Report 2018-132 Recommendation 15 Responses
Report 2018-132: Bureau of Gambling Control and California Gambling Control Commission: Their Licensing Processes Are Inefficient and Foster Unequal Treatment of Applicants (Release Date: May 2019)
Recommendation #15 To: Justice, Department of
To ensure that it treats applicants consistently, the bureau should begin conducting periodic reviews by November 2019 to determine whether staff are following procedures when conducting background investigations for applicants for all license types.
1-Year Agency Response
To ensure that staff and managers from different units apply procedures consistently, the BGC created a policy that outlines the processes for upper management review. The policy specifies which reports should be elevated to the BGC Staff Services Manager II and the Assistant Director level for review and approval. The policy also establishes a weekly meeting for staff to discuss unique files to ensure consistency of review.
- Completion Date: March 2020
- Response Date: April 2020
California State Auditor's Assessment of 1-Year Status: Fully Implemented
The bureau provided a memoranda outlining the review and elevation process it describes in its response. Upon our requests, the bureau also provided evidence of weekly meetings it has conducted and directives to licensing staff regarding consistency issues those reviews have identified. If the bureau conducts these reviews regularly and thoroughly, it should be able to prevent the types of inconsistent handling of background investigations we identified during our audit.
6-Month Agency Response
April 24, 2019:
- BGC reviewed its policies for each license type and created a new set of procedures that are utilized for work permits, TPPPPS players and supervisors, and key employees. While the tasks are consistent, the level of review is commensurate to license type. Accordingly, additional tasks are required for TPPPPS supervisors and cardroom key employees.
October 24, 2019:
- BGC established a single set of procedures for cardroom and TPPPPS owner license reviews.
- BGC established a policy outlining the steps required for management review of background investigations reports. At a minimum, first-line managers or their lead analysts must:
o Review applicable checklists to ensure compliance with all background investigation procedures
o Review case notes to ensure pertinent information is included in the investigation report.
- Completion Date: October 2019
- Response Date: November 2019
California State Auditor's Assessment of 6-Month Status: Partially Implemented
As the bureau notes in its response, its updated background investigation policy requires first-line managers to review staff work to ensure compliance with required procedures. However, our recommendation is focused on ensuring consistency of treatment across all applications the bureau reviews, which necessitates a higher level of review to ensure that staff and managers from different units apply procedures consistently. When we followed up with bureau managers, they provided a description of upper management review of different application types, but not any additional protocols or examples of these efforts ensuring consistent treatment of applicants across license types.
- Auditee did not substantiate its claim of full implementation
- Auditee did not address all aspects of the recommendation
60-Day Agency Response
CSA's recommendation was to review and revise each of its background investigation policies by November 2019. As of April 24, 2019, BGC reviewed its policies for each license type and created a new set of procedures that is utilized for work permits, Third Party Providers of Proposition Player Services (TPPPPS) players and supervisors, and key employees. While the tasks are consistent, the level of review is commensurate to license type. Accordingly, additional tasks are required for TPPPPS supervisors and cardroom key employees. BGC is currently developing a single set of procedures for cardroom and TPPPPS owner license reviews with an anticipated completion date of September 30, 2019. Additionally, BGC will establish a procedure for conducting periodic reviews to determine staff's compliance with the procedures.
- Estimated Completion Date: November 2019
- Response Date: July 2019
California State Auditor's Assessment of 60-Day Status: Pending
Agency responses received are posted verbatim.