Our audit of the Department of General Services (department), Division of State Architect's (division) processes related to the review of plans for school construction highlighted the following:
As mandated by a state law known as the Field Act (act), the Division of the State Architect (division), part of the Department of General Services (department), supervises the design and construction of K-12 schools and community colleges. The act requires the department—which delegates its responsibilities to the division—to review plans for school construction projects and to ensure that they comply with requirements in Title 24 of the California Code of Regulations (building standards). When the division is satisfied that a set of plans meets legal requirements, it issues an approval letter, which the school district must obtain before beginning construction.
The division and the school districts' licensed architects and structural engineers (design professionals) share responsibility for the time it will take the division to approve construction plans. Once the division receives a complete application for a project, the plan approval timeline moves into three sequential phases: bin time and plan review time, for which the division is primarily responsible, and client time, which is the time it takes the design professionals to make corrections based on the division's comments. The division has a goal of managing its workload to keep bin time—the time between the division's receipt of a complete application and the start of its plan review—below six weeks. Although the division has kept average bin times under six weeks since early 2010, it has done so with a workload that is significantly lower than the level of work it faced in late 2008 and early 2009. From July 2008 through June 2009, the division received an average of 858 new projects each quarter; however, from October 2010 through September 2011, the division received an average of 638 projects each quarter. If the division's workload were to return to previous levels, it would likely again have difficulty meeting its bin time goal and it would risk an increase in the total time it takes to approve plans.
Although the division has a goal for keeping bin time below six weeks, it does not have goals for how long the plan review phase should last. After bin time, projects enter plan review, during which the division ensures that plans meet the minimum requirements of law and of building standards. The division notes any issues it has with the plans and returns them to the design professionals for correction. Without a plan review time goal, the division has less assurance that it is reviewing plans efficiently. Further, without such a goal, design professionals have little certainty about how long they should expect to wait for the division to return the plans.
To help it manage any future increases in workload without negative consequences to its other activities, the division will need to use the retainer contracts it has available. State law allows the division to issue contracts whenever the division deems it necessary to expedite plan review. The division must maintain a list of qualified plan review firms that have signed retainer contracts for plan review work. In the recent past, however, the division was prohibited from using contractors to address high bin times. Instead of contracting, the division shifted staff away from its construction oversight responsibilities. We noted that the division's regional managers believed that the shift affected construction oversight, although they could not quantify the impact. Because the division is likely to need contractors in the future, we believe the division risks lengthening plan approval times if it does not develop a formal policy that defines when it will expedite plan review by using its contracting authority.
Furthermore, the division's performance reports that relate to the length of each phase of the plan approval process do not report clear or accurate information to stakeholders and division management. Instead of reporting information that reflects a snapshot of its current performance, the division reports only on projects that have fully concluded the plan approval process. Because the plan approval process can be long, this means that the division's monthly reports reflect some activities that occurred significantly earlier than the report date, in one case over a year earlier. Further, the division includes data in its reports that cause reported averages for the different phases of the plan approval process to be understated or overstated. For example, the division has included some projects for which no plan review activity occurred because the applications were incomplete, counting the length of time it took to complete each phase as "zero days."
Finally, the division cannot provide assurance that it has received and approved all plan changes before the start of related construction. After the division approves plans, districts must submit plan changes to the division for review and approval before undertaking related construction. However, the division does not have a process to ensure that it has received all relevant plan changes. It also does not have a process for recording and managing all changes to plans that it must review. If the division does not approve plan changes before construction, construction may not comply with building standards and risks being unsafe. According to the former acting state architect, the division is making changes to improve its management of plan changes, which it intends to complete by the end of 2012.
To better gauge the timeliness of its plan review and better communicate with design professionals, the division should develop goals for the time spent on the plan review phase, and measure and report its success at meeting these goals.
In order to avoid delays in plan review, the division should develop a policy that defines when it will expedite plan review using its statutory authority to contract for additional plan review resources.
To more accurately report on its plan review activities to stakeholders and provide relevant information to management, the division should:
To appropriately oversee changes to approved plans, the division should develop policies and procedures to ensure that it:
The department agreed with our recommendations and outlined steps to implement them.