget to the Legislature by February 15 of each year.

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

Recommendation for Legislative Action

To ensure that the State Bar's fund balances do not exceed reasonable thresholds, the Legislature should consider putting a restriction in place to limit its fund balances. For example, the Legislature could limit the State Bar's fund balances to the equivalent of two months of the State Bar's average annual expenditures.

Description of Legislative Action

Legislation has not been introduced to address this recommendation.

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

Recommendation for Legislative Action

To provide the State Bar with the opportunity to ensure that its revenues align with its operating costs, the Legislature should consider amending state law to, for example, a biennial approval process for the State Bar's membership fees rather than the current annual process.

Description of Legislative Action

Legislation has not been introduced to address this recommendation.

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

Recommendation #17 To: Bar of California, State

To determine a reasonable and justified annual membership fee that better reflects its actual costs, the State Bar should conduct a thorough analysis of its operating costs and develop a biennial spending plan. It should work with the Legislature to set an appropriate annual membership fee based upon its analysis. The first biennial spending plan should also include an analysis of the State Bar's plans to spend its current fund balances.

1-Year Agency Response

See May 13, 2016, Spending Plan.

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

The State Bar analyzed its operating costs and provided a spending plan to the Legislature that included an assessment of the annual membership fee. Although this spending plan is not a biennial plan, as indicated in our recommendation, the State Bar's plan addresses the underlying concern of our recommendation--that the State Bar be more cognizant of its actual costs and take steps to align its membership fee based on those costs.

6-Month Agency Response

The State Bar will prepare an analysis of its operating costs and develop a biennial spending plan, which will be submitted to the Legislature by May 15, 2016.

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

60-Day Agency Response

The State Bar will prepare an analysis of its operating costs and develop a biennial spending plan, which will be submitted by May 15, 2016, to the Legislature, as provided in an amendment pending in Senate Bill No. 387. See Response to Recommendation 13 above.

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

All Recommendations in 2015-030

Agency responses received are posted verbatim.