Report 2017-030 Recommendation 6 Responses

Report 2017-030: The State Bar of California: It Needs Additional Revisions to Its Expense Policies to Ensure That It Uses Funds Prudently (Release Date: June 2017)

Recommendation #6 To: Bar of California, State

To assign purchasing cards only to appropriate staff, ensure that the State Bar's records of employees' credit limits reflect those established with the bank, and to verify that staff use purchasing cards only for allowable and necessary expenses, the State Bar should immediately develop a policy that requires justification of the business needs for employees to receive purchasing cards, and use this policy to limit the number of staff issued a purchasing card.

Annual Follow-Up Agency Response From October 2018

Fourteen (14) cardholders have monthly limits greater than $5,000; of these, nine (9) have single purchase limits over $5,000. These limits are permitted for expenses related to administration of the California Bar Examination, or for expenses related to facilities management or other support operations, such as our monthly Lexis and Westlaw subscriptions, monthly employee parking charges, monthly off-site storage charges, copier supplies, miscellaneous IT equipment, and group training registrations. They are assigned only to specific individuals with responsibility for specific operational areas. In some cases payment via invoice is not feasible; in others, payment via invoice would be less efficient. The cardholder who had a $95,000 monthly limit has been reduced to $75,000. We will perform our annual review of all cardholders in January 2019 and will further reduce the number of cardholders with limits over $5,000, where feasible.

  • Completion Date: February 2018

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

State Bar did revise its policy to require justification of the business need for employees to receive purchasing cards and to include an annual review of the business justification for those purchasing cards. However, State Bar continues to allow some State Bar employees to maintain purchasing card limits greater than $5,000 -- including one employee with a limit of $75,000 (monthly). Generally, purchases of this size are not small and recurring expenses, but rather larger purchases that the State Bar should make through the regular procurement process.

  • Auditee did not address all aspects of the recommendation

1-Year Agency Response

New purchasing card policies have been incorporated in Section 6.0 of the State Bar's Procurement Manual as of 2/5/2018.

  • Completion Date: February 2018
  • Response Date: June 2018

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

State Bar did revise its policy to require justification of the business need for employees to receive purchasing cards and to include an annual review of the business justification for those purchasing cards. However, State Bar continues to allow some State Bar employees to maintain purchasing card limits greater than $5,000 -- including one employee with a limit of $95,000 (monthly) and $30,000 (single purchase). Generally, purchases of this size are not small and recurring expenses, but rather larger purchases that the State Bar should make through the regular procurement process.

  • Auditee did not address all aspects of the recommendation

6-Month Agency Response

The State Bar is reviewing its purchasing card policies and will implement this recommendation by January 2018.

  • Estimated Completion Date: January 31, 2018
  • Response Date: December 2017

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

We look forward to the State Bar providing a more complete description of its actions to implement our recommendations, as well as evidence of those actions, at its one-year response in June 2018.


60-Day Agency Response

The State Bar is reviewing its purchasing card policies and will implement this recommendation by January 2018.

  • Estimated Completion Date: January 2018
  • Response Date: August 2017

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


All Recommendations in 2017-030

Agency responses received are posted verbatim.