Report 2015-503 Recommendation 7 Responses

Report 2015-503: Follow-Up—California Department of Social Services: It Has Not Corrected Previously Recognized Deficiencies in Its Oversight of Counties' Antifraud Efforts for the CalWORKs and CalFresh Programs (Release Date: June 2015)

Recommendation #7 To: Social Services, Department of

Social Services should track counties' prosecution thresholds for welfare fraud cases and determine whether they affect counties' decisions to investigate potential fraud, with a focus on determining best practices and cost-effective thresholds. If Social Services' analysis determines that varying prosecution thresholds do affect counties' decisions, it should then work with counties to implement the consistent use of these cost-effective prosecution thresholds.

Annual Follow-Up Agency Response From December 2017

Disagree with recommendation.

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


Annual Follow-Up Agency Response From November 2016

See response to Recommendation 4.

  • Estimated Completion Date: March 2017

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


1-Year Agency Response

Counties are mandated to make a fraud referral for investigation regardless of any prosecution threshold (MPP Section 20-005.1). Therefore, counties' prosecution thresholds cannot affect counties' decisions to investigate potential fraud.

  • Response Date: June 2016

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

Social Services cites its own policy manual when indicating that counties are mandated to make a fraud referral regardless of any prosecution threshold. Our recommendation is asking Social Services to re-evaluate this policy and potentially establish prosecution thresholds based on fraud totals that are cost effective to pursue. Instead of gathering information to evaluate the feasibility of this potential approach, Social Services simply reiterates its existing policy.


6-Month Agency Response

Social Services reasserts its position that there is no direct relationship between a prosecution threshold and counties' decision to investigate welfare fraud. As the Department has explained previously, counties have an obligation to make a fraud referral for investigation regardless of any prosecution threshold.

  • Response Date: December 2015

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

Similar to its previous response, this response by Social Services is supposition. Our recommendation is for Social Services to analyze actual county practices in order to determine whether or not counties' prosecution thresholds affect counties' decisions to investigate potential fraud.


60-Day Agency Response

See initial response.

  • Response Date: August 2015

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

Social Services reasserts that there is no direct relationship between prosecution thresholds and counties' decisions to investigate welfare fraud. However, and as we explained in our comments on the initial response that Social Services provided in the follow-up audit report, Social Services has not taken any action to track how counties determine prosecution thresholds and the effects those thresholds on counties' decisions to investigate potential welfare fraud. We continue to expect Social Services to demonstrate the presence or absence of this effect through an analysis of actual county practices, rather than through supposition.


All Recommendations in 2015-503

Agency responses received are posted verbatim.


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