BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 831
                                                                  Page  1

          Date of Hearing:   May 12, 2009

                   ASSEMBLY COMMITTEE ON BUSINESS AND PROFESSIONS
                                 Mary Hayashi, Chair
                     AB 831 (Monning) - As Amended:  May 11, 2009
           
          SUBJECT  :   State Auditor:  confidential records. 

           SUMMARY  :   Clarifies that state and local government officers  
          and employees that are the subject of, or possess information  
          about, an ongoing audit or investigation, cannot release audit  
          findings.  

           EXISTING LAW  : 

          1)Sets forth the duties and powers of the Bureau of State Audits  
            (BSA) and makes reference to audits and investigative audits. 

          2)Prohibits the State Auditor (SA) or his or her employees from  
            releasing to the public, among other things, any papers,  
            correspondence, or any substantive information pertaining to  
            any audit not completed.

          3)Provides that any officer, employee, or person who violates  
            this prohibition is guilty of a misdemeanor.

          4)Allows state bodies and local legislative bodies to meet in  
            closed session to discuss a confidential BSA final draft audit  
            report.  After the public release of a BSA audit report, those  
            bodies must meet in open session to discuss those reports. 

           FISCAL EFFECT  :   Unknown.  This bill is keyed non-fiscal. 

           COMMENTS  :   

           Previous Committee Action  .  This bill was heard on May 5, 2009  
          and was put over for further hearing.  The author's office has  
          amended the bill to delete specific references to the  
          descriptions of officers and employees that are the subject of  
          an ongoing audit or investigation, as well as related documents  
          or information. 

           Purpose of the bill  .  According to the author's office, "AB 831  
          seeks to clarify that officers and employees of any state or  
          local governmental agency or publicly created entity that is the  








                                                                  AB 831
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          subject of an ongoing audit cannot release information related  
          to that ongoing audit before it becomes final.  This bill is  
          declaratory of existing law.  In the past, there have been  
          several agencies which were the subject of an ongoing audit that  
          decided to release draft recommendations to the public before  
          the SA had officially completed the audit.  Discussing audit  
          findings before they become final by the SA violates all  
          auditing standards in the 'Government Auditing Standards'  
          published by the Comptroller General of the United States and  
          the standards published by the American Institute of Certified  
          Public Accountants." 

           Background  .  The California SA is the State's independent  
          external auditor that provides independent, nonpartisan,  
          accurate, and timely assessments of California government's  
          financial and operational activities in compliance with  
          generally accepted government auditing standards.  The BSA will  
          conduct audits or investigations to evaluate whether the auditee  
          is acting in compliance with existing law.  BSA audits originate  
          from within the bureau, the Joint Legislative Audit Committee  
          (JLAC), or legislation, and BSA investigations originate from  
          complaints from state employees or the public.  State law  
          precludes the SA from discussing or disclosing any aspect of the  
          audit once the audit commences.  The BSA will prepare a  
          confidential final draft report and allow the auditee to respond  
          to the draft findings before a final report version is released.  
           

          State and local legislative bodies are allowed to discuss a  
          response to a confidential final draft BSA report in closed  
          session, as provided in Government Code sections 11126.2 and  
          54956.75.  In addition, agencies are allowed to confer with  
          legal counsel using a confidential attorney-client privilege  
          that would not result in a release of the draft BSA report or  
          investigation. 

          Once a BSA report is finalized and released to the public, state  
          and legislative bodies must meet in open session to discuss the  
          report since it is no longer confidential in nature.  In  
          addition, members of the public are allowed to share information  
          and discuss the final BSA report.   

           Support  .  According to the sponsor, the BSA, "The code currently  
          makes it a misdemeanor to divulge any record, document, or  
          information regarding an ongoing audit.  Some entities have  








                                                                  AB 831
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          taken a position that this language only applies to (the BSA).   
          Thus, AB 831 would clarify that the code includes the officers  
          and employees of any state or local governmental agency or  
          publicly created entity that is the subject of an ongoing audit  
          or investigation.  We believe that the language is declaratory  
          of existing law and simply serves to clarify that auditees  
          cannot publicly release information pertaining to the ongoing  
          audit work of (the BSA) office.  We believe the clarification is  
          necessary because some auditees have expressed different  
          interpretations.  Additionally, this bill does not bear any  
          costs to the State." 

           Oppose .  According to the State Association of County Auditors  
          (SACA), " In many cases, County Boards of Supervisors will  
          request input prior to our responding to an audit.  In order for  
          the Board of Supervisors to discuss the draft audit, it must be  
          addressed in public for Brown Act compliance.  The SACA has  
          historically shared expertise and knowledge from county to  
          county in order to perform complete and accurate audits.  SACA  
          has well established sub-committees which produce guidelines and  
          procedure manuals for compliance with legislative requirements  
          in areas such as Accounting Standards and Procedures, Property  
          Taxes, and the County Budget Manual.  All counties rely on these  
          guidelines for consistent interpretation of legislation.  Upon  
          completion of an audit draft, the auditee has an opportunity to  
          respond to any findings prior to the audit being finalized.   
          Should these findings be contrary to adopted guidelines, it is  
          imperative that we are permitted to discuss the issue with other  
          technical experts."

          According to the County of San Diego, "AB 831 would prohibit  
          county officials from discussing information found in an ongoing  
          audit with key county staff, including county counsel, and  
          restrict county auditors from seeking assistance from other  
          local government officials as technical experts.  It will also  
          prohibit the Board of Supervisors from being informed about the  
          scope and progress of the audit, which surely cannot be in the  
          public interest."

           Related Legislation  .  AB 567 (Villines) expands the restrictions  
          regarding the release of information related to a SA report to  
          the officers and any employee or former officers or employees of  
          any state or local agency or publicly created entity that has  
          been subject to or that has assisted the BSA with an audit or  
          investigation or that has receive a draft copy of any report or  








                                                                  AB 831
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          other draft document from the bureau for comment or review, and  
          replaces references to "investigative audit" with  
          "investigation".  This bill is pending in the Assembly  
          Appropriations Committee. 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Bureau of State Audits (BSA) (sponsor)

           Opposition 
           
          California State Association of Counties (CSAC)
          County of San Diego
          State Association of County Auditors (SACA)
           
          Analysis Prepared by  :    Joanna Gin / B. & P. / (916) 319-3301