The Child Abuse
Central Index
The Unreliability of This Database Puts Children
at Risk and May Violate Individuals’ Rights
May 2022

REPORT 2021‑112

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CALIFORNIA STATE AUDITOR
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May 31, 2022
2021-112
The Governor of California
President pro Tempore of the Senate
Speaker of the Assembly
State Capitol
Sacramento, California 95814

Michael S. Tilden Acting State Auditor

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Respectfully submitted,

|

Sacramento, CA 95814

MICHAEL S. TILDEN, CPA
Acting California State Auditor

621 Capitol Mall, Suite 1200

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916.445.0255

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916.327.0019 fax

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w w w. a u d i t o r. c a . g o v

To better protect children from individuals with a history of perpetrating abuse, the Legislature
should streamline the process for sharing reports of child abuse, which would help DOJ provide the
most complete and accurate response to the background checks authorized users request.

The audit found that the current child abuse reporting process is cumbersome and error-prone,
and it revealed multiple reasons for CACI’s incomplete data. Specifically, DOJ did not always enter
into CACI the reports of child abuse it received from counties, and counties did not always send
reports of child abuse to DOJ for entry into the database. Furthermore, state law allows for
differing interpretations of which child abuse reports the counties should send to DOJ. As a result,
at least one county requires that a social worker interview a suspected child abuser before it will
submit a substantiated report of child abuse to DOJ, while other counties do not generally follow
this interpretation.

Our audit of the California Department of Justice’s (DOJ) Child Abuse Central Index (CACI)—the
database that is meant to be a comprehensive list of individuals with substantiated reports of child
abuse—found that less than half of the 52,000 reports of child abuse that social workers substantiated
from July 2017 through June 2021 were in CACI. This difference means that authorized users of
CACI cannot depend on the database to help protect children when they make decisions about
hiring individuals to work in day care centers or group homes, or about whom they can entrust with
the care or custody of a child.

Dear Governor and Legislative Leaders:

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California State Auditor Report 2021-112

May 2022

Selected Abbreviations Used in This Report
ACHS

California Automated Criminal History System

CACI

Child Abuse Central Index

CWS

Child Welfare Services

CWS/CMS

CWS Case Management System

DOJ

California Department of Justice

California State Auditor Report 2021-112

May 2022

Contents
Summary

1

Recommendations

3

Introduction

7

Audit Results
CACI Is Missing Many Suspects With a History of Child Abuse

13

DOJ and County CWS Agencies Could Not Adequately Explain Why
CACI Is Missing Thousands of Substantiated Reports of Child Abuse

15

CACI Incorrectly Identifies Some Individuals as Having a History of
Child Abuse

20

DOJ Lacks Adequate Controls for Ensuring That CACI Contains
Accurate and Appropriate Records

22

Legislative Action Is Needed to Fix the State’s Error-Prone and
Inefficient Process for Entering Data Into CACI

23

Appendix A
Statewide Statistical Information in CACI

29

Appendix B
Scope and Methodology

39

Response to the Audit
Calaveras County

43

California Department of Justice

45

California State Auditor’s Comments on the Response From
the California Department of Justice
California Department of Social Services
California State Auditor’s Comments on the Response From
the California Department of Social Services

55
59
65

Contra Costa County

69

Kern County

71

California State Auditor’s Comments on the Response From
Kern County

75

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Orange County
California State Auditor’s Comment on the Response From
Orange County

77
79

Shasta County

81

Stanislaus County

83

California State Auditor Report 2021-112

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Summary
Results in Brief

Audit Highlights . . .

The California Department of Justice (DOJ) administers the Child
Abuse Central Index (CACI), a database containing substantiated
cases of physical, sexual, and emotional abuse or severe neglect of
a child (child abuse) that have been forwarded to DOJ by county
Child Welfare Services (CWS) agencies. Authorized users, such
as social welfare, law enforcement, and county licensing agencies,
rely on information in CACI to inform screening decisions for
applicants who wish to care for children or before placing a
child in a foster care home, among other reasons. However, the
effectiveness of CACI as a tool for protecting children is seriously
hindered by inaccurate and incomplete data.

Our audit of CACI highlighted the following:

Specifically, we found that CACI does not contain more than
half of the child abuse cases, or about 27,000 cases, that were
substantiated by county CWS agencies statewide during the
four‑year period ending in June 2021, equating to 22,000 unique
suspects with a history of child abuse being completely excluded
from the database. Moreover, given the significant gap in CACI
reports for the four‑year period we reviewed, it is highly likely
that CACI is also missing a large number of suspects from prior
years that we did not examine. Our review of a selection of
60 cases that were not in CACI from six counties—Calaveras,
Contra Costa, Kern, Orange, Shasta, and Stanislaus—revealed that
miscommunication among county staff and a lack of tracking from
DOJ were major causes of these missing reports. We further found
that state law and certain counties’ processes allow county staff to
substantiate certain cases but not report them to CACI when the
social worker is unable to interview the suspected abuser. Because
of this nuance in state law, some substantiated cases of child sexual
abuse and exploitation are not being reported to CACI. As a result,
the safety of children is at risk because authorized users of CACI
are unable to appropriately vet individuals before enabling them
to have access to children. In fact, when we compared the list of
substantiated reports of child abuse that are not in CACI with
individuals about whom DOJ performed CACI background checks,
we found that DOJ provided at least 224 letters to authorized users,
such as county licensing agencies, indicating that these individuals
did not have substantiated child abuse reports in CACI when
county records indicated otherwise.1

1

As indicated in the Audit Results, available evidence indicates that DOJ sent but did not retain
additional letters to authorized users that had requested expedited background checks for
individuals whose substantiated cases of child abuse are not in CACI. However, we cannot
accurately determine the number of additional letters that DOJ sent.

» Although CACI is meant to be a
comprehensive database of substantiated
cases of child abuse identified by county
CWS agencies throughout the State, we
found that it does not contain records
for as many as 22,000 individuals with
histories of substantiated child abuse
during a recent four-year period.
• Users of this database cannot depend
on it to help protect children from
being placed in the care of individuals
with a history of abusing children.
• In fact, we found that DOJ provided
at least 224 letters to authorized
users indicating that individuals
did not have substantiated child
abuse reports when county records
indicated otherwise.
» Conversely, but on a smaller scale, CACI
incorrectly identifies some individuals
as having a substantiated history of
child abuse.
• We found 298 reports of child abuse
in CACI that were not supported by
county records.
» The State relies on an error-prone manual
process for managing CACI data.
» We recommend legislative action to
reduce errors and inefficiencies in the
child abuse background check process by
giving DOJ direct access to substantiated
child abuse reports contained in the same
system counties use to record the results
of their child abuse investigations.

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Additionally, although the problem is not nearly the same size or
scope as the thousands of missing records in CACI, we identified
298 reports of child abuse in CACI during the same four‑year
period that did not have corresponding substantiated reports of
child abuse in county records. Because these individuals were
included in CACI, DOJ sent at least 25 letters in response to
background checks by authorized users notifying them that these
individuals were a possible match with a known child abuse
suspect in CACI. These records were included in CACI because
of a number of factors, including county CWS agencies’ and DOJ’s
lack of appropriate policies for removing records from CACI. As a
result, DOJ indicated that these individuals had a history of child
abuse, which could result in authorized users denying or delaying
the opportunity for these individuals to care for children.
The source of many of the problems we found is the State’s reliance
on an inefficient, manual process for managing CACI data, a
process that is prone to avoidable errors. As a result, DOJ was
unable to ensure that it had entered all reports into CACI, and
we determined that 22,000 suspects with a substantiated history
of child abuse were not included in CACI. DOJ was also unable
to demonstrate that it has appropriately deleted records from
CACI. These problems can hinder DOJ from quickly and reliably
responding to CACI background checks, and they further increase
the risk that DOJ would send a response letter with incomplete or
inaccurate information. However, the Legislature could resolve this
by changing state law to give DOJ direct access to the same system
that county CWS agencies use to document county‑substantiated
cases, bypassing the cumbersome and error‑prone CACI reporting
process and thereby increasing the accuracy and efficiency of the
background checks DOJ performs on individuals wishing to care
for children.
Agency Comments
Although DOJ believed it needed to provide additional context
related to our audit findings and conclusions, it generally agreed to
implement our recommendations. Social Services generally agreed
with the intent of our recommendations, but expressed concerns
with how it would implement the recommendations. The counties
we reviewed generally agreed with our findings and conclusions
and indicated that they would implement our recommendations.

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Recommendations
The following are the recommendations we made as a result of our
audit. Complete descriptions of the findings and conclusions that
led to these recommendations can be found in the Audit Results
section of this report.
Legislature
To better protect children when an authorized user requests a child
abuse background check, the Legislature should amend state law to
require DOJ to directly access and review CWS Case Management
System (CWS/CMS) data, which counties already use to record
the results of their child abuse investigations. If the Legislature
implements this change, it should no longer require counties to
submit reports of child abuse to DOJ for inclusion in CACI, thus
eliminating redundant efforts and reducing the risk of error.
To maximize the effectiveness of child abuse background checks
in protecting children, the Legislature should amend state law to
require all reports of substantiated child abuse to be included in
DOJ’s background checks. To protect the due process rights of
individuals, the Legislature should continue to require a grievance
hearing process.
DOJ
Until the Legislature amends state law and DOJ develops processes
to use the CWS/CMS data for child abuse background checks,
DOJ should do the following:
• Immediately develop a process for responding to child abuse
background checks that includes checking CACI and the list of
298 reports of child abuse that were not supported by county
records, and working with the California Department of Social
Services (Social Services) to check the list of 27,000 reports of
substantiated child abuse that were not contained in CACI. If
the individual is on either list, DOJ should follow up with the
relevant county to determine whether the individual’s report
should be included in CACI.
• Collaborate with Social Services by November 2022 to identify
and reconcile all reports that should have been submitted to
CACI by counties. Work with counties to enter all missing
reports into CACI by June 2023. This collaboration should not be
limited to the reports in our four‑year audit period.

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• To ensure that it accurately enters all cases of child abuse
it receives, by July 2022 DOJ should develop policies and
procedures to track, enter into CACI, and review data entry
for all reports of child abuse it receives from counties. Also by
July 2022, DOJ should develop policies and procedures to track
those reports that it sends back to counties for correction.
• To ensure that only appropriate records are removed from CACI,
by July 2022 DOJ should develop policies and procedures related
to how staff remove records from CACI. These policies and
procedures should include a process to verify that deletions are
appropriate.
• To prevent omissions in CACI reporting, DOJ should develop
policies and procedures by November 2022 to reconcile CACI
with monthly reports from Social Services to verify that
counties have submitted—and DOJ has entered or deleted as
appropriate—all reports into CACI.
To ensure that authorized users have accurate and complete
information, by July 2022 DOJ should send revised letters for the
suspects whose reports of child abuse were omitted from CACI and
for individuals inappropriately included in CACI. To ensure that it
is able to revise expedited letters if they are later determined to be
incorrect, DOJ should immediately begin maintaining a history of
all responses to expedited background checks.
To ensure that suspects’ information is deleted from CACI in
accordance with state law, by November 2022 DOJ should research
and address the 36,000 reports in CACI lacking birth dates by
entering the suspect’s correct birth date and removing suspects who
no longer meet the CACI requirements.
Social Services
Until the Legislature amends state law and DOJ develops processes
to use CWS/CMS, Social Services should do the following:
• Immediately develop a process to collaborate with DOJ and
counties to review the list of 27,000 reports of substantiated
child abuse that were not in CACI and ensure that all eligible
missing reports are forwarded to DOJ.
• By November 2022, develop monthly reports from CWS/CMS of
cases of child abuse substantiated during the month and another
list of cases that changed from substantiated to not substantiated,
and then provide these reports to the counties and to DOJ.

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• By November 2022, ensure that all counties develop policies and
procedures to review the monthly reports produced by Social
Services and ensure that they have sent all appropriate reports
to DOJ.
• By November 2022, collaborate with DOJ to identify and
reconcile all reports that should have been submitted to CACI
by counties and work with counties to send all reports to
CACI by May 2023. This collaboration should not be limited
to the reports of our four‑year audit period.
Counties
To ensure that it submits accurate and complete information to
CACI, by July 2022 Calaveras County should develop policies and
procedures for reporting all incidents of substantiated child abuse
that it actively investigates, in accordance with state law.
To ensure that they correctly revise and resend reports that were
incomplete and needed correction, by July 2022 Calaveras, Kern,
Orange, Shasta, and Stanislaus counties should develop policies and
procedures for accurately responding to and tracking reports DOJ
sends back for correction.
To ensure that CACI contains accurate and complete information,
and to ensure that individuals’ rights are adequately protected,
by July 2022 Calaveras, Contra Costa, and Shasta counties
should develop policies for removing existing reports in CACI
when warranted.
To ensure that CWS/CMS contains accurate investigation
conclusions, by July 2022 Calaveras and Contra Costa counties
should immediately identify and correct the reports in CWS/CMS
that are incorrectly marked as substantiated.
To ensure fair and impartial grievance hearings and to comply
with state regulations, Contra Costa, Kern, and Stanislaus counties
should, by July 2022 adopt grievance hearing policies allowing
the complainant to challenge the impartiality of the grievance
review officer.
To ensure the confidentiality of sensitive and personally identifying
information protected by state law, Orange and Stanislaus counties
should, by July 2022 adopt grievance hearing policies requiring
the return of confidential evidence when the county provides such
evidence to suspects for a grievance hearing.

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California State Auditor Report 2021-112

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Introduction
Background
Since 1965 state law has required the California
Department of Justice (DOJ) to maintain the
Child Abuse Central Index (CACI) as a statewide
repository for reports of child abuse and severe
neglect. County Child Welfare Services (CWS)
agencies submit substantiated reports to DOJ
after determining through their investigations
that it is more likely than not that an individual
has intentionally caused a child physical harm or
death, has committed sexual assault or exploitation
of a child, or has intentionally failed to provide
food, clothing, shelter, or medical care to a child.2
Throughout this report we refer to these various
acts of abuse and severe neglect as child abuse.
State law restricts the release of information in
CACI to authorized users, listed in the text box,
and to individuals requesting information on
whether they are listed in CACI.

Authorized Users of CACI
For the purpose of investigating or prosecuting child
abuse, or for performing background checks on individuals
who will care for or have regular contact with children,
state law authorizes the following entities to have access
to CACI records:
• California Department of Social Services
• County licensing agencies
• Tribal agencies
• In-state or out-of-state adoption agencies
• Health care practitioners who are treating individuals
reported as possible victims of child abuse
• State or county child death review councils
• Law enforcement agencies
• County welfare departments

The primary purpose of CACI is to centralize
• Prosecutors and court investigators
reports of child abuse so that authorized users
can locate reports about individuals and identify
• Court Appointed Special Advocates
the local agency that investigated the incident.
• Government agencies conducting background
As of August 2021, CACI contained references to
checks for peace officer applicants.
more than 700,000 reports of child abuse. This
• Other county child welfare agencies or their
information enables authorized users conducting
delegates who conduct background investigations on
background checks to determine whether an
applicants seeking employment or volunteer status
individual has been named as a suspect of
that would give them direct access to children.
substantiated allegations of child abuse, and, if so,
Source: State law.
to obtain the investigative information in order
to inform decisions when hiring staff to care for
children or when placing children under someone’s
care. For example, state law requires licensed
adoption agencies to check CACI—in addition to performing a
criminal record review—as part of their vetting process of any
prospective adoptive parent. Should DOJ notify the authorized
user that CACI contains a relevant report, state law requires the
authorized user to obtain the original investigation report and to
form an independent hiring or placement decision based on the
quality of the evidence in the report.

2

Prior to 2012, local law enforcement agencies also sent child abuse reports to DOJ.

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The Importance of CACI
Although state law may require authorized users to perform
criminal history reviews, including a check of criminal information
databases, these databases do not necessarily contain the same
individuals or information that CACI does. Notably, the California
Automated Criminal History System (ACHS) records information
such as arrests or convictions, which require different evidentiary
standards than is required for inclusion in CACI. For example, for
a suspect to be found guilty of a criminal charge of child abuse in a
court proceeding—and have the conviction entered into ACHS—a
court would have found, beyond a reasonable doubt, that the child
abuse occurred. On the other hand, CACI contains substantiated
reports of child abuse, which state law defines as those cases in
which the investigator concluded that child abuse more likely than
not occurred, which is a lower evidentiary standard. Further, state
law prohibits the release of arrest or court information from ACHS
under certain circumstances, such as when the individual completes
education, treatment, or rehabilitation programs in lieu of further
criminal proceedings. In these cases, DOJ would report that ACHS
did not contain any criminal history of the individual, and the only
record of a substantiated investigation of child abuse would come
from CACI. Because some authorized users have access to certain
reports of child abuse only through CACI, it is critical that CACI be
accurate and complete.
State law describes counties as responsible for the completeness
and accuracy of the reports they send to DOJ, and it also requires
DOJ to maintain the database and ensure that the information
counties submit is accurately reflected in CACI. If suspect reports
are not added to CACI as state law requires, authorized users
may lack critical information when deciding whether to allow an
individual to have contact with children. Additionally, to the extent
that authorized users do not perform independent reviews of CACI
information sent to them by DOJ, individuals who are incorrectly
included in CACI may be denied certain rights and privileges, such
as the ability to adopt children or the ability to be employed to care
for children.
Information Flow of CACI Reports
County social workers conduct investigations of suspected
child abuse and document these investigations in the statewide
CWS Case Management System (CWS/CMS) maintained by
the California Department of Social Services (Social Services).
In addition to recording information on the allegations of abuse
and the individuals involved, CWS/CMS contains a variety of
information such as records of foster placements of children,

California State Auditor Report 2021-112

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services provided to families, and relevant actions by the courts.
When social workers complete the associated investigations and
substantiate allegations, CWS/CMS automatically populates a
CACI report with the available data. Social workers then print,
finalize, and mail the reports to DOJ as DOJ requires. According
to DOJ, if it determines that the reports are missing any required
information, it mails the reports back to the county and requires
the county to resend corrected reports. DOJ’s staff manually
enter complete reports into the CACI database. Then, a DOJ
staff member reviews the data entry to ensure that it accurately
reflects the reports before a separate DOJ unit scans and stores
an electronic copy of the reports. Figure 1 shows the CACI report
submission, input, and reporting processes.
When counties need to amend or remove an
existing report from CACI, they may mail, fax, or
email DOJ a request to do so. According to DOJ, it
reviews these requests and either updates the
information in CACI or deletes the record. State
law requires DOJ to remove suspect records from
CACI for the reasons described in the text box.

State law requires DOJ to remove suspect records
from CACI for the following reasons:
• The suspect reaches 100 years of age.
• The suspect was under 18 years of age at the time of the
incident, is listed once in CACI with no subsequent listings,
and 10 years have passed since the date of the incident.

Finally, DOJ staff process the requests from
• The reporting agency notifies DOJ that the suspect should
authorized users to search for individuals in
be removed from CACI because the original report is no
longer substantiated.
CACI. According to DOJ, its staff search for
possible matches between suspects in CACI and
Source: State law.
the individual’s identifying information provided
during the application process. Depending on
the result of the CACI search, DOJ responds to
the authorized user with a letter stating that either there was no
match to CACI suspects or there was a possible match to CACI
suspects. The possible match letter advises the authorized user
to contact the county CWS agency that submitted the report for
further information.3

3

DOJ indicated that it sends a notification to the suspect when there is a possible match to CACI
records and when the purpose of the background check does not involve caring for a relative’s
child. We did not validate whether DOJ consistently performs this notification to the suspect
because we found no requirement that it do so.

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Figure 1
Information Flow for Reports of Child Abuse
COUNTY CHILD WELFARE SERVICES AGENCIES SUBSTANTIATE CASES OF CHILD ABUSE

~

~

cl/

m,

C ►r---=-------c ►r------{ ►r------< ►r-----....

County social worker
investigates and
substantiates an
incident of child abuse.

Social worker enters
the investigation into
CWS/CMS.

County staff print the
report of the incident.

Supervisor reviews the
report and makes
changes, if necessary.

~

~

············································@·································:...: County mails
County staff perform additional
work to revise the report.

~

US Postal Service delivers the report back to
the county child welfare services agency.

···················@····················.

(

~

the report
to DOJ.
US Postal Service delivers the
report to DOJ in Sacramento.

©

j

DOJ ENTERS INFORMATION INTO CACI
----~ ►1------

DOJ mails the report
back to the county to fill
in missing information.

:.........................
Complete

~

I

Missing information

◄ )...---------{◄ 1-------

DOJ evaluates whether the report is
complete or missing information.

~

DOJ sorts and bundles mail for the
unit that processes CACI reports.

~

-------t ►>--------<

DOJ manually enters
the report into CACI.
BACKGROUND CHECK

u1
?

DOJ reviews the
data entry work.

DOJ RESPONDS TO BACKGROUND CHECKS

~t ;

~~

CACI and generates either a “no match”
or a “possible match” letter.

response letter to the
background check requester.

cl------@----o
DOJ searches for the individual in
DOJ prints and mails a

Authorized user requests a background
check, including a CACI search.

Source: State regulations, county policies, and interviews with staff at DOJ and Calaveras, Contra Costa, Kern, Orange, Shasta, and Stanislaus counties.

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Grievance Hearings Process
According to state law, when counties submit a CACI report to
DOJ, they must notify the suspect that a report of the substantiated
child abuse, listing the individual as the suspected perpetrator, has
been added to CACI and that he or she has a right to request a
grievance hearing to challenge inclusion in CACI. Social Services’
regulations allow a county to conduct an internal review of the
matter identified in the request before holding a hearing. State
law and regulations also impose various protections for ensuring
the fairness of grievance hearings, such as requiring the exchange
of evidence between the county and the suspect in advance and
requiring a process that enables the suspect to challenge the
impartiality of the hearing’s presiding officer, whom the county
can select. Moreover, when a hearing concludes that the suspect’s
CACI listing was based on a report that was not or is no longer
substantiated, state law requires county CWS agencies to notify
DOJ of the result, and it requires DOJ to remove that person’s
name from CACI. According to DOJ, it processes written requests
from counties to remove records for individuals, and when it finds
the corresponding individual and report to remove from CACI,
it deletes the individual’s report from the system. If DOJ also
determines that it sent a possible match letter to a CACI authorized
user within the past 12 months, it sends an amended letter to notify
the authorized user of the change in status.
CACI Reporting Is a State‑Mandated Program
In 2007 the Commission on State Mandates found that certain
requirements imposed on county CWS agencies, including CACI
reporting requirements, constitute a state mandate. As such,
county CWS agencies can opt out of this reporting unless they
receive funding from the State. To provide resources for counties to
continue child abuse reporting, recent budget acts have allocated
funding to the counties in the form of Interagency Child Abuse and
Neglect block grants. The vast majority of counties accepted this
grant funding and therefore remained obligated to submit CACI
reports to DOJ. Although at least one county voluntarily continued
to report child abuse to DOJ, four counties opted out of this grant
for some portion of our four‑year audit period and thus were not
required to complete the CACI reporting in those years that they
opted out. We estimate that these four counties were not obligated
to report only about 200 cases of substantiated child abuse, or
0.4 percent of all substantiated child abuse in the State during the
four‑year period we reviewed. Therefore, this particular condition
had little to no effect on the analysis presented in our Audit Results.

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Audit Results
CACI Is Missing Many Suspects With a History of Child Abuse
CACI does not contain all of the reports of child abuse contained
in the county CWS agencies records. In evaluating CWS/CMS data
statewide, we identified more than 52,000 reports of substantiated
child abuse that the counties generated during the four‑year period
ending June 2021. However, as shown in Figure 2, CACI contained
only about 25,000 of these substantiated reports, meaning that
it did not include more than half—about 27,000. These 27,000
reports concern about 25,000 unique suspects, and more than
22,000 of these suspects had no other reported information in
CACI. As a result, authorized users requesting background checks
for these 22,000 individuals may be unaware that these individuals
have a history of substantiated child abuse. Given this significant
gap in CACI reports for the four‑year period we reviewed, it is
highly likely that CACI is also missing a large number of suspects
from other years that we did not examine.
Figure 2
CACI Does Not Contain 22,000 Suspects Because It Is Missing Substantiated Reports of Child Abuse for the Period
of July 2017 Through June 2021

As a result, 22,000 unique
suspects are completely
missing from CACI.

48%

CACI contains more than
25,000 reports that are

supported by county records.

Source: Data from DOJ and Social Services.

CWS/CMS

contains more than
52,000 reports.

52%

Nearly 27,000 reports
appear in CWS/CMS but
do not appear in CACI.

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Children are at risk of being harmed when CACI is incomplete
because the missing data may result in an authorized user
permitting a suspect to have access to children. As we discuss
in the Introduction, CACI enables authorized users conducting
background checks to determine whether an individual has
a history of substantiated child abuse. However, if CACI is
incomplete, DOJ cannot notify an authorized user of a missing
suspect’s abuse record. If the authorized user then permits the
suspect to have access to children, those children are at increased
risk of abuse.
We compared the list of the approximately 27,000 substantiated
reports of child abuse that were not in CACI with the
individuals for whom DOJ performed a requested CACI check
as of August 2021. As a result of our analysis, we found at least
224 instances in which DOJ sent a letter to an authorized user
indicating that an individual did not match with any report in
CACI even though we determined that each of those individuals
had at least one substantiated case of child abuse in CWS/CMS.
These authorized users might have unknowingly made children
more vulnerable to abuse by enabling these suspects to have
access to children. For example, in September 2020, an authorized
user inquired about an individual who was requesting a license for
a family day care. This individual had a history of substantiated
child abuse in CWS/CMS, yet because CACI did not contain
this report, DOJ sent the authorized user a letter stating that the
individual did not match any reports in CACI. As a result of our
inquiry, DOJ worked with the county to obtain the report, and in
March 2022 DOJ notified the authorized user of the child abuse.
However, during the intervening 18 months, the individual may
have inappropriately had access to children.
Available evidence suggests that
the total number of letters DOJ
sent to authorized users indicating
that individuals did not match
to CACI even though they had a
substantiated case of child abuse
is much higher than the 224 letters
we found.

Additionally, available evidence suggests that the total number of
letters DOJ sent to authorized users indicating that individuals
did not match to CACI even though they had a substantiated
case of child abuse is much higher than the 224 letters we found.
These additional letters would have resulted from DOJ’s expedited
CACI background check process. For such expedited background
checks, DOJ only maintains up to two months of request data
and does not retain copies of all of the resulting letters. For the
data available at the time of our review, we found an additional
97 expedited requests for individuals with a history of child abuse
whose reports were not in CACI. Although DOJ did not maintain
letters resulting from all of these requests, these letters would
not have been able to disclose the substantiated cases of child
abuse missing from CACI. Therefore, authorized users could not
have obtained and used these case records in their efforts to vet
or investigate these individuals. Although we cannot quantify
the number of expedited letters in which authorized users would

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not have been notified of substantiated cases of child abuse, we
believe the current incompleteness of CACI greatly diminishes the
reliability of DOJ’s expedited CACI background check process and
poses a significant threat to the safety of children.
DOJ and County CWS Agencies Could Not Adequately Explain Why
CACI Is Missing Thousands of Substantiated Reports of Child Abuse
We followed up on 60 selected reports of child abuse at the
six counties we reviewed, out of the approximately 27,000
substantiated child abuse reports statewide that were not in
CACI, to determine whether the reports met the CACI reporting
requirements and why they were not included in CACI. For the
majority of missing reports, DOJ and the county CWS agencies
could not adequately explain why the reports are missing from
CACI. Overall, the counties appear to have provided 29 of the
60 reports to DOJ, as shown in the Table, but we were unable to
find them in CACI. For another 23 reports, the counties either did
not mail the reports to DOJ or the counties could not demonstrate
that they had done so. For five reports, the counties incorrectly
recorded the cases as substantiated and appropriately did not send
the reports to DOJ. Finally, for the remaining three reports, the
county asserted that the reports did not meet CACI reporting
requirements despite substantiating the allegations of child abuse
against these suspects. Our review confirmed that 52 of the
60 reports should have been entered into CACI. The failures in
communication and data entry throughout the reporting process
are extremely concerning because these reports that should have
been added to CACI represent suspects about which those who
depend on CACI would not be informed.

The current incompleteness of CACI
greatly diminishes the reliability of
DOJ’s expedited CACI background
check process and poses a
significant threat to the safety
of children.

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Table
Counties Failed to Send and DOJ Failed to Enter Reports of Substantiated
Child Abuse
NUMBER OF
REPORTS

Reports counties assert
they sent to DOJ

Reports counties did
not send to DOJ or
could not demonstrate
they had done so

The county maintained a copy of the report in its
case files.

14*

The county maintained a copy of the report in its
case files, but the report lacks some information that
DOJ requires.

15

Subtotal

29

The county failed to send the report to DOJ.

14

The county did not maintain a copy of the report in
its case files but has other evidence it may have sent
the report.
Subtotal

Reports for which the
county incorrectly
recorded the outcome
of the investigation

The county should not have recorded the incident as
substantiated child abuse in CWS/CMS. The county
appropriately did not send a report to DOJ.

Reports the county
substantiated but that
should not be sent
to DOJ

The county substantiated child abuse, but it determined
that its investigations and conclusions did not meet
CACI reporting requirements.
Total

9
23

5

3

60

Source: Analysis of DOJ and Social Services data and county documents.
* DOJ entered one of these reports after we received a copy of the CACI data in August 2021.

DOJ Could Not Adequately Explain Why It Failed to Enter Reports
Into CACI
DOJ could not explain why it failed to enter reports into CACI
because it did not track the reports it received. It also lacked
policies for its process of entering information into CACI. When we
discussed with DOJ the 29 reports that counties appeared to have
submitted but that were not in CACI, the manager of the applicant
services program over CACI background checks (applicant services
manager) was not able to verify that DOJ had received all of those
reports. Specifically, although the applicant services manager stated
that DOJ entered one report into CACI after we obtained data for
our analysis, she was unable to verify that DOJ received the other
28 reports because DOJ did not adequately track the CACI reports
it received. When we showed the applicant services manager
the 28 reports, she indicated that some of the reports lacked key
information, such as the date of the incident, and DOJ likely would
have returned these reports to the county for correction. When we

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reviewed the reports, we confirmed that 15 reports were missing
information DOJ had previously asserted was required. However,
DOJ did not track reports that it sent back to counties. For the
remaining 13 reports, the applicant services manager was not able
to locate the reports and stated that DOJ might not have received
them. As of April 2022, DOJ asserts that it has implemented
procedures to better track reports it receives from counties.
Nevertheless, because DOJ did not track the reports it received
from counties or the reports it sent back to them, it was unable to
verify why these reports are missing from CACI.
Further, while Contra Costa County has policies and procedures for
correcting child abuse reports that DOJ returns to it, the remaining
five counties we reviewed—Calaveras, Kern, Orange, Shasta, and
Stanislaus—lack such policies. Thus, even if DOJ returned reports
to these counties for correction, they may not have adequately
addressed DOJ’s concerns and sent updated reports for DOJ to add
to CACI. Because of the lack of adequate policies and procedures
at DOJ and some counties, many individuals have not been added
to CACI, which limits its usefulness as an investigatory tool and the
ability of authorized users of the database to protect children.
The Six Counties We Reviewed Did Not Always Send Reports to DOJ
For 23 of the 60 cases we reviewed, the counties did not send
CACI reports to DOJ or asserted that they sent the reports but
were unable to demonstrate that they had done so. Specifically, the
counties failed to submit 14 reports of substantiated allegations of
child abuse to DOJ but were not always able to adequately explain
why their staff did not do so. For two cases, a manager at Orange
County stated that supervisors had changed the investigation
disposition to substantiated but failed to inform the staff who were
responsible for sending the reports to DOJ. In addition, a manager
at Stanislaus County told us staff incorrectly identified the suspect
in two reports sent to DOJ. The counties failed to submit another
10 reports that met the reporting requirements to DOJ. Therefore,
individuals who should be in CACI were not added, diminishing its
usefulness for protecting children.
For the nine remaining reports, the counties provided some
evidence that they may have sent the reports to DOJ, but they did
not maintain copies of the reports in their files, as their policies
require. As a result, they could not confirm that they had sent these
reports. Nevertheless, none of the reports were in CACI, which
means authorized users could be uninformed about these suspects’
past child abuse.

For 23 of the 60 cases we reviewed,
the counties did not send CACI
reports to DOJ or asserted that they
sent the reports but were unable to
demonstrate that they had done so.

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As a result of our inquiry into three of
these cases, the county determined
that it should have instead
categorized these cases as general
neglect, which is not reported to DOJ
for inclusion in CACI.

In addition to the 23 cases counties failed to send to DOJ, Calaveras
and Contra Costa counties incorrectly recorded the outcomes of
their investigations for five cases, but appropriately did not send
CACI reports to DOJ. Specifically, Calaveras County acknowledged
that it had previously instructed staff to categorize as child abuse
certain cases in the CWS/CMS system in which newborns
were exposed to controlled substances at birth because of their
mother’s substance abuse but not to report such cases to CACI.
However, according to state law, a newborn’s substance exposure
is not in and of itself a sufficient basis for a report of child abuse.
As a result of our inquiry into three of these cases, the county
determined that it should have instead categorized these cases
as general neglect, which is not reported to DOJ for inclusion in
CACI. Contra Costa County also inappropriately recorded two
reports as substantiated allegations of child abuse in CWS/CMS.
In response to our inquiry, the county indicated that the incidents
should not have been marked substantiated in CWS/CMS because
the allegations were not substantiated following further review, in
one case by county management and in the other case by a juvenile
court. Even though CACI does not contain reports of child abuse
for these cases, because the county incorrectly left the allegations
marked as substantiated in CWS/CMS, the county inaccurately
maintained negative information about the individuals in their
investigation files.
State Law Allows Certain Substantiated Cases of Child Abuse to Not Be
Included in CACI
Finally, for the last three cases, Kern County practices provide for
it to not report these substantiated cases of child abuse to CACI
in accordance with state law. Kern County explained that it did
not submit these reports to CACI because social workers were
unable to interview the suspects, which it considers a necessary
part of the investigation. For example, in one case, law enforcement
was investigating the suspect for human trafficking of a minor.
Although county staff were unable to speak with the suspect,
due to the preponderance of evidence, they substantiated the
allegations of exploitation and closed their investigation. However,
because county staff did not interview the suspect, Kern County
did not report the suspect to CACI. As a result of this practice,
although the suspects in each of the three cases had substantiated
allegations of child abuse, including sexual abuse and exploitation,
Kern County did not submit the reports to CACI.
State law requires counties to report to DOJ all known allegations
of child abuse for which the county has conducted an investigation
and determined that the allegation is substantiated. At the same
time, state law prohibits counties from sending a report to DOJ

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unless it has conducted an active investigation and determined that
the allegation is substantiated. Social Services’ guidance to counties
defines active investigations as including, among many other items,
interviews with the suspect and victim when appropriate and if they
are available. This guidance directs counties to determine whether
they have completed an active investigation on a case‑by‑case
basis in coordination with the county legal counsel. However, the
guidance states that, if a county substantiates an allegation relying
on the results of a law enforcement or other investigation without
conducting the county’s own active investigation, the county may
choose to substantiate the allegation but should not refer the
suspect to CACI. According to the program director of emergency
response, Kern County requires staff to conduct an interview with
the suspect in order to complete an active investigation. If staff
members cannot interview the suspect, they may still substantiate
the allegation of child abuse but will not submit a report to DOJ.
Because county staff did not conduct suspect interviews for these
three cases, Kern County substantiated that the suspects committed
child abuse, but it did not submit the associated reports to DOJ.
Although Kern County’s approach is allowed by state law and Social
Services’ guidance, the other five counties we reviewed typically
wait for law enforcement to finish its investigation before the
county concludes its investigation or reaches a conclusion based
on the available evidence and then reports the suspect to CACI if
it substantiates an allegation of child abuse. For example, Calaveras
County indicates that staff will request that law enforcement
conclude its investigation, but if necessary, staff may decide to
substantiate allegations without the suspect interview, based on
other evidence and with the agreement of county counsel, and
then report the suspect to DOJ. However, Orange County told us
that staff will typically delay closing a case until a law enforcement
investigation is completed, but staff usually cooperate with law
enforcement, so it is rare that a social worker cannot interview the
perpetrator and has to close the case without the interview.
Because counties can substantiate certain allegations of child abuse
and not report the suspects to CACI, which state law currently
permits, CACI’s effectiveness in protecting children is limited.
When a county substantiates an allegation of child abuse, the
county has determined that it is more likely than not that the child
abuse occurred. However, authorized users may be unaware of this
determination if the suspect is not reported to CACI. As a result,
authorized users may unknowingly allow individuals with a history
of substantiated child abuse to have access to children.

State law is limiting CACI’s
effectiveness in protecting
children and authorized users may
unknowingly allow individuals with
a history of substantiated child
abuse to have access to children.

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CACI Incorrectly Identifies Some Individuals as Having a History of
Child Abuse

We identified 298 reports of
child abuse in CACI that were not
supported by the corresponding
county records.

CACI erroneously contains some reports of child abuse that are not
substantiated, which could lead to DOJ informing an authorized
user that an individual is a perpetrator of child abuse when he or she
has no associated report of substantiated child abuse. As a result,
this erroneous information may limit that person’s employment or
opportunity to care for children. In fact, we identified instances in
which DOJ informed authorized users that individuals were a possible
match with someone in CACI based on inaccurate information. For
the four years ending June 2021, we identified 298 reports of child
abuse in CACI that were not supported by the corresponding county
records. Because these reports were in CACI, DOJ sent 25 letters
to authorized users notifying them that individuals were a possible
match with a known child abuse suspect.4 As we discuss in the
Introduction, state law requires the authorized user to follow up with
the relevant county CWS agency for additional information, which
could mitigate the impact of these errors. Additionally, according to
DOJ, it informs individuals when it sends certain letters to authorized
users of a possible match to a known child abuse suspect in CACI.
However, even if the authorized user performs this follow‑up, or the
individual requests a grievance hearing to remove his or her erroneous
information from CACI, the individual’s employment or opportunity
to care for children may be inappropriately denied or delayed.
We followed up on a sample of cases in CACI that were not supported
by CWS/CMS records and found data inaccuracies in CWS/CMS as
well as failures in the counties’ and DOJ’s processes. Specifically, for
the 298 CACI reports, 24 were from the six counties we reviewed.
We followed up with these six counties on all 24 reports in CACI that
were not supported by CWS/CMS records. For three of those reports,
we found that the counties had not recorded the cases as substantiated
reports of child abuse in CWS/CMS even though investigators had
substantiated the cases. However, the county subsequently submitted
these three reports to DOJ and CACI appropriately reflected that the
individuals had a history of child abuse. In three separate instances,
the counties incorrectly submitted reports to DOJ about allegations
of child abuse that did not meet the CACI reporting requirements.
For example, Orange County investigated a mother and substantiated
an allegation of general neglect of her children that, under state
law, should not have been reported to DOJ for inclusion in CACI.

4

As discussed earlier, we also analyzed data for expedited background checks for the period
preceding when we received CACI data in August 2021. We found that DOJ responded to an
expedited request related to one individual who had a report of child abuse in CACI that was
not supported by county records. As a result, DOJ may have inappropriately sent an expedited
response letter indicating that the individual was a possible match with a known child abuse
suspect in CACI.

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In another four instances, the counties sent DOJ amended information
to remove individuals from CACI, but DOJ failed to remove them.
For example, Stanislaus County updated a sexual abuse allegation
from substantiated to inconclusive as a result of a grievance hearing.
Although the county sent DOJ both an amended CACI report and
a request to remove the individual from CACI, DOJ failed to do so.
As we discuss in the next section, this oversight may have occurred
because DOJ did not have policies or procedures for the manual
deletion of records. It also did not track requests for removals and
did not have a process for verifying that removals are appropriate
or complete.
For the final 14 reports, the counties amended the outcomes of their
investigations so that they were no longer substantiated, but they
failed to update DOJ and request that DOJ remove the individuals’
reports from CACI. For example, Shasta County substantiated a
mother’s alleged physical abuse of her son and submitted a CACI
report to DOJ. However, the county then held a grievance hearing
and changed the conclusion to inconclusive. Although the county
changed the conclusion in CWS/CMS, it could not demonstrate that
it sent a request to DOJ asking it to remove the record from CACI.
In fact, the mother’s record remained in CACI in error.
We also reviewed the policies and procedures for conducting CACI
grievance hearings at the six counties to determine whether they
conform to the laws and regulations requiring a hearing of objections
to a suspect’s listing in CACI. Although we found that the counties
generally adhere to those laws and regulations, we identified areas
where some county polices do not meet these requirements.
Specifically, three of the six counties—Contra Costa, Kern, and
Stanislaus—do not have a policy allowing the suspect to challenge
the impartiality of the grievance review officer. State regulations
require that counties allow suspects to request the grievance review
officer be disqualified on the grounds that a fair and impartial
hearing cannot be held or a decision cannot be rendered. In addition,
two of the six counties, Orange and Stanislaus, do not have a policy
requiring that confidential evidence be returned to the county when
the county provides a suspect with such evidence before a grievance
hearing, which could result in the inappropriate release of sensitive
or confidential information regarding the investigation. Finally,
we found that three of the six counties—Calaveras, Contra Costa,
and Shasta—lack policies for removing individuals from CACI if
a grievance hearing determines that the allegations should not be
substantiated. When CACI contains records of child abuse that are
not accurate, individuals may be unjustifiably denied opportunities to
care for children, such as obtaining employment at a child care center
or adopting a child, or the individual may be inappropriately delayed
from caring for children while the results of a grievance hearing are
transmitted to DOJ.

When CACI contains records of
child abuse that are not accurate,
individuals may be unjustifiably
denied opportunities to care
for children.

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DOJ Lacks Adequate Controls for Ensuring That CACI Contains
Accurate and Appropriate Records
We identified more than 36,000
records for suspects that did not
have a recorded date of birth, which
prevents DOJ from removing certain
records from CACI, as required by
state law.

DOJ’s inadequate system controls have resulted in CACI containing
significant errors. In our electronic analysis of CACI data, we
identified more than 36,000 records for suspects that did not have
a recorded date of birth. CACI suspect records that lack a date of
birth prevent DOJ from performing an important responsibility
under state law. Specifically, state law requires DOJ to remove
suspects from CACI when the suspect reaches 100 years of age
or when the suspect was a minor at the time of the incident and
has had no subsequent CACI reports for 10 years. To address this
removal requirement, DOJ developed daily automated processes in
CACI to remove suspects who meet these requirements. However,
when we reviewed these automated processes, we found that
they only consider suspect records that have a valid date of birth.
As a result, the 36,000 suspects with CACI records that do not
contain a valid date of birth would never be removed from CACI
without county or DOJ action to correct their records. Upon
further inquiry, we determined that CACI lacked sufficient controls
to ensure that staff enter all necessary information, including a
suspect’s date of birth. After bringing this issue to its attention, DOJ
modified the CACI system to require the suspect’s date of birth
when entering new reports of child abuse into CACI. Further, the
applicant services manager stated that DOJ is also developing a plan
to address the 36,000 suspect records without a date of birth, and,
as of April 2022, its efforts were ongoing.
Further, DOJ cannot ensure that it appropriately removed records
from CACI because it did not have policies or procedures for the
manual deletion of records and its process lacked key controls.
In addition to CACI’s automated processes for removing certain
suspects’ records, DOJ also performs manual deletion of records
at the request of counties when the county later determines that a
report is not substantiated. However, this task has been performed
independently by a single DOJ staff member, and DOJ did not
have a process to verify that these deletions were appropriate.
DOJ also did not notify the county that it had made the requested
deletions unless the county specifically requested a notification.
According to DOJ, as of April 2022, it requires supervisory approval
before deleting CACI reports. However, because it only recently
implemented this review, DOJ is unable to demonstrate that it has
deleted all records as requested or that the more than 8,000 records
it manually deleted as of August 2021 were appropriately removed.

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Legislative Action Is Needed to Fix the State’s Error‑Prone and
Inefficient Process for Entering Data Into CACI
The State updates CACI using an outdated and inefficient process,
which allows errors and omissions to persist undetected. Additionally,
the process contains an inherent lag between when a county mails
a report of child abuse to DOJ and when DOJ enters that suspect’s
information into CACI. In fact, we found that it typically takes
28 days from the date that counties complete a report of child abuse
to the date that DOJ enters the report into CACI. As a result of
this lag time, an authorized user could request a background check
on an individual and DOJ could report that the individual is not in
CACI even if a county had substantiated an allegation of child abuse
against that individual. Legislative action could improve this process
by amending state law to grant DOJ direct access to the CWS/CMS
system that county CWS agencies use to record the results of their
child abuse investigations.
The State’s Outdated and Inefficient Process Allows Errors and Omissions
to Go Undetected
The State’s process for updating CACI contains multiple steps where
errors and omissions can occur and go undetected. In particular, the
CACI process requires that counties print paper reports from
CWS/CMS and mail them to DOJ, after which DOJ staff manually
enter these reports into CACI. Additionally, if the reports are missing
information, DOJ mails the reports back to counties to provide the
missing information, and then the counties mail them back to DOJ.
However, DOJ did not track the reports it sent back for correction.
As we discuss above, we found numerous errors in nearly every phase
of the CACI process. For example, we reviewed 60 reports of child
abuse and found that counties failed to send at least 14 reports they
should have sent to DOJ. As we explained previously, this failure
results in suspects with a history of substantiated child abuse not being
added to CACI, reducing its usefulness in protecting children from
individuals with a history of child abuse. We also identified individuals
listed in CACI whose reports should have been removed, but the
counties failed to ask DOJ to do so even though they had determined
that the allegations were no longer substantiated. In addition, DOJ
could not account for 28 missing reports that counties indicated they
had sent for inclusion in CACI because DOJ did not have a process for
identifying whether it received and input reports into CACI. Finally,
we found accuracy errors in CACI, such as a lack of a date of birth
for many suspects, misspellings of suspects’ names, and incorrect
investigation reference numbers, which can hinder DOJ’s ability to
quickly and reliably respond to CACI background checks.

We found numerous errors in nearly
every phase of the CACI process.

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If the current process worked as designed, the reports in CACI would
match the investigated, substantiated reports of child abuse in
CWS/CMS. But as we previously discussed, the number of reports in
CACI is less than half of the number of substantiated investigations of
child abuse statewide in CWS/CMS for the four‑year period ending
June 2021. Further, we identified 298 individuals with reports in CACI
that are not supported by information in the county records.
Updating CACI takes far longer than
necessary, and its outdated and
inefficient process increases the risk
that DOJ is providing inaccurate
information to authorized users.

In addition, because the process is outdated and inefficient, updating
CACI takes far longer than necessary and increases the risk that DOJ
is providing inaccurate information to authorized users. For example,
DOJ’s requirement for using physical mail and its manual data entry
process cause unnecessary delays in adding information to CACI,
and the DOJ’s manual entry of reports greatly introduces the risk
of errors. Specifically, it typically takes 28 days from the date that
counties complete a child abuse report to the date that DOJ enters
the report into CACI. During this time lag, which is inherent to the
current process, an authorized user may request a background check
for a suspect not yet entered into CACI, and DOJ would respond
that the suspect is not in CACI. DOJ may still be able to notify an
authorized user after later receiving a report of a suspect whom the
authorized user has employed or allowed to have access to children.
However, the delay would have prevented the authorized user from
identifying information in a timely manner that could affect the
user’s decision to allow the individual to care for children. Although
it occurs less frequently, the same mailing and data entry time lag
may occur when counties request that DOJ remove reports from
CACI, leaving individuals in the database when they no longer have
substantiated allegations of child abuse.
DOJ has maintained this process of using physical mail even though
the Legislature amended state law in 2000 to clarify that CACI
reports may be sent by fax or electronic submission. According to
the applicant services manager, in 2017 DOJ worked with CWS/CMS
staff to develop an electronic submission process for CACI reporting,
but this effort was not successful. However, she stated that, as of
March 2022, DOJ and CWS/CMS staff have renewed discussions
about transferring data electronically.
Legislative Action Is Necessary to Improve CACI Reporting
The CACI process must be improved in order to resolve current
and future errors. As shown in Figure 3, although we identified
three options for improving the CACI process, we recommend that
DOJ have direct access to CWS/CMS as the most efficient option.
Without major changes and legislative action, the issues we identified
will likely persist and pose a significant challenge to CACI’s ongoing
usefulness in protecting children from abuse.

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Figure 3
Comparison of Options for Improving CACI Reporting

CURRENT
PROCESS

1
DOJ has direct access
to CWS/CMS
(Recommended option)

PRO:

• Reporting responsibilities
are unchanged and no
legislative or regulatory
action is taken.
CONs:

• CACI reporting remains
inefficient and prone
to errors.
• CACI lacks many
thousands of suspects of
substantiated child abuse.
• CACI inappropriately
contains data regarding
reports of child abuse that
are not substantiated.
• It takes DOJ a month to
receive and enter reports
of child abuse.

Source: State Auditor analysis.

PROs:

• Eliminates reporting
delays and data
entry errors.
• Eliminates reliance on
postal mail, reducing
costs and time.
• Immediately gives DOJ
access to complete data
without needing to
research historical
differences between CACI
and CWS/CMS.
CONs:

• Cannot be implemented
unless the Legislature
amends state law to allow
DOJ to access CWS/CMS.
• Social Services may need
to build a query or
specific view in CWS/CMS
so DOJ staff can access
only CACI-related
information.

2
Social Services and DOJ
build an electronic
interface to transmit
CWS/CMS data to CACI
PROs:

• Significantly reduces
reporting time.
• Eliminates reliance on
postal mail, reducing
costs and time.
• Improves accuracy of data
entered into CACI.

3
County CWS agencies and
DOJ perform periodic
reconciliations between
CWS/CMS and CACI
PROs:

• No system changes to
CACI or CWS/CMS
required.
• Helps DOJ ensure that all
required reports are
entered into CACI.
CONs:

CONs:

• Would require Social
Services and DOJ to
develop a new technical
solution to regularly
transfer data between
CWS/CMS and CACI, which
could take a substantial
amount of time and has an
associated cost.
• Would require DOJ to
continue to maintain CACI
and ensure that it is up to
date with CWS/ CMS.
• CACI information
continues to substantially
duplicate information in
CWS/CMS.
• Would require significant
work to reconcile
historical differences
between CACI and
CWS/CMS data.

• Would require county
staff time to produce and
mail CACI reports to DOJ.
• DOJ would continue to
incur the cost of staff to
manually enter reports
into CACI.
• No improvement in
reporting time due to
mailing and data entry
requirements.
• Would require significant
work to reconcile the
historical differences
between CACI and
CWS/CMS data.

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It would be more efficient for DOJ
to have direct access to CWS/CMS
for responding to CACI-related
inquiries and simply eliminate the
cumbersome and ineffective CACI
reporting process.

Existing state law requires DOJ to act as the repository of
CACI reports and requires a process for counties to submit
reports of child abuse to DOJ. As we previously explained,
with few exceptions, CACI should reflect all child abuse cases
substantiated by county CWS agencies. Because these agencies
enter substantiated cases of child abuse into CWS/CMS, we
believe it would be more efficient for DOJ to have direct access to
this system for responding to CACI‑related inquiries and simply
eliminate the cumbersome and ineffective CACI reporting process,
as shown in Figure 4. This direct access would not only remove the
problems of inaccurate data entry and missing reports in CACI, it
would also remove the inherent reporting lag between a county’s
substantiation of child abuse and DOJ’s entry of that information
into CACI. Additionally, removing these reporting tasks could
save DOJ staff an estimated $94,000 annually, based on its current
workload, because staff would no longer need to transcribe and
review reports. Further, the six counties we reviewed estimate
that they would collectively save $35,000 annually because county
staff would no longer need to prepare, review, and mail the CACI
reports. However, because CWS/CMS contains more information
than DOJ needs for responding to CACI background checks,
such as allegations of child abuse that are not substantiated or
substantiated cases involving minor suspects who have had no
subsequent CACI reports for 10 years, DOJ would likely need to
work with Social Services to determine how to identify only the
information it needs for CACI reporting. Solutions for limiting the
information DOJ has access to could include CACI‑specific queries
of CWS/CMS and training DOJ staff to navigate and interpret
CWS/CMS information.
A second option for addressing the problems we found with CACI
is to have new reports of child abuse submitted electronically by
transferring data from CWS/CMS to CACI. This option could
ensure that data in CACI is accurate and would reduce the
reporting delays. However, it would require Social Services and
DOJ to develop a technical solution to transfer the data—which
could take a substantial amount of time and have an associated
cost. According to Social Services’ child welfare system branch
chief, Social Services would not implement the solution until it
begins using a new child welfare system beginning in fall 2023. In
addition, this solution would require DOJ to maintain CACI and
ensure its ongoing accuracy and completeness. Further, DOJ would
have to work with Social Services and the counties to resolve the
current significant gap we found in recorded cases between
CWS/CMS and CACI. In addition, if this solution were
implemented completely and accurately, CACI data would
substantially duplicate information in CWS/CMS. However, these
efforts would be unnecessary if DOJ were able to access
CWS/CMS directly.

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Figure 4
Recommended Revision to CACI Process
COUNTY CHILD WELFARE SERVICES AGENCIES SUBSTANTIATE CASES OF CHILD ABUSE

Removed
Step

County social worker
investigates and
substantiates an
incident of child abuse.

Social worker enters
the investigation into
CWS/CMS.

County staff print the
report of the incident.

Supervisor reviews the
report and makes
changes, if necessary.

County mails
the report
to DOJ.

County staff perform additional
work to revise the report.
US Postal Service delivers the report back
to the county child welfare services agency.

US Postal Service delivers the
report to DOJ in Sacramento.

....................

DOJ ENTERS INFORMATION INTO CACI

:· ............ ........ .
►

....
DOJ mails the report
back to the county to fill
in missing information.

Missing information

Complete

DOJ evaluates whether the report is
complete or missing information.

DOJ manually enters
the report into CACI.
BACKGROUND CHECK

DOJ sorts and bundles mail for the
unit that processes CACI reports.

DOJ reviews the
data entry work.

DOJ RESPONDS TO BACKGROUND CHECKS

?

Authorized user requests a child
abuse background check.

DOJ searches for the individual in
CWS/CMS and generates either a
“no match” or a “possible match” letter.

DOJ prints and mails a
response letter to the
background check requester.

Source: State regulations, county policies, and interviews with staff at DOJ and Calaveras, Contra Costa, Kern, Orange, Shasta, and Stanislaus counties.

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A third option that would reduce the errors in the current process is
to establish a reconciliation process. In this option, Social Services
would provide a regular and timely report from CWS/CMS to each
county and to DOJ that lists the reports that each county substantiated
and should have submitted to CACI. DOJ and the counties would
then reconcile these reports against CACI data to determine whether
the counties sent all required reports, and whether DOJ received and
entered all reports. This reconciliation process would require the
fewest technical changes to existing systems. However, it would not
reduce the inefficiencies inherent in sending the reports by U.S. mail
or those caused by counties needing to resubmit reports that are
missing required information. Moreover, it would not reduce the
resource‑intensive and error‑prone task of manually entering reports
into CACI. The reconciliation process would also create additional
costs in staff time for both DOJ and the counties. Finally, DOJ and the
counties would still need to complete a significant amount of work to
reconcile the already known discrepancies between the two systems.
However, because counties and DOJ need to take immediate action
to correct CACI in order to protect children, we believe that this
third option is a necessary interim solution. Establishing DOJ’s
access to CWS/CMS or developing a data transfer mechanism from
CWS/CMS to CACI would require legislative or system changes
that would take time to implement. Therefore, until a permanent
solution is implemented, Social Services and DOJ should implement
a reconciliation process to ensure that counties appropriately submit
substantiated reports to DOJ and that DOJ enters all these reports
into CACI.
Please refer to the section beginning on page 3 to find the
recommendations that we have made as a result of these
audit findings.
We conducted this performance audit in accordance with generally accepted government auditing
standards and under the authority vested in the California State Auditor by Government Code
section 8543 et seq. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on the audit objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.
Respectfully submitted,

~

MICHAEL S. TILDEN, CPA
Acting California State Auditor
May 31, 2022

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Appendix A
Statewide Statistical Information in CACI
The scope and objectives of this audit requested specific statistics
related to the CACI data. We present those statistics in the
following tables. However, CACI does not contain more than
half of the reports recorded in CWS/CMS statewide for the
period of July 1, 2017, through June 30, 2021, as we describe in
this report. Specifically, we found that CACI did not contain
27,000 reports of substantiated child abuse that were recorded in
CWS/CMS. Further, we did not assess the completeness of the
CACI data outside of this four‑year period.
Table A.1
CACI Reports of Child Abuse and Persons Listed on Those Reports From
January 1997 to June 2021
COUNTY

Alameda
Alpine
Amador
Butte
Calaveras
Colusa
Contra Costa

NUMBER OF REPORTS

5,773

NUMBER OF SUSPECTS

5,773

NUMBER OF VICTIMS

7,014

NUMBER OF OTHER
INDIVIDUALS REFERENCED
IN THESE REPORTS*

8,176

14

14

16

11

129

129

171

255

3,349

3,349

3,992

4,906

624

624

798

869

121

121

155

163

3,940

3,940

4,969

6,155

Del Norte

428

428

522

754

El Dorado

1,084

1,084

1,313

1,888

Fresno

5,988

5,988

7,597

11,127

Glenn

555

555

683

1,095

1,732

1,732

2,132

2,849

838

838

1,202

873

Humboldt
Imperial
Inyo

469

469

547

883

Kern

8,698

8,698

10,853

14,533

Kings

1,628

1,628

1,928

2,291

311

311

367

518

Lake
Lassen

622

622

770

639

69,506

69,506

91,075

84,960

Madera

2,171

2,171

2,652

3,656

Marin

1,037

1,037

1,237

1,449

Los Angeles

166

166

208

312

Mendocino

Mariposa

1,480

1,480

1,818

1,945

Merced

2,777

2,777

3,604

3,824
continued on next page . . .

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COUNTY

NUMBER OF REPORTS

NUMBER OF SUSPECTS

NUMBER OF VICTIMS

NUMBER OF OTHER
INDIVIDUALS REFERENCED
IN THESE REPORTS*

Modoc

296

296

329

382

Mono

119

119

138

241

3,315

3,315

4,045

4,816

736

736

823

1,297

Monterey
Napa
Nevada

514

514

587

528

Orange

45,409

45,409

57,228

90,546

Placer

4,159

4,159

5,448

4,260

592

592

693

464

Riverside

15,287

15,287

19,191

21,755

Sacramento

10,518

10,518

13,852

14,318

Plumas

886

886

1,057

954

San Bernardino

San Benito

22,497

22,497

28,133

29,311

San Diego

37,142

37,142

52,803

53,353

San Francisco

2,744

2,744

3,231

3,990

San Joaquin

7,160

7,160

8,823

12,921

San Luis Obispo

2,312

2,312

3,004

3,101

San Mateo

3,024

3,024

3,533

3,469

Santa Barbara

3,673

3,673

4,408

8,047

Santa Clara

7,245

7,245

8,651

7,573

Santa Cruz

2,424

2,424

3,151

3,537

Shasta

2,562

2,562

3,542

5,236

16

16

22

18

Sierra
Siskiyou

629

629

795

1,075

Solano

3,184

3,184

3,694

5,055

Sonoma

3,167

3,167

3,783

4,043

Stanislaus

5,449

5,449

6,680

11,532

Sutter

613

613

756

901

Tehama

351

351

434

632

Trinity

141

141

179

265

Tulare

1,493

1,493

1,721

2,428

Tuolumne

944

944

1,143

1,422

Ventura

4,996

4,996

6,091

8,676

Yolo

1,137

1,137

1,358

1,602

Yuba

992

992

1,212

1,459

309,166

309,166

396,161

463,338

Totals

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects, victims, and other individuals each time they are listed on a report.
* This category includes individuals listed on child abuse reports who were not identified as the suspect or the victim, such as siblings who were
not abused.

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Table A.2
CACI Reports Submitted Before January 2005
COUNTY

Alameda
Alpine
Amador

NUMBER OF REPORTS
BEFORE JANUARY 2005

18,423
29
223

Butte

5,022

Calaveras

1,034

Colusa
Contra Costa

218
12,305

Del Norte

1,412

El Dorado

1,117

Fresno

16,567

Glenn

730

Humboldt

3,074

Imperial

1,618

Inyo

512

Kern

17,229

Kings

1,854

Lake
Lassen
Los Angeles

725
997
127,072

Madera

2,795

Marin

2,516

Mariposa

178

Mendocino

2,209

Merced

2,623

Modoc

216

Mono
Monterey
Napa

112
5,599
672

Nevada

1,219

Orange

79,982

Placer

3,518

Plumas

1,193

Riverside

22,740

Sacramento

26,049

San Benito

794

San Bernardino

40,413

San Diego

45,348

San Francisco

6,337

San Joaquin

10,907
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COUNTY

NUMBER OF REPORTS
BEFORE JANUARY 2005

San Luis Obispo

4,830

San Mateo

6,871

Santa Barbara

2,860

Santa Clara

19,976

Santa Cruz

3,807

Shasta

1,638

Sierra
Siskiyou

65
964

Solano

5,959

Sonoma

6,704

Stanislaus

14,426

Sutter

1,231

Tehama

1,033

Trinity

72

Tulare

5,454

Tuolumne

1,299

Ventura
Yolo
Yuba
County not specified
Total

12,479
1,650
1,745
Less than 10
558,644

Source: DOJ’s CACI database as of August 16, 2021.
Note: To maintain the confidentiality of small groups of children, we redacted groups of less than 10.
Therefore, the total excludes locations with values less than 10.

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Table A.3
Victims and Suspects Listed in Substantiated CACI Reports From
January 1991 to December 2004
COUNTY

Alameda
Alpine
Amador
Butte
Calaveras
Colusa

NUMBER OF SUSPECTS

NUMBER OF VICTIMS

2,669

3,236

Less than 10

Less than 10

14

29

1,816

2,195

177

218

31

35

2,034

2,675

Del Norte

201

258

El Dorado

276

323

Fresno

2,100

2,800

Glenn

153

173

Humboldt

714

864

Imperial

442

624

Contra Costa

Inyo

181

203

Kern

3,472

4,526

Kings

741

887

Lake

185

224

Lassen

180

207

22,027

28,016

Madera

948

1,128

Marin

203

223

Los Angeles

Mariposa

53

72

Mendocino

728

931

Merced

901

1,123

Modoc

87

98

Mono

26

32

1,220

1,440

Napa

293

313

Nevada

233

277

Orange

24,330

33,648

Placer

1,769

2,278

Monterey

Plumas

325

372

Riverside

6,783

9,038

Sacramento

6,164

8,449

405

471

San Benito
San Bernardino
San Diego
San Francisco

9,800

12,361

19,291

29,373

963

1,084

continued on next page . . .

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COUNTY

NUMBER OF SUSPECTS

NUMBER OF VICTIMS

San Joaquin

1,829

2,216

San Luis Obispo

1,248

1,705

San Mateo

1,107

1,248

Santa Barbara

1,490

1,780

Santa Clara

3,026

3,644

Santa Cruz

1,102

1,406

Shasta
Sierra
Siskiyou

543

733

Less than 10

Less than 10

281

385

Solano

1,490

1,739

Sonoma

1,399

1,660

Stanislaus

2,345

2,880

291

359

68

80

Sutter
Tehama
Trinity

12

12

Tulare

664

781

Tuolumne

495

608

2,818

3,490

Yolo

261

319

Yuba

361

428

132,765

175,677

Ventura

Totals

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects and victims each time they are listed on a report. To maintain the
confidentiality of small groups of children, we redacted groups of less than 10. Therefore, the totals
exclude locations with values less than 10.

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Table A.4
Victims and Suspects Listed in CACI Reports by Sex From January 1965 to
August 2021
NUMBER OF SUSPECTS

NUMBER OF VICTIMS

Female

231,223

506,611

Male

460,045

342,713

Unknown
Totals

22,565

20,267

713,833

869,591

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects and victims each time they are listed on a report.

Table A.5
Victims and Suspects Listed in CACI Reports by Race/Ethnicity as Listed on
the Report From January 1965 to August 2021
RACE/ETHNICITY

American Indian
Asian Indian
Black
Cambodian

NUMBER OF SUSPECTS

4,233

NUMBER OF VICTIMS

5,249

905

1,085

88,021

107,161

613

849

Chinese

2,493

2,852

Filipino

3,942

5,136

159

173

Guamanian
Hawaiian

629

549

Hispanic

239,838

302,046

Japanese

424

518

Korean

875

991

Laotian

629

933

Other Asian

8,507

9,941

Pacific Islander

2,856

3,125

Samoan

1,178

1,333

Vietnamese
White
Other
Unknown
Totals

2,750

3,480

286,197

354,619

8,016

10,398

61,568

59,153

713,833

869,591

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects and victims each time they are listed on a report.

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Table A.6
Victims Listed in CACI Reports by Age From January 1965 to August 2021
AGE RANGE

NUMBER OF VICTIMS AS OF THE DATE OF THE INCIDENT
OF CHILD ABUSE

Less than 1 year old

41,916

1–2 years old

74,543

3–6 years old

204,365

7–10 years old

212,801

11–14 years old

219,065

15–17 years old

112,206

18 years old or older
No age recorded
Age less than zero
Total

621
2,312
1,762
869,591

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts victims each time they are listed on a report.

Table A.7
Suspects Listed in CACI Reports by Age From January 1965 to August 2021
AGE RANGE

Less than 10 years old

NUMBER OF SUSPECTS AS OF THE DATE OF THE
INCIDENT OF CHILD ABUSE

628

10–18 years old

23,159

19–29 years old

220,050

30–39 years old

263,425

40–49 years old

121,921

50–59 years old

35,858

60–69 years old

10,322

70–79 years old

1,634

80–89 years old
Age not recorded
Illogical data
Total

116
36,698
22
713,833

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects each time they are listed on a report.

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Table A.8
Types of Child Abuse Reported in CACI Reports From January 1965 to
August 2021
TYPE OF
ABUSE OR NEGLECT

NUMBER OF REPORTS

PERCENTAGE

Mental or Emotional
Suffering

110,610

14.05%

Physical Injury

374,661

47.59

Severe Neglect

61,850

7.86

235,393

29.90

409

0.05

1,204

0.15

Sexual Abuse, Assault, or
Exploitation
Unlawful Corporal
Punishment or Injury
Willful Harming or
Endangerment
Other or Unidentified
Totals

3,150
787,277

0.40
100.00%

Source: DOJ’s CACI database as of August 16, 2021.
Note: Because a report can contain multiple types of abuse or neglect, the total number of reports
in this table exceeds the total number of unique reports.

Table A.9
Number of Victims and Suspects by Type of Report From January 1965 to
August 2021
TYPE OF
REPORT DETERMINATION

NUMBER OF SUSPECTS

NUMBER OF VICTIMS

Suspected Abuse

249,907

287,417

Substantiated Abuse

292,971

376,483

Investigation Initiated

170,955

205,691

Totals

713,833

869,591

Source: DOJ’s CACI database as of August 16, 2021.
Note: This table counts suspects and victims each time they are listed on a report. While CACI contains
reports with these three determinations, for the period from July 2017 through June 2021 CACI only
contained, and we only evaluated, reports of substantiated abuse.

Table A.10
Reported Incidents Removed From the CACI by Requester From
January 1965 to August 2021
ENTITY INITIATING REMOVAL

DOJ
Reporting Agency
Not Listed
Total
Source: DOJ’s CACI database as of August 16, 2021.

NUMBER OF REPORTED
INCIDENTS REMOVED

78,349
8,032
15,231
101,612

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Blank page inserted for reproduction purposes only.

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Appendix B
Scope and Methodology
The Joint Legislative Audit Committee (Audit Committee)
directed the California State Auditor to conduct an audit of CACI
as administered by DOJ to determine whether CACI contains a
complete and accurate set of reports of child abuse. Table B lists the
objectives that the Audit Committee approved and the methods we
used to address them.
Table B
Audit Objectives and the Methods Used to Address Them
AUDIT OBJECTIVE

1

Review and evaluate the laws, rules, and
regulations significant to the audit objectives.

2

Evaluate whether CACI is an effective tool for
investigatory purposes, including the extent to
which reporting agencies submit accurate and
complete reports of abuse and severe neglect.

METHOD

Reviewed and evaluated state laws and regulations, as well as state and county policies,
procedures, and guidance for reporting child abuse suspects to CACI.
• Obtained CACI and CWS/CMS data and performed analysis to match records of child
abuse between the two systems for the period of July 1, 2017, through June 30, 2021.
• Selected six counties—Calaveras, Contra Costa, Kern, Orange, Shasta, and Stanislaus—to
review based on a number of factors, including population and number of CACI reports.
• Reviewed county policies and procedures and interviewed county staff regarding CACI
reporting processes.
• Interviewed DOJ, Social Services, and county staff, and analyzed data to identify
discrepancies between CACI data and CWS/CMS data. Reviewed associated county
case files.
• Reviewed CACI response letters to determine whether the letters contained the same
information as recorded in CWS/CMS.

3

Determine whether DOJ has complied with
state law to remove reports from CACI that do
not meet minimum legal requirements.

• Interviewed DOJ staff to understand CACI’s automated purge processes as well as the
process of manually removing reports from CACI at the request of the reporting agency.
• Reviewed source code of CACI’s automated purge processes for removing suspects that
meet specific legal criteria.
• Reviewed county policies and procedures, and interviewed county staff regarding
processes for requesting removal of reports from CACI.

4

For a selection of reporting agencies, evaluate
the grievance process and determine whether
the reporting agencies have adequate policies
and procedures to receive and review objections
to an individual’s listing in CACI.

Reviewed county policies and procedures, and interviewed county staff regarding grievance
hearing processes.

5

From 1997 to the present, assess whether
parties complied with state law for CACI
reporting requirements by determining
the following:

Performed electronic analysis of CACI data, and calculated numbers of reports entered into
CACI and various related statistics.

a. The number of reports DOJ received and
entered into CACI by county.
b. The number of individuals listed as suspects,
victims, and others on these reports.
continued on next page . . .

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AUDIT OBJECTIVE

6

METHOD

To the extent possible, use data from the CACI to
determine the following:

• Performed electronic analysis of CACI data, and calculated numbers of reports entered
into CACI and various related statistics.

a. The number of records that are based on
reports submitted before January 1, 2005.

• Performed electronic analysis of CACI data to identify the number of records removed
from the system and the reasons for removal.

b. The number of victims and suspects
referenced in substantiated reports
submitted from 1991 to 2004.
c. Demographic information for victims and
suspects by age, race, and gender.
d. The number and percentage of reports by
the type of abuse or neglect reported.

• Reviewed DOJ’s source code for daily automated processes to remove suspects from CACI
who reach 100 years of age or were minors at the time of the incident and have had no
subsequent CACI reports for 10 years.
• Interviewed DOJ staff to understand CACI’s automated purge processes as well as the
process of manually removing reports from CACI at the request of the reporting agency.

e. The number of victims and suspects included
in reports of substantiated or suspected
abuse or neglect.
f. Whether individuals have been appropriately
removed from the CACI data. Specifically,
determine whether (1) individuals who
were at least 100 years old have been
removed, (2) suspects who were younger
than 18 years old at the time of the incident
have been removed if more than 10 years
has passed without a subsequent report, and
(3) individuals have been removed at the
request of the submitting agency.

7

Review and assess any other issues that are
significant to the audit.

None identified.

Source: Audit workpapers.

Assessment of Data Reliability
The U.S. Government Accountability Office, whose standards
we are statutorily obligated to follow, requires us to assess
the sufficiency and appropriateness of computer‑processed
information that we use to support our findings, conclusions, or
recommendations. In performing this audit, we relied on CACI
data we obtained from DOJ and CWS/CMS data we obtained
from Social Services. To evaluate the CACI data, we reviewed
existing information about the data, interviewed staff members
knowledgeable about the data, reviewed selected source code
related to automated purges of records, and performed electronic
testing of the data. For the CWS/CMS data, we performed
electronic analysis to match records of child abuse between the
two systems for the period of July 1, 2017, through June 30, 2021.
We then performed case file reviews for a selection of records that
matched between the two systems as well as a selection of records
that were only found in CACI and a selection of records that were
only found in CWS/CMS. Although we were able to match nearly
all records in CACI to records in CWS/CMS, we found that CACI
contained fewer than half of the records contained in CWS/CMS
for this time period. As a result, we determined that the CACI data

California State Auditor Report 2021-112

May 2022

were not sufficiently reliable for the purpose of determining the
number and content of reports of child abuse for the period from
July 1, 2017, through June 30, 2021, and the data from CWS/CMS
was of undetermined reliability. Although we recognize that data
limitations may affect the precision of some of the numbers we
present, there is sufficient evidence in total to support our audit
findings, conclusions, and recommendations.

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Calaveras Health and Human Services Agency
Cori Allen, Director

509 East St. Charles Street
San Andreas, CA 95249

May 9, 2022
Michael S. Tilden
Acting California State Auditor
The Child Abuse Central Index
Calaveras County strives to ensure that all substantiated cases of physical, sexual, and emotional abuse
or severe neglect of a child is forwarded to the Department of Justice for inclusion in the Child Abuse
Central Index. The review of Calaveras County's reporting procedures contained two recommendations,
correcting the allegations for the sample of substance exposed newborns, and developing policies and
procedures for the following circumstances:
•
•
•
•

reporting all incidents of qualified substantiated child abuse for inclusion in the CACI database
Revision and resubmission of corrected reports to DOJ
Removal of existing CACI reports as the result of a grievance hearing or when warranted
Tracking reports sent between the agency and DOJ, both initial and co1Tected.

Calaveras County has made immediate corrections to the reporting of substance-exposed newborns and
these allegations are being correctly reported in the CWS/CMS case management system. Calaveras
County is revising current Investigation policies to ensure accurate reporting, and all intake and
investigating social workers have been trained on the correct allegations for substance-exposed
newborns.
Calaveras County has made immediate corrections to the practice of reporting of substantiated
allegations for inclusion in the CACI database when law enforcement involvement prevents a complete
investigation from occurring. Calaveras County is revising current Investigation policies to ensure
accurate reporting
Additionally, the 3 cases that were reviewed have been corrected to be categorized as general neglect.
Of the additional 6 cases reviewed, corrected and initial BIC8583 documents have been submitted to
DOJ to correct missing data and to report any suspects that were not previously reported. As of now and
as a policy going forward, all BIC 8583 documents will be scanned into the CWS/CMS system to
maintain an accurate record ofreports sent to DOJ, which will specify the date of mailing. Any
additional documents received from DOJ or revisions as a result of a grievance hearing will be scanned
into the CWS/CMS system for record keeping in addition to the hard copy file that is kept at the county
office.

Human Services
509 East St. Charles Street
San Andreas, CA 95249
Phone (209) 754-6452
Fax (209) 754-3293

Public Health Services
700 Mountain Ranch Road, Suite C2
891 Mountain Ranch Road (Mail)
San Andreas, CA 95249
Phone (209) 754-6460
Fax (209) 754-1709

Behavioral Health Services
891 Mountain Ranch Road
San Andreas, CA 95249
Phone (209) 754-6525
Fax (209) 7 54-6597

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Calaveras Health and Human Services Agency
Cori Allen, Director

509 East St. Charles Street
San Andreas, CA 95249

Formal policy and procedures is an area of focus for Calaveras County. Calaveras County experienced a
recent change in Child Welfare management. With this change, policies and procedures are being
revised to create a consistent process for all employees. Calaveras County will develop formal policies
and procedures to address reporting requirements, revision and resubmission of reports, removal of
existing CACI reports as the result of grievance hearings and to include tracking of reports exchanged
between the county and DOJ on or before July 2022. We in Calaveras County thank the Auditor team
who conducted this thorough and meaningful review of our processes. Due to the efforts of so many, we
are on track to maintaining accurate and complete CACI records on all cases.

Mayle J

Human Services
509 East St. Charles Street
San Andreas, CA 95249
Phone(209)754-6452
Fax(209)754-3293

A Deputy Director

Public Health Services
700 Mountain Ranch Road, Suite C2
891 Mountain Ranch Road (Mail)
San Andreas, CA 95249
Phone(209)754-6460
Fax (209) 754-1709

Behavioral Health Services
891 Mountain Ranch Road
San Andreas, CA 95249
Phone (209) 754-6525
Fax (209) 754-6597

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May 2022

RobBonta
Attorney General

State of California
DEPARTMENT OF JUSTICE
1300 l STREET
SACRAMENTO, CA 958 15-4524
Public: (91 6) 2 10-5000
Fax (91 6) 227-3079
Email : Joe. Dominic@doj.ca.gov

May 10, 2022
Michael S. Tilden, CPA*
Acting California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814

Re:

Draft Audit Report - California State Auditor Report 2021-112; The Child Abuse
Central Index

Dear Mr. Tilden,
The Department of Justice (DOJ) appreciates the opportunity to provide comments
to the above-mentioned draft audit report. Our copy of the draft report contains only the
portions that refer directly to the DOJ. Accordingly, we respectfully offer the below
comments which are limited to those excerpts.
The DOJ would like to provide additional information with respect to the Child
Abuse Central Index (CACI). As a law enforcement agency, the DOJ agrees
wholeheartedly that children must be protected. And the DOJ has a long history of
protecting individuals' rights.
It is disheartening that some of the draft report's assertions suggest otherwise. The
DOJ strongly disagrees with these assertions, which appear to stem from the draft report
incorrectly overstating and inflating the DOJ's statutory role as to CACI and omitting
important factual context. Under state law, the DOJ "shall act only as a repository of [the]
reports" and to ensure that the CACI "accurately reflects the report it receives from the
submitting agency." (Pen. Code,§ 11170, subd. (a)(2); Cal. Code of Regs., tit. 11, § 901,
subd. (a) [emphasis added].) We suggest that providing this additional information in the
report would be beneficial to the public's understanding of CACI.
Only county welfare departments have the specific statutory duty to submit reports
to DOJ after conducting an active investigation and substantiating reports of child abuse
and severe neglect. (Pen. Code,§ 11169, subd. (a) and (b).) When submitting these
reports, the county welfare departments must use the CACI 8583 form. (Pen. Code,§
11169, subd. (a); Cal. Code of Regs., tit. 11, § 901.) Only complete CACI 8583 forms will be
accepted by DOJ and entered into CACI. (Cal. Code of Regs., tit. 11, § 902, subd. (a).)
*

California State Auditor’s comments begin on page 55.

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01

Incomplete forms will be returned to the submitting agency and it is the responsibility of
the submitting agency to resubmit a complete form. (Ibid.) This is because "[t]he
submitting agencies are responsible for the accuracy, completeness, and retention of the
reports." (Pen. Code, § 11170, subd. (a)(2); Cal. Code of Regs., tit. 11, § 901, subd. (a) .) The
DOJ acknowledges the issues and understands the concerns raised in the report. It also
supports efforts to improve the effectiveness CACI. But the DOJ can only include
information in CACI if the county welfare departments first comply with their legal and
regulatory obligations to submit complete reports for inclusion in CACI. Again, DOJ
requests that the report emphasize that DOJ can only enter reports into CACI if the county
welfare departments submit properly completed reports and submit them to the DOJ.
BACKGROUND OF CACI

The DOJ "maintains an index of all reports of child abuse and severe neglect
submitted pursuant to Penal Code section 11169." (Pen. Code,§ 11170, subd. (a)(l).) This
index is known as CACI. California has collected this information since 1965 and CACI is
now governed by the Child Abuse and Neglect Reporting Act (CANRA), codified at Penal
Code sections 11164 through 11174.3. CANRA mandates that certain classes of individuals
must report instances of suspected child abuse or neglect to law enforcement or county
welfare departments. (Pen. Code,§ 11165.9.) But, as discussed above, the county welfare
departments bear the burden of conducting the investigation, determining whether a
report is substantiated, and submitting the complete report to the DOJ for inclusion in
CACI. (Pen. Code,§ 11169, subd. (a) and (b); Cal. Code of Regs., tit. 11, § 901, subd. (a);
Cal. Code of Regs., tit. 11, § 902, subd. (a).)
Similarly, if a county welfare department makes any changes to a report, such as
changing a previous finding of substantiated abuse or misplacing an underlying report,
the agency must report these changes to the DOJ so that it can update CACI and remove
the reported individual from CACI. (Pen. Code,§ 11169, subd. (a); Cal. Code of Regs., tit.
11, § 901, subd. (b) and (d).)
THE DOT'S ROLE REGARDING THE INCLUSION OF INFORMATION IN CACI

Q2

The only responsibility CANRA places on DOJ with respect to CACI is to serve as
the repository of the CACI reports and to ensure that the CACI accurately reflects the
reports it receives from the submitting agencies. (Pen. Code, § 11170, subd. (a)(2); Cal.
Code of Regs., tit. 11, § 901, subd. (a) [emphasis added].) In order for the DOJ to maintain
the repository, the DOJ is completely reliant on the county welfare departments
submitting to the DOJ: a properly completed CACI 8583 for all initial submissions; any
subsequent notifications regarding a prior report; and a notification when the agency no
longer has the report. Consistent with applicable law and regulations, the DOJ also relies
on the cow1ty welfare departments to resubmit any returned incomplete reports. In other

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words, only after the county welfare departments have submitted a properly completed
CACI 8583 can DOJ include the information in CACI.
Ignoring why there may be legitimate reasons for differences between the number
of reports in the Child Welfare Services/Case Management System (CWS/CMS) the audit
report concludes that there are 27,000 reports in the CWS/CMS that are not in CACI and
should be, and an additional 298 reports that are no longer substantiated in CWS/ CMS
and should not be in CACI. In this discussion, the draft audit report improperly implies
that the DOJ received these reports and took no action to update CACI accordingly,
despite the more likely scenario that DOJ did not receive properly completed report forms
from the counties. Of the 27,000 reports, the auditors reviewed 29 reports with DOJ that
the CWS/CMS indicated were sent to the DOJ but were not reflected in CACI. Of these 29
reports, 15 were incomplete and missing information, in violation of the county welfare
departments' responsibilities under both state law and regulations. Consistent with state
regulations, the DOJ would have returned the reports for the agency to provide the
missing information because only properly completed reports from the counties will be
entered into CACI. Of the remaining 14 reports, the DOJ received one report and had
entered it in CACI under its normal processing. But, the state auditors' access to the
entries in CACI preceded this report's receipt and entry. There were an additional 13
reports the DOJ did not possess.
As a result of this review, it is highly likely the reports were returned to the county
to provide missing information OR were never received, rather than the DOJ having
received them and never entering them. The review of the sampled reports as described
above does not support the draft report's faulty assumptions.
THE DOT'S ROLE REGARDING REQUESTS FOR INFORMATION IN CACI

Since the DOJ maintains CACI, it is also responsible for providing information in
CACI to authorized entities conducting a CACI background checks. (Pen. Code,§ 11170.)
But the DOJ can only provide responses based on what is in CACI. If the county welfare
departments never provide the DOJ with a complete report, CACI would not reflect that
information. And any responses to requests for CACI background checks would reflect
either the absence of the report or the no longer substantiated report. DOJ also provides
subsequent notifications to authorized entities if there is a change in what had been
previously provided if it receives new or changed information.
After release of the draft report and before release of the final report, the audit team
is working to provide DOJ and Department of Social Services (DSS) with the relevant
information that will enable the DOJ to better understand the numbers that the audit team
references in its report, potentially further improve CACI, and provide any necessary
updated responses identified in the report. The DOJ appreciates the audit team providing

O3

O4

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O5

the DOJ this important information. Once it receives the critical information from the
audit team, DOJ will begin the critical validation process working with DSS to reconcile its
reports for inclusion in CACI, or those that should be removed, and DOJ will respond to
the background checks accordingly. Indeed, the draft report recognizes that once DOJ was
provided with information for one such individual, it took action by working with the
county and providing a subsequent letter to the authorized entity.
We understand that DSS has technology limitations that has hampered its ability to
provide data to DOJ. Since the CWS/CMS does not directly interface with the DOJ's
CACI/ the counties are precluded from directly submitting the reports electronically to
CACI. The DOJ looks forward to any efforts by the Legislature to implement a technology
solution.
CACI AND CWS/CMS ARE TWO DIFFERENT SYSTEMS WITH DIFFERENT
INFORMATION

O6

07

The DOJ is unsure whether the auditors considered that differences between CACI
and CWS/CMS regarding the 27,000 reports may exist because information maintained by
county welfare departments involve abuse and neglect that may not fit the criteria to be
entered into CACI for several legitimate reasons:
•

Counties may have substantiated reports for "general neglect" under CANRA, but
that information is not reportable to DOJ. (Compare Pen. Code,§ 11165.2 with Pen.
Code,§ 11169, subd. (a).)

•

Counties may enter reports of substantiated abuse in their database, where another
agency other than the county welfare department, like a law enforcement agency,
conducted the investigation and determined the abuse was substantiated. These
reports cannot be submitted to CACI. Indeed, the DSS specifically advised counties
that reporting allegations substantiated by a law enforcement agency violates Penal
Code section 11169, subdivision (a), unless the county welfare departments
conducted their own active investigation. (See ACL 17-85 (ca.gov).) Given the
statutory authority and public guidance from DSS explaining why there may be
substantiated reports maintained by a county welfare department, but not in CACI,
it is a glaring omission from the draft audit report that the discussion of the 27,000
reports has no reference to whether these were both substantiated and actively

investigated by the county welfare deparhnents.
With the above in mind, the DOJ responds to the specific findings below.

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Recommendations to the Legislature:

To better protect children when an authorized user requests a child abuse background check,
the Legislature should amend state law to require DOJ to directly access and review CWS/CMS
system data, which counties already use to record the results of their child abuse investigations. If
the Legislature implements this change, it should no longer require counties to submit reports of
child abuse to DOJ for inclusion in CACI, thus eliminating redundant efforts and reducing the risk
of error.
To maximize the effectiveness of child abuse background checks in protecting children, the
Legislature should amend state law to require all reports of substantiated child abuse to be included
in DO J's background checks. To protect the due process rights of individuals, the Legislature should
continue to require a grievance hearing processes.
DOJ' s Response
The DOJ supports the Legislature taking action to improve the effectiveness of
CACI through statutory changes and increased resources. The DOJ agrees having an
electronic data exchange with CWS/CMS would provide accuracy in CACI as long as the
information in CWS/CMS is accurate, complete, and meets the statutory requirements for
inclusion in CACI.
As an additional recommendation, because it will take time to implement any data
exchange, the Legislature should amend the statutory scheme to require DSS or county
welfare departments to review their CWS/CMS system before issuing any license,
approving an applicant, or making a placement. These entities already have access to this
information in their own CWS/CMS system and this solution will help protect vulnerable
children in the interim.

O8

Before any legislative changes are enacted, DOJ will continue exploring all
additional legally permissible steps it can take, along with the cooperation of the county
welfare departments and DSS.
Recommendations to DOJ

Until the Legislature amends state law and DOJ develops processes to use tlze CWS/CMS data
for child abuse background checks, DOJ should do the following:
•

Immediately develop a process for responding to child abuse background checks that includes
checking CACI and the list of 298 reports of child abuse that were not supported by county
records, and working with Social Services to check the list of 27,000 reports of substantiated
child abuse that were not contained in CACI. If the individual is on either list, DOJ should

09

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follow up with the relevant county to detennine whether the report should be included in
CACI.
DOJ' s Response
The DOJ agrees. DOJ has requested that the audit team provide it with the relevant
information and DOJ has already requested a data exchange with DSS to resolve
any discrepancies. Once the DOJ receives the critical information from the audit
team, it will begin the critical validation process working with DSS to reconcile its
reports for inclusion in CACI, or those that should be removed, and DOJ will
respond to the background checks accordingly.

05

•

Collaborate with Social Services by November 2022 to identify and reconcile all reports that
should have been submitted to CACI by counties. Work with counties to enter all missing
reports into CACI by June 2023. This collaboration should not be limited to the reports in
our four-year audit period.
DOJ's Response
The DOJ agrees. DOJ has already started conversations with DSS regarding how
DOJ can receive information electronically and reconcile any discrepancies between
the information that DSS has that should also be included in CACI. These efforts
are ongoing.

•

To ensure that it accurately enters all cases of child abuse it receives, by July 2022 DO]
should develop policies and to track, enter, and review all reports of child abuse it receives
from the counties. Also by July 2022, DO] should develop policies and procedures to track
those reports that it sends back to counties for correction.
DOJ' s Response

010

The DOJ agrees. Consistent with its obligations under CANRA, the DOJ adopted
implementing regulations, including the requirement that incomplete reports
would be returned to the submitting agencies to be completed and then
resubmitted to the DOJ. (Cal. Code of Regs., tit. 11, § 902, subd. (a).) The DOJ also
had longstanding policies and procedures for training staff regarding entering and
reviewing the reports it received. As recommended, these policies and procedures
have been formally finalized.
In its efforts to make improvements, effective April 18, 2022, the DOJ is now storing
all incoming reports and tracking incomplete reports returned to the reporting
agency to provide missing information. Although there is no statutory obligation

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for the DOJ to track incomplete reports, the DOJ wants to ensure the integrity of
CACI and therefore has begun assisting the county welfare departments in meeting
their statutory and regulatory obligations. The incomplete forms are now stored for
traceability and DOJ will follow-up with the contributing agency if the form is not
resubmitted within thirty days.
The CACI update process has an existing manual verification process, however, a
higher classification is now performing the verification. Effective March 14, 2022,
the DOJ implemented a manual verification process for all CACI entries, including
Consolidations and Deletes. As a long-term solution, the DOJ is also working
towards creating a verification queue within the CACI database to streamline this
process. The estimated time to develop the automated CACI verification queue is
approximately one year.

•

To ensure that only appropriate records are removed from CACI, by July 2022 DOJ should
develop policies and procedures related to how staff remove records from CACI. These
policies and procedures should include a process to verify the deletions are appropriate.
DOJ' s Response
The DOJ agrees. Please see the DOJ' s response to the previous recommendation.

•

To prevent omissions in CACI reporting, DOJ should develop policies and procedures, by
November 2022 to reconcile CACI with monthly reports from Social Services to verify that
counties have submitted-and DOJ has entered or deleted as appropriate-all reports into
CACI.
DOJ' s Response
The DOJ agrees. DOJ has already started conversations with DSS regarding how
DOJ can receive information electronically and reconcile any discrepancies between
the information that DSS has that should also be included in CACI. Once the
automated solution is finalized, which will allow DSS to submit data electronically,
the DOJ will update its policies and procedures accordingly.

•

To ensure that authorized users have accurate and complete information, by July 2022 DOJ
should send revised letters from the suspects whose reports of child abuse were omitted from
CACI and for individuals inappropriately included in CACI. To ensure it is able to revise
expedited letters if later determined to be incorrect, DO] should immediately begin
maintaining a history of all responses to expedited background checks.

O
10

O
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DOJ' s Response
The DOJ agrees and already sends subsequent notifications of any changes to CACI,
including any additions or removals from CACI, pursuant to Penal Code section
11105.2. Subsequent notifications are only permitted when the receiving entity still
has a legal right to receive the information.
With respect to its expedited letters process, the Department is reviewing to
determine if any changes are needed. This is because expedited letters are used for
emergency situations, such as a law enforcement officer having custody of a minor
child and needing to place the child in someone's care before the county welfare
department can take over the child's placement. In this scenario, the law
enforcement officer and law enforcement agency who made the expedited request
would not have a right to receive subsequent information once they no longer have
placement responsibility for the child.

011

•

To ensure that suspects are deleted from CACI in accordance with state law, by November
2022 DO] should research and address the 36,000 reports lacking birth dates by entering the

suspect's correct birth date and removing suspects who no longer meet the CACI
requirements.
DOJ' s Response

012

The DOJ agrees, has already reviewed the 36,000 records, and determined that
35,000 of these records are from the legacy child abuse system with reports dating
from 2008 to 1965. Legacy records did not necessarily include a reported
individual's date of birth because some of these records would have been entered
before the adoption of CANRA and implementing regulations. Only as a result of
Assembly Bill No. (AB) 717 (2011-2012 Reg. Sess.) (AB 717) and AB 1707 (2011-2012
Reg. Sess.) could reported individuals be removed from CACI on the basis of their
age. The dates of birth are now mandatory for CACI entries, in order to ensure that
eligible individuals are removed in accordance with AB 717 and AB 1707.

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If you have any questions or concerns regarding this matter, you may contact
me at the telephone number listed above.
Sincerely,

1/Al.,,---Joe Dominic, Chief/CIO
California Justice Information Services Division
For

ROB BONTA
Attorney General

cc: Venus D. Johnson, Chief Deputy Attorney General
Chris Prasad, CPA, CFE, Director, Office of Program Oversight and Accountability

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Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE
RESPONSE FROM THE CALIFORNIA DEPARTMENT
OF JUSTICE
To provide clarity and perspective, we are commenting on the
response to our audit from DOJ. The numbers below correspond to
the numbers we have placed in the margin of the response.
At no point does our audit report suggest that DOJ does not believe
that children should be protected or that individuals’ rights should
be protected. Further, our report does not overstate or inflate DOJ’s
role in regards to CACI. Rather, we accurately describe DOJ’s and
the counties’ roles on pages 7 through 11 of our report.

01

One of DOJ’s statutory roles in CACI is to accurately maintain the
information it receives from counties. However, as discussed on
page 15, out of the 60 reports we reviewed, counties were able to
provide evidence that they finalized 29 of these reports and they
assert that they sent these reports to DOJ via the US Post Office, as
directed by DOJ. Although DOJ entered one of these reports into
CACI after we received the data, the remaining 28 reports were not
in CACI. As we note on pages 16 and 17, because DOJ did not track
the reports it received from counties or the reports it sent back to
them for correction, it was unable to verify why these reports are
missing from CACI.

02

Our report does not ignore the reasons for differences between
the number of reports in CWS/CMS and the number of reports
in CACI. Rather, we explored the reasons for this discrepancy and
describe the results of our review beginning on page 15.

03

Our conclusions are not based on faulty assumptions, but rather on
an evaluation of the evidence that the counties and DOJ were able
to provide. As shown in the Table on page 16 and as discussed on
page 15, counties were able to provide evidence of these 29 finalized
reports in their case files and assert that they sent these reports
to DOJ via the US Post Office, as directed by DOJ. Although DOJ
stated that it would have returned 15 of these reports because
they were missing information, DOJ did not track all reports it
received or reports it sent back to counties, and is therefore unable
to support its assertion that it is highly likely the reports were
returned to the county to provide missing information or were
never received.

04

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05

State law governing our audits prohibits us from sharing
confidential information between auditees. We provided all of the
critical information to which DOJ has legal access and which we
could lawfully share prior to DOJ sending its written response.
However, Social Services has legal authority over some of the
critical information DOJ needs to follow up on specific child abuse
reports missing from CACI. We provided this information to Social
Services and encouraged it to enter into an agreement with DOJ to
share this information as soon as possible.

06

We carefully considered the differences between CACI and CWS/
CMS, especially as they relate to the population of records that
meet the criteria for inclusion in CACI. As discussed on page 7,
we considered only cases of child abuse and severe neglect, and on
page 18 we describe that cases of general neglect are not reported to
DOJ for inclusion in CACI.

07

Contrary to DOJ’s assertion, we considered the provision regarding
active investigations, which we discuss beginning on page 18 of our
report. Further, our second recommendation to the Legislature,
that it amend state law to require all reports of substantiated child
abuse to be included in DOJ’s background checks, is in response to
this specific issue. However, some of this information was redacted
in the draft report we provided to DOJ because it was related to
other entities.

08

As DOJ acknowledges in its response, DOJ’s suggestion for the
Legislature to amend state law to require Social Services and county
CWS agencies to check CWS/CMS would only apply to Social
Services and county CWS agencies. This recommendation would
not apply to the many other types of authorized users of CACI
discussed in the text box on page 7. Also, to be clear, our audit did
not establish—or attempt to establish—that Social Services and
county CWS agencies are not already checking CWS/CMS prior to
making placement and licensing decisions.

09

We note that DOJ agrees with all of our recommendations despite
its concern that the report needs additional contextual information.

010

DOJ refers to actions that it began taking at the end of our audit
after we shared our findings and recommendations. We are glad to
hear that DOJ is taking positive steps toward implementing those
recommendations and we look forward to reviewing its progress.

011

As discussed beginning on page 14 of our audit report and in our
recommendation, DOJ needs to begin retaining all responses to
its expedited background check process. Because DOJ does not
track these responses for longer than two months, it cannot reliably
determine if its response indicated whether an individual matched

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information in CACI. In the event that DOJ learns of additional
reports of child abuse that should have been in CACI, DOJ does not
know when it is appropriate to send a corrected letter to authorized
users who still have a right to the information.
Although DOJ asserts that many of the CACI records lacking birth
dates are from prior to 2009, DOJ’s response indicates that 1,000
of these records were entered after 2008. While DOJ recently
developed controls in CACI to require a birth date for all new
records, it is still important for DOJ to research and correct all
36,000 reports lacking birth dates to ensure it removes individuals
who no longer meet the CACI requirements.

012

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[ill

STATE OF CALIFORN IA-HEALTH AND HUMAN SERVICES AGENCY

DEPARTMENT OF SOCIAL SERVICES

COSS

744 P Street• Sacramento, CA95814 • www.cdss.ca.gov

KIM JOHNSON
DIRECTOR

GAVIN NEWSOM
GOVERNOR

May 12, 2022

Michael S. Tilden, CPA*
Acting California State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
SUBJECT:

CDSS RESPONSE TO CALIFORNIA STATE AUDITOR’S REPORT

Dear Michael Tilden:
This letter is in response to the recommendations identified for the California
Department of Social Services (CDSS) in the California State Auditor’s (CSA) Report
2021-112 entitled The Child Abuse Central Index. The CDSS is committed to
strengthening existing processes to improve the accuracy and efficiency of reporting to
the Child Abuse Central Index (CACI) by local child welfare services agencies in a
manner which supports the protection of children, while also providing thoughtful
consideration of the privacy and confidentiality of families involved with the child welfare
system and appropriate protections of the due process rights of individuals whose
names are submitted to the CACI. Additionally, the CDSS is committed to supporting
exploration of policies that may increase the fairness and equity of the CACI, which has
received criticism as unfairly and inappropriately impacting individuals whose names
were submitted to the index.
Below you will find the CDSS response to the recommendations in the CSA Report.
CDSS appreciates the opportunity to further discuss these recommendations with the
CSA.
CSA Recommendation #1
Immediately develop a process to collaborate with the Department of Justice (DOJ) and
counties to review the list of 27,000 reports of substantiated child abuse that were not in
CACI and ensure all eligible missing reports are forwarded to DOJ.

*

California State Auditor’s comments begin on page 65.

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Michael S. Tilden
Page Two
CDSS Response:
The CDSS is committed to working in partnership with counties and the DOJ to develop
interagency collaborative processes that may be used to effectively and efficiently
identify whether reports are being appropriately submitted to the CACI. Any processes
developed must be consistent with existing confidentiality laws and the established
CACI due process procedures. The CDSS will take the following steps to assess and
develop these interagency collaborative processes:
•

01
•
•
•

02
03

04

Meet with county child welfare directors and relevant county staff to determine
mutually agreed upon protocols to provide each county with a list of their county’s
reports for further review and assessment, as appropriate;
Meet with the DOJ to explore whether CACI data may be provided to CDSS and
counties for reconciliation purposes, and establish any necessary data sharing
agreements;
Provide technical assistance, training, and issue state guidance to support
county practice; and
Assess what resources may be necessary to successfully implement any new
procedures.

The CDSS recently received the CSA’s methodology for identifying these reports on
May 10, 2022, and is currently assessing this methodology and data. It is critical to note
that while existing data fields indicate a substantiated allegation in the Child Welfare
Services/Case Management System (CWS/CMS), additional review is necessary to
determine whether the report met all criteria under state law for submitting an
individual’s name for purposes of CACI reporting. In order to assess and verify whether
an individual’s name should have been submitted to the CACI based upon a
substantiated allegation in CWS/CMS, the CDSS will partner with counties to assess
establishing protocols and the resources needed to complete a qualitative review for
each of the 27,000 reports, including a review of investigation narratives and logs, in
order to verify the following requirements were met for submission to the CACI:
•
•
•

There is sufficient identifying information regarding the alleged perpetrator to fully
and accurately complete and submit the CACI report in accordance with Section
901 of Title 11 of the California Code of Regulations;
The facts underlying the substantiated allegation meet the specific definition(s) of
child abuse and severe neglect described in Penal Code Sections 11165 through
11165.6 that are used for reporting to the CACI;
The local county child welfare agency conducted an active investigation of the
report and determined the allegation to be substantiated, as required by Penal
Code Section 11169(a); and

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Michael S. Tilden
Page Three
•

The allegation was not subsequently determined to be unsubstantiated through a
grievance hearing or court proceeding.

05

Furthermore, in partnering with counties to develop any necessary protocols, CDSS will
provide technical assistance to support compliance with the required due process
procedures when a name is submitted to the CACI, including appropriate notice to such
individuals that have been listed on the CACI and their right to a grievance hearing.
CSA Recommendation #2
By November 2022, develop monthly reports from CWS/CMS of cases of child abuse
substantiated during the month and another list of cases that changed from
substantiated to not substantiated, and then provide these reports to the counties and to
DOJ.
CDSS Response:
The CDSS agrees with the importance of counties reporting accurate information to the
CACI and is committed to providing support and technical assistance to counties to
strengthen the accuracy and completeness of CACI reports. However, because a list of
substantiated allegations documented in CWS/CMS requires more nuanced analysis of
whether a report met the required criteria for submission to the CACI, the process
described in this recommendation may not accomplish our collective goal. To
determine how existing data may be most effectively leveraged to strengthen county
reporting to CACI, CDSS will:
•
•
•
•
•

Assess whether existing functionality within CWS/CMS supports the feasibility of
generating proposed reports to the counties;
Meet with county child welfare directors and relevant county staff to determine
what data and protocols will effectively provide counties with additional tools to
strengthen CACI reporting;
Meet with the DOJ to explore whether CACI data may be provided to CDSS and
counties for ongoing reports and reconciliation purposes, and establish any
necessary data sharing agreements;
Provide technical assistance, training, and issue state guidance to support
county practice; and
Assess what resources may be necessary to successfully implement any new
procedures.

06

07
01

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Michael S. Tilden
Page Four
CSA Recommendation #3
By November 2022, ensure that all counties develop policies and procedures to review
the monthly reports produced by Social Services and ensure that they have sent all
appropriate reports to DOJ.
CDSS Response:
The CDSS is committed to partnering with counties and the DOJ to develop appropriate
ongoing reconciliation processes to strengthen county reporting to the CACI, including
issuing state guidance for existing and new procedures. Counties update the policies
and procedures of their child welfare program according to CDSS policy guidance
typically issued through All County Letters (ACL) or regulation updates. To support
county updates to their local policies, the CDSS will take the following course of action:
•

•

08

09

Develop and issue an ACL providing counties with written guidance on their
ongoing duties and responsibilities to ensure accurate and timely data entry into
CWS/CMS as well as the commitment to submit CACI reports to the DOJ by
counties that receive optional Interagency Child Abuse and Neglect (ICAN) block
grant funding.
Develop and issue state guidance on any review and reconciliation procedures
established for CACI reports, including procedures for county child welfare
agencies to receive any data reports, how to reconcile potential discrepancies
identified by the reports, and how to ensure reports are submitted correctly or
identified as inappropriate for submittal.

The CDSS anticipates the reconciliation process will be a large workload for county
child welfare agencies to complete as they will need to complete a qualitative review for
all cases to correctly verify which substantiated reports should have been listed on the
CACI. Only counties receiving the optional ICAN block grant funding are required to
continue submitting reports to DOJ for the purposes of listing a perpetrator on the CACI.
If counties opt-out, they are not required to report. Requiring counties to participate in
this new reconciliation process could have potential unintended consequences. County
child welfare agencies may choose to
opt-out of receiving the ICAN Block Grant funds and discontinue reporting to the CACI
in subsequent fiscal years due to the county not having the resources to be able to
support this new activity.
CSA Recommendation #4
By November 2022, collaborate with DOJ to identify and reconcile all reports that should
have been submitted to CACI by counties and work with counties to enter all reports

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63

May 2022

Michael S. Tilden
Page Five
into CACI by May 2023. This collaboration should not be limited to reports of our
four-year audit period.
CDSS Response:
The CDSS is committed to collaborating with counties and DOJ to determine the most
effective solution for the reconciliation of records in a manner consistent with existing
confidentiality laws and due process requirements. The process will also be dependent
upon DOJ’s ability to provide CACI information for a reconciliation process to help
strengthen accurate and consistent CACI reporting by county child welfare agencies.
Additionally, any process for counties to submit reports from prior years will require
thoughtful assessment of whether sufficient due process can be provided.
CSA’s Recommendation Impacting CWS/CMS:
The Legislature should amend state law to require DOJ to directly access and review
CWS/CMS system data.
CDSS Response:
The CDSS supports exploring alternative opportunities to leverage existing data to
improve the accuracy of CACI reporting, including CDSS and county access to CACI
data for reconciliation purposes. Any proposed access to local child welfare data
contained in CWS/CMS by another entity must thoughtfully consider the confidentiality
and privacy of families involved with the child welfare system, the due process
protections for individuals whose names are submitted to the CACI, and the technical
capabilities and limitations of the existing system. The CWS/CMS holds underlying
investigation and case information involving families who receive child welfare services
that is strictly confidential under state and federal law. The CWS/CMS is a confidential
case management system and was not designed to provide access to specific data for
purposes of a CACI background check as proposed by the CSA. Due to the current
technical limitations of the CWS/CMS, there is not currently a confidential and secure
way to grant the DOJ access to the CWS/CMS without also granting access to all
referral and case data, including information of individuals whose names are not
reportable to CACI.
Additionally, it is not feasible to make changes to the current legacy system due to the
existing governance process, specifically how system changes are requested,
developed, and implemented. The technical aspects involved to create a new level of
restrictive access as stated above would be subject to building a case for a business
need. Given the system’s limited technical capabilities and existing structure, making
system changes to the CWS/CMS requires additional funding and contractual

010

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Michael S. Tilden
Page Six
amendments and at a minimum involves a comprehensive analysis process to analyze,
estimate costs, and develop any changes before implementation could take place. The
CWS/CMS will be decommissioned and replaced with the Child Welfare
Services-California Automated Response Engagement System (CWS-CARES).

0

11

Child safety is of utmost importance to CDSS, and CDSS will explore all opportunities to
improve information sharing and data quality. The new case management system in
development, CWS-CARES, has existing plans to exchange CACI information with the
DOJ, where feasible and appropriate. The implementation of a data exchange between
CACI and CWS-CARES would allow for proper consideration of children, youth, and
families’ confidentiality rights and maintain appropriate separation between the two
systems, which serve distinct statutory purposes. Additionally, it could improve the
accuracy and timeliness of CACI information submitted to DOJ.
RESPONSE FOLLOW UP
Questions or requests for clarification regarding the information in this letter should be
directed to Debbie Richardson, Chief, Office of Audit Services at
Debbie.Richardson@dss.ca.gov.
Sincerely,

-e~
KIM JOHNSON
Director

California State Auditor Report 2021-112

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Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE
RESPONSE FROM THE CALIFORNIA DEPARTMENT OF
SOCIAL SERVICES
To provide clarity and perspective, we are commenting on the response
to our audit from Social Services. The numbers below correspond to
the numbers we have placed in the margin of the response.
Social Services’ list of steps it indicates it will take notably lacks a key
activity: sharing with DOJ the list of 27,000 reports of child abuse in
CWS/CMS, which were not in CACI. We provided this list to Social
Services and asked that it enters into a data sharing agreement and
then share the data with DOJ. As we discussed on page 14, DOJ has
already provided responses to authorized users stating that at least
224 individuals do not have a history of child abuse even though
that same individual has substantiated reports of child abuse in
CWS/CMS. It is crucial that Social Services share with DOJ the full
list of 27,000 reports of child abuse from CWS/CMS so that DOJ
can work with counties to prioritize researching and submitting any
eligible missing reports of child abuse. DOJ can then send revised
letters to authorized users, as appropriate.

01

In November 2021, Social Services staff provided us system
documentation from CWS/CMS, which outlined how to identify
reports of substantiated child abuse. We relied on this documentation,
as well as multiple discussions with Social Services’ staff, when
developing our methodology and conducting our analysis. We also
reviewed in detail a selection of 60 substantiated child abuse reports
missing from CACI. Based on our review of these 60 reports, we
understand that some portion of the 27,000 missing reports will
ultimately be determined to not meet the criteria to be in CACI.
However, we are convinced by the evidence we have analyzed that
the majority of these 27,000 child abuse reports do need to be in
CACI and that Social Services needs to act swiftly to help DOJ
protect children.

02

We acknowledge that not all 27,000 reports of substantiated child
abuse in CWS/CMS may be eligible for CACI and that additional
review is necessary to determine whether these reports meet the
criteria for inclusion in CACI. Therefore, we do not recommend that
all of these reports be summarily entered into CACI. Instead, we
recommend that Social Services immediately develop a process to
collaborate with DOJ and counties to review this list.

03

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04

We recognize that reports of child abuse must meet certain
requirements to be included in CACI and our analysis accounted
for these requirements when there was sufficient data to do so. As a
result, and as we discuss on page 15, we determined that 52 of the 60
child abuse reports we reviewed met the reporting requirements and
should have been included in CACI.

05

We recognize that grievance hearings and court proceedings
can result in an allegation no longer being substantiated, and we
accounted for this factor in our data analysis. Specifically, while we
evaluated reports of child abuse for the four-year period ending
June 2021, we removed any reports of child abuse which were no
longer substantiated as of November 2021—the date we received a
copy of Social Services’ CWS/CMS data.

06

We recognize that a nuanced analysis is required to determine
whether a report belongs in CACI. That is why we recommend that
Social Services develop monthly reports of newly substantiated
reports of child abuse and furnish them to the counties, and ensure
that counties review these reports against the CACI reports that
they develop and send to DOJ each month.

07

It is unclear why Social Services needs to assess whether
CWS/CMS could generate reports of substantiated child abuse
when we used this same data to conduct our analysis identifying
these discrepancies.

08

We disagree with Social Services’ characterization that this monthly
reconciliation process will create a large workload for the counties.
On an ongoing basis, counties are already completing the necessary
qualitative reviews to determine whether reports of child abuse meet
CACI reporting requirements before sending reports to DOJ. We
are simply recommending that the counties reconcile the monthly
reports of substantiated child abuse recorded in CWS/CMS against
the CACI reports, which the counties already sent to DOJ, to ensure
that the counties have sent all eligible reports.

09

We believe Social Services is overstating the potential workload for
counties to help ensure that their substantiated child abuse reports
are in CACI. Further, we believe counties will focus their attention
on the intended consequence of our recommendation, which is
ensuring that CACI is accurate and complete so that children are
better protected. Finally, our recommended reconciliation process
is intended to be a temporary solution until the Legislature amends
state law and allows DOJ access to the substantiated reports of child
abuse in CWS/CMS data directly.

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May 2022

Social Services asserts that technical limitations in CWS/CMS
may prohibit sharing information directly with DOJ. Additionally,
it states that before making technical changes to its system to
implement our recommendation, it would have to build a case
for a business need to do so. We believe that ensuring child abuse
background checks are based on accurate and reliable information
is a sufficient business need considering that one of Social Services’
core missions is to protect vulnerable children. Further, if the
Legislature amends state law to require all reports of substantiated
child abuse to be included in DOJ’s background checks, as
discussed on page 3, Social Services would need to make fewer
technical changes to CWS/CMS, which could allow Social Services
to more quickly provide CWS/CMS access to DOJ.

010

Social Services suggests implementing a data exchange to
transfer information to CACI. However, if Social Services were to
effectively implement this solution, CACI data would substantially
duplicate information in CWS/CMS. This effort to establish a
copy of CWS/CMS data would be unnecessary if DOJ were able
to access CWS/CMS directly. Further, as we state on page 26,
Social Services estimated that it would not begin implementing
the data exchange until fall 2023, during which time DOJ would
have responded to many child abuse background checks without
the benefit of up-to-date information. This delay underscores
the importance of Social Services sharing available data with
DOJ immediately.

011

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Marla Stuart, Director

40 Douglas Drive, Martinez, CA 94553 • Phone: (925) 608-5000 • Fax: (925) 313-9748 • www.ehsd.org

May 10, 2022

To: Michael S. Tilden
Acting California State Auditor
From: Marla Stuart, MSW PhD
Employment and Human Servicef

n
~

~

Director

CONTRA COSTA COUNTY'S RESPONSE TO DRAFT FINDINGS OF THE CALIFORNIA STATE AUDIT
REGARDING THE CHILD ABUSE CENTRAL INDEX
The State Audit reviewed the effectiveness of the Department of Justice's CACI database, which
contains substantiated cases of physical, sexual, and emotional abuse or severe neglect of child
abuse. The identified review period was July 2017-June 2021. The California State Auditor
conducted a thorough review of Contra Costa County Children and Family Services' compliance
with Child Abuse Centralized Indexing (CACI) requirements.
We appreciate the Californ ia State Auditor taking the time to review Contra Costa County's
current policies and make recommendations on how the County can improve its processes to
ensure the effectiveness of the CACI database. Contra Costa County generally agrees with the
findings and recommendations of the draft audit report. The recommendations are in the
following areas:

•
•
•

Develop policies for removing existing reports in CACI when warranted
Adopt grievance hearing policies allowing the complainant to challenge the impartiality
of the grievance review officer
Identify and correct inaccuracies in CWS/CMS

Develop policies for removing existing reports in CACI when warranted
Contra Costa County Children and Family Services will enhance its current policies to include
instructions on removing reports from the CACI database when warranted by subsequent
findings or hearings that the allegations should not be substantiated.
Adopt grievance hearing policies allowing the complainant to challenge the impartiality of the
grievance review officer
Contra Costa County Children and Family Services will enhance its current policies to include the
steps that allow a grievant to challenge the impartiality of the grievance hearing officer.

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Identify and correct inaccuracies in CWS/CMS
Contra Costa County Children and Family Services w ill correct the inaccuracies noted in the
Audit.
To strengthen and improve our processes, the Contra Costa County Children and Family Services
should complete the items mentioned above by June 2022.
If you have any questions or require additional information, please contact Children and Family
Services Bureau Director, Kathy Marsh via email at kmarsh@ehsd.ccco unty.us or phone at {925)

608-4815.

Aging & Adult Services • Children & Family Services • Workforce Services • Community Services • Workforce Development Board

Employment o. Human Service, partner, with the community to deliver quality ,ervice, to en,ure acceff to re,ow-ce, that support, protect, and
empower individuals and families to achieve self-sufficiency

California State Auditor Report 2021-112

71

May 2022

~

Lita Morillo
Director

Opportunity. Options. Empo\11/erment.

May 10, 2022
Michael S. Tilden*
Acting California State Auditor
621 Capital Mall, Suite #120
Sacramento, CA 95814
Dear Mr. Tilden.
Thank you for the opportunity to work together in this process of reviewing our procedures and
practices in Kern County in regards to the Child Abuse Central Index. The department has
reviewed the report, The Child Abuse Central Index and the following is our response:
Finding #1: The review revealed that miscommunication among county staff and REDACTED
were major causes of these missing reports.
Recommendation #1: To ensure that they correctly revise and resend incomplete reports
needing correction, by July 2022, Kern should develop policies and procedures for accurately
responding and tracking reports DOJ sends back for correction.
Response to Finding and Recommendation: The Department partially concurs with this
finding and the department will be compliant with auditor's recommendation.
Achievable Deadlines for Resolution: The Department has a procedure in place including an
established CACI representative who receives DOJ forms that require correction and has an
established procedure for their process. The Department will update related policies and
procedures. In addition the Department will develop a tracking system, including creating a
CACI log that will be maintained by the investigating program. The CACI representative will
work with the case assigned staff member to ensure forms are corrected and sent back to DOJ for
correction. The Department anticipates this will be completed by August 2022.
Recommendation #2: To ensure fair and impartial grievance hearings and to comply with state
regulations, Kern should, by July 2022, adopt grievance hearing policies allowing the
complainant to challenge the impartiality of the grievance review officer.
Current Status and Achievable Deadline for Resolution: The Department will update
grievance hearing related policies. to address complainant challenges of the grievance officer.
The Department is also working on establishing a contract with the California Central Training
Academy, who will provide the grievance hearing officers in the event a complainant challenges
Tel 661 .631 .6000 Fax 661.631 .6631 TTY 800.735.2929
100 E. California Avenue P.O . Box 511
Bakersfield, CA 93302 www.KCDHS.org
Kem County Department of Human SeNices is an equal opportunity employer.

*

California State Auditor’s comments appear on page 75.

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the impartiality of a grievance officer. In addition, the Department will also be training
additional grievance hearing officers to increase the pool of available grievance hearing officers.
By September 2022, the Department will be compliant with auditor's recommendation.
Finding #2: CACI is missing many suspects with a history of child abuse.
Response to Finding: The Department concurs with this finding and the department will be
compliant with auditor's recommendation.
Achievable Deadlines for Resolution: The Department will correct any cases that are required
to be corrected due to the audit findings. The Department is and will continue to review CACI
related policies and procedures and will be providing CACI focused training to all child welfare
social workers and supervisors. By November 2022, the Department will be compliant with
auditor's recommendation.
Finding #3: County CWS Agencies could not adequately explain why CACI 1s m1ssmg
substantiated reports of child abuse.
Response to Finding: The Department concurs with this finding and the department will be
compliant with auditor's recommendation.
Achievable Deadlines for Resolution: The Department is and will continue to review CACI
related policies and procedures and will be providing CACI focused training to all child welfare
social workers and supervisors. By November 2022, the Department will be compliant with
auditor's recommendation.
Finding #4: Kem County lacked policies and procedures for correcting child abuse reports that
DOJ returns to it.
Response to Finding and Recommendation: The Department partially concurs with this
finding. The department does have a procedure but the procedure for correcting child abuse
reports but it is not outlined in a policy.

01

Achievable Deadlines for Resolution: Kem has a designated CACI representative who receives
all the reports sent back from DOJ requiring correction and makes the required corrections and
will send the corrected form back. The procedure is in place but not detailed in policy.
Therefore, the Department is and will continue to review and update CACI related policies and
procedures and will be providing CACI focused training to all child welfare social workers and
supervisors. The Department anticipates this shall be completed by November 2022.
Finding #5: The Counties we reviewed did not always send reports to DOJ
Recommendation: Although Kern County's approach is allowed by state and Social Services'
guidance, other counties we reviewed typically wait for law enforcement to finish its
investigation before the county concludes its investigation or the county reaches a conclusion
based on the available evidence and reports the suspect to CACI if it substantiates an allegation
of child abuse.

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May 2022

Response to Finding and Recommendation: The Department partially concurs with this
finding. As stated in the audit, state law allows certain substantiated cases of child abuse to not
be included in CACI. Furthermore, in response to waiting for law enforcement to complete their
investigation, in Kem County, Law Enforcement can delay response on an investigation or delay
a Social Worker from completing a full investigation sometimes up to 6 months to a year. Due to
these delays and to be in compliance with our Division 31 regulations, Kem is not able to keep
the referrals open for that extended amount of period.
Achievable Deadlines for Resolution: Kem will request CDSS provide further guidance in
regards to defining "active investigation" to provide guidance in those circumstances where the
perpetrator is not interviewed. Kem will update policies as required once the guidance is
received and anticipate to be completed by November 2022.
Finding #6: CACI erroneously contains some reports of child abuse that are not substantiated,
which could lead to DOJ informing an authorized user that an individual is a perpetrator of child
abuse when he or she has not associated report of substantiated child abuse. As a result, this
erroneous information may limit that person's employment or opportunity to care for children.
Response to Finding: The Department concurs with this finding and the department will be
compliant with auditor's recommendation.
Achievable Deadlines for Resolution: The Department is and will continue to review CACI
related policies and procedures and will be providing CACI focused training to all child welfare
social workers and supervisors. The Department anticipates this shall be completed by July
2022. The Department will work on reviewing and updating our policies and procedures as
required and provide a refresher training for our staff and supervisors to ensure all the staff is
familiar with the process by November 2022.
Thank you again for the opportunity to work together. If you wish to discuss our response further
or have any questions, please contact Program Director, Limbania Sandoval at 661-631-6335 or
email at sandovl@kerndhs.com.
Sincerely,

Lito Morillo
Director

CC

Ryan Alsop, Chief Administrative Officer

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Comments
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE
RESPONSE FROM KERN COUNTY
To provide clarity and perspective, we are commenting on the
response to our audit from Kern County. The numbers below
correspond to the numbers we have placed in the margin of
the response.
Although Kern County claims to have a procedure in place for
accurately responding to and tracking reports that DOJ sends
back to it for correction, it was unable to provide documentation
of this procedure during the audit. Nevertheless, in response to
our recommendations, Kern County acknowledges that it plans to
update its policies and procedures to describe how it responds
to these requests, and that it will develop a system to track
these requests.

01

As we discuss on pages 18 and 19, because Kern County
determined that it did not perform an active investigation for
certain substantiated cases of child abuse, it did not forward these
cases to CACI for inclusion in child abuse background checks,
as allowed by state law. To address this gap in reporting to CACI,
on page 3, we recommend that the Legislature amend state law
to require all substantiated cases of child abuse be included in
background checks.

02

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County of Orange

SOCIAL SERVICES AGENCY
500 N. STATE COLLEGE BLVD.
ORANGE, CA 92868-1673
(714) 541-7700

DEBRA J. BAETZ
DIRECTOR

AN TRAN

CHIEF DEPUTY DIRECTOR

DORTHE LEE

DIVISION DIRECTOR
ADMINISTRATIVE SERVICES

JYOTHI ATLURI

May 10, 2022
Mr. Michael S. Tilden*
Acting California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, California 95814

DIVISION DIRECTOR
ASSISTANCE PROGRAMS

CHRISTINE SNAPPER

DIVISION DIRECTOR
CHILDREN & FAMILY SERVICES

GAIL ARAUJO

DIVISION DIRECTOR
FAMILY SELF-SUFFICIENCY &
ADULT SERVICES

ANNE H. LIGHT, M.D.

MEDICAL DIRECTOR

Subject: Report No. 2021-112 – Child Abuse Central Index
Dear Mr. Tilden:
The County of Orange Social Services Agency (SSA) has received the California State Auditors
(CSA) Child Abuse Central Index draft report dated May 31, 2022. The opportunity to review
the report and provide a response is appreciated.
SSA is committed to delivering quality services that are accessible and responsive to the
community. In the spirit of collaboration, we welcome the external evaluation process to make
valuable recommendations for system improvement.
As a child welfare agency, SSA agrees that the accuracy of agency records and those of the Child
Abuse Central Index (CACI) are vitally important. SSA strives to ensure accuracy and has
developed and maintained numerous policies and procedures to safeguard data integrity. Even
so, the audit found an opportunity for policy and process improvement, and SSA is committed to
implementing that recommendation.
SSA would like to thank CSA for its work on this audit and for allowing us an opportunity to
respond, enabling an avenue with which to improve our practice.
Enclosed, please find our response to the audit recommendations. If I can be of further
assistance, please don't hesitate to contact me at Debra.Baetz@ssa.ocgov.com or by phone at
714-541-7773.
Sincerely,

Debra J. Baetz
Director

County of Orange Social Services Agency

* California State Auditor’s comment appears on page 79.

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Response to California State Auditors report
CSA Recommendation #1: Develop policies to accurately respond to and track reports
DOJ sends back for correction.
SSA Response: The agency agrees with this recommendation and has already begun
discussions to ensure we accurately respond to and track reports DOJ sends back for
correction as identified in the audit. We will fulfill the recommendation within the
timeline detailed in the report.
CSA Recommendation #2: Adopt grievance hearing policies requiring the return of
confidential documents when the county provides such evidence to suspects for a
grievance hearing.

01

SSA Response: A grievant receives documents by filing a Welfare and Institutions Code
§827 “Petition for Access to Juvenile Case File” (aka 827 Petition) with the Orange
County Superior Court. Once approved by the court, SSA then redacts the documents
and they are released by the SSA Custodian of Records. As records are acquired through
a legal process, SSA does not have the authority to request the return of the documents.
SSA will develop a policy should there be any change in how records are obtained.

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Comment
CALIFORNIA STATE AUDITOR’S COMMENT ON THE
RESPONSE FROM ORANGE COUNTY
To provide clarity and perspective, we are commenting on the
response to our audit from Orange County. The number below
corresponds to the number we have placed in the margin of
the response.
Although Orange County directs complainants to use the
“827 Petition” process—which is a process to obtain a court order
to access juvenile case file information—to obtain evidence relevant
to their grievance hearings, neither state regulations governing
CACI nor the statutes authorizing the 827 Petition process
requires complainants to use this process. Instead, state regulations
governing the grievance hearing process require Orange County to
provide evidence to complainants upon request. Thus, we stand by
our recommendation that Orange County should develop grievance
hearing policies that address the return to it of confidential
documents that suspects obtain outside of the 827 Petition process.

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Shasta County

l-lealth & l-luman
Services Agency

Children's Services
Branch

Tuesday, May 10, 2022
Michael S. Tilden, CPA, Acting California State Auditor
California State Auditor’s Office
621 Capitol Mall, Ste 1200
Sacramento, CA 95814
Subject: Response to the California State Auditor’s Office regarding Shasta County Child Abuse Central
Index Audit (2021-112 – Confidential Draft Audit Report)
Dear Mr. Tilden:
Thank you for the opportunity to review the draft of the California State Auditor's Audit findings for Shasta
County Health and Human Services Agency, Children’s Services Branch.
We agree with the recommendations contained in the copy of the redacted report and have already initiated
corrective actions on the issues that were brought to our attention during the review process. Our Agency is
committed to improving internal practices to ensure the health and safety of the children of Shasta County.
We thank your staff for their professionalism and time in performing this review to help strengthen our
operations. If you have any questions or require additional information, please have your staff contact me
directly.
Sincerely,

Miguel Rodriguez, MSABA, LCSW
Children’s Services Branch Director
1313 Yuba St. Redding, CA 96001
Phone: (530) 225-5885
Fax: (530) 225-5190
Email: marodriguez@co.shasta.ca.us

“Engaging individuals, families and communities to protect and improve health and wellbeing.”
Miguel Rodriguez, MSABA, LCSW, Branch Director
www.shastahhsa.net

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May 2022

COMMUNITY SERVICES AGENCY
Christine Huber, MSW
DIRECTOR

May 10, 2022
Michael Tilden, CPA
C/0 R. Wade Fry, MPA
California State Auditor
621 Capitol Mall, Ste 1200
Sacramento, CA 95814
WadeF@auditor.ca.qov
Re: State Auditors' Draft Report 2021-112
Dear Michael TIiden,
The County of Stanislaus has reviewed a draft redacted report of California State Audit No 2021-112
regarding the Child Abuse Central Index. Community Services Agency has identified three
recommendations in the report specific to Stanislaus County. We have no objection to the three
recommendations and have no other comment on the remainder of the document.
The County understands the importance of the Child Abuse Central Index and ensuring that correct
information is submitted to the Department of Justice. In addition, we are committed to following all
legal mandates and ensuring the policy identifies all necessary components. We welcome the
opportunity to review our practices and if you have any further questions, I can be reached at
(209)558-2500.
Sincerely,

Christine Huber, MSW
Director

WE

■I■

BUILD •■■

COMMUNITY

251 E. Hackett Road, Modesto, CA 95358
P.O. Box 42, Modesto, CA 95353-0042
Phone: 209.558.2500 Fax: 209.558.2558
csa-stanlslaus.com

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