Report 2021-104 Recommendation 7 Responses

Report 2021-104: Metropolitan Water District of Southern California: Its Leadership Has Failed to Promote Transparency or Ensure a Fair and Equitable Workplace (Release Date: April 2022)

Recommendation #7 To: Metropolitan Water District of Southern California

To ensure timely response to EEO complaints, by October 2022 MWD should update its investigation procedures to include time frames that match DFEH best practices for responding to, investigating, and closing EEO complaints and should adhere to those time frames. MWD should report to its board quarterly on how many EEO complaints have been received and investigated, including how many of those investigations surpassed the time frames in MWD's procedures.

1-Year Agency Response

Metropolitan fully implemented the recommendation to update its investigation procedures and improve EEO complaint response, tracking and reporting. EEO is now using a new and improved case management system, iSight. Report tool trainings were held for EEO staff in March 2023. Quarterly reports to the Board, which include how many EEO complaints have been received and investigated, started in October 2022. The April report to the Board covers January-March 2023.

Since establishing the 90 business-day timeline on October 18, 2022, we have received 40 complaints into the EEO Office. Of those, 23 have been closed, 13 are currently under investigation, and four are in the process of intake assessment. Two of these have exceeded the 90-day timeline established. Both instances had extenuating circumstances.

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

MWD provided revised investigation procedures that address various gaps we identified in its prior procedures with respect to DFEH best practices. In addition, MWD reported to its board in April 2023 that of 23 cases it had closed since October 2022, only one had exceeded the 90-day time frame in its procedures. MWD should continue to strive to adhere not only to the overall time frame, but also the individual components of its new procedures, and in so doing, assess the reasonableness of those time frames the resources it needs to perform the procedures effectively and consistently.

6-Month Agency Response

Metropolitan updated its EEO policies (H-07 and H-13), which state that all investigations must be promptly addressed.

The EEO Complaint and Investigative Procedures (EEO Procedures) were developed and the deadlines for responding to, investigating and closing EEO complaints are included.

Metropolitan implemented a new system to manage investigations, which will make reporting to the Board on a quarterly basis administratively efficient and accurate.

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

This recommendation was fully implemented at the one-year agency response.

60-Day Agency Response

Metropolitan updated its EEO policies (H-07 and H-13), which state that all investigations must be promptly addressed.

Metropolitan is implementing a new system to manage investigations with a new case management vendor, i-Sight. This system will make reporting to the Board on a quarterly basis administratively efficient and accurate.

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

MWD's revised EEO and sexual harassment policies do not contain time frames for responding to, investigating, and closing EEO complaints. We will evaluate this recommendation in October 2022 to assess whether MWD has implemented such time frames and the reporting practices included in the recommendation.

All Recommendations in 2021-104

Agency responses received are posted verbatim.