Response to 2017-2018 Grand Jury Report: Riverside County Sheriff's Department,

The committee will establish guidelines for these administrative responsibilities. These guidelines shall include pre-approved amounts and spending categories for day-to-day operational expenditures from the IWF, authorized by the Sheriff and not requiring further approval. Annually at the end of each fiscal year, the board will review and establish the approved operational spending amounts and categories for the following fiscal year.

In addition, the committee will also develop and/or review and approve all proposed substantial expenditures from the IWF. They will oversee the preparation of an annual report of IWF expenditures for the County's Board of Supervisors.

All proposals for substantial IWF expenditures and any contracted services must be approved by the IWF-C by a majority vote at any IWF-C meeting or as a result of a telephone or e-mail poll of the committee's members.

All IWF purchases and any contracted services shall follow purchasing guidelines. This is to ensure that purchases or contracts are the best deal or acted upon in good faith on behalf of the inmate beneficiaries. By using the established standards provided by the Purchasing Department, a paper trail for auditing purposes is created. Upon appointment to the committee by the Sheriff, all members (citizen or not) are expected to read and become familiar with these guiding documents and adhere to them. Newly appointed members are mentored by existing members and are expected to provide input based on their reading and comprehension of the guiding documents. Newly appointed members routinely seek guidance by asking questions of the experienced committee members. This method of training is congruent with the normal practices of training for any person in a new assignment, whether in the public or private sector. Respondent RCSD disagrees with the characterization by the Grand Jury that "... there is no true, impartial or neutral citizen representative sitting on this committee," on the basis that it is inaccurate, incomplete and misleading. Although the voting citizen member of the IWF-C is a retired Assistant Sheriff from RCSD, the implication that such member lacks impartiality is without merit. The current citizen member is a former Sheriff's employee and current resident of Riverside County who provides a valuable historical perspective. Such citizen member's wealth of experience and institutional knowledge from time spent within RCSD serves to increase accountability and bolster the decision-making process regarding IWF expenditures. Respondent RCSD disagrees with the characterization by the Grand Jury that "A single "civilian" cannot truly represent the more than three million citizens of the County. True public transparency requires more than one civilian member," on the basis that it is inaccurate and misleading. The IWF operates as provided by law in accordance with California Penal Code § 4025. The IWF- C is an advisory body established by the Sheriff. The purpose of the IWF-C is to assist the Sheriff with the day-to-day administration of the IWF and to develop and/or review and approve proposals for expenditure. The Sheriff is the trustee of the IWF and maintains executive overview of the IWF-C. The Sheriff has sole authority to accept, reject, or amend decisions made by the committee. Moreover, the Sheriff is an elected official who serves all of the residents of Riverside County.1 Number 5: FEES CHARGED TO FAMILY AND FRIENDS There are fees charged to the family and friends of County inmates per the Professional Service Agreement for Jail Commissary Services between the County of Riverside and Contractor, dated October 25, 2016, [12] for deposit of funds to trust accounts. No fees for this process will be borne by the County. The County has agreed that the Contractor may charge these fees for deposit services. The Deposit Services Fee Structure is as follows: Cash Fee Structure Gross Amount Deposited Cash at Lobby Kiosk $0.01-$20.00 $1.00 $20.01-$40.00 $2.00 $40.01-$200.00 $3.00 1 According to the most recent report issued by the U. S. Census Bureau on March 22, 2018, the population of Riverside County stands at 2,423,266 as of July 1, 2017. Credit Card Fee Structure Gross Amount Deposited Web Phone $2.95 $3.95 $0.01-$19.99 $5.95 $6.95 $20.00-$99.99 $7.95 $100.00-$199.99 $8.95 Orange, San Bernardino, and San Diego County Inmate Welfare Fund contracts do not charge deposit fees. Response: Respondent disagrees wholly with the finding. Respondent Riverside County Sheriff's Department ("RCSD") disagrees with the characterization by the Grand Jury that "Orange, San Bernardino, and San Diego County Inmate Welfare Fund contracts do not charge deposit fees" on the basis that it is an inaccurate and misleading portrayal of how inmate deposits are treated by these three counties in comparison to the RCSD IWF. A fee structure for deposits to inmate trust accounts can be found directly in the San Bernardino and San Diego County IWF commissary contracts. A cursory investigation into the matter revealed that it is inaccurate and misleading to say these three counties do not charge deposit fees and/ or provide the same level of convenient access to making deposits to inmate trust accounts similar to that offered by RCSD. Both San Bernardino and San Diego County Sheriff's Departments do in fact charge deposit fees. While the Orange County Sheriff's Department does not charge deposit fees, they also do not provide for convenient deposit service similar to the surrounding counties. Each of the counties referenced by the Grand Jury will be discussed in detail below. Orange County Sheriff's Department The Orange County Sheriff's Department ("OCSD") does not charge deposit fees. However, this is because the OCSD does not provide for a convenient option to the friends and family members of their inmates to make deposits. OCSD has limited itself to two cashiering offices on a county- wide basis where such deposits can be made. They are located at OCSD's Inmate Reception Center in the City of Santa Ana and at the Theo Lacy Facility in the City of Orange. In order for members of the public to deposit fees to an inmate's trust account, they must route all deposits through one of these two offices in the form of cash or money order. OCSD does not provide for on-site kiosk, website, or toll-free phone number deposits to these accounts. San Bernardino County Sheriff's Department The San Bernardino County Sheriff's Department ("SBSO") provides for convenient deposits to inmate trust accounts similar to those offered by RCSD. SBSO negotiated for the use of lobby kiosks, telephone, and web deposits to their inmate trust accounts through their commissary vendor, Aramark Correctional Services LLC. This contract amendment was signed and became effective on January 06, 2016. Specifically, refer to Section F.2 on for the language which permits the commissary contractor to charge these fees and Attachment A on for the schedule of fees. A summary of the fee structure charged to the friends and family members of SBSO inmates who make deposits to their trust accounts as per this contract is outlined below: Commissary Deposit Fees Deposit Amount Kiosk Web Phone $2.95 $0-$20.00 $2.95 $2.95 $20.01-$100.00 $3.95 $3.95 $3.95 $100.01-$200.00 $4.95 $4.95 $4.95 *In addition to the above outlined fee structure, for each deposit made using a credit or debit card, a 3.5% service fee will be added to the total amount of the transaction It is worth mentioning the fees charged to the friends and family members of SBSO inmates who make deposits to their trust accounts are higher than those which were negotiated by RCSD to be charged to family and friends of the inmates housed within RCSD jail facilities. San Diego County Sheriff's Department The San Diego County Sheriff's Department ("SDSO") provides for convenient deposits to inmate trust accounts similar to those offered by RCSD. SDSO negotiated for the use of lobby kiosk systems through a contract amendment with their inmate telephone services provider, Securus Technologies. These kiosks are provided through a Securus subsidiary company named TouchPay Holdings LLC. This contract amendment was signed and became effective on January 08, 2016.3 Specifically, refer to Section 2. Trust/Commissary on pages 4-5 of Exhibit B to the contract amendment. A summary of the fee structure charged to the friends and family members of SDSO inmates who make deposits to their trust accounts as per this contract amendment is outlined below: 2 See attached Exhibit 1. See attached Exhibit 2. Cash Fee Structure Gross Amount Deposited Cash at Lobby Kiosk $0-$25.00 $2.95 $3.95 $25.01-$50.00 $4.45 $50.01-$100.00 $5.45 $100.01 $200.00 Credit Card Fee Structure Gross Amount Deposited Phone Kiosk Web $0-$20.00 $2.95 $3.95 $3.95 $20.01-$50.00 $3.95 $3.95 $3.95 $50.01-$100.00 $4.45 $4.45 $4.45 $100.01-$200.00 $5.45 $5.45 $5.45 *In addition to the above outlined fee structure, for each credit/debit card transaction, the customer/depositor will be charged the base fee as listed above plus 3.5% of the face amount of each transaction. It should be noted that the fees charged to the friends and family members of SDSO inmates who make deposits to their trust accounts are higher than those which were negotiated by RCSD to be charged to family and friends of the inmates housed within RCSD jail facilities. RCSD's Deposit Services Fee structure features charges by the commissary contractor as a means of providing the convenience of deposits at an on-site kiosk, via website, or by toll-free phone number. These fees are similar to convenience fees charged at Automated Teller Machines (ATM), which are routinely accepted amongst the general public. The RCSD took measures during contract negotiations with the commissary services provider to keep these fees reasonable and stagnant for the duration of the contract. In addition, the RCSD also maintains a cost-free option to the public by accepting U.S. Postal money orders for depositing funds into inmate trust accounts without a fee. This option is provided by RCSD in recognition that some friends and family members of inmates may not wish to pay a convenience fee. Number 6: RETURN OF MONIES TO INMATES There is an inefficient method used to return funds to inmates who are no longer in custody. Currently, the IWF contract [12] states: If an inmate has been released, the CONTRACTOR will keep commissary items and advise the COUNTY of the inmate's invoice status. The COUNTY will make adjustments and attempt to notify the inmate by mail regarding the commissary balance. The COUNTY will hold the inmate's money for ninety days (90), if unclaimed by the inmate within that time; the money will be deposited to the County General Fund. [sic] Based on the current wording in the contract, there is no proactive and timely process in place for returning monies back to the inmate at the time of his/her release. There is no written notification process in documents researched to notify an inmate on the process of how to obtain any monies retained on his/her account. By the current policy's own wording, the Sheriff waits until the released inmate contacts the Sheriff to obtain his/her monies. Currently, money is held for up to 90 days waiting for a released inmate to inquire about his/her money. The Grand Jury researched several county detention centers to ascertain how they return monies to released inmates. The following procedure from Placer County seems to be a comprehensive and efficient method used to return such monies: If an inmate is released during normal business hours, the inmate will receive a check or debit card for the funds from their commissary account. If the inmate is released after business hours, the inmate may return to the jail to request their check in person during normal business hours. If the inmate would like their check mailed, he/she must contact the jail accounting office during normal business hours and provide a current mailing address. Response: Respondent disagrees wholly with the finding. Respondent Riverside County Sheriff's Department ("RCSD") disagrees with the characterization by the Grand Jury that "There is an inefficient method used to return funds to inmates who are no longer in custody," on the basis that it is inaccurate, incomplete and misleading. When an inmate is booked into one of the five Riverside County jails, an Inmate Trust Account is created for that inmate. That account includes a tracking mechanism for commissary spending. Upon release from one of the Riverside County jails, the balance of the inmate's trust account will be released to him/her in accordance with Corrections Division Policy 506.11. If the inmate placed a commissary order prior to his/her release, there is a likelihood the funds to cover the cost of the commissary order were removed from the inmate's trust account prior to the inmate being released from custody. In this case, the inmate would be owed a refund for the commissary order. This is when the process outlined by the IWF commissary contract takes place, but that is only part of the process. At the end of each month, the commissary contractor provides Corrections Accounting staff a list of inmates who are owed a commissary refund. The accounting staff follows established policies and procedures to notify an inmate via written letter. The letter is sent to the last known address of the inmate and notifies him/her of the refund amount, along with instructions for claiming a refund. In the event where the commissary refund amount was not issued back to the inmate as a result of an undeliverable address, it then becomes unclaimed money. The County of Riverside adheres to the requirements of California Government Code § 50055 in processing the unclaimed money. In addition, the unclaimed inmate money claim procedure is publicly listed on the Riverside Sheriff website: www.riversidesheriff.org/corrections/money.asp. Moreover, as an additional protective measure, RCSD accounting staff periodically check the Jail Information Management System to see if inmates owed refunds come back into RCSD custody on a later date. If the inmate is back in custody, any refund balance due is placed in the inmate's trust account. Respondent RCSD disagrees with the characterization by the Grand Jury that the "procedure from Placer County seems to be a comprehensive and efficient method used to return such monies" on the basis that it is inaccurate and misleading. In Placer County, an inmate orders commissary items electronically that results in money being transferred out of the inmate account into a pending payment account. When an inmate is released, the inmate's commissary account is checked to see if the inmate placed an order that has not yet been received. In such event, money is credited back to the inmate account and the commissary order is adjusted automatically, a debit card or check is then issued to inmate for the full amount to the inmate. Placer County houses a much smaller number of inmates (approximately 1000 inmates) than RCSD does. As a result, they are able to schedule delivery of commissary order items for the same day once every week. If a release is done prior to commissary delivery, assigned staff are able to credit back an inmate's commissary order prior to issuing a debit card with the balance of the inmate's trust fund balance and in most cases that cancels the order. All undeliverable orders are returned to the commissary vendor. However, there are infrequent instances where they have an undeliverable commissary order due to the release of the inmate. Once ordered items are returned to the commissary vendor and the unspent money is credited back to the inmate, the funds are then left in the inmate's account for future use or they become treated as unclaimed money, similar to the process followed by RCSD. Placer County sends out a letter to the inmate prior to the unclaimed money being forfeited. Number 7: SUBSIDIZED VENDING MACHINE SNACKS FOR STAFF The Contractor is providing the vending machine snacks for staff at a reduced price at all of the detention facilities. As referenced within the vendor's commissary pricing menus submitted in the contract of 2016[12], a Snicker's bar for an inmate is $1.58 (Exhibit A), while that same candy bar is sold to staff for $.85 cents (Exhibit B). The negotiated contract mentioned provides employee vending machine pricing. There are 50 listed snack and drink items which are provided by the Contractor under the IWF contract. Response: Respondent disagrees wholly with the finding. Respondent Riverside County Sheriff's Department ("RCSD") disagrees with the characterization by the Grand Jury that there are "SUBSIDIZED VENDING MACHINE SNACKS FOR STAFF" on the basis that it is inaccurate, incomplete and misleading. The same contractor who provides commissary services for inmates also provides vending services for RCSD staff. However, although the vending prices of the items sold vary from the commissary pricing, these vending services are not subsidized. The vending service for RCSD staff is provided separately from the inmate commissary system, furnished at no extra cost to the county, and no part of the commissions revenue collected as part of commissary services for the IWF is used to cover any portion of the vending service.4 Vending services and commissary are two very different services and it is akin to making an apple to oranges comparison. Labor costs associated with the standard stocking of a self-serve vending machine with personnel already on site conducting commissary delivery equates to a low overhead. The costs to process inmate-specific special orders and to deliver them far outweighs the standard stocking of a self-serve vending machine. Costs to operate the commissary system are not impacted by the vending services and vice versa. Infrastructure to set up the commissary ordering system is extensive, consisting of equipment, kiosks, web operation, hard wiring the jails, and technical support are just a portion of the costs associated with establishing and maintaining an efficient commissary system. In addition to the costs for processing and filling individual orders, there are also the costs associated with operating delivery vehicles, fuel, insurance, and labor to deliver the product 4 See attached Exhibit 3. personally to each inmate. There is no comparison between costs involved in the standard stocking of a self-serve vending machine to those costs associated with the processing and delivery of individualized commissary orders. As a result, the cost of a $1.58 Snicker's bar is reasonable under the circumstances. Number 8: WEIGHTING OF BID SELECTION FOR COMMISSARY CONTRACTOR The Sheriff Department's contract with the Contractor requires the County to assume no cost or risk. County Procurement awards contracts based on competitive pricing by soliciting written bids from available vendors. The purpose of competitive bidding is based on the lowest possible price, for the benefit of the County Inmates. The County Request for Proposal (RFP) [10] requires a commission or service fee to be paid to the RCSD. A first-year payment of $1.5 million and following years (year two up to five years) commission payments equal to 45.3% of the vendor's gross revenues, prorated based on inmate head count, is a fundamental part of the business requirements in order for the Contractor to be approved and granted the contract. The RCSD deposits the commission from the Contractor to the IWF account. The monies are primarily used for the benefit of the inmates but can also be used for other expenses as defined in California Penal Code Section 4025(e). The net effect of the commission the Contractor is required to pay is an increase in the cost of goods sold to inmates in the jail commissary, in contrast to the price for the same goods sold to the general public. As a result, the Contractor sells goods and services to County inmates at an inflated price (profits plus commission), and as an exclusive agent of the Sheriff's Department, passes the contractually required commission to the inmate in the form of higher prices. A review of the Purchasing Department's Jail Commissary Services Evaluation Scoring Sheet (Exhibit C) with the selection criteria, reflects a weight of forty percent toward the vendor's ability to satisfy business requirements, which includes the commission, while cost to the inmates was weighted at twenty percent. Under this weighting criteria, the Contractor was awarded the contract because a greater emphasis was placed on the amount of money paid to the County rather than on the lowest price of goods provided to the inmate. A majority of goods charged at the commissary, based on the pricing matrix, have a markup value ranging between 40 and 70 percent over and above standard commercial pricing. Response: Respondent disagrees wholly with the finding. Respondent Riverside County Sheriff's Department ("RCSD") disagrees with the characterization by the Grand Jury that "A review of the Purchasing Department's Jail Commissary Services Evaluation Scoring Sheet (Exhibit C) with the selection criteria, reflects a weight of forty percent toward the vendor's ability to satisfy business requirements, which includes the commission, while cost to the inmates was weighted at twenty percent. Under this weighting criteria, the Contractor was awarded the contract because a greater emphasis was placed on the amount of money paid to the County rather than on the lowest price of goods provided to the inmate," on the basis that it is an inaccurate, incomplete and misleading portrayal of the bid selection criteria and which fails to mention the equal weight of twenty percent afforded to the criteria which references cost to the county. For clarification purposes, the weighting criteria utilized during the bid selection process is developed by the County Purchasing Department, not RCSD. In evaluating the Purchasing Department's Jail Commissary Services Evaluation Scoring Sheet (Exhibit C), equal weight is given to the criteria OVERALL COST TO THE COUNTY and OVERALL COST TO INMATES at twenty percent each. The initial criteria referenced that was assigned a weight of forty percent is "Criteria #1- Overall responsiveness and general understanding of the RFP requirements. This section includes Vendor's ability to satisfy business requirements." This criterion covers the bidder's capability to fulfill virtually every performance aspect of the RFP, including one aspect for commission. As such, it was appropriate for the Purchasing Department to assign the heaviest weight to the most comprehensive criteria contained in the Purchasing Department's Jail Commissary Services Evaluation Scoring Sheet. Respondent RCSD disagrees with the characterization by the Grand Jury that "A majority of goods charged at the commissary, based on the pricing matrix, have a markup value ranging between 40 and 70 percent over and above standard commercial pricing," on the basis that it is inaccurate, vague and ambiguous. The respondent is unfamiliar with the criteria utilized by the Grand Jury to define the vague and ambiguous term "standard commercial pricing." Per the Professional Service Agreement for Jail Commissary Services between the County of Riverside and Keefe Group LLC (Section 3.4, pages 4 – 5), the cost of the goods sold to inmates in the jail commissary and proposed price increases for these goods are governed by the Consumer Price Index (CPI) - All Consumers, All items - Greater Los Angeles, Riverside, and Orange County areas. The apparent assumption by the Grand Jury that the price of goods sold in the commissary is based upon the contractor's commission requirements is therefore erroneous. Commissary items purchased by the inmates are hand delivered to them by the vendor. This is a unique purchasing experience not commonly enjoyed by those who shop at national retail stores. The closest comparable buying experience would be through a mail order retailer, such as Amazon. For the purposes of comparison, an inmate can order a 1.86 oz. Snicker's bar from the jail commissary for $1.58. If a member of the general public was to order the same candy bar for delivery to their home from Amazon, the cost would be $4.01.5 Riverside County inmates who choose to participate in a business relationship with the commissary vendor do so willingly. Any funds routed to the IWF through these commissary sales are returned to the inmates in the form of programs, training, services, and equipment which benefit them. To undervalue these benefits which are provided to the inmates by the IWF and compare the cost of goods available to the general public is an ill-considered comparison. Major national retailers that provide similar items enjoy superior volume buying power which exceeds that of a jail commissary contractor. Number 9: INDIGENT KITS PAID FOR BY THE VENDOR The commissary Contractor is required by the County, as an inducement to be the sole contractor, to supply 35,000 Indigent Kits to the inmate population free of charge. Per SHARC-96115-003-11/23, Section 11-Indigent Kits of the agreement, [12] states: CONTRACTOR, at its sole cost and expense, will provide a minimum of 35,000 indigent inmate kits to the COUNTY annually. additional indigent kits beyond this amount, For the CONTRACTOR will provide indigent kits to those inmates who qualify for the program at no profit to the CONTRACTOR. [sic] The Counties of Orange, San Bernardino, and San Diego [6] all have stipulations in their contracts and policies that their indigent kits expense will be borne from their General Fund and not through the IWF. Their policies reflect that cleanliness and hygiene are basic functions (like feeding) that must be provided by the County and not through the IWF. The RCSD Contractor supplies the inmate kits at their cost, which is then passed on to the inmate in the form of higher prices for any and all goods and services to recoup their costs. See attached Exhibit 4. Response: Respondent disagrees wholly with the finding. Respondent Riverside County Sheriff's Department ("RCSD") disagrees with the characterization by the Grand Jury that "The Counties of Orange, San Bernardino, and San Diego [6] all have stipulations in their contracts and policies that their indigent kits expense will be borne from their General Fund and not through the IWF. Their policies reflect that cleanliness and hygiene are basic functions (like feeding) that must be provided by the County and not through the IWF," on the basis that it is inaccurate, incomplete and misleading. Title 15, California Code of Regulations, § 1265, states in pertinent part: "There shall be written policies and procedures developed by the facility administrator for the issue of personal hygiene items... Each inmate to be held over 24 hours who is unable to supply himself/herself with the following personal care items, because of either indigency or the absence of an inmate canteen..." The statement "supplied because of indigency or the absence of an inmate canteen," refers to RCSD's commissary which serves as an inmate canteen for the purposes of the Title 15 regulation. California Penal Code § 4025(e) states in pertinent part: "the inmate welfare fund shall be expended by the sheriff primarily for the benefit, education and welfare of the inmate confined in the jail ...inmate welfare funds may be used to augment those required county expenses as determined by the sheriff to be in the best interests of inmates." As a benefit and for the welfare of the inmates, the Sheriff utilizes IWF funds to pay for these personal care items as allowed by law. Respondent RCSD disagrees with the characterization by the Grand Jury that "The RCSD Contractor supplies the inmate kits at their cost, which is then passed on to the inmate in the form of higher prices for any and all goods and services to recoup their costs," on the basis that it is an inaccurate, incomplete and misleading portrayal of how indigent kits are provided to inmates by RCSD. Per SHARC-96115-003-11/23, section 11(A), "CONTRACTOR, at its sole cost and expense, will provide a minimum of 35,000 indigent inmate kits to the COUNTY annually. For additional indigent kits beyond this amount, the CONTRACTOR will provide indigent kits to those inmates who qualify for the program at no profit to the CONTRACTOR." In 2017, the vendor provided 53,383 indigent kits to RCSD inmates, of which 35,000 were provided at no cost to the RCSD, which resulted in a significant cost savings to the county. Per section 11(B), The "COUNTY will provide only the reimbursement of the cost of the additional kits..." The additional amount of 18,383 indigent kits provided by the vendor were paid for by the IWF at the actual cost rate of $2.30 per kit. As trustee of the IWF, the Sheriff has a fiduciary responsibility toward the inmates wherein the Sheriff is entrusted with funds kept for their benefit. The RCSD followed the County's Purchasing Department guidelines to ensure a transparent and equal opportunity for all vendors to submit a competitive response to the Request for Proposal (RFP) for commissary services. The vendor that was awarded the contract was selected because they agreed to pay the highest commissions and do so while simultaneously offering the lowest possible prices to the inmates. It is presumptive for the Grand Jury to draw the conclusion that the vendor is passing on the cost of the indigent kits to the inmate through higher prices on goods and services provided by the commissary versus absorbing the costs through reduced profits. An alternative conclusion can be drawn where there is an expectation in the private sector that to remain competitive as a retail business these types of expenses would simply be considered part of the cost of doing business. Number 10: INADEQUATE AUDITS Audits are conducted on the IWF with the purpose of increasing transparency. IWF Bylaw Section B-Audits [18] states: The Corrections Division Administrative Manager (FINANCE) will monitor and perform a monthly audit of all IWF expenditures and prepare pertinent management reports for the IWF. A non-County entity or outside accounting firm shall conduct an annual audit of the IWF [sic]. The Corrections Administrative Manager (FINANCE) will initiate and coordinate with the Sheriffs Contracts Unit a request for quote for audit services in accordance with Riverside County Purchasing guidelines. These entities with the approval and concurrence of the Corrections Chief Deputy for Support Services will select the outside accounting firm to prepare said audit. To avoid exclusivity, the accounting firm will rotate every three years. Part C - Annual Report [18] states: The Corrections Administrative Manager (FINANCE) will be responsible for the preparation of an annual report of all revenue, expenditures, current balance, and transactions of the IWF. An itemized report of expenditures will be included in the public information plan for each facility. Pursuant to 4025(e) of the Penal Code, the itemized expenditure report and a copy of the annual IWF audit will be submitted annually to the County Board of Supervisors. All audits are only distributed within the IWFC and thereby lack independent scrutiny or oversight during the year. The monthly audits are neither reviewed nor monitored by the Assistant Sheriff of Corrections or the Undersheriff or any other neutral party. The independent audits conducted annually focus strictly on accounting of numbers and as such, do not address internal controls. Internal Controls provide guidance for establishing and maintaining an effective system of operations and accounting principles in accordance with the County's policies. Internal controls refer to the methods and procedures used to provide reasonable assurance regarding the achievement of objectives in the following categories: [4]