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Response synthesis and audit

Board response to benefit theft

The adopted Board response agrees with all five findings, describes existing monitoring and service practices, and plans advocacy and reporting improvements.

Response by Solano County Board of Supervisors · 2026-08-04

11

Addressed

1

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.

5

Implemented

2

Will be implemented

0

Requires further analysis

0

Will not be implemented

0

Unclear

How to read this audit

Scores assess the response’s stated position and explanation, not whether the jury or Board is factually correct. Planned actions, conditional advocacy and reported implementation remain distinct.

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 12 of 12 items

finding · F1

Although skimming has decreased, it remains to be seen whether or how long it will take criminal organizations to figure to how to bypass chip readers.

Audit: Addressed

Response says

Agrees that chip cards reduce theft without eliminating adaptation risk.

Audit analysis

Explicit agreement covers the remaining risk and identifies ongoing monitoring and collaboration; effectiveness is not independently tested.

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

Explicit agreement covers the remaining risk and identifies ongoing monitoring and collaboration; effectiveness is not independently tested.

Scoring confidence: high

recommendation · R1A

HSS continue monitoring data trends and continue collaborating with Federal and State agencies to monitor criminal efforts underway to defeat the chip technology.

County: ImplementedAudit: Addressed

Response says

Claims monitoring and collaboration are already operating.

Audit analysis

The response identifies current tracking and interagency work, rather than promising that future attacks cannot succeed.

Extracted commitments

Continue monitoring EBT fraud trends and collaborating with state and federal partners.

Responsible party
Solano County Health and Social Services
Timing
No timeframe stated

recommendation · R1B

In collaboration with other HSS agencies throughout the State, lobby federal and state governments to improve cybersecurity protections for EBT cards.

County: Will be implementedAudit: Partially addressed

Response says

Plans advocacy through interagency and legislative channels as resources permit.

Audit analysis

Future advocacy is acknowledged, but no completion date or measurable cybersecurity improvement is committed. Feasibility and coordination qualify the action.

Extracted commitments

Pursue cybersecurity advocacy with other agencies through available channels.

Responsible party
Solano County Health and Social Services
Timing
As interagency coordination, resources and feasible advocacy opportunities permit. · Conditional timing

finding · F2

Reported data does not clarify discrepancies such as size of household, number of thefts per report, amount of benefits, etc., which leads to possible underreporting of theft.

Audit: Addressed

Response says

Agrees current reporting omits factors affecting incident totals.

Audit analysis

Agreement covers limitations in household, benefit and multiple-theft data; reporting constraints and State parameters are explained without validating all counts.

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

Agreement covers limitations in household, benefit and multiple-theft data; reporting constraints and State parameters are explained without validating all counts.

Scoring confidence: high

recommendation · R2

By July 1, 2027, HSS fine-tune report methodology to include factors which influence fluctuating numbers.

County: Will be implementedAudit: Addressed

Response says

Plans feasible reporting enhancements on or before July 1, 2027.

Audit analysis

The response adopts a date and describes refinement within State-system and data-availability constraints. Completion and improved data quality are not yet demonstrated.

Extracted commitments

Fine-tune theft reporting to capture relevant household, incident and benefit factors where feasible.

Responsible party
Solano County Health and Social Services
Timing
2027-07-01 · Exact date

finding · F3

Call Center waiting time has improved since the height of skimming complaints in 2023-2024.

Audit: Addressed

Response says

Agrees call-center wait times have improved.

Audit analysis

The Board expressly accepts the finding and describes process improvements; the audit does not independently measure wait times.

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

The Board expressly accepts the finding and describes process improvements; the audit does not independently measure wait times.

Scoring confidence: high

recommendation · R3

Continue to improve Call Center hold times. Adopt process improvement management.

County: ImplementedAudit: Addressed

Response says

Claims call-center process improvements are in place.

Audit analysis

Existing workflow, training and service monitoring are offered as implementation; continued improvement is a continuing action, not a guarantee of a fixed wait time.

Extracted commitments

Continue monitoring and improving call-center workflows and hold times.

Responsible party
Solano County Health and Social Services
Timing
No timeframe stated

finding · F4

Reimbursement processing time has improved to comply with the 10-day requirement.

Audit: Addressed

Response says

Agrees reimbursement processing has improved to meet the ten-day requirement.

Audit analysis

Explicit agreement identifies the processing standard and current practice; agency statements are not an independent compliance sample.

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

Explicit agreement identifies the processing standard and current practice; agency statements are not an independent compliance sample.

Scoring confidence: high

recommendation · R4

Maintain the current level of compliance.

County: ImplementedAudit: Addressed

Response says

Claims current reimbursement processing meets the mandated timeframe.

Audit analysis

The response directly claims implementation and continued monitoring, without proving every claim is processed on time.

Extracted commitments

Maintain and monitor timely processing of replacement benefits.

Responsible party
Solano County Health and Social Services
Timing
No timeframe stated

finding · F5

The Department has provided public outreach to educate benefits recipients on how to protect their EBT cards from skimming, enhancing protection against theft.

Audit: Addressed

Response says

Agrees the department has provided protective outreach.

Audit analysis

Agreement identifies educational channels and protective guidance; client uptake and loss prevention are not independently verified.

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

Agreement identifies educational channels and protective guidance; client uptake and loss prevention are not independently verified.

Scoring confidence: high

recommendation · R5A

Continue to provide and update educational outreach efforts as new skimming technologies emerge.

County: ImplementedAudit: Addressed

Response says

Claims ongoing outreach and updates already occur.

Audit analysis

The Board describes existing education and adaptation to new threats, with no separate future completion date.

Extracted commitments

Continue updating educational outreach as skimming threats evolve.

Responsible party
Solano County Health and Social Services
Timing
No timeframe stated

recommendation · R5B

Encourage clients to use direct deposit for cash benefits.

County: ImplementedAudit: Addressed

Response says

Claims clients are already informed about direct deposit and other delivery options.

Audit analysis

The response addresses encouraging the cash-benefit option; it does not establish universal eligibility, enrollment or a reduction in fraud.