Report I2016-2 Recommendation 3 Responses

Report I2016-2: Investigations of Improper Activities by State Agencies and Employees: Conflict of Interest, Violation of Post-Employment Ethics Restrictions, Waste of State Funds, Misuse of State Resources, and Incompatible Activities (Release Date: August 2016)

Case Number I2015-0849

Recommendation #3 To: Water Resources Control Board

Provide training to those responsible for reviewing statements of economic interests regarding how to identify conflicts of interests and when to consult with legal counsel.

Agency Response From October 2018

The Water Board reported that it had developed a training module and posted the training on its intranet website in February 2018 so its supervisors and managers can view the training on demand. In addition, the Water Board stated that it will make newly hired supervisors and managers aware of the training and stated that it requires them to review the training on its intranet. Finally, the Water Board stated that during the annual statement of economic interests filing process, it will provide information about the training to all supervisors and managers.

California State Auditor's Assessment of Status: Fully Implemented


Agency Response From November 2017

The Water Board reported that in February 2017 it distributed a memo prepared by its chief counsel that explained the importance of conflict-of-interest reviews, when to consult counsel for advice, and the Water Board's new review process to help avoid conflict-of-interest violations. In addition, the Water Board stated that it would develop a training module for its supervisors and managers to review annually on its intranet site.

California State Auditor's Assessment of Status: Partially Implemented


Agency Response From April 2017

The Water Board reported that due to the timing of developing a best practices memo, it determined that it was impractical to train all supervisors and managers before the annual due date for the annual statement of economic interests. Thus, the Water Board distributed the best practices memo with instructions for supervisors and managers to contact the Water Board's legal staff with any questions. It also provided executive management with instructions on implementing these procedures. Further, the Water Board stated that, as part of developing a training curriculum for supervisors on best practices for human resources-related issues, it would include the review processes in this future training.

California State Auditor's Assessment of Status: Partially Implemented


Agency Response From February 2017

The Water Board reported that its new process is in place and being implemented. However, the Water Board has not described to us how it will provide training to staff responsible for reviewing statements of economic interests.

California State Auditor's Assessment of Status: Partially Implemented


Agency Response From September 2016

The Water Board informed us that its Division of Administrative Services management will perform an initial screening of all statements of economic interests that staff submit. If division management notes potential conflicts of interest, the Water Board will refer the issue to the appropriate highest level manager for resolution.

California State Auditor's Assessment of Status: Pending


All Recommendations in I2016-2