San Diego County Grand Jury
2021-2022
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Findings & Recommendations
6 findings
F1:
The City has received multiple notifications that holdover leases are a concern, yet the percentage of leases in holdover status has continued to increase. Fact: The Torrey Pines Gliderport lessee paid a required $5,000 deposit when it submitted a proposal for the 2016 RFP. Fact: The $5,000 fee was applied to the 2017 RFP, when no proposals from the 2016 RFP were deemed to be responsive. Fact: The current Torrey Pines Gliderport lessee was the successful bidder for the 2017 RFP, but the lease was not implemented due to the lessee’s required improvements being dependent on the unfunded Torrey Pines General Development Plan. Fact: DREAM retained the $5,000 fee, even though the 2017 RFP was not executed Fact: DREAM continues to hold the $5,000 agreement fee from 2016 and plans to use it to offset costs incurred in the three-year lease currently being negotiated.
F2:
There are processes in place for handling the faithful performance deposits for RFPs successfully executed, but no process found for handling deposits for successful RFPs that cannot be executed due to no fault of the proposer, resulting in extended retention of funds. Ibid. Fact: The 1998 lease for Torrey Pines Gliderport required public liability and property damage insurance in the amount of not less than $1 million Combined Single Limit Liability and not less than $1 million in third person liability covering flight operations. Fact: Since the 1998 lease is still in effect, required insurance coverage has not increased in 24 years. Fact: The 2016 and 2017 RFPs specified increased insurance coverage for public liability and property damage insurance in the amount of not less than $5 million Combined Single Limit Liability and not less than $5 million in third person liability covering flight operations. Fact: The three-year lease that will be finalized and executed in 2022 includes insurance requirements for $5 million for any one occurrence and $10 million aggregate, with the City as an additional insured
F3:
The increased insurance requirements in the pending 2022 three -year lease indicate a need for a substantial increase in coverage for the TPG, which could also be a concern for other properties in long-term holdover. Fact: There is no requirement in older, holdover current leases for annual property inspections at the Torrey Pines Gliderport.
F4:
DREAM does not have a consistent process for inspecting Torrey Pines Gliderport; property report forms do not include detail on resolution of deficiencies noted, nor responsible party. Fact: City Council Policies 700-10 (Disposition of City-Owned Real Property was last revised in 2012. Fact: The 2016/2017 Grand Jury recommended updating these documents and DREAM replied that this would be done by June 30, 2017. Fact: The February 2022 City Auditor report noted that these policies had not been updated.
F5:
DREAM had previously agreed to updating Council Policies 700-10 in 2017; five years later, this has not been done. Fact: The 2016/2017 Grand Jury found DREAM did not have adequate staffing to accomplish necessary tasks. Fact: Despite DREAM’s response to the 2016-2017 Grand Jury report indicating it would have adequate resources by 2017, inadequate staffing levels persist until this day. Fact: The February 2022 City of San Diego audit found that the department was significantly understaffed, and that budgeted positions have decreased instead of increased, since 2017.
F6:
Inadequate staffing is the reason for ongoing operational shortcomings, such as continuing large numbers of holdover leases, inconsistent documentation of insurance records, and irregular property inspections.
Additional Recommendations
6
Not linked to specific findings.
22-25:
Consider outsourcing or short-term hiring to facilitate the evaluation of all
22-26:
Consider developing a process for the return of good faith deposits to
22-27:
Create a process to review insurance requirements on holdover properties to
22-28:
Create a consistent and thorough process for inspecting leased properties in
22-29:
Update Council Policy 700-10, to better reflect current market realities and
22-30:
Conduct a comprehensive staffing analysis to ensure a plan and funding is
Findings and recommendations not yet extracted.
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Findings & Recommendations
3 findings
F01:
Transparency in the CFD process for the homeowner is available but not in a meaningful or helpful way. Fact: The previously cited Government Code sections include educational information about the CFD process.
F02:
Education for the buyer or homeowner does exist but only if they seek out information. Fact: California Government Code Section 53340.2 requires the legislative body to identify the responsible department, create procedures to respond promptly to inquiries concerning CFD levies on tax bills. Fact: The intended purpose of a special tax, administrative costs, why a CFD was created, and the duration of the CFD levies are not stated in a consumer-friendly manner Fact: In all the agencies studied, audits are not regularly performed on CFDs for financial concerns or performance issues.
F03:
Oversight of the CFD process is the critical missing ingredient to a comprehensive understanding of individual CFDs. Annual reports that are available are not meaningful to the average homeowner.
Additional Recommendations
4
Not linked to specific findings.
R4:
Assessments levied for maintenance. San Diego County sample tax bill. https://www.sdttc.com/content/dam/ttc/docs/new-homeowners-property-tax- guide.pdf. 64
R5:
Reasonable annual administrative costs. An annual escalation of costs may occur with a cap of 2% on the bonded indebtedness and 6% on the maintenance assessment for CFDs if used to fund public services. Any increases cannot exceed the 1.86% cap.4 It should be noted this tax burden cap applies at the time the CFD is adopted and is only applicable to the parcels within the region that is under the County of San Diego’s land use jurisdiction. Each agency is responsible for setting its own limits. Existing developments are exploring the use of CFD special taxes to fund business improvements, landscaping, and street improvements.
22-23:
Take immediate measures to create procedures, over and above what the law
22-24:
Create procedures for oversight, over and above what the law requires, to
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Findings & Recommendations
8 findings
F1:
Of the agencies interviewed, a majority are both issuing agency and processing agency. Although CVC 40220 language often refers to a “processing agency,” compliance requirements are logically presumed to apply to both issuing and processing agencies. Fact: CVC 40220 (1) (A) (ii) requires a processing agency to disclose “the availability of a low- income payment plan “a “person’s right to request an indigency determination,” and the “timeframe in which to apply” in both the notice of parking violation and on its public internet website, including “a web page link and telephone number to more information.” 5 5 COMPLIANT PARKING CITATION (SAMPLE TEXT): CVC 40220 allows for installment payments to qualifying low- income individuals who apply within 120 days from the issuance of a notice of parking violation, or within 10 days after an administrative hearing determination, whichever is later. For more information, including about applying and determining if you qualify, please call (list issuing agency phone number) or visit our website (list URL address). 117
F2:
During our investigation, the Grand Jury found, of the 24 issuing agencies’ written parking citation notices we solicited and inspected, these 11 municipalities, the San Diego County Sheriff’s contracted city services, plus five San Diego County community colleges were not compliant with AB 503 or AB 3277 amended CVC 40220 requirements: • Carlsbad • Chula Vista • Del Mar* • Encinitas* • Escondido • Imperial Beach* • Lemon Grove* • National City • Oceanside • Poway* • San Marcos* • San Diego County Sheriff’s Contracted Services • Grossmont-Cuyamaca College • MiraCosta College • Palomar College • San Diego Community College • Southwestern College *Cities using San Diego County Sheriff’s Contracted Services, including issuing parking citations Fact: The older AB 503 amended version of CVC 40220, approved September 2018, contained many of the current compliance requirements, but had a lower installment plan limit of $300, and specified a shorter 60-day deadline for filing a payment plan application.
F3:
The Grand Jury considered agency parking citation notices with an AB 503 version of CVC 40220, which does notify violators of the availability of a payment plan, to be partially compliant. During our review, these eight agencies had partially compliant citations: • Coronado • El Cajon • La Mesa • San Diego County • San Diego City Regional • Santee • Solana Beach • Vista 118 Fact: As per CVC 40220 (1) (A) (ii) (III) and (IV), in addition to the compliance requirements for a parking violation notice, a processing agency’s public internet website must also include “clear language about how the person can request an indigency determination…” plus the “documents needed by the processing agency to make an indigency determination.”
F4:
During our investigation, the Grand Jury found some agencies already had AB 3277 fully compliant webpages, or AB 503 partially compliant webpages. They are: • Chula Vista • El Cajon • Encinitas • Escondido • La Mesa • Poway • San Diego City • San Diego County Sheriff • San Marcos • Vista
F5:
Website compliance revisions can be measured in real time. As of May 10, 2022, the Grand Jury found that these previously non-compliant agency websites are now CVC 40220 compliant: • Carlsbad • Coronado • Del Mar • Imperial Beach • National City • Oceanside • Santee Fact: An issuing agency that contracts with a private vendor for processing/collection services is mandated to follow the procedures of CVC 40200.6 (b) “The governing body of the issuing agency shall establish written policies and procedures pursuant to which the contracting party shall provide services.” And CVC 40200.6 (c) “The issuing agency shall be responsible for all actions taken by contracting parties and shall exercise effective oversight over the parties”
F6:
Contracting a processing/collection service does not excuse a public issuing or processing agency from CVC 40220 compliance requirements. The Grand Jury found these public agency websites had no informational payment plan webpages or verbiage. And/or their linked contracting vendor’s main/landing webpage did not have CVC 40220 information, or the information was not “readily accessible in a prominent location.” Therefore, as of May 10, 2022, these agencies were not compliant. • Lemon Grove 119 • Solana Beach Fact: CVC 40220 (1) (D) (i) requires state universities and community colleges to "adopt a parking citation payment plan for persons with multiple unpaid parking citations," with a policy that includes abeyance of late fees and no DMV itemization. Alternatively, CVC 40220 (1) (D) (ii) requires a “district governing board that fails to implement a parking citation payment plan pursuant to clause (i) shall implement the payment plan as provided in subparagraphs [1] (A) to [1] (C), inclusive, and subdivision (c),” (the same compliance requirements that apply to other processing agencies).
F7:
Four of the five community colleges interviewed by the Grand Jury did not adopt their own payment plan policy – but used CVC 40220 (1) (A) to (C). As of May 10, 2022, the Grand Jury found that these previously non-compliant websites are now compliant: • Grossmont-Cuyamaca Community College • MiraCosta Community College • Palomar Community College • Southwestern Community College
F8:
Community colleges that adopt their own parking citation payment plan policy must consider this compliance requirement, CVC 40220 (1) (D) (i) (III) “Each California State University and community college district campus shall post the parking citation payment policy on its internet website for students’ awareness and access.” With only one sentence on one webpage, with no parking citation payment policy postings, or any additional information or weblinks, the Grand Jury finds this website non-compliant: • San Diego Community College District – San Diego City College
Additional Recommendations
6
Not linked to specific findings.
22-49:
Revise their parking citation notices to be CVC 40220 compliant with
22-50:
Revise their parking citation notices to be CVC 40220 compliant with
22-51:
Revise their parking citation notices to be CVC 40220 compliant with
22-52:
Revise their parking citation notices to be CVC 40220 compliant with
22-53:
Ensure that revisions to their website be completed no later than
22-54:
Ensure that revisions to their website be completed no later than
Findings & Recommendations
2 findings
F1:
As a result of funding shortfalls, crime labs are understaffed and under-equipped to meet SB 22 requirements. Assembly Bill 18 Language, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB18. Fact: To meet SB 22 mandated SAK testing timeframes without funds for additional staff and equipment, crime labs have shifted priorities and personnel away from other areas, such as: homicides, gang shootings, child abuse, property crimes, narcotics, and firearms testing. Fact: Ample financial resources are required for prioritized DNA evidence testing, because analysis is a costly service. Fact: The SDPD Crime Lab outsourced the testing of 1,806 backlogged SAKs to Bode Labs at a cost of $885/kit, for a total cost of approximately $1.6 million. Fact: SDPD continues to use Bode Labs for current SAK testing throughout 2022 at a new contracted price of $1,975/kit – over twice the original cost to test historical kits.
F2:
Availability of resources is often a limiting factor in the processing of Sexual Assault Kits (SAKs). Any concerted effort to process SAKs in a timely manner must include adequate staffing and financial resources.
Additional Recommendations
4
Not linked to specific findings.
22-19:
The Chief Administrative Officer for the County of San Diego lobby the
22-20:
The San Diego County Board of Supervisors increase budgetary appropriations
22-21:
The Government Affairs Department for the City of San Diego lobby the
22-22:
The San Diego City Council to increase budgetary appropriations that will
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Findings & Recommendations
4 findings
F1:
Not all LEAs are in compliance with AB 27 and SB 400. Fact: The McKinney-Vento Homeless Assistance Act required Local Educational Agencies to “disseminate public notice of rights for unhoused students in locations frequented by parents and youth, in a manner and form understandable to them.” This includes posters not only in the school, but at the local library, shelters, health centers, etc.
F2:
A stronger focus on coordination of efforts between schools and SDCOE and state agencies would also facilitate a more integrated, comprehensive response to the problem. Fact: AB 27 and SB 400 require that a school shall post contact information for both the district liaison and school liaison (if there is one) on its website.
F3:
Few districts and schools surveyed have easy to find contact information on their websites. Fact: McKinney-Vento Act states that school personnel receive professional development and training. Fact: Although training may be offered, attendance is not required and there is insufficient documentation to prove attendance. Indeed, many schools reported “none” for training.
F4:
Although districts offer training, there is inconsistency in training, content, and requirements.
Additional Recommendations
4
Not linked to specific findings.
22-15:
Work with all LEAs to immediately come into compliance with AB 27 by
22-16:
Assist district liaisons to coordinate with school liaisons to implement
22-17:
Coordinate a review of all school and school district websites to ensure
22-18:
Advocate with school and district leadership to invest in training and
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Findings & Recommendations
3 findings
F1:
Traditional public relations and/or educational outreach is not improving public and political support for wastewater and stormwater reuse as potable water. The Public awareness of the Pure Water Program is limited. Fact: There are no current federal regulations specifically governing potable water reuse in the United States. State regulations, policies and federal guidance addressing aspects of the reclamation process exist, including requirements for wastewater treatment, and drinking water treatment. Fact: The EPA sets national enforceable drinking water standards and retains oversight authority over tribal and federal and state, water programs. Fact: State agencies collect large amounts of information regarding water use that could support improved local and regional water system resilience. Fact: Comprehensive regulations do not exist for some of the direct potable reuse projects, making permitting and public acceptance a challenge.
F2:
The California State Water Resources Control Board is developing regulations for potable reuse. In 2014, Board’s Division of Drinking Water finalized groundwater replenishment regulations, which were incorporated in the recycled water-related regulations. In 2017, Assembly Bill 574 was signed into law and established a deadline of December 2023 for initial State Direct Potable Reuse regulations. Fact: 9.4 million people in California urban service areas (35% of those served) live in low income, rural, or underserved regions with limitations to their water access. Fact: The IRWM Water Needs Assessment seeks to engage, or increase engagement of, disadvantaged communities with the Integrated Regional Water Management Program. Fact: Californians dependent upon small water systems or private wells are vulnerable to groundwater contamination. As the water table drops, larger suppliers balance the potential threat of emerging contaminants against their ability to supply water. These concerns are addressed by the recently passed State of California Senate Bill 552. Fact: SDCWA and the San Diego Regional Water Quality Control Board supports the capacity, participation, and full integration of tribal governments and DACs in regional planning processes.
F3:
The implementation of SB-552 is important for small water suppliers in rural areas. Recently approved State of California legislation encourages the development of water shortage strategic plans and encourages administrative funding to mitigate the impact of drought and to promote water resiliency and water re-use.
Additional Recommendations
11
Not linked to specific findings.
22-31:
Support regional water reclamation efforts by improving public trust in the safety and
22-32:
Support small water agencies in their efforts to comply with new laws for agency water
22-33:
Solicit the participation of small water suppliers and DACs in water re-use policy and
22-34:
Support water reclamation efforts by improving public trust in the safety and benefits of
22-35:
Incorporate new current state regulatory standards for potable water reuse into their
22-36:
Support small water agencies in their efforts to comply with new laws for agency water
22-37:
Solicit the participation of small water suppliers and DACs in water re-use policy and
22-38:
Support the City of San Diego water reclamation efforts by improving public trust in the
22-39:
Incorporate new current state regulatory standards for potable water reuse into their
22-40:
Support small water agencies in their efforts to comply with new laws for agency water
22-41:
Solicit the participation of small water suppliers and DACs in water re-use policy and
Findings & Recommendations
6 findings
F1:
The use of Smart Streetlights cameras as previously used prior to September 2020, enhances public safety. Fact: As previously used, the proposed usage of Smart Streetlight camera footage is as an investigative tool only.
F2:
A resumption of utilization of Smart Streetlights would not create any valid privacy issues. Fact: Violent crime in the City of San Diego is on the rise.
F3:
The recent dramatic rise in crime in the City of San Diego, approaching the level of exigent circumstances, dictates that in the interest of public safety there is an urgent need for San Diego Police to be able to use Smart Street lights.
F4:
This exigent need requires one time accelerated legislative action to make needed contracts fiscal appropriations. Ibid. San Diego Police Department Slide Presentation, op. cit. Fact: In 2016, the City of San Diego bought Smart Streetlights Technology financed with a loan from General Electric (GE) in the amount of $30.23 million. Fact: Between 2016 and 2018, the City of San Diego installed some, but not all, of the Smart Streetlights. Fact: Although the cameras are no longer in use, the City of San Diego continues to make annual payments of $2.3 million to repay the GE loan.
F5:
The City of San Diego’s continual annual loan repayments of $2.3 million for equipment that is still in the possession of the City but no longer in use, is fiscally irresponsible. Fact: Special interest groups, including law enforcement, are understandably concerned about an invasion of their privacy rights when the government uses new technology. Fact: Privacy Advisory Boards/Boards are good tools to help legislators understand the complexities of new technology. Fact: The April 5, 2022, legislation establishing a Privacy Advisory Board makes no provision for inclusion of representatives from law enforcement or Victims’ Rights Advisory Groups. Fact: Best practices documents state that “city council decisions are more likely to be seen as fair and considerate if all people having a stake in the outcome” are involved. Fact: The City Ordnance establishing the Privacy Advisory Board requires the Mayor to appoint 9 members subject to City Council approval.
F6:
A fair, balanced, and unbiased Privacy Advisory Board should include culturally diverse representation from across the spectrum of professions, to include law enforcement, and victims’ rights advocates to ensure citizen’s rights are being protected while enabling law enforcement to continue providing for the public’s safety.
Additional Recommendations
5
Not linked to specific findings.
22-44:
Immediately consider issuing an executive order to rescind the previous
22-45:
Consider appointing members of law enforcement and victims' rights
22-46:
Consider, in the event the moratorium is lifted, enacting fiscal appropriations
22-47:
Recognize this immediate action is being taken because of exigent
22-48:
Approve a composition of the Privacy Advisory Board that includes law
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Findings & Recommendations
2 findings
F1:
The COVID-19 virus presents a serious risk to the staff and inmates at San Diego County’s detention facilities and to the public health and safety generally. Fact: The CDC permits the use of both rapid antigen and NAATs (including the PCR method) to detect COVID-19 infection. Fact: Rapid antigen tests generally return results more quickly than a PCR test. Fact: Most NAATs require laboratory processing and the turnaround time for test results is usually one to three days. Fact: At the time of the Grand Jury inspections, conducted from August 2021 to December 2021, the SDSD administered only PCR tests.
F2:
At the time of the Grand Jury inspections, SDSD arrestees may have been unnecessarily exposed to COVID-19 because of the delayed test results.
Additional Recommendations
2
Not linked to specific findings.
22-42:
Amend its CODVID-19 prevention protocal to required mandatory COVID-19
22-43:
Test all arrestees at intake with rapid antigen tests approved under the FDA's
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Findings & Recommendations
9 findings
F01:
While it is recognized that presentations by AIS and the San Diego County District Attorney’s Elder Abuse Unit have included an overview of all types of elder abuse, the majority of the recent focus has been on elder scams and financial abuse. Fact: County agencies are primarily sharing information about elder abuse with small select groups. Fact: An expanded awareness of elder abuse is included in the safety section of the “Aging Roadmap” presented to the Board of Supervisors in September 2019. Fact: AIS’s initial action steps to expand awareness of elder abuse include developing and conducting a community awareness campaign of signs of elder abuse and how to report suspected elder abuse. 22 “Health and Community Support,” Attachment A, of Update on the Aging Roadmap and the County’s Aging Initiatives, September 15, 2020, https://www.livewellsd.org/content/dam/livewell/topics/aging/roadmap/Aging%20Roadmap%20Board%20Letter %20and%20Attachment%20A.pdf. Ibid. 24 “Senior Centers: What We Have Now and What We Need,” San Diego Seniors Community Foundation, Summer 2019, , https://sdscf.org/wp-content/uploads/2019/08/San-Diego-Senior-Center-Assessment-2019.pdf. 34
F1:
The EPC engages an extensive list of stakeholders in routine collaboration to address the issue of elder abuse in San Diego County; however, the County’s commitment to coordinating a response to elder abuse has not extended to include CBSC managements’ attendance at scheduled meetings of both EPC and AIS. Fact: California Welfare & Institutions Code Section 15630 establishes legal responsibility for mandated reporting as well as penalties for failure to report. Fact: Mandated reporter training is accessible for agency use on both State and San Diego County websites or through Aging & Independence Service Outreach and Education Teams.
F02:
Presentations to small select groups do not achieve the expanding of public awareness of the signs of elder abuse and how to report suspected elder abuse to the extent as outlined in the “Aging Roadmap.” Fact: While AIS has begun to increase public awareness of signs of elder abuse and how to report suspected elder abuse and needs, a larger audience could be reached through the use of media.
F2:
Regardless of whether CBSC staff qualify as mandated reporters, since the staff of CBSCs interact on a regular basis with their senior clientele, receiving mandated reporter training would be beneficial for them to recognize signs of elder abuse and how to report suspected elder abuse. Fact: CBSCs are regularly used by seniors and are a critical point for addressing elder abuse.
F03:
Forms of media such as billboard signage, social media, and TV and radio public service announcements would provide opportunities for expanding public awareness of signs of elder abuse and how to report suspected elder abuse. Fact: Between AIS, APS, the San Diego County District Attorney’s Elder Abuse Unit, and eight additional county-wide law enforcement agencies, there are multiple phone numbers for reporting elder abuse.
F3:
Since CBSCs are regularly used by seniors, there exists an opportunity for educating their clientele and the local community about the types of elder abuse and how to report suspected elder abuse. Fact: An update given to the San Diego County Board of Supervisors by the Health & Human Services Agency stated: “The Age Well Health & Community Support Team envisions communities that offer accessible health and community services, technology to support aging in place, and village-like support systems”. Fact: “Technology Training and COVID-19” and “Technology to Support Aging in Place” were included in the update to the Board of Supervisors, both acknowledging the technology divide among senior adults and the resulting inability for senior adults to access relevant services.
F04:
Multiple phone numbers for reporting suspected elder abuse could cause confusion and frustration for the public and subsequently cause failure to report. Community-Based Senior Centers (CBSC) Fact: The San Diego County Elder and Dependent Abuse Blueprint was unveiled in 2018 with a commitment to coordinate a community response to elder abuse through communication, collaboration, cooperation, and training. Fact: The Elder Protection Council (EPC) was subsequently created and designed to bring together law enforcement, health and aging officials, County prosecutors, and other community agencies to work collaboratively in addressing and reducing incidence of elder abuse. Fact: The EPC meets quarterly or tri-annually with approximately 80-100 participants from various sectors including the San Diego County District Attorney’s Office, law enforcement, licensing agencies, FBI, community partners, hospitals, social workers, and care agencies to build relationships between parties, learn what is being done, and coordinate efforts to reach their mission. Fact: AIS has no legal obligation or authority over CBSCs and consequently provides no oversight of CBSCs.
F4:
Since CBSCs are routinely used by seniors, an opportunity exists to create on-site hubs of technology access along with training for those needing assistance to access support for safe, healthy, and independent living. Fact: CBSCs face the challenge of providing maximum services to their clientele on a minimal budget dependent on their individual city’s general funds, grants, and membership or activity fees.
F5:
CBSC’s budgetary constraints hinder hiring adequate qualified staff, developing relevant programs, and creating dedicated space with computer workstations for senior clientele access.
Additional Recommendations
14
Not linked to specific findings.
22-1:
Focus presentations on all areas of elder abuse, not just the recent focus on
22-2:
Provide information regarding signs of elder abuse and how to report
22-3:
Expand public awareness of signs of elder abuse and how to report suspected
22-4:
Seek additional funding (for example, grants and reallocating a portion of
22-5:
Recognize World Elder Abuse Awareness Day (June 15) as an annual
22-6:
Advertise the San Diego County Adult Protective Services hotline number in all
22-7:
Focus presentations on all areas of elder abuse, not just the recent focus on
22-8:
Provide information regarding signs of elder abuse and how to report
22-9:
Establish and coordinate a consortium comprised of CBSC management to
22-10:
Advocate for mandated reporter training of CBSC staff.
22-11:
Create and provide a digital presentation regarding all-inclusive areas of elder
22-12:
Work with CBSCs to secure funding for the creation of on-site hubs of
22-13:
Work with CBSCs to secure funding for hiring adequate, qualified staff and
22-14:
Include representation from CBSCs on the Elder Protection Council to keep