HomeMy WebLinkAbout2022-03-22; City Council; ; Code Enforcement Program Audit and Status Update on Open Audit Recommendations from Previous Audits•CIT V CO UNCfl
Staff Report
M eeting Date:
To:
From:
Staff Contact:
March 22, 2022
Mayor and City Council
Scott Chadwick, City Manager
Robert Threatt, Internal Audit Manager
robert.threatt@carlsbadca.gov, 442-339-2418
Laura Rocha, Deputy City Manager, Administrative Services
laura.rocha@carlsbadca.gov, 442-339-2415
CA Review CKM
Subject: Code Enforcement Program Audit and Status Update on Open Audit
Recommendations from Previous Audits
District : All
Recommended Action
Receive a presentation on the results of an internal audit of the city's code enforcement
program and a status update on the open audit recommendations from an internal audit of the
city's credit card program performed in fiscal year 2020-21.
Executive Summary/Discussion
The City Council approved the fisca l year 2021-22 Internal Audit Plan, which included an audit
of the city's code enforcement program. The results of the audit, which are attached as Exhibit
1, found the code enforcement program is well supported by existing policies and procedures.
This was evident in the results noted during testing of audit selections.
The area of greatest opportunity for improvement noted during the audit related to the city's
management of case file data. This is code enforcement data t he city's code enforcement
officers enter into the EnerGov enterprise system for every code violation they investigate.
Utilizing the available data, management has an opportunity to identify key metrics and
strengthen reports generated from existing code enforcement data. Such value-added reports
will enable management to further develop staff and to maximize available staffing resources.
This presentation will cover the audit's objectives, methodology and provide a summary of the
results. (See Exhibit 1.) It will also co"'.er t he four corrective actions the internal auditor
recommended to the city's Code Enforcement Division in response to the audit results.
In fiscal year 2020-21, the city's internal auditor performed an audit of the city's credit card
program that resulted in eight audit recommendations, with which management concurred.
{See Exhibit 2.) Of the original recommendations, two remain open. This presentation will also
provide the City Council with a status update on those items.
March 22, 2022 Item #8 Page 1 of 17
Fiscal Analysis
The presentation on the code enforcement program audit results, as well as the status update
regarding the open audit recommendations are informational items with no direct fiscal impact.
Next Steps
The Internal Audit Manager will monitor the status of the four new audit recommendations
until they are fully addressed.
Environmental Evaluation
This action does not constitute a "project" within the meaning of the California Environmental
Quality Act under California Public Resources Code section 21065 in that it has no potential to
cause either a direct physical change in the environment, or a reasonably foreseeable indirect
physical change in the environment.
Public Notification
This item was noticed in keeping with the state's Ralph M. Brown Act ~nd available for public
viewing and review at lea st 72 hours before the scheduled meeting date.
Exhibits
1. Report 2022-02, Code Enforcement Program Audit
2. Open Audit Recommendation Status Report
March 22, 2022 Item #8 Page 2 of 17
March 22, 2022
Exhibit 1
Internal Audit of the
City's Code
Enforcement Program
REPORT
March 2022
Robert Threatt
Internal Audit Manager
Report 2022-02
Item #8 Page 3 of 17
Exhibit 1
TABLE OF CONTENTS
INTRODUCTION
Scope & objectives ......................................................................................................... 3
Methodology .................................................................................................................. 3
Summary of results ........................................................................................................ 3
Background ..................................................................................................................... 4
O BJ ECTIVE 1 : POLI CI ES A ND PROCEDURES
Policies and procedures objective .................................................................................. 4
Test results ..................................................................................................................... S
OBJECTIVE 2 : ADHERENCE TO GUIDELI N ES
Adherence to guidelines objective ................................................................................. 8
Test results ..................................................................................................................... 9
OB JECTIVE 3 : METRICS AND REPORTING
Metrics and reporting objective ..................................................................................... 9
Test results ..................................................................................................................... 10
REC O MM EN DATI O N S
Recommendations and management's response .......................................................... 13
2 I Audit of the City's Code Enforcement Program
March 2{ 2022 Item #8 Page 4 of 17
Exhibit 1
INTRODUCTION
Scope & objectives
The period covered by the code enforcement program audit included fiscal years 2018-19,
2019-20 and 2020-21. The audit had three objectives:
• To assess whether the division has reliable policies and procedures to support
effective code enforcement
• To evaluate whether a selection of cases from the most recent three-year period
adhered to applicable guidelines
• To assess whether the city uses case data and metrics to provide meaningful
information to management
Methodology
• Interviewed city staff from the Community Development and the Information
Technology departments
• Ana lyzed three fiscal years of code enforcement case file data
• Performed direct observations via a ride-a-long with a code enforcement officer
• Researched city policies, guidelines and the municipal code
• Researched programs from comparable cities in San Diego County
• Received demonstrations of new technologies, one hosted by the city and another
by a third party, both of which are expected to support code enforcement activities
Summary of Results
The audit procedures resulted in the identification of audit recommendations for
management's consideration. The first area evaluated was the city's policies and procedures
on code enforcement activities. Code enforcement staff rely heavily on the municipal code
and the city's Case Prioritization and Process Guide when carrying out their duties. While
these resources provide the program foundation and framework within which code
enforcement staff operate, it's recommended the city publish a set of core procedures to
serve as a training resource for the city's code enforcement officers.
The second objective called for the evaluation of the prior three years of documented code
enforcement case files. The auditor evaluated case files for the degree to which code
enforcement personnel adhered to existing guidelines. This objective was achieved by
selecting samples of case files from the three-year period. Samples were selected using
varying procedures t o ensure a representative sample.
The final objective called for an evaluation of how well the city leverages its case file data to
track and report on key metrics. To evaluate the city's use of data, t he city's internal auditor
examined the code enforcement program's reporting activities and the enterprise system
that maintains the case files. This was achieved primarily by interviewing code enforcement
Exhibit 1
and information technology personnel and reviewing reports available in EnerGov, the
enterprise system.that maintains code enforcement data.
Background
The Code Enforcement Division administers education and enforcement activities to
promote compliance with local code sections and maintain a safe living and working
environment, while also seeking to maintain the quality of life Carlsbad residents have come
to enjoy. Th e division achieves these goals by evaluating and enforcing code compliance on
a wide range of issues. The issues range from construction without a permit, unsafe
buildings, junk and debris on private properties, inoperative vehicles in front yards, sign
standards, property maintenance and construction noise, among others.
The Code Enforcement Division is comprised of five full-time code enforcement officers: a
division manager, a senior code enforcement officer and three part-time code technicians,
one of which assigned to the weekend shift. There are two part-time positions assigned to
support compliance with the short term vacation rental regulations. There are also one to
three part-time administrative assistants who support the code enforcement program by
receiving incoming calls, assigning reports of possible code violations and by mailing the
notices generated by the different enforcement actions.
Code enforcement officers receive complaints of possible violations through several intake
points. This includes calls made to a dedicated code enforcement phone line, a dedicated
email account, complaints relayed from city staff or through direct observation by code
enforcement officers.
The goals of the code enforcement program include ensuring compliance with established
state and local regulations to protect public health, safety, and general welfare and to
maintain the high quality of life enjoyed by the City of Carlsbad. Experience has shown that
non-compliance in large part stems from a lack of knowledge of the city's building and
municipal codes. To account for this lack of familiarity, code enforcement officers follow
progressive citation protocols (as detailed in t he Case Prioritization and Process Guide, on
pages 19-20). The protocols are designed to resolve issues of non-compliance at the lowest
level possible, and begin with educating the property or business owner about the relevant
code section{s).
OBJECTIVE 1 : POLIC I ES AND PROCEDURES
To assess whether the division has reliable policies and procedures to support effective
code enforcement.
The process of evaluating the city's policies and procedures to determine the degree to
which they support the code enforcement program began with identifying the specific
policies or procedures intended to support the code enforcement program. This was
achieved by interviewing management, reviewing program resources, such as the city's code
enforcement website and through the auditor's observations during the course of the audit
engagement. The auditor determined the relevant policies and procedures were comprised
Exhibit 1
of the Carlsbad Municipal Code and the Case Prioritization and Process Guide. While other
documents were identified, such as guidelines for the placement of politica I signs, or street
and sidewalk vendor guidelines. Those guidelines all originate in the municipal code.
Both the municipal code and the Case Prioritization and Process Guide house key policies
and procedures that support the city's Code Enforcement Program.
The auditor then evaluated these policies and procedures identified by interviewing code
enforcement officers rega rding their use of the noted policies and procedures, and by
testing documented case files from fiscal years 2018-19 through 2020-21.
The auditor tested the case files for evidence that the documented procedures were
followed, and that the policies were adhered to. Collectively, these procedures permitted
the auditor to determine the degree to which t hese policies and procedures are utilized and
if there are any gaps in existing measures that require addressing.
During the testing of audit samples (Objective 2) and throughout this audit, the policies and
procedures were evaluated for their collective coverage and impact on the city's code
enforcement program. The auditor found the Case Prioritization and Process Guide provided
more than just a broad framework for code enforcement staff to operate within, but also a
detailed set code enforcement processes and guidelines.
One such guideline is known as the Progressive Citation Protocols, which identify a hierarchy
of progressively stronger enforcement actions that code enforcement officers are to follow.
The idea behind progressive enforcement actions is that a bulk of the code enforcement
violations stem from a lack of familiarity with the code requirements on the part of the city's
property and business owners. Therefore, the city has chosen to progress through a set of
warnings and notifications, giving its community members ample opportunity to correct the
identified violation without the appllcation of any administrative citations or fines.
The following outlines the different steps found in the Progressive Citation Protocol (Case .
Prioritization and Process Guide, pages 19-20).
• Verbal Warning -Allows 24 hours for the property owners to correct an
error. This is typically reserved for very minor violations such as trash
cans left on the street for too long. Larger or more significant issues of
non-compliance often begin with a courtesy notice.
• Courtesy Notice (CN) -A written warning, for violations that aren't as
minor in nature, which typically includes a 14-day compliance period to
permit the property or business owner time to resolve the issue.
• Notice of Violation (NOV) -A notice of violation is sent to the property
or business owner if they fail to comply with the previously referenced
notices or verbal warnings. The not ice will also come with a compliance
period, typically 14-days as with the courtesy notice. It isn't unusual for
a code enforcement officer to issue a second notice and compliance
period before escalating a matter to a citation.
• Administrative Citations (AC) -The escalation of the issues to
administrative citations is reserved for cases of non-compliance where
the responsible party fails to timely comply and generally fails to put
forth a good faith effort to resolve t he matter. Adm inistrative citations
start at $100 per violation, then increase to $200 and then $500 per
violation.
• Referral to City Attorney's Office -If administrative citations do not gain
the attention of the property or business owner, code enforcement
officers have the ability to refer matters to the City Attorney's Office for
additional escalation.
Exhibit 1
There was a clear pattern observed during the testing of case file selections for the prior
three fiscal years. Across each of the years, despite notable amounts of staff turnover, code
enforcement performance was very consistent with respect to the application of the
progressive citations protocols. The protocols had resulted in a standardized approach to
managing code violations, or at a minimum, based on the sample of case files examined. In
case file after case file selected and reviewed during the audit test work, it was noted that
officers consistently issued warnings, either a verbal or a written courtesy notice -or two.
Then only after sending a notice of violat ion and providing generous compliance periods,
typically lasting 14 days, did officers issue administrative citation{s).
An example of the progressive citation protocols being followed was noted in case file 2020-
1, which involved a boat being stored on a home's front lawn, in violation of city regulations.
This case was opened in Oct. 2020 and resolved in Sept. 2021. The case started with a
courtesy notice and eventually progressed on to one administrative citation and then a
second. The property owner appealed the citations. The first citation was upheld and the
second was set aside for 30 days to give t he property owner time to comply. The property
owner was unable to do so, so the second administrative citation was reinstated. The
property owner had to pay $300 in fines and eventually moved the boat to an off-site
storage location. While the case results in fines, the code enforcement officer and also the
administrative hearing official, provided opportunities to avoid fines.
Case file 2020-2 provides a second example of the use of the progressive citation protocols.
In this instance, the code enforcement officer was assigned to address violations at a house
with severely overgrown vegetation and accumulated junk throughout the yard. Th e officer
worked closely with the property owner as was evidenced in the 41 different activities
recorded in the case files. Those activities included 19 site visits and five phone calls, which
culminated in a positive result for t he property owner, the reporting party and the city, with
no administrative citations applied because the property owner saw the project through to
completion. The code enforcement officer followed the established process and the
property owner ultimately complied voluntarily. The code enforcement officer had
opportunities to progress to administrative citations. While that may have led to a quicker
resolut ion, the officer exercised discretion, which is permitted in the guidelines. By the time
the yard was cleared of storage and severe overgrowth, the reporting party was aiding the
property owner with the clean-up.
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Exhibit 1
The Case Prio ritization and Process Guide also includes a system through which complaints
or reports of non-compliance are categorized and prioritized. With those steps, comes a
standard timeline for when certain categories of case files are expected to be addressed
(see Case Prioritization and Process Guide, pages 23-24). The purpose of this process is to
prioritize cases and to assign code enforcement staff to the cases (complaints) known to
cause the greatest impact to either the condition of a property, to a business or posing a
threat to the residents of the city. The city developed and published categories 1-4 in the
Case Prioritization and Process Guide and assigned target response dates, referred to as
goals, by when each category of complaint is expected to be remedied. ·
Prioritizations and timelines
Violation Description of City's initial Crty's target for category Types of violations
(priority) conditions response resolution
Immediate threat, Severely damaged
unsafe and structure, Within one Within 3 business 1 hazardous unsecured and/or business day of days of complaint.
conditions abandoned complaint
structures
Inoperable or
Nuisance and abandoned Within t hree Within 30 business 2 blight-causing vehicles, outdoor business days days storage, trash and
debris
Vegetation/yard, Within five Within 50 business 3 Miscellaneous lighting, business business days days license
Permanent
encroachments on Within ten Within 90-180 4 Permit requiring right-of-way, business days business days construction,
grading
In addition to the Case Prioritization and Process Guide, the city's municipal code provides
the underlying authority for the enforcement activities undertaken by code enforcement
officers.
Collectively the city's municipal code and the Case Prioritization and Process Guide provide
considerable policy and procedure support for code enforcement activities. The only area
where the auditor was unable to identify any support is in t he area of training. It's
recommended that the division creat e a code enforcement procedure manual to serve as
both a resource for day-to-day .activit ies and as a training document for new staff.
Recommendation 1: The Code Enforcement Division should immediately develop and
implement a code enforcement procedure manual to serve as both a training and
operations resource for staff.
Exhibit 1
OBJECTIVE 2 : ADHEREN CE TO GUIDELINES
To evaluate whether a selection of case files from the most recent three-year period
adheres to applicable guidelines
The procedures the auditor performed to test whether code enforcement activities adhered
to program guidelines involved examining selected case files from fiscal years 2018-19,
2019-20 and 2020-21. The selections, case files stored within EnerGov, the system the city
uses to track code enforcement activities, were evaluated for adherence to code
enforcement guidelines such as those in the Case Prioritization and Process Guide.
The initial audit selections were made using a statistically random sample. Using that
process, a sample size of 15 was made from each of the three fiscal years. During the course
of testing the randomly selected case files it was noted that the random sample was not
representative of the population of case files in that it lacked differentiation in the types,
known as sub-groups in EnerGov. Below are a number of the common categories cited in
code enforcement case types:
Examples of categories found in EnerGov
• Unpermitted construction
• Illegal construction
• Short term vacation rentals
• Trash/debris
• Noise (Construction times)
• Outdoor storage
• Right-of-way encroachments
• Vegetation {overgrowth)
• Zoning violations
To ensure the audit tested a representative sam pie of case files from EnerGov, a batch of 15
haphazard sample selections was made from each fiscal year. A haphazard selection is a
non-statistical sample that is influenced by auditor judgment. In this case, it enabled the
auditor to make a representative sample selection without making an excessive amount of
selections that would have been required if solely relying on random statistical sampling.
The chart below that shows, by fiscal year, the total number of case files subject to audit
procedures. It also shows the two types of samples that were made, and the number of
selections made using each sam piing technique. Audit sample sizes are a factor of the
number of data entries being tested, the goals of testing and the assessed level of risk that
the selected samples will not be in compliance with stated standards. In the case of testing
code enforcement case files, while there were a moderate number of data entries, the initial
test results of the random samples resulted in a very low assessed risk level, resulting in the
sample sizes noted below.
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Item #8 Carf st:Jftd.7
Exhibit 1
Code enforcement cases
Fiscal year Total case files Random sample Haphazard sample
20~8-19 941 15 15
2019-20 738 15 15
2020-21 : 855 15 15
Testing t he selected case files found consistent results: staff consistently used the
progressive citation protocols in how they managed cases and followed the standard
guidelines in carrying out their duties. The auditor found consistency in how they
progressed through the different notifications, with a warning, then a courtesy notice, a first
notice of violation, a second and, finally, and only when needed, administrative citations. A
designated training officer would provide for greater consistency.
Recommendation 2: Management should identify a code enforcement officer to serve as a
training coordinator for the division. Identifying such a role will help ensure t he code
enforcement officers continue to maintain their uniform approach to addressing complaints
and serving the city's residents and businesses. The uniformity will result in part from having
a single point of contact for training and from the implementation of a code enforcement
procedure manual, as noted in Recommendation 1.
OBJECTIVE 3 : METRICS & REPORTING
To assess whether the city uses case data and metrics to provide meaningful intormation
to management.
The primary methods the auditor used to assess how the city uses its case file data in
EnerGov were interviews of staff and a review of EnerGov's reporting functionality. Initially,
interviews were focused on the code enforcement program staff but were expanded to IT
Department personnel to assess EnerGov's functionality and the process the city uses to
manage the enterprise system.
On Aug. 20, 2021 the city's internal auditor met with Code Enforcement Program Manager
Dave Thielker, to discuss the use of data and the tracking of metrics. During the meeting Mr.
Thielker said code enforcement data was not being routinely supplied to different levels of
management. He attributed that in part to the limitations of the reporting features of the
EnerGov system. Mr. Thielker noted that EnerGov does have a number of ready-made
reports that can be generated. However, their use and impact are limited in part because
the data requires heavy formatting once it is exported, and, in some cases, needs to be
merged with other reports to enable effective analysis. This is in part because the standard
system-generated reports provide very segmented data. Ideally, code enforcement staff
would have access to comprehensive reports that are ready made and do not require labor-
intensive filtering or formatting before they can be shared with decision makers.
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Item #8 cmslijcf
Exhibit 1
When questions then focused on t he EnerGov system and its functionality, Mr. Thielker
indicated he was actively working with the Information Technology Department to improve
upon the reports in EnerGov. The goal is to develop improved performance management
t ools and reports to track code enforcement trends that would provide actionable data to
management.
These steps address the focal point of the third audit objective directly. The city has
significant amounts of dat a at its disposal. Seeing certain improvements through to
completion would enable management to regularly obtain reliable and actionable data,
maximize existing staffing resources and enable the program manager to further develop
those staff, all significant benefits for the city.
At the time of the audit fieldwork, the Code Enforcement Division had several open requests
to t he Information Technology Department for improvements to EnerGov, as shown in the
table below:
Open and active ServiceNow tickets as of Oct. 2021
Priority Filed Request
Report for a time period on: cases opened/ closed,
2-High 1/21/2021 number of inspect ions completed, number of re-
inspections completed, number of notices issued,
number of citations issued.
,.
Create report showing which sections of code are
3-Moderate 1/21/2021 currently in the database, their violation descriptions,
the corrective courses of action,
Create a report by code officer assigned on cases due
3-Moderate 1/26/2021 for re-inspection and their dates. Prefer to be able to
list the case number, case category, sub type, last
i .
action completed and re-inspection date
The auditor met with Paul Waldron, Information Technology Project Manager, to gain
insight into how these requests for improvements were ma naged. This included who
received and was assigned to address the service tickets, how the priorities were managed
within IT, barriers, or delays that a ticket may encounter and communications with the
requestor. Service requests are filed by staff from the Code Enforcement Division with an
initial priority rating and tracked by IT Department staff in a system called ServiceNow.
These inquiries revealed opportunities for improvement in how the Information Technology
Department and Community Development Division communicate about such request s for
improvements in software applications.
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Exhibit 1
Mr. Thielker said he met with business systems specialist staff in Information Technology on
a bi-monthly basis to discuss code enforcement tickets. During the recurring meetings, they
would discuss pertinent details of any open tickets including their current status, any
cha llenges encountered and their prioritization. Paul Waldron confirmed this process but
emphasized that the business systems specialists also must balance competing priorities
from different work groups with the available resources that serve t he entire city, including
significant IT projects.
So, while t he staff member making the request may have indicated a certain priorit y level -
in this case, t he above referenced improvements to EnerGov were of a high or moderate
priority to the Code Enforcement Division -the requests were t hen reassessed from a city-
wide perspective by the business syst ems specialists and the IT Department.
Mr. Waldron noted that in addition to Code Enforcement and other divisions in Community
Development each meeting with t he business systems specialists, the Community
Development Department overall had a management representative that he met with
routinely to discuss department-wide priorities.
Ultimately there were three priority sett ing steps in this process. The first instance was upon
entry of t he service ticket into the system used to track such requests, then when it was
adjusted, at times, as the result of meetings between the Code Enforcement Division and
business systems specialist staff due to any of several reasons. Those reasons included the
available resources or the feasibility of a request. Then, t he third instance was when the
department overall communicated to the IT staff any departmental priorities that tied into
city initiatives.
The communication among stakeholders and the IT Department is critical and the city had at
least three points where priorities were evaluated. That is a healthy level of communication
for such a process. However, a common risk with business communications is ensuring they
are coordinated and well communicated to all stakeholder groups.
The auditor discovered through discussions with Mr. Thielker that he was unaware of the
departmental priorities being overlaid upon his division's requests. This may very well have
contributed to t he delay in addressing certain of the division level priorities. At a minimum,
it caused uncertainty from the division's perspective.
Improvements to EnerGov's reports are needed so that case file data and metrics can help
better inform management decision-making. But although requests for these improvements
have been entered, they aren't moving to completion for one reason or another.
It should be noted that, along with other priority projects, there were two large scale
information technology projects implemented or ongoing du ring the course of the year
when the IT department would have been addressing the service requests listed above.
Undoubtedly, this greatly impacted resources.
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Item #8 C~ss'jcf
Exhibit 1
Also during the course of the audit, Community Development managers coordinated w ith
their different divisions and the IT Department to implement a streamlined process by
which priorities are determined and communicated. Taking these steps has greatly
improved communication and is ensuring that all stakeholders are present at least during
the-department's prioritization process.
Recommendation 3: To evaluate the performance of its code enforcement officers and to
maximize the use of code enforcement data residing in EnerGov, the Code Enforcement
Division must identify and monitor key metrics. Once specific metrics are identified, code
enforcement staff should coordinate with the IT Department to determine how to best
extract this information from EnerGov. If EnerGov is unable to support this activity the city
should prioritize the identification {or procurement) of a software application that can.
The list below offers a sample of key metrics the code enforcement program could use to
monitor the performance of staff, to identify trends of non-compliance, and assign staff to
achieve the greatest impact, among other potential benefits.
Key metrics
• Total cases by all groups
• Total cases by all subgroups
• Cases opened by code officer
• Cases closed by code officer
• Reinspections completed by code officer
• Courtesy notices issued by code officer
• Notices of violation by code officer
• Administrative citations issued by code officer
• Certificates of non-compliance issued
• Stop work notices by officer
While there are numerous data points already entered in EnerGov by code enforcement
staff, new data points may need to be added to enable the tracking of key metrics. If this is
the case, this will require close coordination between the IT Department and code
enforcement staff.
There are other potential software solutions than EnerGov. The city has the use of Tableau,
a business intelligence application that is well-suited for pulling data together from multiple
sources and providing detailed reports. There also is a system known as GoGov, which
appears to have considerable upside in terms of the efficiency in how code cases could be
managed and in the suite of standard reports that are available.
Recommendation 4: In the context of the EnerGov enterprise system, it's recommended
that the IT and Community Development Departments coordinate a recurring meeting {bi-
monthly, monthly, etc.) that brings together all divisions within Community Development to
discuss and prioritize ServiceNow requests that originated during the period with IT
representatives. Such a meeting will also serve as an opportunity for IT staff to openly
discuss with the requestor, and management, any requests that require referral to Tyler
Assist. Tyler-Assist is a third-party contractor that consult s with the city regarding the
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Item #8 clttsBrld7
Exhibit 1
functionality of EnerGov. If Tyler-Assist is unable to find a solution, then IT staff should
discuss remaining options with the party that originated the service request. The goal of this
process is to ensure such requests are activity worked until resolved or until all options are
exhausted. A secondary goal is to ensure all parties receive the same information and stay
on the same page, throughout the process
SUMMARY OF RECOMMENDATIONS
Recommendation 1: The Code Enforcement Division should immediately begin the
implementation of a code enforcement procedure manual to serve as both a training and
operations resource for staff. Existing policies and procedures, such as those established by
the city's municipal code and the Case Prioritization and Process Guide provide the
foundation for the code enforcement program and the framework within which staff
operate. While there are other topical procedure documents available, they do not provide
the breadth of information and deta ii necessary to serve as a resource or to support code
enforcement operations.
Management response: The Community Development Department concurs with this
recommendation and anticipates that a day-to-day operations guide will be developed and
implemented within the next 12 months.
Recommendation 2: Management should Identify a code enforcement officer t o serve as a
training coordinator for the division. Identifying such a role will help ensure the code
enforcement officers continue to maintain their uniform approach to addressing complaints
and serving the city's residents. The uniformity will result in part from having a single point
of contact for training and from the implementation of a code enforcement procedure
manual as noted in recommendation #1.
Management response: Community Development concurs with this recommendation and
anticipates that the Senior Code Enforcement Officer will act as the Code Enforcement
Division training coordinator. At the time of the audit, the Senior Code Enforcement Officer
position was assisting the Housing & Homeless Services Department while it fills vacancies.
This position has since returned to us and we are current ly in the recruitment process.
Recommendation 3: To evaluate the performance of its code enforcement officers and to
maximize the use of code enforcement data residing in EnerGov the Code Enforcement
Division must identify and monitor key metrics. Once specific metrics are identified, code
enforcement staff should coordinate with the Information Technology Department to
determine how to best extract t his information from EnerGov. If EnerGov is unable to
support this activity the city should prioritize the identification or procurement of a software
application that can.
Management response: Community Development concurs with this recommendation with
a modification. The Code Enforcement Case Prioritization and Process Guide currently
establishes caseload levels and processing timeline targets, categorized by violation type as
reflected in Sections 6 and 7. The case processing tasks that should be used in EnerGov to
track whether the Code Enforcement Division staff are meeting the targets are listed in
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Item #8 Ca1isBftd7
Exhibit 1
Section 10. Therefore, Community Development finds that the key metrics needed to track
and manage the processing of casework have already been identified. However, Community
Development agrees that there are other metrics outside of case management that would
be important information to evaluate, such as number of cases per council district, areas of
high concentration of code cases ("hot spots"), and code case types by geographic area.
Community Development agrees to develop a list of additional metrics that help track
enforcement trends, which could be used to inform the public and help the department
develop programs and processes that can address identified issues.
Community Development recognizes, and agrees with the Auditor, that EnerGov is not
currently structured to track all of the tasks listed in Section 10. Furthermore, while a lot of
the data that could be used to track enforcement trends is currently tracked in EnerGov, the
system is not configured for the department to easily extract from EnerGov the data to
generate reports and maps. Community Development agrees to work with IT to either
update EnerGov to modify the system to generate these metrics or to contract with an
outside vendor who specializes in code enforcement tracking software (i.e., GoGov). The
goal is to ultimately have a tracking system in which weekly case processing reports and
maps are automatically generated so management can quickly and easily determine
whether processing targets are being met and how resources can be best deployed based
on enforcement trends. See response to Recommendation 4, below, for completion
timeline.
Recommendation 4: The auditor recommends that the IT and Community Development
Departments coordinate a recurring meeting (bi-monthly, monthly, etc.) that brings
together all divisions within Community Development to discuss and prioritize Service Now
requests that originated during the period related to the EnerGov system. Such a meeting
will also serve as an opportunity for IT staff to openly discuss with the requestor, and
management, any requests that require referral to Tyler-Assist. Tyler-Assist is a third-party
contractor that consults with the city regarding the functionality of EnerGov. If Tyler-Assist is
unable to find a solution, then IT staff should discuss remaining options with the party that
originated the request. The goal of this process is to ensure ServiceNow requests are activity
worked on until resolved or until all options are exhausted. A secondary goal is to ensure all
parties receive the same information and stay on the same page, throughout the process.
Management response: Community Development concurs with this recommendation and
will start holding combined recurring meetings with IT on a bi-monthly basis in January
2022. Time lines to complete ServiceNow ticket requests will be dependent upon
coordination with Information Technology, given that department's capacity and resource
constraints.
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City of Carlsbad
Status Update of Open Internal Audit Recommendations
Audit Engagement: 2021-01 City Credit Card Program Audit
City Council Date: March 22, 2022
No. Recommendation
1 The Finance Department should communicate
guidance citywide about the taxability of employee
appreciation related items and gifts to ensure that
city departments give and report them in compliance
with the Internal Revenue Code.
2 To ensure that lodging purchases made during city
business-related travel are appropriate, the Finance
Department should update its travel guidelines and
procedures to adopt either the state or the federal
government's annual lodging rates by geographic
location, and require employees to submit written
justification when rates must exceed these
established maximums.
Management Response
The Finance Department will send an annual
citywide email reminding all employees and
managers of the Internal Revenue Code, with
specific examples to ensure compliance, and setup
a process whereby departments report any
renumeration to employees.
The Finance Department will update the travel
guidelines and procedures to include a maximum
reimbursement based on the Federal Travel
Regulations, which may be overridden with
appropriate justification and approval.
Departmenf(s) Deadline Status
Finance 6/30/2022 In Progress -The Finance
Department is evaluating
IRS guidance concerning
fringe benefits and de
minimis treatement of
gifts. Once they conclude
findings, an annual
communication will follow.
Finance 6/30/2022 In Progress -The Finance
Department is evaluating
available lodging rates (e.g.
the federal GSA rate) and
an update to the city's
travel policy. At the
conclusion, guidance will
be communicated.
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Code Enforcement Audit Report &
Open Audit Recommendations Status
Update
Laura Rocha, Deputy City Manager,
Administrative Services
Robert Threatt, Internal Audit Manager
Administrative Services
March 22, 2022
PROPOSED ACTION
Receive the code enforcement internal audit
report and a status update regarding open
audit recommendations from an audit of the
city’s credit card program.
ITEM 8: CODE ENFORCEMENT AUDIT
TODAY’S PRESENTATION
•Identify audit objectives
•Discuss audit methodology
•Present audit results, audit recommendations and
management’s response to each
•Status update regarding open audit
recommendations
•Questions?
ITEM 8: CODE ENFORCEMENT AUDIT
CODE ENFORCEMENT PROGRAM AUDIT
AUDIT OBJECTIVES
•To assess whether the division has reliable policies and
procedures to support effective code enforcement.
•To evaluate whether a selection of case files from the most
recent three-year period adhere to applicable guidelines.
•To assess whether the city uses case data and metrics to
provide meaningful information to management.
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT METHODOLOGY
•Interviewed Code Enforcement and IT Department staff
•Direct observations
•Analyzed code enforcement case file data
•Reviewed city policies and procedures
•Reviewed new technologies
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 1: To assess whether the division has reliable
policies and procedures to support effective code
enforcement.
•Well supported by the city’s Case Prioritization and
Process Guide and Carlsbad Municipal Code
•Example: Progressive citation protocols
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 1 continued
•Audit Recommendation 1: Implement code
enforcement procedure manual to serve as a
training resource
•Management Response 1: Concurred and anticipates
completing within a year
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 2: To evaluate whether a selection of case files
from the most recent three-year period adhere to
applicable guidelines.
•Tested case file data from FY19, FY20 and FY21
which are found in EnerGov, a city enterprise system
•Consistent application of guidelines noted
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 2 continued
•Audit Recommendation 2: Management should
identify a senior code enforcement officer to
serve as a training officer to ensure the
continuation of excellent standardized service
•Management Response 2: Concurs and expects
the Senior Code Enforcement Officer to fill this
role
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 3: To assess whether the city uses code enforcement
case file data and metrics to provide meaningful information to
management.
•Testing identified several factors impacting the use of data
•EnerGov reporting limitations
•Multiple priority setting meetings
•Limited resources
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 3 continued
•Audit Recommendation 3: The division should
leverage the existing code enforcement data by
identifying and monitoring key metrics, which will
allow them to generate value added reports for
use by management and other decision-makers.
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 3 continued
•Management Response 3: Concurs and indicated
they will work with the IT Department to update
EnerGov or identify a resource that can deliver
the necessary reports.
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 3 continued
•Audit Recommendation 4:
•IT and Community Development Departments
streamline meeting where ServiceNow tickets are
reviewed, and priorities set
•Ensure all divisions within Community Development
are represented
ITEM 8: CODE ENFORCEMENT AUDIT
AUDIT RESULTS & FINDINGS
Objective 3 continued:
•Management Response 4:
•Concurs with this recommendation and has already
established a single recurring meeting to review the
groups ServiceNow tickets
•All divisions represented to ensure awareness
regarding departmental priorities and available
resources
ITEM 8: CODE ENFORCEMENT AUDIT
Open Audit Recommendations
City’s Credit Card Program Audit, February 2021
•Taxability of employee appreciation awards (e.g.,
small gifts and gift cards)
•To ensure that lodging purchases made during city
business-related travel are appropriate
ITEM 8: CODE ENFORCEMENT AUDIT
Open Audit Recommendations
Taxability of employee appreciation awards (e.g.,
small gifts and gift cards).
•In progress
•Completion due by 6/30/2022
•The Finance Department is evaluating IRS
guidance concerning the fringe benefits of small
gifts. Once they conclude findings, an annual
communication will follow.
ITEM 8: CODE ENFORCEMENT AUDIT
Open Audit Recommendations
To ensure that lodging purchases made during
city business‐related travel are appropriate
•In progress
•Completion due by 6/30/2022
•The Finance Department is evaluating the
available lodging rates (e.g., federal GSA rate)
and an update to the travel policy.
ITEM 8: CODE ENFORCEMENT AUDIT
Questions?
Audit Objectives Audit Procedures Audit Recommendations
ITEM 8: CODE ENFORCEMENT AUDIT