State High-Risk Audit Program

CSU AND UC HAVE MADE EFFORTS TO CONTROL TUITION AND FEES IN THE PAST DECADE​

Background​

We first identified the affordability of higher education as a state high-risk issue in Report 2013-604, December 2013, noting challenges associated with the funding of higher education and the extent of access it provided. In 1960 the State published A Master Plan for Higher Education in California, which provided a roadmap for the future of higher education in the State. Reviews of the plan have reaffirmed its principles and emphasized the need for improved access to affordable higher education. As components of the State’s public higher education system, the University of California (UC), the California State University (CSU), and the California Community Colleges (CCC) each have a responsibility to align its services with the State’s goal of making higher education accessible and affordable to every Californian. However, in 2010 the Legislature identified the ability of the State’s public system of higher education to carry out the master plan as being at risk because of unprecedented population growth and extraordinary social and economic changes.

Although we originally included the CCC as part of this high-risk issue, we removed it in Report 2017-601, January 2018, because it had improved its ability to provide courses and services to students. In Report 2019-601, January 2020, we reported that from 1992 to 2017, undergraduate tuition had increased by about 340 percent at the CSU and 440 percent at UC. In our state high-risk assessment Report 2021‑601, August 2021, we noted that issues related to the affordability of higher education persisted.

Assessment​

By taking steps to control tuition and fee increases, the CSU and UC have made sufficient progress toward eliminating the basis on which the State Auditor designated this issue high-risk. For example, both university systems have held their tuition relatively flat since 2013. The CSU did not increase tuition during that time, and UC increased its tuition only two times, once by 3 percent in academic year 2017–18 and once by 4 percent in academic year 2022–23. As of academic year 2022–23, the CSU’s annual tuition is $5,742 and UC’s is $11,982. Similarly, both universities raised their fees moderately. Since 2018 the CSU increased its systemwide fees by $222 and UC increased its systemwide fees by $184.

With support from the State, the CSU and UC were able to avoid significant tuition and fee increases, even as inflation increased by 1.2 percent to 8 percent annually over a five year period. If the two institutions’ tuition had kept pace with inflation during these years, the CSU’s academic year 2022–23 tuition would have been $6,850 and UC’s would have been $13,649. A recent report recommended that the CSU increase its tuition in predictable amounts because of growing costs and insufficient funding from the State to cover its expenditures. In July 2023, the interim chancellor recommended a multiyear tuition proposal that would raise tuition rates by 6 percent beginning in academic year 2024–25, with one-third of the increase dedicated to financial aid. However, the CSU has not yet adopted this initial proposal. UC approved a tuition stability plan that took effect in 2022. The plan allows for the adjustment of tuition for each incoming undergraduate class at a rate slightly above inflation but subsequently holds the tuition rate flat for that class for up to six years.

Financial aid programs also increase access to higher education and have remained a viable option for the majority of resident students in both systems. For the most recent reporting period—academic year 2021–22—a variety of financial aid programs allowed nearly 60 percent of undergraduate students to pay reduced tuition at the CSU. Likewise, student aid allowed 55 percent of UC undergraduate students to pay no tuition. The university systems reported that in 2021–22, nearly 82 percent of CSU undergraduate students received some form of financial assistance, and 70 percent of UC undergraduate students received grants and scholarships.

The CSU and UC have attempted to address other expenses related to attending college that have increased in the past decade. The costs of housing, food, transportation, books, child care, health care, and supplies contribute to the overall cost of higher education. The CSU reports that the average cost of food and housing for its undergraduate students increased between about 3 percent to 6 percent annually from academic years 2018–19 to 2023–24. The average cost of living, which includes food and housing, increased by a total of 12 percent for UC’s undergraduate students during the same period.

Although expenses other than tuition and fees account for about 66 percent of the total cost of attending the CSU and 60 percent of the cost of attending UC, they are often beyond the university systems’ control. However, to help alleviate food and housing insecurity for students, the Legislature appropriated $15 million per year from 2019 through 2022 for UC and between $6.5 million to $31.5 million per year during the same period for CSU. Both university systems have used these funds to offer a wide range of services. For example, both the CSU and UC offer food pantry and food distribution programs, meal voucher programs, CalFresh application assistance, and multiple emergency housing programs.

Although the affordability of higher education continues to be a concern for many Californians, the CSU and UC have slowed the rate of tuition and fee increases in the past decade relative to inflation. Both university systems have also made attempts to mitigate other barriers to higher education—such as costs associated with food and housing—that are often beyond their direct control. Given these ongoing efforts, it is unlikely that a high-risk audit of higher education expenses would result in recommendations leading to a significant reduction in tuition, fees, or other costs such as food and housing.

Status: Removed from the high-risk list​

California State University Office of the Chancellor response. The UC did not provide a response.

CALSTRS HAS IMPLEMENTED CORRECTIVE ACTION TO DECREASE THE RISK POSED BY ITS UNFUNDED LIABILITY​

Background​

The California State Teachers’ Retirement System (CalSTRS) provides retirement, disability, and survivor benefits to the State’s more than 1 million public school educators and their families, primarily through a defined benefit pension plan (benefit plan). CalSTRS uses the funding it receives from its members, their employers, and the State to generate investment income, which it uses to help pay retirement benefits. Pension funds operate on a long-term horizon, working to guarantee benefit payments for existing and future retirees. According to CalSTRS, the most financially prudent way to provide such benefits is to fund the benefit plan fully by maintaining sufficient assets to cover all payments the program is obligated to make.

Despite this goal, CalSTRS has historically not had sufficient assets to fully fund the benefit plan. In essence, the funds it has received, along with the investment income they have generated, have not been sufficient to cover projected costs. The gap between CalSTRS’ assets and its liabilities is its unfunded liability. According to CalSTRS, its unfunded liability was partly a result of poor investment returns during the financial crisis from fiscal years 2007 through 2009 and partly a result of its inability to adjust the amount that plan participants and employers were required to contribute.

We identified CalSTRS as a high-risk agency in Report 2011-601, August 2011, because of the extent of its unfunded liability. In 2014 the Legislature enacted a CalSTRS funding plan that provided CalSTRS with certain limited authority to increase contribution rates for employers and the State in order to eliminate its existing unfunded liability by June 2046. We have monitored CalSTRS’ implementation of the funding plan as part of our high-risk assessments to determine the progress it has achieved.

Assessment​

CalSTRS has made significant progress in eliminating the basis on which we identified it as high-risk. Its continued financial progress indicates that the agency is on track to eliminate its unfunded liability by 2046. According to CalSTRS’ actuarial valuation reports, its implementation of the funding plan decreased its unfunded liability from $107 billion in 2018 to $89 billion in 2022. Despite investment losses in fiscal year 2021–22, CalSTRS reported that it remains slightly ahead of schedule in its goal of fully funding the benefit plan by 2046.

CalSTRS has also taken steps to better mitigate the risks it faces in its financial planning, thereby making its achievement of the funding plan’s goals more likely. For example, CalSTRS lowered its investment return assumptions from 7.5 percent to 7 percent. It also updated its mortality assumptions to account for the increased life expectancy of its members, thereby adding an expected additional two-to-three years of beneficiary payments to its planning.

We based our decision to remove CalSTRS from our high-risk list on several factors. First, the creation of the funding plan in 2014 and CalSTRS’ subsequent implementation of it represent a change in circumstance that reduces the risk of serious detriment. Further, by implementing the funding plan for several years, CalSTRS has demonstrated a strong commitment to mitigating the risk created by its unfunded liability and to meeting its goal of full funding by 2046. Finally, it is unlikely that a high-risk audit would result in recommendations leading to significant additional reduction in CalSTRS’ unfunded liability.

Status: Removed from the high-risk list​

The agency did not provide a response.

THE STATE IS ADDRESSING ITS OPEB LIABILITIES​

Background​

The State provides health and dental benefits as part of the retirement package it offers to many state employees. The State generally pays the majority of health insurance premiums and at least a portion of dental premiums for retirees, depending on their years of service and dates of hire. The State refers to these benefits as other postemployment benefits (OPEB). Paying OPEB for retired employees is a large cost for the State in any given year. For example, in fiscal year 2020–21, the State paid nearly $2.6 billion in OPEB for retired employees. The State tracks and reports its calculated future OPEB payments as a liability, which totaled about $99 billion as of the end of fiscal year 2020–21.

In Report 2008-601, June 2009, we explained that the State’s OPEB liability could grow so rapidly that it could affect the State’s credit rating. The State has since implemented a plan to eliminate its unfunded OPEB liability by 2046 (prefunding plan). Under the prefunding plan, the State negotiates with employee bargaining units to determine the percentage of employee compensation that employees and the State will make to a trust. California Public Employees’ Retirement System (CalPERS) invests the contributions to create investment income, which state law authorizes for OPEB expenditures either when a specific bargaining unit’s subaccounts reach 100 percent funding or after July 2046, whichever comes first.

Assessment​

The State has made significant progress to eliminate the basis upon which we identified its OPEB liabilities as a high-risk issue. The State’s prefunding plan is now in its eighth year, with $5.1 billion in assets as of June 30, 2022. The State Controller’s Office annually publishes a report on the status of contributions and the progress toward meeting the State’s liability. This report stated that as of June 30, 2022, the State Controller’s Office expected five of the State’s 23 employee bargaining units to be fully funded by 2046, with the remaining to be fully funded by 2050. According to the Department of Finance, if a bargaining unit does not meet the 2046 goal, the State will continue to pay for OPEB for retirees covered under that unit.

Several factors contributed to our decision to remove the State’s OPEB liabilities from our high-risk list. First, the creation of the prefunding plan and its subsequent implementation represent a change in circumstances that reduces the risk of serious detriment such that it is no longer substantial. When we added the State’s OPEB liabilities to the high-risk list in Report 2006-601, May 2007, no prefunding plan existed and the State relied on funding necessary contributions annually. Further, the State has taken sufficient corrective action by implementing the prefunding plan for several years, thereby demonstrating a strong commitment to controlling the risk created by its unfunded liability. Finally, the State’s progress makes it unlikely that a high-risk audit would result in recommendations leading to a significant reduction in the State’s OPEB liabilities. We are therefore removing this issue area from the state high-risk list; however, we will continue to monitor it as part of our existing Annual Comprehensive Financial Report (ACFR) audit.

Status: Removed from high-risk list​

The responsible agencies did not provide a response.

PUBLIC HEALTH HAS MADE SUFFICIENT PROGRESS IN IMPLEMENTING OUTSTANDING RECOMMENDATIONS​

Background​

The California Department of Public Health’s (Public Health) mission is to advance the health and well-being of California’s diverse people and communities. Among other things, Public Health is responsible for protecting people from environmental health issues such as lead poisoning, ensuring that patients in hospitals and skilled nursing facilities receive adequate care, and reducing health and mental health disparities among vulnerable and underserved communities.

We designated Public Health as a high-risk agency in Report 2006-601, May 2007. Since that time, we have maintained its designation as a high-risk agency because of a variety of concerns, including the large number of public safety-based recommendations that it had not implemented.

Assessment​

Public Health has made sufficient progress to eliminate the basis for the concerns on which the State Auditor identified it as high-risk. In Report 2017-601, January 2018, we reported that Public Health had not implemented 22 recommendations from various previous reports; we further noted that the conditions that occasioned those recommendations could still pose a substantial risk of the loss of life, significant injury, or a broad reduction in Californians’ overall health or safety. In Report 2019-601, January 2020, we reported that Public Health had made progress in this area: as of November 2019, it had only 11 unimplemented recommendations older than one year, three of which it indicated it would not implement. Currently, the department has only a limited number of outstanding recommendations, which we discuss below:

• Skilled Nursing Facilities: Absent Effective Oversight, Substandard Quality of Care Has Continued, Report 2017-109, May 2018: In this audit of skilled nursing facilities, we concluded that Public Health had not fulfilled many of its oversight responsibilities meant to ensure that nursing facilities meet quality‑of‑care standards. For example, we found that Public Health had made inconsistent licensing decisions and had not issued citations for facilities’ noncompliance with federal and state requirements in a timely manner. As a result, we made three recommendations to Public Health. As of September 2022, Public Health had partially implemented two of three recommendations and had one recommendation we rated as pending implementation.
  As part of our current high-risk assessment, we reviewed the status of these three recommendations. Our assessment determined that the department has fully implemented one recommendation, which required an upload of inspection findings to a database called Cal Health Find. This upload increased public transparency related to deficiencies at skilled nursing facilities and thereby improved oversight. We also noted that Public Health has generally continued to improve in its issuance of timely citations resulting from inspections of nursing homes, thereby making substantial progress in its implementation of a second recommendation. Finally, Public Health has partially implemented the third recommendation, which involves defining a process for facility application review to ensure that an applicant has demonstrated compliance with state and federal recommendations.
• Childhood Lead Levels: Millions of Children in Medi-Cal Have Not Received Required Testing for Lead Poisoning, Report 2019-105, January 2020: In this audit, we reported that millions of children in California had not received required lead poisoning testing and made seven recommendations to address the problems we had identified. Public Health subsequently implemented six of these recommendations. However, in our update on outstanding recommendations, Report 2022-041, January 2023, we reported that Public Health had not finished developing its lead evaluation regulations, the remaining recommendation from the January 2020 report. 8 We intended this recommendation to better ensure that children with lead poisoning are identified and treated.
  As part of our current high-risk assessment, we reviewed Public Health’s status on the implementation of this recommendation. As of July 2023, Public Health had finalized one package of draft regulations that focus on risk factors for lead poisoning. It expects to obtain external approval of these regulations by October 2023 from the California Health and Human Services Agency and by December 2023 from the Department of Finance. Public Health is still working to incorporate a new federal blood lead reference value into its regulatory package.
• Youth Suicide Prevention: Local Educational Agencies Lack the Resources and Policies Necessary to Effectively Address Rising Rates of Youth Suicide and Self Harm, Report 2019-125, September 2020: In this audit, we issued 23 recommendations to 10 entities, and one of our recommendations was to Public Health. Our report found that it had not established a program to support the development of school-based health centers to increase student access to health and mental health professionals as required by a 2007 law. In October of 2022, Public Health provided our office with an update on its efforts to implement our related recommendation and reported that it had worked with the School‑Based Health Alliance to obtain additional information and evaluate the resources needed to develop a public school health center support program. However, Public Health has been unable to identify funding opportunities to establish the program. The review we conducted as a part of this high-risk assessment found that Public Health has still not been able to secure the necessary funding to establish the program.
• Hospice Licensure and Oversight: The State’s Weak Oversight of Hospice Agencies Has Created Opportunities for Large-Scale Fraud and Abuse, Report 2021-123, March 2022: In this audit, we identified numerous indicators that hospice agencies were engaged in fraud, particularly in Los Angeles County. We also identified a likely large-scale effort to defraud Medicare and Medi-Cal hospice programs. We issued 28 recommendations, one of which was to Public Health. Specifically, we recommended that until the Legislature authorizes Public Health to issue emergency regulations to combat fraud, Public Health should use its existing regulatory authority to increase oversight of hospice agencies. In March 2023, Public Health reported that it was developing emergency hospice regulations to incorporate recommendations from our report and to address stakeholder feedback; it expects to complete this recommendation by the end of 2023.

We based our decision to remove Public Health from our state high-risk list on the significant progress it has made in implementing our recommendations. In doing so, Public Health has demonstrated a strong commitment to controlling the individual risks that we created the recommendations to address. Further, it has implemented corrective actions to mitigate risk to the public.

Status: Removed from the high-risk list​

Public Health’s response

THE STATE HAS MADE SUFFICIENT PROGRESS IN IMPROVING ITS TRANSPORTATION INFRASTRUCTURE​

Background​

The California Department of Transportation (Caltrans) and the California Transportation Commission (Transportation Commission) are generally responsible for ensuring that the State’s highway systems are in good condition. The Transportation Commission is responsible for allocating funds for the construction of highway, transit, and active transportation improvements, such as biking and walking paths, throughout California. Caltrans plans, develops, maintains, and operates the statutorily designated California State Highway System (state system). The state system includes 50,000 lane miles of pavement, 13,200 bridges, 213,000 culverts and drainage facilities, and nearly 21,000 transportation management system assets.

We first designated California’s deteriorating transportation infrastructure as a high‑risk issue in Report 2006-601, May 2007. At that time, we expressed concern about the lack of funding for transportation system upkeep and repairs as well as about the related decline in the condition of the state system because of deferred maintenance. Keeping the State’s transportation infrastructure in good repair is important, because it enhances safety and maintains the useable life of critical state assets. Further, Caltrans has reported that addressing deferred maintenance is more expensive to the State than providing preventive maintenance.

In 2017 the Legislature passed the Road Repair and Accountability Act of 2017 (Road Repair Act) to invest $54 billion over the next decade to fix roads, freeways, and bridges. The Road Repair Act set goals for Caltrans, as Table 1 describes. For example, Caltrans was to fix 500 additional bridges by 2027. The Road Repair Act also increased oversight of Caltrans and of Road Repair Act funds by establishing an inspector general for that agency and by expanding the Transportation Commission’s supervisory role. In our most recent high-risk assessment, Report 2021-601, August 2021, we maintained transportation infrastructure as a high-risk issue area in order to continue monitoring Caltrans’ progress in improving the state system.

Table 1​

Caltrans Is on Track to Meet the Goals of the Road Repair Act​

Source: Caltrans annual reports.
Note: The Legislature set a fifth goal related to correcting potholes and cracks in pavement. Caltrans factors the completion of this goal into its pavement metric.
* Pavement conditions for 2022 are projections.
† Information on bridges is presented by fiscal year.
‡ Caltrans and the Transportation Commission have interpreted the goal of fixing 500 additional bridges as meaning 500 more than their average annual repair rate of 114. The numbers indicated are cumulative totals that do not include the prior annual average of 114 each year.

Assessment​

Caltrans and the Transportation Commission have made significant progress toward eliminating the basis on which we identified transportation infrastructure as a high-risk issue. As Table 1 shows, as of 2022 Caltrans had exceeded the goals that the Legislature set for three of four categories and was making progress on the fourth. Caltrans reported that 99.25 percent of the pavement in the state system and 90.4 percent of culverts were in good or fair condition as of 2022. It further reported that it had exceeded the goal to repair an additional 500 bridges. Finally, it was also on track with the fourth goal, ensuring that 90 percent of traffic management systems are in good condition by 2027: 77 percent of these systems were in good repair in 2022.

Caltrans uses a website focused on providing transparency and accountability for the Road Repair Act to publicly report its progress in implementing the goals that the Legislature set. On this website, Caltrans has reported that the number of pavement lane miles it has repaired annually since the passage of the Road Repair Act has increased by 80 percent. It has further reported that its annual repair of linear feet of culverts in the same time period increased by about 700 percent. Caltrans has also reported on the Road Repair Act funds it has invested in projects to date, on the status of such projects, on the number of jobs the act has created—more than 225,000—and on the other effects that the additional funding has had for Californians.

According to Caltrans, the funding provided by the Road Repair Act will be sufficient to meet the act’s goals. In addition, the Road Repair Act requires Caltrans to implement efficiency measures with the goal of generating at least $100 million per year in savings, which Caltrans reported it has exceeded. Since fiscal year 2017–18, Caltrans has reported savings of between $133 million and $340 million annually through cost avoidance, new construction management practices, and other efficiencies. For example, Caltrans transitioned from painted stripes to new materials that last six times longer, resulting in $34 million in ongoing savings. Caltrans invests these savings in the maintenance and rehabilitation of the state system. Further, Caltrans has reported that many of the efficiencies it has created will prevent future construction delays, have positive environmental effects, or increase safety.

We based our decision to remove transportation infrastructure from our high-risk list on several factors. First, the additional funds provided by the Road Repair Act represent a change in circumstances that, due to their extensive and ongoing nature, reduce the risk of serious detriment such that it is no longer substantial. When we added transportation infrastructure to the high-risk list in Report 2006-601, May 2007, such a funding plan did not exist and the State’s infrastructure was slowly deteriorating. Further, as we have demonstrated above, Caltrans and the California Transportation Commission have taken sufficient corrective action by improving the state of transportation infrastructure, thereby demonstrating a strong commitment to mitigate the risk. Moreover, the Road Repair Act created an inspector general—who conducts a variety of compliance audits on the use of Road Repair Act funds each fiscal year—to provide increased oversight to Caltrans.

Status: Removed from the high-risk list​

CalSTA’s response

CDCR IS MAKING PROGRESS IN IMPROVING ITS HEALTH CARE DELIVERY​

Background​

The California Department of Corrections and Rehabilitation (CDCR) operates all state adult prisons, oversees a variety of community correctional facilities, and supervises incarcerated adults and adults released to parole supervision. CDCR operates 33 institutions and, as of June 2023, housed about 96,000 incarcerated people. The department has a constitutional duty to provide its incarcerated population with health care.

In 2005 a federal court found that CDCR’s health care system violated the U.S. Constitution’s prohibition against cruel and unusual punishment. The court found that this resulted in significant harm to the State’s prison-incarcerated population. To remedy the inadequate health care CDCR was providing, the court appointed a federal receiver (receiver) to take control of CDCR’s health care system until it was constitutionally adequate. In Report 2006-601, May 2007, we added CDCR’s provision of health care to incarcerated people as a high-risk issue to the State. Since that time, we have tracked the progress CDCR has made in providing constitutionally adequate care in part by reviewing the number of institutions the receiver has delegated back to CDCR’s oversight.

Assessment​

Since our last assessment, Report 2021‑601, August 2021, the receiver delegated health care at an additional institution—Wasco State Prison—back to CDCR’s oversight. This brings the number of institutions for which the receiver has returned control of health care to CDCR to 20, or 59 percent of its facilities. Figure 2 shows a timeline of the receiver’s delegation of health care at institutions back to CDCR. The receiver is currently considering whether to delegate another institution back to CDCR in 2023.

Figure 2​

The Federal Receiver Has Recently Returned to CDCR’s Care Control of More Institutions​

Source: CDCR reports and documentation.

Figure 2 description:​

A bar chart shows two columns per year beginning in 2004, one column shows the institutions under CDCR’s care and the second one institutions under the receiver’s care. CDCR transferred care of all institutions to the receiver in 2005. The receiver returned one institution to CDCR’s care in 2015, a total of nine by 2016, and 20 by 2022. The chart also shows an increase in the total number of CDCR institutions from 32 in 2004 to 35 in 2015, and a reduction to 33 in 2022.

OIG Medical Inspection Cycles​

OIG performs medical inspections in cycles. During each cycle, OIG inspects the medical care delivered at every CDCR adult institution. Afterward, OIG publishes a report of its results for each institution. Once all institutions have been reviewed, OIG begins a new cycle. It is currently performing Cycle 7 reviews.
Source: OIG website.
In addition to the receiver’s returning an additional institution to CDCR’s care, the Office of the Inspector General (OIG) whose functions are described in the text box, has improved the rate at which it performs medical inspections and produces reports. Because the receiver must consider OIG’s reports on the adequacy of the health care an institution provides when determining whether to delegate responsibility for that institution back to CDCR, delays in the completion of OIG’s reports could impede the receiver’s ability to return institutions to CDCR’s care.

Our last high‑risk assessment reported that OIG had not finished performing its Cycle 6 reviews, which it began in 2019, and that it had issued reports for only nine of 35 institutions (26 percent) as of June 2021. However, as Figure 3 shows, OIG had issued medical inspection reports for 30 of 34 institutions (88 percent) and commenced its Cycle 7 inspections as of June 2023. In its 30 Cycle 6 inspection reports, OIG concluded that the health care provided at 21 institutions (70 percent) was adequate during the inspection period. This presents an improvement over the prior cycle, when OIG found 57 percent of the institutions provided adequate health care.

Figure 3​

OIG Has Made Significant Progress in Completing Its Cycle 6 Inspection Reports​

Source: OIG reports.
* We include the California Correctional Center inspection report in this tally since OIG completed that report. The California Correctional Center permanently closed in June 2023.

Figure 3 description:​

The figure consists of two pie charts. The first pie chart show the OIG issues nine reports by June 2021, 26 percent of the total. A second pie chart shows the OIG issues 30 reports by June 2023, 88 percent of the total.
CDCR has made significant cumulative progress to eliminate the basis upon which we identified it as high risk. We based our decision to remove CDCR from the high-risk list primarily on two factors. First, CDCR has made significant progress in providing constitutionally adequate care, with the receiver having delegated 20 of CDCR’s facilities back to its control. Further, OIG is now providing increased oversight, so it is unlikely that a high-risk audit of CDCR’s health care delivery would result in recommendations leading to additional significant changes in the department’s provision of constitutionally adequate care.

Status: Removed from the high-risk list​

The agency did not provide a response.

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We prepared this report under the authority vested in the California State Auditor by Section 8546.5 of the Government Code.

Respectfully submitted,

GRANT PARKS
California State Auditor

August 24, 2023


Staff:
John Lewis, MPA, CIA, Audit Principal
Nick Phelps, JD, Senior Auditor
Cecilia White, MPPA

Data Analytics:
R. Wade Fry, MPA
Grant Volk, MA, CFE

Legal Counsel:
Natalie Moore