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6 <br />2023-2024 San Mateo County Civil Grand Jury <br />Survey and Survey Response Analysis <br />The Civil Grand Jury designed a survey focused on an entity’s assessment of its internal controls, <br />reporting, training and risk evaluation. See Appendix A for the survey. The Civil Grand Jury sent <br />the survey to 75 entities. <br />The Civil Grand Jury reviewed and analyzed the responses. <br />Interviews with Entities <br />By rule, the Civil Grand Jury must interview an entity to use that entity’s responses to a survey <br />as a matter of fact. The Civil Grand Jury interviewed 28 entities, mostly focusing on entities that <br />did not conduct an assessment of its internal controls in the last 18 months. <br />The Civil Grand Jury also interviewed a Certified Public Accountant with experience serving as <br />external auditor of entities within San Mateo County. <br />DISCUSSION <br />Regulatory History <br />In 2013, our California Assembly approved Bill No. 1248, to require the state controller to <br />establish internal controls for California local agencies. Bill No. 1248 applies to the County of <br />San Mateo and the cities, special districts and other local government entities, except school <br />districts. Bill No.1248 appears in the California Government Code section 12422.5. <br />In 2014, The General Accounting Office (GAO) of the U.S. Government issued the Green Book. <br />The U.S. Comptroller General prescribes internal control standards in the Green Book for the <br />federal government. The Green Book says that state, local and quasi-governmental agencies and <br />not-for-profit organizations may adopt the Green Book as a framework for an internal control <br />system. <br />In 2015, the California State Controller’s Office issued “Internal Control Guidelines - California <br />Local Agencies” to comply with California Government Code section 12422.5. The State <br />Guidelines refer to the Green Book, among other resources. <br />The State Guidelines refer to the same structure of internal controls in the Green Book as well as <br />the Committee of Sponsoring Organizations of the Treadway Commission (COSO) publications, <br />both of which refer to the Governing Board’s responsibility to ensure completion of periodic risk <br />assessments and to oversee internal controls. <br />Schools in San Mateo County are governed by the California Education Code (EDC). The <br />county superintendent of schools may review or audit internal controls of any school district in <br />its county per the California Education Code section 1241.5. The guidance in the Green Book <br />and the State Guidelines naturally apply. <br /> <br />6.C. - Page 10 of 22 <br />89