The Bureau of State Audits presents its review and evaluation of the reports submitted by the California Department of Corrections (CDC) and the California Youth Authority (CYA) on the accomplishments of the early intervention pilot program for workers' compensation injuries. The types of worker injuries that are most likely to benefit from early intervention are defined as those injuries resulting in 30 days or more of disability from work, or cases in which the injury was alleged to be the result of psychological stress or its physical manifestation.
In response to Chapter 1233, Statutes of 1988, we obtained the reports prepared by the directors of the CDC and the CYA on the accomplishments of the early intervention pilot program. Complete copies of the CDC's and the CYA's reports are attached to this letter as Attachments A and B, respectively. Our report focuses on our review of the two departments' reports in terms of the accuracy of the data compiled, its completeness, and the reports' compliance with statutory mandates. This review was originally required of the Office of the Auditor General (OAG). However, the OAG was closed in December of 1992 due to budget reductions, but in May 1993 the Bureau of State Audits began operation pursuant to Government Code Section 8456.8 and assumed responsibility for this review.
During our review of the reports submitted by the CDC and CYA, we noted the following conditions:
Effects of Other Workers' Compensation Reforms
Events other than the 1989 implementation of the early intervention program, such as the passage of major workers' compensation legislation in 1989 and 1993, are currently blurring the CDC's and the CYA's attempts to measure the effectiveness of early intervention.
No Mechanism Exists To Effectively Collect Certain Data
The CDC and the CYA were unable to report on certain data requested by the Legislature because no mechanism currently exits to effectively collect the data requested. The statute requires the reporting of the number of workplace injuries meeting early intervention criteria that are reported on a specific state form, the CalOSHA Log 200. However, the Cal-OSHA Log 200 is not designed to effectively identify injuries meeting the criteria for early intervention. Therefore, both the CDC and the CYA relied on information supplied by the State Compensation Insurance Fund (SCIF) as the more accurate source for this data.
Some Data Not In Conformance With Law
Some of the data presented by the CYA and the CDC does not completely conform to statutory requirements. Specifically, the CYA used a data source other than the one requested by statute in reporting on one data element and did not include certain cost data in reporting on another data element. In addition, the CDC used a survey approach in reporting one of its data elements instead of reporting on its entire workforce as required.
Some Data Could Not Be Validated
We were unable to validate the accuracy of some of the source data used by both departments in compiling their reports. Both the CDC and the CYA derived the cost information appearing in their respective reports from data included in a two-year study conducted by the SCIF. This study included data compiled from cases meeting the criteria for early intervention. However, because the SCIF staff gathered the cost information included in the study from 14 of its district offices on various occasions over a two-year period rather than as of a baseline date, it was not possible for us to validate this cost data.
Some Data Was Inaccurate
Some of the data reported by the two departments was not accurate. We found inaccuracies in some of the source data used by both the CDC and the CYA in compiling their reports. Furthermore, some of the data elements that both departments reported and stated came from a specific source did not agree with that source.
The recent passage of major workers' compensation legislation is blurring the CDC's and the CYA's attempts to measure the effectiveness of early intervention. For this reason, the Legislature may wish to consider deferring further attempts to evaluate the accomplishments of the early intervention pilot program until sufficient time has elapsed to accumulate data unaffected by competing workers' compensation legislation.