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Response synthesis and audit

Responses to report 2602

Board and Auditor-Controller accept many gaps but differ on organizational placement, GAGAS applicability and oversight. They promise selected charters, safeguards, risk planning and disclosures, sometimes with different committees or dates. Default download opens the five-page Board response; Auditor-Controller audits open its separate eight-page original.

Response by Contra Costa County Board of Supervisors; Contra Costa County Auditor-Controller

49

Addressed

8

Partially addressed

0

Not addressed

0

Unclear

County's stated disposition

These categories reflect the County's response to each recommendation, separate from this audit's assessment.

1

Implemented

15

Will be implemented

3

Requires further analysis

5

Will not be implemented

0

Unclear

How to read this audit

Editorial engagement review only, not a legal ruling or verification of factual claims, forecast accuracy or completed implementation. Finding scores assess the response’s stated position, reasons and traceability, not agreement with the jury. Each audit selects its unchanged original and physical PDF page. Dates are included only when supplied by the document; undated responses are not assigned inferred dates. Recommendation deadlines are not copied into agency commitments unless independently stated in the answer. Separate originals remain separate; default download opens the Board response.

Commitments

Actions stated in the response

These are commitments extracted from the County's response. They describe what the response says will happen; they do not verify that implementation occurred.

23

Extracted commitments

11

Definite or bounded timing

2

Conditional timing

10

No timeframe

BOS2602-R2 · No timeframe stated

Identify and mitigate potential audit conflicts and self-review threats while retaining IAD within the Auditor-Controller.

No target date stated

BOS2602-R4 · No timeframe stated

Require a formal IIA Standard 7.1 independence safeguards framework.

No target date stated

BOS2602-R5 · Exact date

Require annual disclosure of independence threats and safeguards to Finance Committee.

2027-01-01

BOS2602-R6 · Exact date

Require annual Finance Committee review of IAD independence and safeguards.

2027-01-01

BOS2602-R8 · No timeframe stated

Consolidate internal and external audit oversight within Finance Committee, rather than create a separate Audit Committee.

No target date stated

BOS2602-R11 · No timeframe stated

Implement the recommendation to review and approve the IAD charter; no separate implementation timetable supplied.

No target date stated

BOS2602-R15 · No timeframe stated

Implement the recommendation to include risk-assessment methodology, key risks and prioritization rationale in audit plans; no separate timetable supplied.

No target date stated

BOS2602-R16 · No timeframe stated

Implement the recommendation to document risk-to-engagement linkage and high-risk inclusion/exclusion; no separate timetable supplied.

No target date stated

BOS2602-R18 · No timeframe stated

Implement the recommendation for prospective Board approval of the risk-based annual plan; no separate completion date stated.

No target date stated

AC2602-R1 · No timeframe stated

Direct IAD to comply with IIA, excluding GAGAS, and revise manual references accordingly.

No target date stated

AC2602-R3 · Bounded timeframe

Analyze which ACFR assignments can be handled by non-IAD personnel.

During the September–December 2026 ACFR process.

AC2602-R3 · Conditional timing

Consider reassigning certain ACFR assignments to other divisions, subject to analysis and staffing constraints.

Beginning with the fiscal year ended June 30, 2027 ACFR process, where reassignment is appropriate.

AC2602-R3 · No timeframe stated

Assess ACFR assignments for independence impairments and document safeguards for IOC.

No target date stated

AC2602-R4 · Exact date

Develop and use an IIA Standard 7.1 independence safeguards framework.

2027-01-01

AC2602-R5 · Exact date

Communicate identified independence threats and safeguards to IOC.

2027-01-01

AC2602-R10 · Exact date

Develop an IAD charter.

2027-01-01

AC2602-R12 · Exact date

Implement documented risk-assessment methodology aligned with IIA.

2027-04-01

AC2602-R13 · Exact date

Revise manual and administrative bulletin for documented risk-based planning, submitting bulletin updates for County Administrator concurrence.

2027-01-01

AC2602-R14 · Exact date

Require documented Board, oversight-committee and senior-leadership input in annual risk assessment.

2027-01-01

AC2602-R17 · Bounded timeframe

Carry out the directed shift to fiscal-year audit planning.

Beginning with FY2027–28; response claims the direction has already been issued.

AC2602-R19 · Bounded timeframe

Direct adoption of an ongoing quality assurance and improvement program as part of IIA compliance.

IIA compliance anticipated by December 1, 2027, not a guaranteed completion date.

AC2602-R21 · No timeframe stated

Periodically distribute audit reports and management responses to Finance Committee.

No target date stated

AC2602-R22 · Conditional timing

Post charter and annual plan after Finance Committee approval and annually post completed IIA-compliant reports.

Charter once established and approved; plan when approved; completed reports annually.

Item-by-item review

Findings and recommendations

Assessments describe whether the response engages each cited item. Finding scores separately describe statutory-elements completeness under California Penal Code § 933.05(a) and public usefulness. They do not independently verify the response or constitute a legal conclusion.

Showing 57 of 57 items

finding · BOS2602-F1

F1: California Government Code Section 1236 requires that employees conducting audits for public agencies follow standards of the Institute of Internal Auditors (IIA) or the U.S.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F1; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F1; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F2

F2: The Internal Audit Division’s (IAD) Policies and Procedures Manual, Section 2.1, directs that it “follow applicable professional auditing standards in conducting our audits,” and defines which IIA or GAGAS standards are applicable to specific audit situations.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F2; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F2; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F3

F3: The IAD’s placement within the Auditor-Controller's organizational structure creates an organizational independence threat under GAGAS §§3.27–3.58 and IIA Standard 7.1.

Audit: Partially addressed

Response says

Says internal audit is an inherent core responsibility of an auditor-controller’s office.

Audit analysis

Position is implied rather than explicit; institutional responsibility does not squarely explain the asserted independence threat or its safeguards. No supporting record is identified.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

4/10

2/4

Statutory elements

Stated position
1/2
Applicable disagreement elements
1/2

2/6

Public usefulness

Coverage
1/2
Reason specificity
1/2
Support traceability
0/2

Position is implied rather than explicit; institutional responsibility does not squarely explain the asserted independence threat or its safeguards. No supporting record is identified.

Scoring confidence: high

finding · BOS2602-F4

F4: The Internal Operation Committee’s (IOC) failure to exercise charter approval, audit plan pre-approval, and direct report receipt as required by IIA Standards 6.1, 6.2, 8.1, 9.4, 11.3 and Principle 8 leaves this organizational independence threat unmitigated, constituting an independence impairment in fact and appearance under GAGAS §3.56.

Audit: Partially addressed

Response says

Partially disagrees, citing annual IOC review of prior activities and approval of the next audit plan.

Audit analysis

Identifies plan approval as disputed and gives a concrete oversight account, but does not resolve charter approval, direct report receipt, or the distinction between impairment in fact and appearance.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

7/10

3/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
1/2

4/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
1/2

Identifies plan approval as disputed and gives a concrete oversight account, but does not resolve charter approval, direct report receipt, or the distinction between impairment in fact and appearance.

Scoring confidence: high

finding · BOS2602-F9

F9: The IOC of the Board of Supervisors (Board), consisting of two supervisors, is responsible for functional oversight of the IAD.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F9; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F9; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F10

F10: The IOC holds one meeting per year at which the IAD presents its prior year activities and upcoming audit plan.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F10; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F10; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F11

F11: No documentation was found of additional meetings, interim audit reporting, or direct communication between the IAD and the IOC between annual plan presentations.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F11; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F11; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F12

F12: A single annual meeting does not satisfy the ongoing communication, timely reporting, and report distribution obligations imposed by IIA Principle 8, IIA Standards 8.1 and 15.1, GAGAS §§6.06 and 9.56, each of which requires engagement throughout the year.

Audit: Addressed

Response says

Disagrees: the cited standards set no minimum meeting count; says current reporting and Single Audit and Measure X presentations supply oversight.

Audit analysis

Gives a finding-specific standards interpretation and identifies other audit presentations. Engagement does not establish that the interpretation or current practice satisfies professional standards.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Gives a finding-specific standards interpretation and identifies other audit presentations. Engagement does not establish that the interpretation or current practice satisfies professional standards.

Scoring confidence: high

finding · BOS2602-F13

F13: The Board’s Finance Committee, consisting of two supervisors, is responsible for functional oversight of external audit activity.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F13; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F13; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F14

F14: Neither the IOC nor the Finance Committee requires financial or audit expertise as a condition of membership, inconsistent with the Government Finance Officers Association's (GFOA’s) Audit Committees best practice and IIA guidance on audit committee effectiveness, both of which identify such expertise as a threshold condition for effective audit oversight.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F14; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F14; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F15

F15: Neither the IOC nor the Finance Committee includes public members independent of County management as a condition of membership.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F15; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F15; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F20

F20: The IOC is not provided with information to determine whether proposed annual audit plans address the County’s highest-risk areas, as required by IIA Principle 8, IIA Standards 8.1 and 9.4.

Audit: Addressed

Response says

Partially disagrees: IOC reviews activities and approves plans; acknowledges highest-risk discussion could be more explicit.

Audit analysis

Separates existing oversight from the admitted risk-discussion gap with concrete assertions; no particular plan or meeting record is identified.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
1/2

Separates existing oversight from the admitted risk-discussion gap with concrete assertions; no particular plan or meeting record is identified.

Scoring confidence: high

finding · BOS2602-F21

F21: IAD implements its annual audit plan without prior Board input or approval, eliminating the Board's opportunity to influence audit priorities before audit work has begun, inconsistent with IIA Principle 8 and IIA Standards 8.1 and 9.4, which collectively require that the board review and approve the risk-based audit plan before implementation.

Audit: Addressed

Response says

Partially disagrees: IOC approves the next plan, followed by separate Board review and approval.

Audit analysis

Directly disputes lack of prior input/approval through an asserted sequence; no dated plan or approval record is supplied.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
1/2

Directly disputes lack of prior input/approval through an asserted sequence; no dated plan or approval record is supplied.

Scoring confidence: high

finding · BOS2602-F22

F22: Findings F4, F10, F11, F12, F18, F19, F20, F21, and F26 collectively establish that the IOC and Board do not fulfill the audit oversight responsibilities required by IIA Principle 8 and Standards 8.1 and 15.1, and GAGAS §§3.46 and 6.06 — including charter approval, prospective audit plan approval, ongoing engagement, risk-based planning oversight, and direct receipt of audit reports.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F22; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F22; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F23

F23: The IAD’s schedule is based on a calendar year, inconsistent with the fiscal year that governs the County’s overall planning, budgeting, and operational processes.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F23; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F23; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · BOS2602-F28

F28: The deficiencies documented in Findings F3 through F8, F16 through F21, F24, F25, F26, and F27 collectively establish that the IAD does not operate in conformance with the IIA and GAGAS standards required by California Government Code Section 1236 and directed by its own Policies and Procedures Manual.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F28; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F28; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

recommendation · BOS2602-R2

R2: By January 1, 2027, the Board of Supervisors should consider evaluating alternative organizational reporting structures for IAD that reduce organizational and self-review threats, including placement outside the Auditor-Controller’s span of control.

County: Requires further analysisAudit: Addressed

Response says

Requires further analysis; IAD will remain within the Auditor-Controller, while the County will identify and mitigate conflicts and self-review threats.

Audit analysis

Explains rejection of relocation while proposing safeguards. No analysis scope or completion date is given.

Extracted commitments

Identify and mitigate potential audit conflicts and self-review threats while retaining IAD within the Auditor-Controller.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R4

R4: By January 1, 2027, the Board of Supervisors should consider requiring the Auditor-Controller to develop, document, and implement a formal independence safeguards framework consistent with GAGAS §§3.40–3.58 and IIA Standards 7.1.

County: Requires further analysisAudit: Partially addressed

Response says

Requires further analysis; Board will require an independence safeguards framework under IIA Standard 7.1.

Audit analysis

Does not expressly address GAGAS, recusal, independent review, or segregation of ACFR duties. No agency completion date is stated.

Extracted commitments

Require a formal IIA Standard 7.1 independence safeguards framework.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R5

R5: By January 1, 2027, the Board of Supervisors should consider requiring the Auditor-Controller to annually disclose to the IOC, or, if established, the Audit Committee, all identified independence threats and the safeguards implemented to mitigate them, consistent with GAGAS §3.59 and IIA Standard 7.1.

County: Will be implementedAudit: Addressed

Response says

Will require annual disclosure of independence threats and safeguards to the Finance Committee by January 1, 2027.

Audit analysis

Concrete commitment changes the recipient from IOC/proposed Audit Committee to Finance Committee and cites IIA rather than GAGAS. Preserve that scope.

Extracted commitments

Require annual disclosure of independence threats and safeguards to Finance Committee.

Responsible party
Contra Costa County Board of Supervisors
Timing
2027-01-01 · Exact date

recommendation · BOS2602-R6

R6: By January 1, 2027, the Board of Supervisors should consider requiring an annual review by the IOC of IAD’s organizational independence, documented safeguards, and any identified independence impairments to ensure continued compliance with IIA Standard 7.1 and GAGAS §§3.40–3.58.

County: Will be implementedAudit: Addressed

Response says

Will require annual Finance Committee review of independence, safeguards and impairments by January 1, 2027.

Audit analysis

Explicit future action substitutes Finance Committee for IOC; implementation remains an agency promise.

Extracted commitments

Require annual Finance Committee review of IAD independence and safeguards.

Responsible party
Contra Costa County Board of Supervisors
Timing
2027-01-01 · Exact date

recommendation · BOS2602-R7

R7: By January 1, 2027, the Board of Supervisors should consider requiring the IAD to report to the IOC no less than quarterly on the status of audit engagements, demonstrating alignment with the approved audit plan and documented risk assessment, consistent with IIA Principle 8, Standards 8.1 and 11.3, and GAGAS Chapter 6.

County: Will not be implementedAudit: Addressed

Response says

Declines quarterly IOC reporting, arguing standards impose no specific minimum number of engagements; Finance Committee will reorganize oversight.

Audit analysis

Explains refusal of the requested frequency; does not promise quarterly reporting under a different committee.

recommendation · BOS2602-R8

R8: By January 1, 2027, the Board of Supervisors should consider consolidating the internal and external auditor oversight as currently performed by the IOC and Finance Committee into a single Audit Committee.

County: Will not be implementedAudit: Addressed

Response says

Declines a new separate Audit Committee; will consolidate internal and external oversight within Finance Committee.

Audit analysis

Refusal and alternative institutional arrangement are explicit; consolidation is not the proposed new committee.

Extracted commitments

Consolidate internal and external audit oversight within Finance Committee, rather than create a separate Audit Committee.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R9

R9: By January 1, 2027, the Board of Supervisors should consider adopting IOC, or Audit Committee, membership that conforms to GFOA's Audit Committees best practice guidance by including a minimum of three members, at least one with expertise in governmental accounting principles, internal controls, and audit committee functions, and at least one public member independent of County management.

County: Will not be implementedAudit: Partially addressed

Response says

Declines proposed membership rules, citing collective expertise of committee members, County officials and external auditors.

Audit analysis

Explains expertise alternative but does not directly explain rejection of an independent public member or minimum membership count.

recommendation · BOS2602-R11

R11: By April 1, 2027, the Board of Supervisors should consider reviewing and approving the IAD's Audit Charter, consistent with IIA Standard 6.2, which requires that the governing body approve the internal audit charter and conduct periodic reviews to ensure it remains current.

County: Will be implementedAudit: Partially addressed

Response says

States that the recommendation will be implemented.

Audit analysis

Future acceptance is explicit, but gives no implementation steps or independently stated completion timetable. The recommendation’s date is not recorded as a separately confirmed agency promise.

Extracted commitments

Implement the recommendation to review and approve the IAD charter; no separate implementation timetable supplied.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R15

R15: By January 1, 2027, the Board of Supervisors should consider requiring that all audit plans presented for its approval include a summary of the risk assessment methodology, key risks identified, and the rationale used to prioritize audit engagements, consistent with IIA Standards 9.3 and 9.4 and GAGAS §§8.03–8.07.

County: Will be implementedAudit: Partially addressed

Response says

States that the recommendation will be implemented.

Audit analysis

Future acceptance is explicit, but gives no implementation steps or independently stated completion timetable. The recommendation’s date is not recorded as a separately confirmed agency promise.

Extracted commitments

Implement the recommendation to include risk-assessment methodology, key risks and prioritization rationale in audit plans; no separate timetable supplied.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R16

R16: By January 1, 2027, the Board of Supervisors should consider requiring the IAD to document the linkage between identified risks and the audit engagements included in the annual audit plan, including justification for inclusion or exclusion of high-risk areas.

County: Will be implementedAudit: Partially addressed

Response says

States that the recommendation will be implemented.

Audit analysis

Future acceptance is explicit, but gives no implementation steps or independently stated completion timetable. The recommendation’s date is not recorded as a separately confirmed agency promise.

Extracted commitments

Implement the recommendation to document risk-to-engagement linkage and high-risk inclusion/exclusion; no separate timetable supplied.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

recommendation · BOS2602-R18

R18: By December 1, 2026, the Board of Supervisors should consider directing the Auditor-Controller to submit the IAD's annual risk-based audit plan for Board approval before the fiscal year to which the plan applies begins.

County: Will be implementedAudit: Partially addressed

Response says

States that the recommendation will be implemented.

Audit analysis

Future acceptance is explicit, but gives no implementation steps or independently stated completion timetable. The recommendation’s date is not recorded as a separately confirmed agency promise.

Extracted commitments

Implement the recommendation for prospective Board approval of the risk-based annual plan; no separate completion date stated.

Responsible party
Contra Costa County Board of Supervisors
Timing
No timeframe stated

finding · AC2602-F1

F1: California Government Code Section 1236 requires that employees conducting audits for public agencies follow standards of the Institute of Internal Auditors (IIA) or the U.S.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F1; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F1; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F2

F2: The Internal Audit Division’s (IAD) Policies and Procedures Manual, Section 2.1, directs that it “follow applicable professional auditing standards in conducting our audits,” and defines which IIA or GAGAS standards are applicable to specific audit situations.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F2; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F2; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F3

F3: The IAD’s placement within the Auditor-Controller's organizational structure creates an organizational independence threat under GAGAS §§3.27–3.58 and IIA Standard 7.1.

Audit: Addressed

Response says

Disagrees, citing public-sector IIA guidance, the elected office’s independence from audited departments, and the claimed absence of GAGAS audits.

Audit analysis

Identifies the whole disputed independence proposition and reasons grounded in named standards/manual. This does not verify audit practices or independence.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies the whole disputed independence proposition and reasons grounded in named standards/manual. This does not verify audit practices or independence.

Scoring confidence: high

finding · AC2602-F4

F4: The Internal Operation Committee’s (IOC) failure to exercise charter approval, audit plan pre-approval, and direct report receipt as required by IIA Standards 6.1, 6.2, 8.1, 9.4, 11.3 and Principle 8 leaves this organizational independence threat unmitigated, constituting an independence impairment in fact and appearance under GAGAS §3.56.

Audit: Addressed

Response says

Partially disagrees: accepts an unmitigated threat in appearance under IIA but rejects a GAGAS impairment because IAD does not conduct GAGAS audits.

Audit analysis

Clearly distinguishes accepted and disputed scope and explains its standards interpretation using the Policies and Procedures Manual.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Clearly distinguishes accepted and disputed scope and explains its standards interpretation using the Policies and Procedures Manual.

Scoring confidence: high

finding · AC2602-F5

F5: IAD personnel participate in preparation of the County’s Annual Comprehensive Financial Report (ACFR), a management responsibility of the Auditor-Controller.

Audit: Addressed

Response says

Partially disagrees: accepts ACFR participation and management responsibility, but says staff are non-supervisory management under the Local 21 MOU.

Audit analysis

Identifies an inference the respondent disputes and cites a checkable employment agreement; the formal finding itself does not explicitly say staff are non-management.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

10/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

6/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
2/2

Identifies an inference the respondent disputes and cites a checkable employment agreement; the formal finding itself does not explicitly say staff are non-management.

Scoring confidence: high

finding · AC2602-F6

F6: The participation of IAD personnel in ACFR preparation and their subsequent auditing of those same financial reporting processes and controls represents a self-review threat as defined in GAGAS §§3.30 and 3.39.

Audit: Addressed

Response says

Disagrees because IAD does not perform GAGAS audits; says the manual is being revised to remove GAGAS references.

Audit analysis

Explains the standards objection but does not squarely discuss whether preparing and auditing the same processes creates a self-review threat under other applicable standards.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
1/2
Reason specificity
2/2
Support traceability
2/2

Explains the standards objection but does not squarely discuss whether preparing and auditing the same processes creates a self-review threat under other applicable standards.

Scoring confidence: high

finding · AC2602-F7

F7: The IAD has no documentation demonstrating that organizational and self-review independence threats have been formally identified, evaluated, or mitigated through safeguards, as required by GAGAS §§3.40–3.58 and IIA Standard 7.1.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F7; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F7; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F8

F8: The IAD has no documentation that the impact of IAD staff participation in ACFR preparation (a non-audit management activity) on independence and objectivity has been formally assessed and disclosed to the oversight body, as required by GAGAS §3.59 and IIA Standards 7.1 and 8.1.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F8; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F8; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F16

F16: The County’s IAD operates under Administrative Bulletin 212.1 (1975), which does not include all the elements of an Audit Charter required by IIA Standard 6.2.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F16; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F16; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F17

F17: The IAD presented its 2026 annual audit plan as “risk based.” However, the plan did not include a documented risk assessment as required by IIA Standards 9.3 and 9.4.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F17; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F17; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F18

F18: IAD has no documented risk-assessment methodology as required by IIA Standard 9.3.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F18; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F18; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F19

F19: IAD’s risk assessments do not include input from the Board or senior County executives, as required by IIA Standards 8.1 and 9.4.

Audit: Addressed

Response says

Partially disagrees: no formal proactive input process exists, but Board and executives have supplied requests incorporated into annual plans.

Audit analysis

Separates lack of formal process from asserted informal input; no particular request or annual plan is identified.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

9/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

5/6

Public usefulness

Coverage
2/2
Reason specificity
2/2
Support traceability
1/2

Separates lack of formal process from asserted informal input; no particular request or annual plan is identified.

Scoring confidence: high

finding · AC2602-F24

F24: The IAD does not maintain an ongoing quality assurance and improvement program, as required by IIA Standard 8.3 and GAGAS Chapter 5, which require audit organizations to establish and maintain internal quality assessment processes to evaluate conformance with professional standards.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F24; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F24; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F25

F25: The IAD has not undergone an external quality assessment review in more than 25 years.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F25; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F25; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F26

F26: The IAD does not distribute its reports to the IOC, as required by IIA standards 11.3 and 15.1 and GAGAS Chapter 9.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F26; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F26; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F27

F27: The IAD does not post its completed audit reports or annual audit plan on its public webpage, inconsistent with GAGAS Chapter 9, which requires public availability of completed audit reports, and the recommendations of the Association of Local Government Auditors and the National Association of State Auditors, Comptrollers and Treasurers.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F27; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F27; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

finding · AC2602-F28

F28: The deficiencies documented in Findings F3 through F8, F16 through F21, F24, F25, F26, and F27 collectively establish that the IAD does not operate in conformance with the IIA and GAGAS standards required by California Government Code Section 1236 and directed by its own Policies and Procedures Manual.

Audit: Addressed

Response says

Agrees with the finding without additional explanation.

Audit analysis

Explicit agreement engages F28; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Finding-response score

Document completeness and usefulness—not factual verification or a legal conclusion.

6/10

4/4

Statutory elements

Stated position
2/2
Applicable disagreement elements
2/2

2/6

Public usefulness

Coverage
2/2
Reason specificity
0/2
Support traceability
0/2

Explicit agreement engages F28; the response adds no finding-specific reasoning or independently checkable support. Agreement is not independent verification.

Scoring confidence: high

recommendation · AC2602-R1

R1: By December 1, 2026, the Auditor-Controller should consider directing the IAD to comply with the IIA and GAGAS auditing standards as adopted in IAD’s Policies and Procedures Manual and as required by California Government Code Section 1236.

County: Will not be implementedAudit: Addressed

Response says

Will not implement in its entirety: directs IIA compliance, rejects GAGAS compliance and is removing GAGAS references from the manual.

Audit analysis

Provides a reasoned partial refusal citing Government Code Section 1236. Disposition preserves refusal rather than implying acceptance of both standards.

Extracted commitments

Direct IAD to comply with IIA, excluding GAGAS, and revise manual references accordingly.

Responsible party
Contra Costa County Auditor-Controller
Timing
No timeframe stated

recommendation · AC2602-R3

R3: By January 1, 2027, the Auditor-Controller should consider prohibiting IAD personnel from participating in the preparation of the ACFR or performing other management functions to comply with IIA Standard 7.1 and GAGAS §§3.87-3.89.

County: Requires further analysisAudit: Addressed

Response says

Will analyze ACFR assignments during September–December 2026, consider reassignment beginning with the June 30, 2027 year-end process, and document independence safeguards.

Audit analysis

Describes staffing/experience constraints and analysis rather than a blanket prohibition by January 1.

Extracted commitments

Analyze which ACFR assignments can be handled by non-IAD personnel.

Responsible party
Contra Costa County Auditor-Controller
Timing
During the September–December 2026 ACFR process. · Bounded timeframe

Consider reassigning certain ACFR assignments to other divisions, subject to analysis and staffing constraints.

Responsible party
Contra Costa County Auditor-Controller
Timing
Beginning with the fiscal year ended June 30, 2027 ACFR process, where reassignment is appropriate. · Conditional timing

Assess ACFR assignments for independence impairments and document safeguards for IOC.

Responsible party
Contra Costa County Auditor-Controller
Timing
No timeframe stated

recommendation · AC2602-R4

R4: By January 1, 2027, the Board of Supervisors should consider requiring the Auditor-Controller to develop, document, and implement a formal independence safeguards framework consistent with GAGAS §§3.40–3.58 and IIA Standards 7.1.

County: Will be implementedAudit: Addressed

Response says

Promises partial implementation: an IIA Standard 7.1 safeguards framework developed and in use by January 1, 2027; rejects GAGAS applicability.

Audit analysis

Concrete date and narrower standards scope are stated; completion is not verified.

Extracted commitments

Develop and use an IIA Standard 7.1 independence safeguards framework.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-01-01 · Exact date

recommendation · AC2602-R5

R5: By January 1, 2027, the Board of Supervisors should consider requiring the Auditor-Controller to annually disclose to the IOC, or, if established, the Audit Committee, all identified independence threats and the safeguards implemented to mitigate them, consistent with GAGAS §3.59 and IIA Standard 7.1.

County: Will be implementedAudit: Addressed

Response says

Promises partial implementation: communicate identified threats and safeguards to IOC by January 1, 2027, excluding GAGAS-related audits.

Audit analysis

Retains partial label and scope; does not expressly repeat the recommendation’s annual cadence.

Extracted commitments

Communicate identified independence threats and safeguards to IOC.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-01-01 · Exact date

recommendation · AC2602-R10

R10: By January 1, 2027, the Auditor-Controller should consider developing an Audit Charter for the IAD aligned with IIA Standard 6.2.

County: Will be implementedAudit: Addressed

Response says

Will develop an IAD charter by January 1, 2027.

Audit analysis

Specific deliverable and date are given, not evidence of an adopted charter.

Extracted commitments

Develop an IAD charter.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-01-01 · Exact date

recommendation · AC2602-R12

R12: By January 1, 2027, the Auditor-Controller should consider requiring the IAD to adopt and implement a documented risk assessment methodology that includes defined risk factors, risk-ranking or scoring criteria, and a systematic process for identifying and prioritizing risks as required by IIA Standards 9.3 and 9.4.

County: Will be implementedAudit: Addressed

Response says

Will implement a documented IIA risk-assessment methodology by April 1, 2027.

Audit analysis

Agency date is three months later than the recommendation’s January 1 date.

Extracted commitments

Implement documented risk-assessment methodology aligned with IIA.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-04-01 · Exact date

recommendation · AC2602-R13

R13: By January 1, 2027, the Auditor-Controller should consider directing the IAD to revise its Policies and Procedures Manual and any applicable administrative bulletins to incorporate requirements for a documented, risk-based audit planning process aligned with IIA Standards 9.3 and 9.4.

County: Will be implementedAudit: Addressed

Response says

Will revise the manual and administrative bulletin for documented risk-based planning, submitting bulletin updates for County Administrator concurrence; completion by January 1, 2027.

Audit analysis

Identifies documents, process and date; concurrence is part of the stated workflow, not verified approval.

Extracted commitments

Revise manual and administrative bulletin for documented risk-based planning, submitting bulletin updates for County Administrator concurrence.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-01-01 · Exact date

recommendation · AC2602-R14

R14: By January 1, 2027, the Auditor-Controller should consider requiring that the annual risk assessment process include documented input from the Board of Supervisors, its designated oversight committee, and senior county leadership, consistent with IIA Standards 8.1 and 9.4.

County: Will be implementedAudit: Addressed

Response says

Will require documented Board, oversight-committee and senior-leadership input by January 1, 2027.

Audit analysis

Explicit input-process commitment and date.

Extracted commitments

Require documented Board, oversight-committee and senior-leadership input in annual risk assessment.

Responsible party
Contra Costa County Auditor-Controller
Timing
2027-01-01 · Exact date

recommendation · AC2602-R17

R17: By December 1, 2026, the Auditor-Controller should consider directing the IAD to shift the Internal Audit Division’s audit planning from a calendar to a fiscal year schedule beginning with the 2027-28 fiscal year.

County: ImplementedAudit: Addressed

Response says

Claims implementation because IAD has been directed to move to fiscal-year planning beginning FY2027–28.

Audit analysis

The claimed completed act is the direction; future fiscal-year transition is not independently verified as complete.

Extracted commitments

Carry out the directed shift to fiscal-year audit planning.

Responsible party
Contra Costa County Auditor-Controller
Timing
Beginning with FY2027–28; response claims the direction has already been issued. · Bounded timeframe

recommendation · AC2602-R19

R19: By December 1, 2026, the Auditor-Controller should consider directing the IAD to adopt and maintain an ongoing quality assurance and improvement program, as required by IIA Standard 8.3 and GAGAS Chapter 5.

County: Will be implementedAudit: Addressed

Response says

Will adopt an ongoing quality program as part of IIA compliance, anticipated by December 1, 2027; excludes GAGAS.

Audit analysis

Anticipated compliance date is a year after the recommendation’s December 1, 2026 deadline and is not an unconditional completion guarantee.

Extracted commitments

Direct adoption of an ongoing quality assurance and improvement program as part of IIA compliance.

Responsible party
Contra Costa County Auditor-Controller
Timing
IIA compliance anticipated by December 1, 2027, not a guaranteed completion date. · Bounded timeframe

recommendation · AC2602-R20

R20: By December 1, 2026, the Auditor-Controller should consider directing the IAD to undergo an external quality assessment review as required by IIA Standard 8.4 and GAGAS §5.179.

County: Will not be implementedAudit: Addressed

Response says

Declines an external quality review as written until IIA standards have been followed for at least a year.

Audit analysis

Explains sequencing/resource rationale; gives no fixed future review date.

recommendation · AC2602-R21

R21: By December 1, 2026, the Auditor-Controller should consider directing the IAD to distribute all completed audit reports, including management responses, directly to the IOC (or, if established, the Audit Committee) consistent with the direct communication requirements of IIA Standards 11.3 and 15.1 and the report distribution requirements of GAGAS Chapter 9.

County: Will be implementedAudit: Addressed

Response says

Will periodically distribute audit reports and management responses to Finance Committee as part of IIA compliance.

Audit analysis

Recipient differs from IOC/proposed Audit Committee and no explicit delivery date is supplied.

Extracted commitments

Periodically distribute audit reports and management responses to Finance Committee.

Responsible party
Contra Costa County Auditor-Controller
Timing
No timeframe stated

recommendation · AC2602-R22

R22: By December 1, 2026, the Auditor-Controller should consider directing the IAD to post the audit charter, annual audit plan, and all completed audit reports to the County's public website, consistent with GAGAS Chapter 9, which requires that audit organizations make completed audit reports publicly available, and the transparency recommendations of the Association of Local Government Auditors and the National Association of State Auditors, Comptrollers and Treasurers.

County: Will be implementedAudit: Addressed

Response says

Will post charter and plan after Finance Committee approval and annually post completed IIA-compliant audit reports.

Audit analysis

Conditional approvals and limitation to IIA-compliant reports remain explicit; no independent completion date.

Extracted commitments

Post charter and annual plan after Finance Committee approval and annually post completed IIA-compliant reports.

Responsible party
Contra Costa County Auditor-Controller
Timing
Charter once established and approved; plan when approved; completed reports annually. · Conditional timing