Department of Motor Vehicles: Administrative and Statutory Changes Will Improve Its Ability to Detect and Deter Misuse of Disabled Person Parking Placards

Department of Motor Vehicles

Administrative and Statutory Changes Will Improve Its

Ability to Detect and Deter Misuse of Disabled Person

Parking Placards

Report -

April 

COMMITMENT

INTEGRITY

LEADERSHIP

For questions regarding the contents of this report, please contact MargaritaFernández, Chief of Public Aﬀairs, at ..

This report is also available online at www.auditor.ca.gov | Alternate format reports available upon request | Permission is granted to reproduce reports

 Capitol Mall, Suite  | Sacramento | CA | 

CALIFORNIA STATE AUDITOR

.. | TTY ..

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Doug Cordiner Chief Deputy

Elaine M. Howle State Auditor

621 Capitol Mall, Suite 1200 Sacramento, CA 95814 916.445.0255 916.327.0019 fax www.auditor.ca.gov

April 18, 2017 2016-121

e Governor of California

President pro Tempore of the Senate

Speaker of the Assembly

State Capitol

Sacramento, California 95814

Dear Governor and Legislative Leaders:

As requested by the Joint Legislative Audit Committee, the California State Auditor presents this audit

report concerning the Department of Motor Vehicles’ (DMV) disabled person parking placard program.

Disabled person parking placards (placards) and disabled person or disabled veteran license plates (plates)

allow people to park in parking spaces for people with disabilities, in metered spaces without paying

the meter, and in time-limited spaces without having to worry about those limitations. ese beneﬁts

create a signiﬁcant incentive for misuse. is report concludes that changes to DMV’s administration,

and statutory changes by the Legislature, will allow for better detection and deterrence of the misuse of

placards andplates.

DMV does not suﬃciently ensure that applications for placards or plates are legitimate. For example, we

found that medical providers certifying the majority of applications we reviewed did not include suﬃcient

information regarding the placard holder’s disability to meet requirements in state law. In addition, we

questioned whether the signatures of medical providers on several of the applications we reviewed matched

information on ﬁle with the appropriate Department of Consumer Aﬀairs’ healing arts boards (health

boards), and noted that DMV does not work with the health boards to review selected applications, as

state law allows. Further, DMV has not canceled permanent placards of thousands of individuals who are

likely deceased. Speciﬁcally, we compared the name and date of birth of active placard holders from DMV’s

data to the U.S. Social Security Administration’s Death Master File and identiﬁed nearly 35,000 matches.

We also found that, as of June 30, 2016, nearly 26,000 placard holders were age 100 or older, despite an

estimated centenarian population in California of roughly 8,000. Further, some permanent placard holders

have requested an unusually high number of replacements for lost or stolen placards, and state law does

not limit the number of replacements a holder may receive. However, DMV had not identiﬁed any of

these issues because it does not actively analyze placard applications or application data and, consequently,

DMV may be allowing people to fraudulently obtain placards.

Additionally, although DMV’s Investigations Unit performs eﬀective sting operations to catch those

misusing placards, it has not established speciﬁc expectations for the number of operations its district

oﬃces should conduct. In each of the sting operations we reviewed, investigators found an average misuse

rate of 15 percent. However, we noted great variance in the number of sting operations that six of DMV’s

district oﬃces conducted, ranging from one to 18 during ﬁscal years 2013–14 through 2015–16. By not

establishing reasonable goals to conduct regular sting operations, DMV fails to detect and deter as much of

the continued placard misuse as it can, which aﬀects those with disabilities who need special parking access.

Finally, local parking enforcement lacks immediate access to DMV’s placard information, preventing these

oﬃcials from eﬃciently identifying and seizing misused placards.

Respectfully submitted,

ELAINE M. HOWLE, CPA

State Auditor

Blank page inserted for reproduction purposes only.

vCalifornia State Auditor Report 2016-121

April 2017

Contents

Summary 1

Introduction 7

Chapter 1

Inadequate Processes for Reviewing Applications and Revoking

Placards Increase Misuse 15

Recommendations 30

Chapter 2

Better Communication and Coordination Will Help Detect and

Deter Misuse of Disabled Person Parking Privileges 33

Recommendations 47

Appendix A

A Comparison Between Parking Beneﬁts for People With Disabilities

in California and SelectOther States 51

Appendix B

Disabled Person Parking Placard Abuse Cases Investigated by

theDepartment of Motor Vehicles’ Investigations Unit,

Fiscal Years 2013–14 Through 2015–16 53

Appendix C

Scope and Methodology 55

Responses to the Audit

California State Transportation Agency 61

Department of Motor Vehicles 63

vi California State Auditor Report 2016-121

April 2017

Blank page inserted for reproduction purposes only.

1California State Auditor Report 2016-121

April 2017

Summary

Results in Brief

In reviewing the State’s disabled person parking placard program

(placard program), we identiﬁed several improvements the

Department of Motor Vehicles (DMV) and the Legislature can

make that will reduce fraud and misuse. For example, DMV does

not suﬃciently review applications for disabled person parking

placards (placards) and disabled person or disabled veteran license

plates (plates) to ensure they are legitimate. Further, DMV issues

renewal placards to many thousands of placard holders who are

likely deceased because its process for identifying them is limited.

Also, we found that state law provides no limitations on the number

of replacement placards a person may receive, and we noted that

two people each received more than  replacement placards over

three years. In addition, we found that the enforcement of placard

misuse would improve if DMV established reasonable goals for

the number of enforcement activities it conducts. Finally, DMV

could provide parking enforcement oﬃcials better information to

determine whether a placard is valid or being misused.

California grants special parking privileges to people with certain

disabilities outlined in state law. ese people may apply for a placard

to display in their vehicle or for a special license plate. To obtain

placards or plates, they must submit a two-page application to DMV

that includes a description of the disability and a certiﬁcation from

an authorized medical provider. Both placards and plates allow these

permitted individuals to park in parking spaces designated for people

with disabilities, in metered spaces without paying the meter, and in

time-limited spaces without having to worry about those limitations.

ese beneﬁts create a signiﬁcant incentive for misuse.

Our review of applications for placards and plates found that

most medical providers are not including enough information

on applications when certifying disabilities. State law requires

authorized providers to fully describe the illness or disability that

qualiﬁes the applicant for disabled person parking privileges.

We expected that DMV would have a process in place to work

with the Department of Consumer Aﬀairs’ healing arts boards

(healthboards)—those responsible for licensing and investigating

complaints against medical providers—to review a selection

of these applications, as state law allows. However, DMV does

not have agreements in place with the health boards. With the

assistance of medical experts from the health boards, we reviewed

a representative sample of  original applications DMV approved

and found that applications, or  percent, did not include

a full description of the illness or disability. Projecting to the

population of applications for placards or plates as a whole, this

Audit Highlights . . .

Our review concerning the California

Department of Motor Vehicles’ (DMV)

disabled person parking placard

program highlighted the following:

» DMV does not suﬃciently ensure

applications for disabled person parking

placards (placards) and disabled person

or disabled veteran license plates (plates)

are legitimate.

• Out of 96 applications we sampled,

DMV approved 70 applications that

did not include suﬃcient medical

information to demonstrate that the

applicant qualiﬁed.

• DMV approved applications that

contained certiﬁcations of disabilities

by unauthorized medical providers.

• DMV does not ensure the validity of

medical provider signatures.

» DMV has not canceled permanent

placards for individuals who are likely

deceased—as of June 30, 2016, nearly

26,000 placard holders were age 100

or older.

» State law provides no limits on the

number of replacement placards a person

may receive.

» DMV has not established speciﬁc

expectations to conduct regular sting

operations for its district oﬃces.

» Local parking enforcement lacks

immediate access to DMV’s placard

information, limiting its ability to verify

placards during enforcement activities.

California State Auditor Report 2016-121

April 2017

suggests that DMV approved up to . million applications from

July  through June  without suﬃcient information to

demonstrate that the applicant was qualiﬁed. According to the

deputy chief of DMV’s Investigations Unit (Investigations), DMV

has not worked with thehealth boards to review applications

because DMV assumedthe health boards would not provide

DMV with information due to the privacy requirements in federal

law. However, the medical experts we worked with were able to

identify deﬁciencies in the applications without needing to review

additional sensitive information. When DMV does not ensure that

applicants include complete certiﬁcations, it creates opportunity for

individuals to receive placards without a qualifying diagnosis.

Further, DMV does not have a process to review medical provider

signatures to ensure that they are legitimate. DMV requires those

medical providers certifying disabilities on placard applications to

sign the applications. We compared the medical provider signatures

included in our sample of  applications to oﬃcial documents

maintained by the boards that provided their medical licenses. Based

on this comparison, we question whether  of the medical providers’

signatures reasonably matched oﬃcial documents. Again, projecting

this percentage of questionable signatures to the population of

applications, we estimate that more than , applications

approved from July  to June  may not be valid. When DMV

does not review the validity of medical provider signatures, it risks

issuing placards to individuals who submit fraudulent certiﬁcations.

DMV has not canceled permanent placards for thousands of

individuals who are likely deceased. State law requires DMV to match

placard records with the California Department of Public Health’s

(Public Health) Vital Statistics ﬁle and to withhold renewals for

permanent placard holders identiﬁed as deceased. DMV performs

this match monthly. However, we compared the name and date of

birth of active placard holders from DMV’s data to the U.S. Social

Security Administration’s Death Master File (master ﬁle) and

identiﬁed nearly , matches. Although this comparison indicates

that DMV likely has not canceled thousands of deceased individuals’

placards, these results are not precise. For example, there might be

a deceased person in the master ﬁle with the same name and date

of birth as a placard holder in California who is alive. To identify

deceased individuals using Public Health’s data, DMV relies on

matches of the full name and date of birth. However, we found that

DMV’s data did not always include correct names. Further, according

to thechief ofDMV’s registration operations division (registration

division chief), DMV does not require applicants to provide

documentation of their full legal name because DMV believes it

lacks authority in state law to refuse applicants who do not provide

such veriﬁcation. As a result, someone intending to commit fraud

could fabricate an application on behalf of a nonexistent or deceased

3California State Auditor Report 2016-121

April 2017

relative, and DMV might well approve the application and issue the

individual a permanentplacard. Also, based on a separate analysis,

as of June , , we identiﬁed nearly , placard holders in

DMV’s data that were age  or older. is number is signiﬁcantly

higher than the estimated , individuals that comprised

California’s entire centenarian population as of , indicating

that DMV’s process for canceling placards of deceased individuals

isinadequate.

In addition, some permanent placard holders have obtained

many replacements. In reviewing DMV data, we found that

nineindividuals received  or more placards each from July

through June , including two who each received more than

replacements over that period. State law allows individuals to

request replacement placards in the event their permanent placard

is lost or stolen, and it does not limit the number of replacements

an individual can receive. When state law allows individuals an

unlimited number of permanent placard replacements, the number

of placards in circulation and available for misuse grows.

e most common type of placard fraud DMV observes involves

one person using another person’s valid placard. To catch this

type of fraud or misuse, Investigations conducts sting operations

wherein an investigator approaches a driver displaying a placard or

plate and veriﬁes that the placard or plate belongs to the driver or to

someone being transported by the driver. However, Investigations

has not established speciﬁc expectations for the number of sting

operations its district oﬃces must conduct. As a result, we found

great variance across district oﬃces, ranging from one to sting

operations from ﬁscal years – through –. According

to the deputy chief of Investigations, some oﬃces did not conduct

many sting operations because DMV has higher investigative

priorities such as identity theft. Nevertheless, by not establishing

reasonable goals to conduct regular sting operations, DMV fails

to detect and deter as much of the continued placard misuse

as it can, which aﬀects those with disabilities who need special

parkingaccess.

In addition, local parking enforcement lacks immediate access to

DMV’s placard information, limiting its ability to verify placards

during its enforcement activities. Only law enforcement oﬃcials

who are sworn peace oﬃcers have direct, immediate access to

this information, whereas parking enforcement oﬃcers, who are

non-sworn, do not. We spoke to parking enforcement oﬃcials

in sixcities across the state—Berkeley, Fresno, LosAngeles,

Sacramento, San Francisco, and Santa Cruz—and none reported

having immediate access to DMV’s placard information. Instead,

they generally must call local law enforcement dispatchers each

time they need to verify a placard number. However, this process

California State Auditor Report 2016-121

April 2017

is time consuming, and four of the six oﬃcials we spoke with

conﬁrmed that their parking enforcement oﬃcials typically do

not contact a dispatcher to determine whether placards are valid.

According to the registration division chief, DMV could create

and maintain a database containing the requisite information.

is database could be used to grant immediate access to local

enforcement oﬃcials in lieu of contacting local law enforcement.

Without such a database, local parking enforcement cannot

eﬃciently identify and seize placards that drivers are misusing.

Selected Recommendations

Legislature

To increase DMV oversight of applications for placards or plates,

the Legislature should modify current law to require DMV to

conduct at least quarterly audits of a selection of applications for

placards or plates and to seek the health boards’ cooperation in

doing so.

To assist DMV in more accurately identifying deceased individuals

with active permanent placards, the Legislature should amend state

law to require DMV to use the U.S. Social Security Administration’s

Death Master File to inform its eﬀorts to identify and cancel

deceased individuals’ placards.

To assist DMV in identifying deceased placard holders, the

Legislature should require that all who apply for a placard or

plate include their full legal name and date of birth, and provide

satisfactory proof of this information at the time of application.

To reduce the risk of placard misuse, the Legislature should limit

to no more than two the number of replacements of permanent

placards an individual may obtain during the two-year placard

renewal period. e Legislature should require that those

desiring replacements beyond that limit reapply and submit new

certiﬁcations of disability.

DMV

To reduce the risk of fraudulent applications, by September 

DMV should seek interagency agreements with the health boards

responsible for licensing providers authorized to certify disabilities

on placard applications. e agreements should include, but not be

limited to, the following:

5California State Auditor Report 2016-121

April 2017

• A review by medical experts of a sample of placard applications

each quarter to ensure that the disability certiﬁcations

meetstaterequirements. For any application that does not meet

state requirements, DMV should require that the applicant and

his or her provider submit the information needed so thatthe

application meets state requirements. DMV should cancel

theplacards of those who do not respond within  days.

• A process for obtaining copies of provider signatures and

routinely comparing the signatures with those on a sample of

placard applications. Investigations should conﬁrm questionable

signatures with providers.

To better deter placard abuse, by September  DMV should

establish reasonable goals regarding the number of sting operations

each of its district oﬃces should conduct each quarter. If competing

priorities require a district oﬃce to miss its goal for a given quarter,

Investigations should document its justiﬁcation for missing the

goal. Further, Investigations should monitor its district oﬃces’

eﬀectiveness in meeting the quarterly goals.

To better equip local parking enforcement oﬃcials to promptly

identify invalid placards, by December  DMV should develop

and implement an application, database, or other technology

that will allow non-sworn parking enforcement oﬃcials to have

immediate access to information on placard status.

Agency Comments

DMV agreed with our recommendations and stated that it will

implement them.

6 California State Auditor Report 2016-121

April 2017

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7California State Auditor Report 2016-121

April 2017

Introduction

Background

State law allows people with disabilities to apply to the Department

of Motor Vehicles (DMV) for a disabled person parking placard

(placard) or disabled person or disabled veteran license plate (plate).

Speciﬁcally, placard or plate holders may park for an unlimited

time in parking spaces with posted time limitations and may park

in metered spaces for an unlimited time without having to pay

meter fees. In addition to free, unlimited parking, displaying a valid

placard or plate permits the holder to park in blue zones and certain

designated parking stalls and spaces that are restricted to those

displaying such a placard or plate.

DMV oﬀers license plates and three types of placards:

temporary, travel, and permanent. Figure  on the following

page depicts thediﬀerent types of plates and placards. People

with a temporarydisability, such as a broken leg, can apply for a

redtemporary placard. ese placards are valid for up to sixmonths

and are renewable up to six consecutive times. People with a

permanent qualifying disability can receive a blue permanent placard

and canalso receive a license plate. Permanent placards expire on

June of every odd-numbered year, and DMV automatically issues

and mails renewal placards. Finally, a travel placard is a temporary

placard that DMV issues to permanently disabled people meeting

the disability requirements in state law. DMV issues this placard to

nonresidents for no more than days and to California residents

for no more than  days. Travel placards are for use when a placard

holder would not have the original placard available. For example,

the placard holder leaves a car parked at an airport but also needs a

placard for a rental vehicle at their California destination.

e application for both plates and placards is identical. Individuals

may apply for them in person at DMV ﬁeld oﬃces throughout

the state or by mail through DMV’s oﬃces in Sacramento.

As of

June,, there were approximately . million placards and

plates active in California. Figure  on page  shows the proportions

of this number that are permanent placards, temporary placards,

and plates. Plates are associated with a speciﬁc vehicle. On the other

hand, placardsare associated with the applicant, who need not be a

driver. State law allows others, such as parents or family members,

who are transporting a disabled person to use a placard. As of

June, , the median age of placard holders was ; however,a

DMV has ﬁeld oﬃces in more than  locations throughout the state that oﬀer a variety of

services, such as vehicle registration and driver’s license processing, in addition to accepting

placard or plate applications. DMV’s Investigations Unit has  district oﬃces throughout the

statewhere DMV’s investigators work.

8 California State Auditor Report 2016-121

April 2017

Figure 1

Types of Disabled Parking Placards and License Plates

Permanent Placard

TYPE IMAGE DESCRIPTION

A placard that has a ﬁxed expiration date of June 30 every

odd-numbered year, and that the DMV issues to a permanently

disabled person who meets the disability requirements in

state law.

Temporary Placard

A placard that the DMV issues for a maximum of six months to a

temporarily disabled person meeting the disability requirements

in state law. Individuals may renew temporary placards up to

six consecutive times.

Travel Placard

License Plate

A placard that the DMV issues to permanently disabled people

meeting the disability requirements in state law. The DMV issues

this placard to nonresidents for no more than 90 days and to

California residents for no more than 30 days. It is for situations

where a placard holder would not have the original placard

available. For example, the placard holder leaves a car parked at

an airport but also needs a placard for a rental vehicle at his or her

California destination.

A special license plate the DMV issues to vehicle owners

with permanent disabilities and is only valid on the

vehicle it is assigned to.

Disabled Veteran

License Plate

A special license plate the DMV issues to vehicle owners

who are veterans of the armed services with permanent

disabilities. The State does not assess vehicles with these

plates an annual vehicle license fee.

Sources: DMV and California state law.

9California State Auditor Report 2016-121

April 2017

person of any age may have a placard, including children.

Forexample, in our random sample of placard applications that

DMV received from July  through June, one was for an

individual under the age of ﬁve years. DMValso issues some plates

and placards to organizations that transport disabled individuals.

State law limits any applicant to one active permanent placard at

atime.

Figure 2

Disabled Person Parking Placards and Plates Active as of June 30, 2016

Temporary Placards—130,000 (4%)

Permanent Placards—

2.4 million (83%)

Plates*—381,000 (13%)

Total Disabled

Person Placards

and Plates

2.9 million

Source: California State Auditor’s analysis of data obtained from DMV’s Vehicle/Vessel Registration

Master File.

Note: An individual may own multiple disabled person or veteran license plates and a single

disabled person parking placard.

* The term plates includes disabled person and disabled veteran license plates.

Obtaining a placard or plate requires certiﬁcation by a medical

provider of the applicant’s disability unless the disability is readily

observable and uncontested. Alternatively, disabled veterans may

submit a certiﬁcate from the United States Department of Veterans

Aﬀairs in lieu of submitting a certiﬁcation by a provider. State law

establishes the disabilities that qualify for the program, and DMV

places these disabilities into eight categories on its application.

Further, state law speciﬁes the types of providers who may certify

disabilities for obtaining a plate or placard, and it limits the types

of disabilities certain providers may certify. For example, only

optometrists or physicians and surgeons with a specialization in

diseases of theeye may certify that an applicant is legally blind.

Table  on the following page lists the types of qualifying disability

categories and the types of providers that may diagnose them.

10 California State Auditor Report 2016-121

April 2017

Table 1

DMV Disability Categories and Medical Provider Types

DISABILITY CATEGORIES PROVIDER MAY CERTIFY*

MEDICAL PROVIDER TYPES

SEVERE

LUNG

DISEASE

SEVERE

CARDIOVASCULAR

DISEASE

SUBSTANTIALLY

IMPAIRED

MOBILITY

UNABLE

TO MOVE

WITHOUT AN

ASSISTIVE

DEVICE

SIGNIFICANT

LIMITATION

IN USE OF

LOWER

EXTREMITIES

LOSS, OR

LOSS OF USE,

OF ONE OR

BOTH LOWER

EXTREMITIES

LOSS, OR

LOSS OF USE,

OF BOTH

HANDS

LEGALLY

BLIND

†

Sources: California state law, DMV disabled person parking placard and license plate application, and DMV’s vehicle registration manual.

* In addition to the categories above, disabled veterans qualify if they have lost the use of one or more limbs or have a mobility-related disability rating

of 100 percent from the Department of Veterans Aﬀairs or the military branch from which they were discharged.

†

A physician and surgeon who has a specialty in diseases of the eye may also make certiﬁcations related to Category 8.

Although people can claim several types of disabilities on their

applications for placards and plates, the most common relate to

substantially impaired mobility or signiﬁcant limitation of the use

of the lower extremities. Figure  presents the proportion of the

disabilities claimed in our representative sample of  applications

drawn from the universe of original applications DMV approved

from July  through June .

Finally, according to state law,

an applicant does not need a disability certiﬁcation from a medical

provider if the disability is readily observable and uncontested. In

that case, a DMV staﬀ person may certify the disability.

Misuse of Disabled Person Parking Placards

e ability of placard users to park for free in metered parking

spaces and for unlimited amounts of time in time-restricted parking

zones creates a signiﬁcant incentive for abuse. For example, a

person might misuse the placard of a deceased person, a stolen

placard, or a placard belonging to someone else. is abuse

We selected a random sample from a population of more than . million original plate and

placard applications DMV approved from July  through June . We used a  percent

conﬁdence interval and a  percent precision rate to determine an appropriate sample size.

Ourresults should be interpreted as a best estimate, and they include a range of potential

valuesbased on the sampling criteria we chose.

Physician and Surgeon

Physician’s Assistant

Chiropractor

Nurse Practitioner

Optometrist

Nurse Midwife

11California State Auditor Report 2016-121

April 2017

persists despite heavy penalties, including criminal convictions,

formisusing placards. Under state law, lending a placard to another

person or using another person’s placard is punishable by a base

ﬁne of up to , and up to six months of imprisonment. In

addition, a city or county may adopt an ordinance or resolution to

assess an additional penalty of  as long as it uses the revenue

generated by the penalty to enforce disabled person parking. Also,

when a person misuses another’s placard or plate, courts may

impose additional civil penalties of ,. Placard abuse involving

falsifying DMV documents is a felony, which is punishable by up

to three years in a state prison. According to DMV’s budget oﬃcer,

DMV does not receive any funding from the penalties for placard

misuse. e ﬁnes generated through issuance of citations for

placard abuse go to cities and counties.

Figure 3

Disability Categories and Descriptions Listed on a Representative Sample of Disabled Person

ParkingPlacardand License Plate ApplicationsApproved by DMV

July 1, 2013, Through June 30, 2016

Loss, or Loss of Use, of Both Hands—(1%)

Development

programs—

$1,350 (47%)

Signicant Limitation in

Use of Lower Extremities—(40%)

Substantially Impaired

Mobility—40%

Legally Blind—(2%)

Loss, or Loss of Use, of Both Lower Extremities—(2%)

Severe Cardiovascular Disease—(4%)

Severe Lung Disease—(4%)

Unable to Move Without an Assistive Device—(7%)

Source: California State Auditor’s analysis of a representative sample of the proportion of disabilities claimed in original disabled person

parking placard and license plate applications approved by DMV from July 1, 2013, through June 30, 2016.

The Disabled Person Parking Law Has Changed Over the Years

e scope of California’s placard and plate law has expanded

over time. In  the Legislature gave those needing the aid of a

wheelchair or who had lost the use of both legs the right to park for

an unlimited time in zones with time limits. In  the Legislature

expanded the privilege to include those who had lost the use of

oneor both legs or who needed the aid of a mechanical device.

In the privilege was further expanded to those who had lost

the use of one or more limbs. In  the Legislature expandedthe

California State Auditor Report 2016-121

April 2017

law again to apply to individuals who had lost the use of both

hands. e Legislature also allowed people with disabilities the

right to park in metered spaces for free

in response to a disabled

veteran who was able to drive using prosthetic devices, but who

was unable to handle small coins and could not pay a parking meter.

Over time, the Legislature has added additional disabilities to the

list of those eligible for special parking privileges, such as severe

lung disease and legal blindness. Although the impetus for the free

parking beneﬁt was one person’s inability to use a meter, the beneﬁt

currently applies to all placard or plate holders.

Some states have restricted who is eligible for free parking. We

reviewed disabled person parking policies in nine states in addition

to California. Appendix A beginning on page  includes the results

of our review. Several of the states we reviewed oﬀer free metered

parking for those using placards, and some had no time restrictions.

However, two states we reviewed have employed two-tier systems.

Speciﬁcally, in Illinois and Michigan, all placard holders may park in

spaces designated for people with disabilities. However, to receive

the beneﬁt of free parking in metered spaces, they must have a

disability that limits their ability to use a parking meter. According

to a representative of the Illinois Oﬃce of the Secretary of State,

when the law passed in , only about  percent of placard

holders were eligible for meter-exempt parking—signiﬁcantly

decreasing the number of people receiving free parking. In  the

California Legislature considered a bill to implement a two-tiered

program similar to the ones in Illinois and Michigan; however, that

bill did not come to a vote. According to a legislative analysis of

the bill, the purpose was to address placard fraud and to provide

better parking access to those with disabilities, but opponents were

concerned the bill would substantially aﬀect people with disabilities

who encounter multiple physical barriers. e opposition stated

that if rampant abuse is occurring, DMV and the municipalities

should address the fraud through enforcement rather than further

burdening those in the disabled community.

Department of Motor Vehicles’ Investigations of Placard Misuse

DMV’s Investigations Unit (Investigations) is responsible for active

fraud and counterfeit detection, investigation, and enforcement,

including enforcing the laws regarding misuse of placards. When

fully staﬀed, Investigations employs about investigators

across the State at its  district oﬃces in DMV’s threeregions.

Investigators are sworn peace oﬃcers who, in addition

toinvestigating placard fraud and misuse, investigate a variety

of driver’s license and motor vehicle related crimes, including

identity theft, odometer fraud, and automobile dealer misconduct.

According to Investigations’ supervisor of IT projects and support,

13California State Auditor Report 2016-121

April 2017

from ﬁscal years – through – DMV initiated a total

of more than , cases. Of those cases, ,were related to

placards and  of those, or about  percent, were generated

by complaints Investigations received from parties external

to Investigations, including the public, law enforcement, and

other units within DMV. Investigations initiated the remaining

casesitself.

Investigations’ primary tactic for stopping placard misuse is

through sting operations. During a sting operation, investigators

stake out a predetermined location, approach drivers who park

using a placard or plate, and issue infraction or misdemeanor

citations to those found to be misusing the placard or plate.

According to the deputy chief of Investigations, investigators

conduct sting operations in a variety of locations, including

department store parking lots, sporting events, college campuses,

and areas where they receive complaints of misuse. Occasionally,

local law enforcement oﬃcers participate. According to DMV’s

records, from ﬁscal years – through –, Investigations

conducted  sting operations, including one statewide operation

involving all district oﬃces during which investigators issued more

than  citations in oneday. More than , of the cases that

investigators opened from July  through June  resulted in a

conviction. AppendixB on page  includes the number of placard

and plate investigations that DMV conducted from July 

through June and the outcomes of those investigations.

Local Authorities’ Attempts to Combat Placard Misuse

Local parking enforcement oﬃcials play the most signiﬁcant

role in combatting placard abuse as they routinely patrol their

communities. However, the enforcement tactics and strategies

these oﬃcials use vary. To identify these strategies, as well as how

signiﬁcant a problem placard misuse is within cities, we interviewed

oﬃcials from six cities: Berkeley, Fresno, Los Angeles, Sacramento,

San Francisco, and Santa Cruz. Parking enforcement oﬃcials

at ﬁve of these six cities stated that placard abuse was a large

problem within their cities—only Santa Cruz said that it was not.

Los Angeles reported that, in some areas of the city, the majority

of vehicles parked on the street display a placard. Because of the

magnitude of placard misuse, according to the assistant director

of the enforcement division of the San Francisco Metropolitan

Transportation Agency (SFMTA), San Francisco has  full-time

parking enforcement oﬃcials speciﬁcally dedicated to identifying

and citing people fraudulently using placards.

California State Auditor Report 2016-121

April 2017

e ﬁve cities reporting signiﬁcant placard abuse said that they

conduct sting operations, but the frequency varied by city. For

example, Los Angeles reported that it had more than quadrupled

the number of sting operations, which it refers to as compliance

checks, as a result of the growing misuse of placards—from

in to  in . According to Fresno’s parking supervisor,

Fresno conducts a sting operation roughly every four months

in partnership with DMV. SFMTA’s assistant director of the

enforcement division reported that when parking enforcement

oﬃcials discover a vehicle displaying an invalid placard and they are

unable to make contact with the driver, the oﬃcial has the vehicle

towed. Despite these eﬀorts, four of these ﬁve parking enforcement

oﬃcials believe their enforcement activities have little or no eﬀect

on mitigating placard abuse. Essentially, they were of the opinion

that people fraudulently using placards will continue to do so,

particularly given the beneﬁt of free parking and the minimal risk of

being caught or ﬁned.

15California State Auditor Report 2016-121

April 2017

Chapter 1

INADEQUATE PROCESSES FOR REVIEWING APPLICATIONS

AND REVOKING PLACARDS INCREASE MISUSE

e Department of Motor Vehicles (DMV) does not suﬃciently

ensure that applications for disabled person parking placards

(placards) or disabled person or disabledveteran license plates

(plates) are legitimate, nor is it taking suﬃcient steps to cancel

placards for deceased placard holders or to ensure that placard

holders claiming replacement placards can legitimately do so. We

also found applications for placards or plates with illegible disability

certiﬁcations and with a medical provider certifying a type of

disability he or she was not allowed to certify. Further, we identiﬁed

thousands of likely deceased holders whose placards were still

active. Finally, some placard holders requested an unusually high

number of replacements for lost or stolen placards, and state law

does not limit the number of replacements a holder may receive.

However, DMV had not identiﬁed any of these issues because it

does not actively analyze placard applications or application data.

DMV Has Not Adequately ScrutinizedPlacard Applications, and We

Question the Validity of Some Applications

DMV does not suﬃciently review applications for the disabled

person parking placard program (placard program) to ensure they

are legitimate, and it does not consistently follow the policies it

has in place to review applications. Individuals desiring a placard

or plate must complete a two-page application that includes a

certiﬁcation from an authorized, licensed medical provider that the

applicant has a qualifying disability. e applicant does not need

a provider’s certiﬁcation if the applicant has a readily observable

and uncontested disability that is veriﬁed by a DMV employee, is

an organization involved in transporting people with disabilities,

or is a disabled veteran whose disability has been certiﬁed by the

United States Department of Veterans Aﬀairs. However, we found

that DMV does not adequately review these applications. For

example, DMV staﬀ are supposed to reject applications that are

illegible, yet we found illegible disability information in  percent of

the applications we reviewed. Further, we identiﬁed that ﬁveother

applications were certiﬁed by podiatrists, whom state law does not

currently authorize to certify disabilities. We also found another

two applications where the medical provider certifying the disability

was not allowed to certify that type of disability under state law,

even though DMV has issued guidance for its staﬀ to look for this

issue. Further, we found that  percent of the applications we

reviewed did not include enough information on the applicants’

disabilities to meet requirements in state law for certiﬁcation, and

California State Auditor Report 2016-121

April 2017

nearly  percent of the providers’ signatures on the applications

did not match the signatures on paperwork on ﬁle with the

appropriate healing arts boards of the Department of Consumer

Aﬀairs (health boards). Without following the controls in place to

review applications, DMV may be allowing people to fraudulently

obtainplacards.

DMV Did Not Ensure That Medical Provider Certiﬁcations of Individuals’

Disabilities Contained Required Detail

Some medical providers are not including enough information

regarding the applicant’s disability to satisfy state requirements.

State law requires authorized providers to include a full description

of the illness or disability on the application for a placard. We

worked with the appropriate health boards responsible for licensing

the various medical providers to review our sample of applications

for compliance with state law. e health boards have medical

experts they employ or consult with to conduct, for example,

investigations of licensed medical providers. ese medical

experts found that  of the  original applications we reviewed,

or percent, did not include a full description of the illness or

disability. If we project to the population of applications for placards

or plates DMV approved from July  through June , this

suggests that DMV approved nearly . million applications that did

not include enough information to meet requirements in state law

for certifying the applicant’s disability.

Although state law allows it to do so, DMV does not collaborate

with the health boards to review applications. e chief of DMV’s

registration operations division (registration division chief )

noted that employees cannot question medicalinformation on

the application because they are notmedical professionals. is

explanation seems reasonable. However, DMV has missed an

opportunity to provide for a review of applications to ensure

that providers’ certiﬁcations are suﬃcient. State law requires

providers who certify an applicant’s illness or disability to retain

suﬃcient information to support the diagnosis for inspection

by the respective health boards at DMV’s request. e law also

authorizes DMV to conduct annual, random audits of placard

applications to verify the authenticity of the disability certiﬁcates

and to review information supporting placard applications.

us, we expected DMV to be working with the health boards to

periodically review a selection of placard applications or at least

provide guidance to medical providers on the requirements of the

program. However, DMV has done neither. DMV’s deputy chief of

DMV’s Investigations Unit (Investigations) noted that DMV had

not worked with the health boards because it assumed that the

Although state law allows it to

do so, DMV does not collaborate

with the health boards to

reviewapplications.

17California State Auditor Report 2016-121

April 2017

boards would not provide DMV with information because of the

privacy requirements in the federal Health Insurance Portability

andAccountability Act of  (HIPAA).

HIPAA establishes national standards to protect individuals’

medical records and other personal health information and sets

forth the circumstances in which medical providers who conduct

certain health care transactions electronically may use or disclose

suchprotected information. For example, such providers may

discloseprotectedhealthinformation when a patient consents to

suchdisclosure. Additionally, HIPAA permits providersto disclose

protected health information without a patient’s authorization

when required by statute or regulation. However, while HIPAA

permitsdisclosure without patient consent when statute or regulation

requires disclosure, state law generally requires the applicable health

boards to obtain patient consent unlesstheapplicable board issues

an investigative subpoena or otherwise obtains a valid legal order. For

example, the executive director of the Medical Board of California noted

that it cannot get access to patient records without patient consent

unless it has compelling evidence available to obtain a court order.

Despite limitations in federal and state law, DMV and health boards

have opportunities to identify insuﬃcient certiﬁcations and launch

investigations. Although patients or providers willfully defrauding

DMV are unlikely to voluntarily provide incriminating information,

we found that the medical experts were able to identify signiﬁcant

deﬁciencies by reviewing only the description of the illness or

disability provided on the applications for placards or plates without

needing access to additional medical information. Further, when

DMV or the health boards determine—for example, through an

audit of a selection of placard applications—that an applicant’s

certiﬁcation is insuﬃcient, DMV has the authority to ask for

additional information to meet the requirements in state law and

cancel the placard if, after a reasonable time, the applicant does not

respond. Finally, were DMV to accumulate enough evidence against

a provider, it could work with the applicable health board to open

an investigation, and the health board could, if necessary, issue an

investigative subpoena. us, despite limitations in federal and state

law, cooperation between the health boards and DMV could ensure

that providers are including adequate information on applications to

support the certiﬁcation of disabilities.

Also, we found that DMV had approved many applications inwhich

the providers’ certiﬁcations of the disabilities were illegible, which

makes us question the validity of these certiﬁcations. DMV’s

application requires that providers include a full, legible description

of the illness or disability. However, we determined, and the

medical experts conﬁrmed, that the disability certiﬁcations for

ﬁveoforiginal applications we reviewed, or  percent,were

DMV and health boards have

opportunities to identify

insuﬃcient certiﬁcations and

launch investigations.

California State Auditor Report 2016-121

April 2017

illegible. Projecting to the larger population of applications

approvedfrom July through June , DMV may have

approved more than , illegible applications for placards or

plates from July through June . DMV already requires staﬀ

to review applications for all required information and to ensure that

the provider properly completes the certiﬁcation, which includes

providing legible information. DMV’s registration division chief

attributed the approvals of these illegible applications to human

error. When DMV does not ensure that applications include all

information thelaw requires and that all such information is legible, it

creates the opportunity for applicants to submit fraudulent disability

certiﬁcations and receive placards or plates without a qualifying

illness or disability.

DMV Allowed Some Medical Providers to Certify Disabilities That They

Were Not Legally Permitted to Certify

In our audit sample, podiatrists certiﬁed disabilities for a number of

applicants for placards even though they are currently not allowed to

do so. We found a range of medical provider types in our representative

sample of applications and, as Figure  shows, medical providers in the

physician and surgeon category certiﬁed the majority of disabilities in

the applications we reviewed. However, in ﬁve of the  applications

we reviewed, or  percent, podiatrists certiﬁedthe qualifying disability.

Projecting to the larger population of applications approved from

July through June, we estimate that podiatrists certiﬁed more

than ,of the more than .million applications DMV approved

during the audit period, even though podiatrists are not one of the

sixtypes of medical providers allowed to certify disabilities for a placard

orplate.

State law identiﬁes speciﬁc provider types that may certify disabilities

for the placard program, but podiatrists are not included. As shown

in Table  in the Introduction on page , only certain provider

types, including physicians and surgeons, may certify disabilities for

placard and plate applications. Further, under state law, only those

issued physicians and surgeons certiﬁcates by either the Medical

Board of California or the Osteopathic Medical Board of California

are permitted to practice medicine as physicians and surgeons. In

contrast, podiatrists are certiﬁed to practice podiatric medicine

and are therefore precluded from certifying applicants’ disabilities.

When we brought this to DMV’s attention, its registration division

chief noted that he had been unaware that podiatrists were certifying

applicants’ disabilities.

Nevertheless, DMV staﬀ should have identiﬁed and denied applications

certiﬁed by podiatrists. While all of the podiatrists in our sample

indicated they were either a physician or surgeon, each of them also

By not ensuring that applications

include all information the

law requires, DMV creates

theopportunity for applicants

to submit fraudulent disability

certiﬁcations and receive placards

or plates without a qualifying

illness or disability.

19California State Auditor Report 2016-121

April 2017

listed their medical provider number as assigned by the Board of

Podiatric Medicine. ese numbers are distinct from those of other

providers authorized to certify disabilities underthe placard program.

Speciﬁcally, podiatrists’ numbers begin with theletter “E” followed

by four digits, whereas providers licensed bythe Medical Board of

California have numbers that begin with“A,” “C,” or “G” followed

generally by ﬁve or six digits, and those licensed by the Osteopathic

Medical Board of California always begin with “A.” erefore, DMV

staﬀ could have easily identiﬁed and rejected those applications certiﬁed

by podiatrists. DMV provides no training to the staﬀ that process

these applications to identify provider numbers that do not align with

expectations, nor does a DMV reference manual for staﬀ provide

instruction on identifying unusual provider numbers. Although DMV

staﬀ should have rejected applications certiﬁed by podiatrists, because

there were a notable number of such applications and because of

podiatrists’ role in medical treatment of the foot as established in state

law, we consider podiatrists appropriate medical providers to certify

certain disabilities for placards or plates. However, allowing them to

make certiﬁcations would require a change in state law.

Figure 4

Types of Medical Providers That Certiﬁed Disabilities for the Disabled Person Parking Placard Program Based

onaRepresentative Sample of Applications Drawn From the Universe of Applications Approved by DMV

July 1, 2013, Through June 30, 2016

Physician’s Assistant—(4%)

Physician and Surgeon—(85%)*

Chiropractor—(4%)

Podiatrist—(5%)

†

Nurse Practitioner—(2%)

Sources: California State Auditor’s representative sample of certiﬁcations drawn from the universe of original applications for

disabledpersonparking placards (placards) or disabled person or disabled veteran license plates (plates) approved by DMV fromJuly 1, 2013,

through June 30, 2016, and state law.

Note: State law authorizes optometrists and nurse midwives to certify disabilities on applications for placards and plates; however, none

appeared in our sample. Our results should be interpreted as a best estimate and include a range of potential values based on the sampling

criteria we chose. We used a 95 percent conﬁdence interval and a 10 percent precision rate to determine an appropriate sample size.

* The category of physician and surgeon includes osteopathic physicians, which represented 4 percent of our sample. Althoughosteopaths

are licensed by a diﬀerent entity, state law considers them to be physicians and surgeons.

†

State law does not currently authorize podiatrists to certify disabilities on applications for placards and plates.

California State Auditor Report 2016-121

April 2017

Additionally, although state law speciﬁes the particular disabilities

each type of provider may certify, DMV approved some

applications that did not meet those requirements. For two of the

 original applications we reviewed, providers certiﬁed disabilities

that they are not allowed to certify under state law. For example, a

physician and surgeon with a specialty in endocrinology (the body

system that controls hormones) and internal medicine certiﬁed

that an applicant had a vision-related disability. However, state

law only permits an optometrist or a physician and surgeon with

a specialty in diseases of the eye to make such a certiﬁcation.

Projecting our ﬁnding to all applications for placards and plates

that DMV approved from July through June , DMV may

have inappropriately approved more than , applications that

contained certiﬁcations of disabilities the medical provider was not

allowed tomake.

DMV provides its staﬀ with direction that, if followed, should

prevent approval of applications containing these inappropriate

certiﬁcations, thereby reducing the risk of violations of eligibility

requirements for placards or plates. DMV’s registration manual

includes a brief outline of the types of medical providers that

may certify speciﬁc disability categories. When we asked about

theconcerns we identiﬁed with the applications we reviewed, the

registration division chief was unaware that staﬀ were approving

applications that were not eligible. He noted that DMV oﬃces have

personnel assigned to review and monitor placard applications,

among other activities, but he could only oﬀer human error as

the reason for the incorrect application approvals. According to

him, staﬀ who process placard applications receive some training

related to reviewing and processing these applications, and DMV’s

training materials discuss eligibility requirements for plates and

placards. When DMV does not ensure that only authorized

medical providers are certifying disabilities for placards or plates, it

increases the risk that an individual without a qualifying disability

will receive a placard or plate, making it more diﬃcult for those

with qualifying disabilities to ﬁnd parking.

DMV Does Not Verify the Authenticity of Medical Provider Signatures

When processing placard applications, DMV staﬀ do not review

medical provider signatures to determine whether they are

legitimate. In general, state law requires that an authorized provider

sign the application, unless the applicant’s disability is readily

observable and uncontested. State law also requires DMV to

examine and determine whether every application ﬁled with it is

genuine, and permits DMV to reject any applications thatit believes

are not. According to the registration division chief, reviewing

provider signatures would require DMV staﬀ to either contact each

The registration division chief was

unaware that staﬀ were approving

applications that were not eligible.

21California State Auditor Report 2016-121

April 2017

provider or compare the signature on the application to a conﬁrmed

copy of the provider’s signature. He explained that because of the

volume of applications DMV receives, conducting this type of

review would be time consuming and impractical. Although this

may be a reasonable explanation for not reviewing every signature

during the processing of applications, state law authorizes DMV

to annually audit a random sample of applications to verify the

authenticity of the certiﬁcation. For example, DMV could work

with the health boards to obtain documentation, such as license

renewal applications, of provider signatures for comparison. If

DMV identiﬁed questionable signatures, it could conduct further

investigation, such as contacting the provider to conﬁrm the validity

of the signature. However, DMV does not perform such audits,

increasing the risk that applicants are forging provider signatures to

obtain a placard or plate. Further, in ﬁve of the six cities where we

interviewed parking enforcement oﬃcials, those oﬃcials said that

placard misuse was a signiﬁcant problem, depriving their cities of

parking revenue and their disabled residents of being able to park

close to their desired destinations.

According to the deputy chief of Investigations, the division does

not have software that allows it to randomly select applications

from the Vehicle/Vessel Registration Master File (registration

system) for review. She explained that Investigations has tried to

obtain such programs but found that they were costly. We question

the reasonableness of this explanation given that Investigations

could sample applications through means other than a software

program. For instance, Investigations could periodically use an

inexpensive random number generator, such as that available in

common spreadsheet software, to select a sample of newly received

applications from ﬁeld oﬃces and the processing unit at DMV

headquarters. It could then compare the providers’ signatures to

those on documents the health boards maintain.

Without a regular process to review the validity of provider

signatures, DMV risks issuing placards to fraudulent applicants.

We compared the providers’ signatures included in our sample of

 original applications approved from July  through June 

to documents from the appropriate health boards to determine

whether the signatures reasonably matched. We questioned the

validity of  signatures, or nearly  percent. Using the method

of projection previously described, this suggests that more than

, applications approved during our audit period may not

bevalid. In one case, neither the provider’s signature northe

provider’s license number matched the physician named on

theapplication. Although we could not deﬁnitively conclude that

theseapplications were submitted fraudulently, the evidence is

suggestive of fraudulent intent. us, in January  we forwarded

In ﬁve of the six cities where we

interviewed parking enforcement

oﬃcials, those oﬃcials said

that placard misuse was a

signiﬁcantproblem.

California State Auditor Report 2016-121

April 2017

our ﬁndings to DMV’s Investigations for further review. As

of March , Investigations had not completed its work on

thesecases.

DMV’s Current Processes for Revoking Placards Do Not Prevent Misuse

Inadequate processes at DMV have allowed for misuse of placards.

We found that DMV’s process of using the vital records from the

California Department of Public Health (Public Health) to remove

deceased individuals’ placards from its database has overlooked

thousands of likely deceased individuals. Since DMV renews

permanent placards every two years indeﬁnitely, if it does not

identify individuals who are deceased, it will continually mail new

placards to them. Additionally, state law allows placard holders

to request an unlimited number of replacement placards if their

permanent placard is lost or stolen. From July  through

June, two placard holders received more than  replacement

placards each. Finally, although its responsibilities include

protecting DMV’s programs through active fraud detection, DMV

has not performed analyses of its data related to placards and plates

to identify potential fraud. Because DMV has not been proactive in

identifying and addressing these issues, many invalid placards are

likely in circulation and being misused.

Because of Limitations in DMV’s Processes, Many Likely Deceased

Individuals’ Placards Are in Circulation

State law requires DMV to compare its placard records to Public

Health’s Vital Statistics ﬁle and withhold any renewal for placard

holders that DMV identiﬁes as deceased. State law charges Public

Health with the registration of all deaths that occur within the State,

which it does by processing death certiﬁcates that are originally

prepared by funeral homes, coroners, and medical examiners.

According to the chief of Public Health’s policy and research

branch, and to a contract DMV has with Public Health, Public

Health provides to DMV monthly ﬁles of deceased individuals.

DMV uses the monthly ﬁle from Public Health and compares the

ﬁrst name, last name, middle name or initial, and date of birth to

information within its registration system that maintains placard

holder information. When a match is found, the placard record

is updated to reﬂect that the person is deceased, which prevents

the placard from being automatically renewed. Figure  displays a

ﬂowchart of this process. We found that DMV canceled more than

, individuals’ permanent placards from July  through

June  using this matching process. We also have reasonable

assurance that DMV appropriately ceased mailing any renewal

placards to these individuals.

23California State Auditor Report 2016-121

April 2017

Figure 5

DMV Deceased Persons Matching Process

If there is a match

California Department of Public Health

(Public Health)

LOCAL

REGISTRATION DISTRICT

FUNERAL HOMES

AND CORONERS

Department of Motor Vehicles

DMV

Initiate and submit

death certicate

Reviews and registers

the certicate

Registers certicate

and forwards to the

State for review

Matches the le to list of

current disabled parking placard holders

Public Health sends a monthly

vital statistics le (le)

to DMV via a secure transfer

DMV cancels

placards of

deceased holders

If there is a match

Sources: California state law, California State Auditor’s analysis of DMV’s vital statistics matching process, and interviews with oﬃcials from PublicHealth.

However, we performed additional analyses of DMV placard

holder data and identiﬁed thousands of individuals who are likely

deceased yet still have active placards. We compared the names

and birth dates of individuals with permanent placards active as of

June,, to the U.S. Social Security Administration’s Death

Master File (master ﬁle) and identiﬁed nearly , matches.

Although this comparison indicates that DMV likely has not

canceled thousands of deceased individuals’ placards, these results

are not precise. In particular, the master ﬁle is cumulative and

includes deceased individuals from across the U.S., increasing the

risk that a person with an active placard is matched with someone

who has the same name and date of birth, but is alive. In contrast,

Public Health’s ﬁle includes only individuals whose deaths occurred

in California. Further, the master ﬁle is composed of data provided

by sources beyond those Public Health uses, such as post oﬃces,

ﬁnancial institutions, other states’ vital records agencies, and

federal agencies. As a result, the master ﬁle is more comprehensive

than Public Health’s ﬁle in some ways, which may contribute to

the higher number of deceased placard holders we identiﬁed with

active placards. According to the registration division chief, DMV

has concerns about using the master ﬁle to cancel active placards.

California State Auditor Report 2016-121

April 2017

For example, he noted that DMV has concerns over misidentifying

active placard holders as deceased, given the national nature of

the dataset, the presence of common names, and the inclusion

ofindividuals who died many years ago. Because of DMV’s

concerns and because of diﬀerences between the data within the

master ﬁle and Public Health’s ﬁle, we selected  people with active

placards who our analysis indicated were deceased. We located

obituary records or other information online to corroborate that

ﬁve of these  people were indeed deceased. Despite DMV’s

concerns, these results demonstrate that many people should no

longer have activeplacards.

We performed a separate analysis of DMV’s placard holder data

and identiﬁed another population of individuals with active

placards who could be deceased. As of June , , nearly ,

placard holders with active, permanent placards in DMV’s data

were age  or older. is number is signiﬁcantly higher than

the estimated , individuals that comprised California’s entire

centenarian population as of . ese results indicate that

DMV’s process for canceling placards of deceased individuals is

inadequate, given that thousands of individuals age  or older

who are likely deceased still have active placards. Similar to our

previous analysis, we took steps to determine whether our results

included any individuals who were indeed alive. We were able to

corroborate, based on available evidence, that ﬁve of a selection of

 individuals we identiﬁed in this analysis were in fact deceased.

We provided a listing of these  individuals to DMV, and it was not

able to adequately demonstrate whether any of them should have

activeplacards.

ese results demonstrate that the process DMV uses to identify

deceased individuals and cancel their placards needs improvement,

and that DMV needs procedures beyond data matches to ensure

it identiﬁes deceased placard holders. Speciﬁcally, DMV relies on

precise matches based on full name and date of birth, as recorded

in its data and as compared to that in Public Health’s ﬁle, to identify

deceased placard holders. However, we found that DMV’s data did

not always include the correct name of the individual; for example,

we identiﬁed that DMV staﬀ did not correctly enter into its system

 percent of applicants’ names as reﬂected on the corresponding

applications from July  through June . Such issues prevent

DMV from adequately identifying the deceased placard holders

because its process requires an exact match between its data and

Public Health’s ﬁle based on ﬁrst, last, and middle name or initial.

Further limiting the accuracy of DMV’s process is that it does not

require placard applicants to provide proof of their legal name

and date of birth. Although state regulations and DMV’s placard

application require applicants to use their true full name and date

DMV’s process for canceling

placards of deceased individuals is

inadequate, given that thousands

of individuals age 100 or older

who are likely deceased still have

activeplacards.

25California State Auditor Report 2016-121

April 2017

of birth on an application, DMV does not require that they provide

any supporting documentation proving this information, such as

a driver’s license or birth certiﬁcate. According to the registration

division chief, DMV lacks authority in state law to refuse applicants

who do not provide such veriﬁcation. We agree that state law

does not explicitly require individuals applying for a placard to

provide supporting documentation proving their true full name or

date of birth on the application. However, we note that state law

grants DMV the authority to establish procedures for the issuance

and renewal of placards and allows DMV to require additional

information or reject an application if DMV is not satisﬁed with

the truth of any statement contained in such application. erefore,

we believe that DMV could have used this authority to establish

reasonable supporting documentation requirements proving

applicants’ true full names and dates of birth. However, in light of

DMV’s interpretation of state law, it may be necessary to revise state

law to make this an explicit requirement. Without this requirement,

someone intending to commit fraud could fabricate an application

with any name or date of birth, as well as a certiﬁcation of disability,

and DMV would approve the application and issue the individual a

permanent placard.

DMV’s practice of automatically renewing permanent placards

every two years also limits its ability to ensure that it does not mail

renewal placards to deceased people. DMV renews permanent

placards every two years indeﬁnitely unless it cancels the placards,

such as when it identiﬁes deceased placard holders. We reviewed a

selection of other states’ renewal requirements and noted that some

require individuals to periodically submit a new application and

certiﬁcation of their disability. For instance, Florida and Michigan

require placard holders to reapply every four years. If DMV does

not identify an individual as deceased, it will automatically continue

to send him or her a new placard every two years. Unless the

placard is returned to DMV, it will remain in circulation, increasing

the risk that someone will fraudulently use the placard and deprive

a person with a disability of needed parking. Requiring placard

holders to periodically reapply to the program will ensure that

DMV will no longer send placards to deceased individuals.

Placards Reported as Lost or Stolen Can Be Subject to Misuse

Placard holders may obtain an unlimited number of replacements

for permanent placards.

State law allows those holding permanent

placards to request replacements in the event a placard is lost

We limited our analysis to permanent placards because they are valid for two years, have a ﬁxed

expiration date, and are automatically renewed. Further, temporary placards account for only

percent of the total placards and plates active as of June , .

DMV’s practice of automatically

renewing permanent placards every

two years also limits its ability to

ensure that it does not mail renewal

placards to deceased people.

California State Auditor Report 2016-121

April 2017

orstolen–without the need for recertiﬁcation of eligibility—and

it does not limit the number of such replacements. DMV must

cancel the existing placard when it provides a replacement;

however, when DMV cancels a placard in its system, this does

not take the physical placard out of circulation. An unscrupulous

person may continue to use such a placard until an enforcement

oﬃcial discovers it is not valid and seizes the placard. We identiﬁed

nearly , individuals to whom DMV issued replacements of

permanent placards from July  through June , as shown

in Table . evast majority were issued only one replacement

placard. However, about , individuals were issued four or

more replacement placards during the period from July 

through June—representing more than one placard per year.

Even more concerning is that nine individuals received  or more

replacement placards each during those three years, and two of

them received more than  replacement placards each. Although

we cannot conclude that the individuals obtained these replacement

placards fraudulently, the high number of replacements suggests

a signiﬁcant risk of fraud. In February , we shared with

Investigations the names and placard information for those

individuals who received more than  replacements over the past

three years. As of March, Investigations had not completed its

work on thesecases.

Table 2

Replacements of Permanent Disabled Person Parking Placards DMV

Issued From July 2013 Through June 2016

NUMBER OF REPLACEMENTS

PER INDIVIDUAL

NUMBER OF INDIVIDUALS

WITH REPLACEMENTS

TOTAL NUMBER OF

REPLACEMENTS

1 288,038 288,038

2 38,834 77,668

3 6,401 19,203

Subtotals of 3 or Fewer

Replacements

333,273 384,909

4 1,501 6,004

5 437 2,185

6-10 332 2,274

11-15 24 295

16+ 9 175

Subtotals of 4 or More

Replacements

2,303 10,933

Totals 335,576 395,842

Source: California State Auditor’s analysis of data obtained from DMV ‘s Vehicle/Vessel Registration

Master File.

Note: As of June 30, 2016, there were approximately 2.4 million active, permanent disabled person

parking placards.

27California State Auditor Report 2016-121

April 2017

According to the registration division chief, DMV cannot refuse

requests for replacement placards if the requestor already has a

valid permanent placard. Holders of active placards may request

a replacement placard at any time by submitting an application

stating that their old placard was lost or stolen or by surrendering

the placard—for example, if it has been mutilated—at a DMV

oﬃce. e replacement application does not require a new medical

certiﬁcation. Further, according to the registration division chief,

DMV has never considered tracking replacement placards. If the

Legislature limits the number of replacement placards an individual

can receive, DMV will need to determine how to implement such

alimit.

Allowing people to receive multiple replacement placards

increases the number of permanent placards potentially in use.

Unless people surrender found placards or enforcement oﬃcials

seize placards, those reported as lost or stolen are available for

misuse. When enforcement oﬃcials seize placards for misuse,

state law requires that they report the placard numbers to DMV

and that DMV cancel the seized placard. Data DMV provided us

regarding conﬁscated placards that it had canceled suggest that

people are misusing placards previously reported as lost or stolen.

Additionally, most local parking enforcement oﬃcials we spoke to

said that they generally look for the presence of a placard and an

expiration date, but they do not routinely, if at all, verify whether

the placards have been reported as lost or stolen. According to

DMV’s records, enforcement oﬃcials submitted about , seized

placards to DMV in —which DMV canceled—with almost

 percent recorded as invalid because they were lost, stolen, or

otherwisereplaced. is indicates that people are misusing placards

that had been reported as lost or stolen.

Further, we performed a visual survey of vehicles displaying

placards along six blocks in downtown Sacramento during a

weekday in January . Of the  parked cars we observed,  had

placards or plates, and one of those had been canceled after being

reported as stolen and thus was being misused. It is reasonable to

conclude that some people are fraudulently using canceled placards

when parking their vehicles in order to take advantage of free or

convenient parking. Without limits on the number of permanent

placard replacements someone may request, DMV risks issuing

many more additional placards than necessary and reducing the

parking available to people with disabilities who are using their

placards appropriately. We address DMV’s ability to use its data to

identify individuals who are potentially misusing replacements in

the next section and the potential to improve enforcement of this

misuse in Chapter .

Without limits on the number of

permanent placard replacements

someone may request, DMV risks

issuing many more additional

placards than necessary and

reducing the parking available to

people with disabilities who are

using their placards appropriately.

California State Auditor Report 2016-121

April 2017

DMV’s Investigations Unit Has Missed the Opportunity to Identify

Potential Fraud by Analyzing Data on Placard Applications

Investigations does not analyze placard data, which could reveal

potentially fraudulent activity. DMV’s registration system contains

placard holder information, including name, date of birth, address,

and the certifying medical provider’s license number. Because

Investigations’ responsibilities include protecting DMV’s programs

through active fraud detection, we expected it to proactively

and periodically review placard application data to identify

potential fraud. Speciﬁcally, if it regularly reviewed these data,

Investigations could identify people who have multiple active

placards, people with multiple replacement placards, or medical

providers who certify disabilities for an abnormally large number

of placard applications. However, Investigations does not conduct

suchreviews.

By not analyzing data on placard applications, DMV allows the

largest perpetrators of placard fraud to go undetected. As discussed

earlier, in our review of data, we found nine individuals who each

obtained  or more replacement placards from July  through

June , including two who obtained more than  each. In

addition, we identiﬁed about , individuals who had two or

more active permanent placards as of June , . ree people

had more than three, including one who had . DMV has a system

control that notiﬁes its staﬀ if a person submitting an original

application might also have an existing placard by identifying

placard holders with the same ﬁrst three letters of the applicant’s

last name and date of birth. However, because multiple individuals

could share the ﬁrst three letters of a last name and date of birth,

DMV allows staﬀ to override this control. Further, we found that

some people submitted multiple original applications, even though

DMV’s records indicate they already had an active placard. We

reviewed placard applications DMV received from six people who

already had one or more active placards and determined that, in

each case, these people submitted multiple original applications.

According to the registration division chief, some people may

be submitting the wrong form when they want to change their

address or request a replacement. ese duplicates represent

signiﬁcantly less than  percent of all permanent placards active as

of June,. Nevertheless, according to the registration division

chief, while DMV has not taken steps to identify and reduce such

instances of multiple placards in the past, it is now looking at the

practice to determine what actions might be appropriate in extreme

cases. If DMV is not taking steps to detect this type of activity,

people can apply for and obtain multiple placards with little risk

of being caught. In February , we submitted the names and

associated placard numbers for people with two or more active

We found nine individuals who each

obtained 16 or more replacement

placards from July 2013 through

June 2016, including two who

obtained more than 20 each.

29California State Auditor Report 2016-121

April 2017

placards to the deputy chief of Investigations and to the registration

division chief. As of March , Investigations had not completed

work on this information.

Additionally, DMV’s database is missing a signiﬁcant number

of medical provider license numbers. A provider certifying a

disability on a placard or plate application must include his or

her medical license number, and DMV protocol requires that its

staﬀ input thislicense number into its registration system when

issuing plates or placards. We analyzed the records of more than

. million original placard and plate applications DMV approved

from July  through June , and found that DMV staﬀ did

not enter medical provider license numbers in its registration

system for more than ,, or roughly  percent, of these

applications.

Further, DMV staﬀ did not enter the provider license

number for  percent of the applications in our representative

sample. e registration division chief noted that some records

missing provider license numbers may occur when an applicant’s

disability is due to loss of one or both lower extremities or both

hands. In cases for which the permanent disability is readily

observable and uncontested, DMV staﬀ may certify the disability

on the application. However, we found no such applications that

were certiﬁed by DMV staﬀ in our representative sample from

this period and thus conclude that most, if not all, of the more

than , records should have included the provider license

number. e registration division chief presumed that the missing

provider license numbers occurred because staﬀ failed to input this

information into registrationsystem.

Without consistent entry of the provider license number, DMV

is missing an opportunity to determine whether certain types of

providers, or certain individual providers, are certifying disabilities

on an abnormally high number of applications. In fact, according to

a DMV press release in July , Investigations started Operation

Blue Zone, which resulted in the arrest of three suspects on felony

charges, in response to a complaint by one of DMV’s ﬁeld oﬃce

staﬀ members who identiﬁed a high volume of certiﬁcations

from a single provider. However, Operation Blue Zone was the

result of staﬀ observation and not based on any data analysis that

DMVperformed.

When asked why Investigations does not analyze placard data,

the deputy chief explained that it does not have a program that

allows it to do so. She stated that in the past, Investigations pursued

acquiring a data analytics program but found that the programs

We excluded disabled veteran license plates, commercial disabled person license plates, and

placards issued to organizations that do not require medical provider licensenumbers.

DMV is missing an opportunity to

determine whether certain types

of providers, or certain individual

providers, are certifying disabilities

on an abnormally high number

ofapplications.

California State Auditor Report 2016-121

April 2017

were too costly. However, DMV’s chief of its internal audits division

(internal audits) noted that internal audits recently acquired a

program to extract data from the registration system. He told

us that internal audits is willing to use this program to provide

Investigations with periodic data extracts, which Investigations can

use to analyze placard data. When we informed Investigationsof

internal audits’ software and asked why Investigations has not

previously coordinated with internal audits, the deputy chief

said that Investigations was unaware that internal audits had a

data analytics program. After we spoke with Investigations and

internal audits, Investigations initiated the process of obtaining

a data extract for analysis. Further, the registration division chief

noted that the registration division recently acquired and installed

an analytics tool, which will allow it to examine placard records

and identify unusual patterns or outliers. As of March , the

registration division chief expected the tool to be in place by

theend of the month. e deputy chief of Investigations indicated

that she plans to work with the registration division to use the

new tool to identify potential fraud indicators. Once DMV begins

regularly analyzing its data, it will be able to more eﬀectively

identify fraudulent activity and monitor the placard program.

Recommendations

Legislature

To increase DMV oversight of applications for placards or plates,

the Legislature should modify current law to require DMV to

conduct at least quarterly audits of a selection of applications

for disabled placards or plates and to seek the health boards’

cooperation in doing so.

To better align the placard program with the needs of Californians

with disabilities, the Legislature should amend state law to include

podiatrists on the list of medical providers approved in state law to

certify applications for disabilities related to their specialty.

To assist DMV in more accurately identifying deceased individuals

with active permanent placards, the Legislature should amend state

law to require DMV to use the U.S. Social Security Administration’s

Death Master File to inform its eﬀorts to identify and cancel

deceased individuals’ placards.

To assist DMV in identifying deceased placard holders, the

Legislature should require that all individuals with permanent

placards reapply every four years.

31California State Auditor Report 2016-121

April 2017

To assist DMV in identifying deceased placard holders, the

Legislature should require that all who apply for a placard or a

plate include their full legal name and date of birth, and provide

satisfactory proof of this information at the time of application.

To reduce the risk of placard misuse, the Legislature should limit

to no more than two the number of replacements of permanent

placards an individual may obtain during the two-year placard

renewal period. e Legislature should require that those

desiring replacements beyond that limit reapply and submit new

certiﬁcations of disability.

DMV

To reduce the risk of fraudulent applications, by September 

DMV should seek interagency agreements with the health boards

responsible for licensing providers authorized to certify disabilities

on placard applications. e agreements should include, but not be

limited to, the following:

• A review by medical experts of a sample of placard applications

each quarter to ensure that the disability certiﬁcations meet

state requirements. For any application that does not meetstate

requirements, DMV should require that the applicant and his

or her provider submit the information needed so that the

application meets state requirements. DMV should cancel

theplacards of those who do not respond within  days.

• A process for the health boards to develop guidance for medical

providers related to how to meet state requirements.

• A process for obtaining copies of provider signatures and

routinely comparing the signatures with those on a sample of

placard applications. Investigations should conﬁrm questionable

signatures with providers.

To help ensure that DMV approves only those applications

that qualify for the placard program as speciﬁed in state law, by

September  and annually thereafter, DMV should provide

additional direction and training to its staﬀ that addresses the

following program requirements:

• e types of medical providers that may certify

qualifyingdisabilities.

• e disability categories each type of medical provider

maycertify.

California State Auditor Report 2016-121

April 2017

• e legibility of medical provider certiﬁcations.

• e entry of medical provider numbers into its

registrationsystem.

To identify potentially fraudulent applications, beginning

immediately and quarterly thereafter, DMV Investigations should

obtain placard application data from its registration system and

analyze those data. At a minimum, this analysis should include a

review of the following:

• Individuals who have been issued multiple active placards.

• Individuals who apply for an excessive number of

replacementplacards.

• Providers who certify an abnormally large number of

placardapplications.

• Individuals over  years of age with active placards.

33California State Auditor Report 2016-121

April 2017

Chapter 2

BETTER COMMUNICATION AND COORDINATION WILL

HELP DETECT AND DETER MISUSE OF DISABLED PERSON

PARKING PRIVILEGES

e Department of Motor Vehicles (DMV) can improve its

enforcement eﬀorts related to misuse of disabled person parking

placards (placards) or disabled person or disabled veteran

license plates (plates), and it can improve the eﬀectiveness

of its enforcement through better public outreach. Based on

theexperience of both DMV and local parking enforcement, the

most common type of placard misuse is one person using another

person’s valid placard. DMV’s Investigations Unit (Investigations)

conducts organized enforcement operations—known as sting

operations—to catch people misusing placards in this manner;

however, it has not established speciﬁc expectations for the

frequency of such operations. We found that for the sixsting

operations we reviewed, the number of operations varied by district

oﬃce, ranging from one to  over our three-year audit period

from July  through June . Further, while the stings DMV

conducts are eﬀective at catching misuse, DMV generally does

not publicize the results through the media, limiting the stings’

eﬀectiveness as a deterrent for this type of abuse. Also, at the local

level, we spoke to parking enforcement oﬃcials in six cities and

they stated they lack immediate access to placard information that

could help them enforce the law. Further, the majority said they

would like to work more closely with DMV, including receiving

training to help their local enforcement oﬃcials detect and deter

placard misuse. Until DMV establishes reasonable expectations for

consistently taking enforcement actions to prevent placard abuse

and improves local enforcement oﬃcials’ access to informationand

training, DMV’s ability to detect and deter placard fraud will

belimited.

DMV’s Placard Enforcement Activities Need Expanding, and It

Could Help Deter Placard Misuse by Publicizing the Results of

ItsInvestigations

e rate of placard misuse is signiﬁcant. Investigations’ district

oﬃces conducted  sting operations from July  through

June. During a sting operation, an investigator observes

someone using a placard to park for free or in a space designated

for people with disabilities, asks the person whether the placard

legally belongs to him or her, and conﬁrms this information

using DMV’s registration system. We reviewed the results for

six of DMV’ssting operations conducted from July  through

June  at a variety of locations including shopping centers, a

California State Auditor Report 2016-121

April 2017

college campus, downtown Sacramento, and a stadium that hosts

professional sporting events. During those activities, investigators

made contact with  people whose vehicles displayed a placard and

found that  of them, or about  percent, were misusing the placard.

e rate of misuse was higher in two of the threesting operations

conducted at locations requiring payment for parking— percent

at a college campus and  percent in downtown Sacramento.

esehigher rates were consistent with the rate that the LosAngeles

Department of Transportation (LADOT) identiﬁed during

itssting operations.In LADOTreported that it conducted

stingoperations, which it refers to as compliance checks, and

found that about percent of the individuals they contacted were

misusingplacards.

According to DMV’s deputy chief of Investigations and parking

enforcement oﬃcials from six cities, the most common form

of placard misuse they encounter involves someone using

another person’s valid placard. We reviewed  cases of placard

misuse that originated from six of DMV’s sting operations and

foundthat in cases, the person cited was using an active placard

thatbelonged to someone else. In the remaining cases, three were

using expired placards and one was using a placard that had been

reported as lost or stolen. e deputy chief said that to apprehend

someone fraudulently using someone else’s valid placard, a DMV

investigator must approach a person using a placard to conﬁrm the

placard’svalidity.

Although the sting operations are eﬀective, DMV has not

established speciﬁc expectations for the number of sting operations

it conducts of placard misuse. According to the deputy chief of

Investigations, some district oﬃces set their own goals for stings,

but DMV does not have a policy or goal regarding the number

of sting operations that its district oﬃces must conduct. We

reviewed the operations that six district oﬃces conducted during

ﬁscal years – through – and found that the number

of operations varied by district oﬃce, ranging from one to  over

the three-year period. e deputy chief of Investigations said

thatthemanagement for two of these six district oﬃces—Fresno

and Sacramento—established an expectation of one placard misuse

sting operation per month for ﬁscal years– and–.

Fresno and Sacramento actually conducted and sting

operations respectively from ﬁscal years – through –,

which is less than the stated goal but signiﬁcantly more than the

other district oﬃces we reviewed. For example, the Vallejo district

oﬃce, which did not have a goal during that time, conducted only

one sting operation during the three years. By not setting goals

for the number of sting operations it expects its district oﬃces to

conduct, DMV has missed the opportunity to routinely identify

placardmisuse.

We reviewed the sting operations

that six district oﬃces conducted

from ﬁscal years 2013–14

through2015–16 and found that

the number of operations varied by

district oﬃce, ranging from one to

18 over the three-year period.

35California State Auditor Report 2016-121

April 2017

Investigations indicated that because of competing priorities, it

does not regularly conduct sting operations. e deputy chief of

Investigations explained that investigators handle numerous types

of cases, many of which, such as identify theft, are more serious

than placard misuse and that district oﬃces do not perform more

sting operations because of other pressing priorities. For example,

she stated that in ﬁscal year –, Investigations was focused

on cases surrounding implementation of new legislation extending

driving privileges to undocumented residents: during that time,

two of the oﬃces we reviewed—Los Angeles Metro and Vallejo—

had heavy workloads for cases regarding this issue, and for that

reason Investigations did not expect the Vallejo oﬃce to conduct

any placard sting operations that year. However, the prevalence of

placard misuse necessitates regular enforcement activity, especially

in areas with heavy abuse. For example, we expected that the

Brisbane district oﬃce, which has the city of SanFrancisco within

its jurisdiction, would have conducted more sting operations

because the San Francisco Municipal Transportation Agency

(SFMTA) has reported, based on data it has gathered along

with its enforcement activities, that fraudulent placard use is a

signiﬁcant problem in the city. However, that oﬃce conducted only

twosting operations during the three years we reviewed. Although

Investigations may have higher-priority cases, by not conducting

regular sting operations, Investigations is limited in its ability to

detect placard misuse.

DMV is also missing an opportunity to leverage the results of

the sting operations it does conduct to possibly deter those who

would otherwise misuse placards. e sting operations it conducts

are eﬀective—in each of the six sting operations we reviewed,

investigators contacted an average of  people and issued an

average of  citations and two warnings per operation, representing

an average misuse rate of about  percent. However, from ﬁscal

years – through –, Investigations publicized the

results of only one sting operation, a statewide operation on a

day in  when investigators issued more than  citations.

According to the deputy chief of Investigations, DMV has only

rarely publicized the results of its sting operations because it does

not believe thatthe press is interested in publishing them. However,

we disagree. Around the time when the Joint Legislative Audit

Committee approved this audit in May , several newspapers

and other media reported throughout the state on placard misuse

or on the approval of this audit. After we brought our concern

to DMV’s attention, it issued a press release regarding a sting

operation in March  in downtown Sacramento, in the same

area where we performed the visual survey of vehicles displaying

placards that we discuss in Chapter  on page . According to

DMV, percent of the people it contacted were misusing placards.

Several news organizations covered the outcome of the operation.

The prevalence of placard misuse

necessitates regular enforcement

activity, especially in areas with

heavy abuse.

California State Auditor Report 2016-121

April 2017

Further, ﬁve of the six cities’ parking enforcement oﬃcials we

interviewed agreed that placard misuse was a signiﬁcant problem,

depriving their cities of parking revenue and their disabled residents

of being able to park close to their desired destinations. e senior

traﬃc supervisor for LADOT stated that in some places the

majority of cars parked on the street display a placard, purportedly

because of placard abuse. e penalties for placard misuse are

high. Unlike other traﬃc infractions, such as running a red light or

parking next to a ﬁre hydrant, someone misusing a placard could

be charged with a misdemeanor crime, potentially resulting in a

base ﬁne of up to ,, additional civil penalties of ,, and

up to six months in jail. us, publicizing these penalties and the

results of DMV’s sting operations could increase awareness of

thepenalties for placard misuse and deter people from fraudulently

usingplacards.

Placard abuse harms the disabled community, businesses, and

municipalities. When nondisabled individuals misuse placards,

they make it more diﬃcult for people with disabilities to ﬁnd

parking close to their desired destinations. If people misusing

placards occupy spaces designated for people with disabilities and

metered spaces, people with disabilities must park farther from

their destinations or may not have access to them at all, causing

unnecessary hardship. Placard misuse therefore undermines

the purpose of the disabled person parking placard program,

which theLegislature implemented, in part, to improve access

for people with disabilities. In addition, businesses are aﬀected

when peoplemisuse placards as it reduces turnover in front of or

near their storefronts. e parking services manager of the city of

Sacramento stated that he receives complaints from businesses

alleging that people misusing placards park all day, taking up spaces

that their customers could use.

Finally, misuse hurts municipalities by reducing the parking

revenues they collect. Because placard holders are not required to

pay meter fees, the value of a placard can be signiﬁcant, especially

in areas where parking is expensive. For example, according to a

report it released in November , San Francisco’s city services

auditor estimated that in certain downtown areas of San Francisco

a placard could be worth , of savings a year on parking

fees. is represents signiﬁcant lost revenue for the city. In its

November report, the city services auditor estimated that the

city did not collect . million in parking fee revenue in ﬁscal

year– because of people parking for free with disabled

placards or plates. A portion of those people likely misused the

parking beneﬁt. If we apply the  percent rate of misuse we

identiﬁed when reviewing DMV’s enforcement activities, the

city missed out on about . million in annual parking revenue.

When nondisabled individuals

misuse placards, they make it more

diﬃcult for people with disabilities

to ﬁnd parking close to their

desireddestinations.

37California State Auditor Report 2016-121

April 2017

However, if the actual misuse rate was closer to the  percent

misuse rate in Los Angeles discussed earlier, San Francisco may

have missed out on about . million.

Parking placards are so valuable that there is a black market

for them. According to the deputy chief of Investigations,

Investigations regularly receives and investigates reports of placards

for sale online. In fact, after spending roughly an hour online in

February , we found and reported to DMV three placards for

sale—one had expired, another belonged to a deceased individual,

and the seller of the third appeared to intentionally hide the placard

number. We shared this information with Investigations, and as

of March  they had not completed an investigation into the

placards for sale.

Lack of Training and Current Policies May Limit Complaints of Placard

Misuse That DMV’s Investigations Unit Receives and Impede Its Ability

to Monitor the Eﬀectiveness of Its Investigations

DMV staﬀ who are responsible for processing applications for

disabled placards do not receive training on fraud detection,

and Investigations has inadequate policies that hinder its ability

to receive complaints from the public and track investigations.

TwoDMV units process disabled placard applications: staﬀ

in DMV’s ﬁeld oﬃces located statewide process applications

submitted in person, and the Special Processing Unit (processing

unit) atDMV’s headquarters in Sacramento processes those

applications DMV receives by mail. Because state law requires

DMV to examine and determine the genuineness and regularity of

every placard application, we expected that DMV would be training

these employees on how to identify potential fraud in placard

applications. However, according to DMV’s training manager,

DMV provides ﬁeld oﬃce staﬀ with only one fraud-related training,

which is not speciﬁc to disabled placards; that training is focused

instead on identifying fraud in identity documents, such as driver’s

licenses. As noted in Chapter , DMV does not require applicants

to provide documentation of their identity when they submit their

placard applications. Although the training manager asserted

that some of the fraud concepts covered in the training could be

applied to placard applications, this training alone does not equip

ﬁeld oﬃce staﬀ to identify the types of fraud most likely to be

encountered in the applications, such as forged or false medical

providerinformation.

Further, DMV does not provide any fraud training to the staﬀ

working at headquarters in its processing unit. According to the

former program manager who oversaw that unit, it processes

between  and  placard applications each day, and given this

Parking placards are so

valuablethat there is a black

market forthem.

California State Auditor Report 2016-121

April 2017

volume, she stated that staﬀ would notice if something were wrong

with a particular placard application. If this were the case, however,

we likely would not have found the frequency in the occurrence of

the issues described in Chapter  related to applications containing

illegible disability descriptions or certiﬁcations of disabilities the

medical providers were not authorized to make. If the employees

who process placard applications do not receive training on how

to identify potential fraud indicators within those applications,

it is unlikely that they will be able to do so or will know to look

for signs of fraud. e deputy chief of Investigations stated that

training on the speciﬁc types of fraud in a placard application could

include being aware of when a particular ﬁeld oﬃce receives several

applications certiﬁed by the same medical provider, identifying

when a provider’s address is suspiciously far from the applicant’s

address, and observing whether the provider’s handwriting

appears to be the same as the applicant’s handwriting. Without

such training, DMV lacks assurance that staﬀ have the knowledge

necessary to identify and report questionable applications.

In addition to providing training for DMV staﬀ who process

placard applications, Investigations could make it easier for the

public to submit complaints regarding placard misuse. Currently,

Investigations’ complaint policy requires complainants to submit

all complaints by mail, using a standardized hard-copy complaint

form, to one of Investigations’ district oﬃces. Complainants can

either go online to print the form or, according to the deputy

chief of Investigations, pick one up from their local DMV ﬁeld

oﬃce. Instructions on the form direct the complainant to mail the

completed form to the DMV Investigations district oﬃce closest

tothe location of the incident; these instructions also state that this

is the only way to submit a complaint to DMV. However, according

to the deputy chief of Investigations, DMV does accept complaints

submitted in other ways. She explained that if someone leaves a

complaint form at a local ﬁeld oﬃce, it will be forwarded to the

appropriate Investigations district oﬃce. Further, she stated that

although it is not DMV’s policy to accept complaints by telephone,

investigators always accept such complaints from law enforcement

and many investigators accept telephone complaints from the

public, although it is likely that not all do so. DMV does not have an

online option or process for the public to ﬁle complaints regarding

placard misuse.

Although not consistently followed, this policy makes reporting

potential placard fraud and abuse unnecessarily burdensome for

the public. Requiring complainants to print, complete, and mail in a

complaint form may discourage the submission of valid complaints.

We reviewed DMV’s placard-related investigations from July 

through June  and found that complaints DMV received from

members of the public comprised only about  percent of the

If the employees who process

placard applications do not

receive training on how to identify

potential fraud indicators within

those applications, it is unlikely

that they will be able to do so or will

know to look for signs of fraud.

39California State Auditor Report 2016-121

April 2017

,investigation cases DMV initiated during that same three-year

period. Without more eﬃcient channels for submitting complaints,

DMV risks that placard fraud and abuse will go unreported.

However, Investigations has not simpliﬁed its process for reporting

complaints of placard misuse. When we brought this issue to

DMV’s attention, the deputy chief of Investigations said that it is

open to changing its policy to allow people to make complaints

regarding placard misuse via telephone and online, and she agreed

that doing so would be beneﬁcial because it could increase the

number of complaints received from the public. She also believed

that Investigations would be able to handle any associated increase

in complaints.

In addition to limiting the complaints it receives, Investigations’

process prevents it from monitoring how quickly investigators

complete their cases. According to the deputy chief of

Investigations, DMV requires its investigators to leave cases open

in the investigations database until a court adjudicates the case.

We expected that Investigations would regularly review thelength

of time that placard abuse cases had been open to ensure that

investigators are completing their investigations within a reasonable

time frame. However, DMV’s process limits its ability to do so.

Speciﬁcally, the deputy chief of Investigations stated that DMV

requires its investigators to regularly check with the court to

determine whether the court has adjudicated the case and then

enter the court disposition into the database before closing the case.

Tracking the court’s adjudication is beneﬁcial; however, becausethe

database reﬂects the date that the investigator entered the court

disposition, which can be days or even weeks after the disposition,

rather than the date the investigator completed the investigation,

Investigations cannot determine the amount of time investigators

are taking to complete their work. As a result, Investigations cannot

ensure that investigators are promptly addressing complaints of

placard fraud and abuse. e deputy chief of Investigations again

acknowledged that Investigations is open to changing its process,

stating that doing so would better allow the unit to monitor the

time it takes investigators to close cases.

Further, investigators do not consistently follow up with the courts

to determine case outcomes. As of August , according to data

DMV provided from its investigations database, (percent)

of the , cases initiated from July  through June  were

still open, some for more than two years. We reviewed  of the

open cases and found that in nine of them, the investigations

were complete but the investigator had not yet obtained a court

disposition to close the cases, even though, according to the

deputy chief of Investigations, the courts had likely adjudicated

the cases based on the length of time the cases had been

open.edeputychief of Investigations said the tenthcase

Investigators do not consistently

follow up with the courts to

determine case outcomes;

21percent of the 3,082 cases

initiated from July 2013 through

June 2016 were still open, some

formore than two years.

California State Auditor Report 2016-121

April 2017

was stillopen. She explained that supervisors are supposed to

monitor how long cases have been open and follow up with

their investigators to ensure that they enter case adjudication

information when it becomes available and then close the cases.

Even when investigators enter the case outcome, inconsistencies

in the way they do so impede Investigations’ ability to monitor the

results of its investigations. When closing a case in the database,

investigators select from a variety of codes that indicate the

outcome of the case, and Investigations expects its investigators

to use the appropriate codes when doing so. However, in our

review of the database, we found the investigators’ use of the codes

lacked uniformity. For example, the deputy chief of Investigations

conﬁrmed that investigators used the codes for “no jurisdiction,”

“investigative threshold not met,” “insuﬃcient evidence,” and “no

action warranted” interchangeably. erefore, for the cases where

investigators applied these codes, we were unable to determine by

reviewing the data the speciﬁc reasons Investigations closed the

cases. According to the deputy chief, Investigations does not have

a manual that describes how investigators should use status codes,

but she acknowledged that such a manual could help establish

consistency. She also stated that investigators do not consistently

use the codes and do not regularly check with the courts to obtain

case adjudications because they need more concrete direction and

training. She explained that in April , Investigations would

begin retraining its investigators on following up with the courts

and the proper use of the status codes. If DMV does not obtain the

outcomes for its cases or accurately enter them into its system, it

cannot eﬀectively use its database to monitor its investigations to

ensure that they are timely and are achieving the desired results.

DMV Has Not Ensured That Parking Enforcement Agencies Have

Direct Access to Placard Records or Needed Training Regarding

Eﬀective Enforcement, Although This Could Help Mitigate

PlacardMisuse

Local parking enforcement’s lack of immediate access to DMV’s

placard information prevents these oﬃcials from eﬃciently

identifying and seizing misused placards. As we discussed

previously, the most common form of placard misuse is one

person using another’s active placard, and identifying that type of

misuse typically requires a sting operation. However, oﬃcials can

identify another type of misuse—using an invalid placard, such as

onereported lost or stolen, or using one that belongs to a deceased

individual—by determining whether the placard is valid from

DMV’s records. We reviewed DMV’s records to identify the reasons

that enforcement oﬃcials had seized placards, and we found that

of the roughly , placards seized for misuse and submitted to

Local parking enforcement’s lack of

immediate access to DMV’s placard

information prevents these oﬃcials

from eﬃciently identifying and

seizing misused placards.

41California State Auditor Report 2016-121

April 2017

DMV for cancellation during , about , or  percent, of

the placards were invalid because they had been reported lost or

stolen, they belonged to a deceased placard holder, or they had been

replaced. us, this type of misuse is not uncommon. If oﬃcials

can promptly access DMV’s placard information, the likelihood is

greater that they will catch and cite people using invalid placards.

e time it takes parking enforcement to obtain placard

information discourages them from determining whether

placardsare valid. Parking enforcement oﬃcials in the six cities

we contacted noted that they have the primary responsibility for

enforcing placard laws, rather than law enforcement oﬃcials such

as the local police. However, parking enforcement oﬃcials do not

have immediate access to DMV’s placard information because

they are not sworn peace oﬃcers. According to the California Law

Enforcement Telecommunications System (CLETS) administration

section at the Department of Justice, with proper statutory

authorization parking enforcement could obtain indirect access to

CLETS information by calling and requesting the information from

a dispatcher. However, this process is time consuming, and parking

enforcement oﬃcials in four of the six cities we contacted reported

that they typically do not contact a dispatcher to verify whether

placard numbers are valid. Oﬃcials from two cities, Sacramento

and San Francisco, reported that they have designated one parking

enforcement oﬃcial or more to patrol for placard misuse, but

because verifying the validity of placards is time consuming,

they explained that their remaining parking enforcement oﬃcials

generally do not do so. Lack of prompt access to DMV’s placard

information hinders the ability of these oﬃcials to identify invalid

placards that are in fraudulent use.

Although DMV oﬀers a variety of channels for law enforcement

and parking enforcement to obtain placard information, only

some provide immediate information. State law requires DMV

to provide law enforcement and parking enforcement with

accesstoits placard information, and DMV provides this access

in several ways. However, the speed at which those agencies can

obtain the information through each channel varies. For example,

law enforcement and parking enforcement can request hard-copy

placard records through the mail, but DMV’s stated processing time

for such requests is generally seven to  business days. Although

DMV’s law enforcement call center provides law enforcement and

parking enforcement with quicker access to placard information,

this access is also not timely enough for those oﬃcials who need to

immediately access information for multiple vehicles, such as a row

of vehicles parked on a busy metered street. We reviewed DMV’s

call records from August  through August  and found

that the average wait time for callers was about threeminutes. If a

parking enforcement oﬃcial encountered a block with  vehicles

The time it takes parking

enforcement to obtain placard

information discourages them

from determining whether placards

arevalid.

California State Auditor Report 2016-121

April 2017

displaying placards and wanted to check the validity of those

placards, the oﬃcial would have to either repeatedly contact the

call center and wait an average of three minutes for each vehicle,

or keep the DMV representative on the phone while the oﬃcial

checked each vehicle. ree of the largest parking enforcement

agencies we interviewed conﬁrmed this would be too time

consuming to be practical. Additionally, the DMV call center

responds to requests from law enforcement, government agencies,

and the media regarding all vehicle registration inquiries, not

just those related to placards. e call center manager conﬁrmed

that repeated calls for placard information would strain the

center’s resources and increase wait times. Although we found

threeminutes to be a reasonable wait time for the call center

in general, it does not provide fast enough access for parking

enforcement oﬃcials to use when on patrol.

e two remaining channels for access to placard information

aﬀord users immediate access. However, parking enforcement

cannot obtain direct access to either channel. Speciﬁcally, law

enforcement, as sworn peace oﬃcers, can directly access DMV

vehicle registration information, including placard information,

using CLETS, but parking enforcement are not sworn peace

oﬃcers, and as a result cannot directly access CLETS. With proper

authorization, a parking enforcement agency could obtain CLETS

information indirectly, for example by calling a law enforcement

dispatcher with CLETS access. However, according to the CLETS

administration section, under no circumstances could a parking

enforcement agency obtain mobile access to CLETS, such as

through handheld devices or terminals in their vehicles.

DMV also provides access to its registration system through its

own data communications system, which contains the same placard

information that is accessible through CLETS. However, according

to the program manager in DMV’s Information Services Branch,

this access is expensive because of the security measures and

protocols that must be in place given the sensitivity of the data. As

a result, she explained that typically only large agencies, such as the

State Board of Equalization and the Franchise Tax Board, obtain

this type of access to DMV records.

Nevertheless, DMV may have an opportunity to create and

maintain a database for parking enforcement oﬃcials to

immediately access the validity of placards. Given the limitations

that parking enforcement faces in accessing placard information,

we asked about the feasibility of DMV developing its own database

containing only the information necessary to identify valid placards.

According to the registration division chief, DMV could create and

maintain a database containing all canceled and inactive placards,

and update that database regularly. However, he explained that

The two remaining channels for

access to placard information

aﬀord users immediate access.

However, parking enforcement

cannot obtain direct access to

eitherchannel.

43California State Auditor Report 2016-121

April 2017

DMV has never considered creating such a database and, therefore,

does not have an estimate of the amount of time or money it

would take to create and maintain such a database. All six parking

enforcement oﬃcials we spoke to indicated that if DMV developed

such an application, their agencies would use that technology.

In addition to more timely access to placard information, the

majority of parking enforcement oﬃcials we interviewed wanted

more guidance and training from Investigations, but DMV has not

provided these resources because it was unaware of the demand

for them. As previously noted, oﬃcials from each of thesix cities

we interviewed explained that parking enforcement, not law

enforcement, bears primary responsibility for upholding placard

laws. We expected to ﬁnd that Investigations, as a subject matter

expert, would provide some guidance and training to parking

enforcement agencies to aid their eﬀorts to eﬀectively identify

and prevent placard misuse. According to the deputy chief of

Investigations, DMV has provided training to parking enforcement

when they have requested it, but this has been limited. However,

DMV was unable to produce evidence demonstrating that it

had provided this training. She said that DMV was unaware that

parking enforcement agencies wanted information and training,

and has instead focused on providing outreachand training

on placard abuse to law enforcement agencies. However, local

parking enforcement, not law enforcement, is the most appropriate

audience for such training. By educating local parking enforcement

agencies on strategies for addressing placard abuse, Investigations

could help to improve local enforcement eﬀorts, which could help

deter misuse and free up parking for those with disabilities. Such

information and training could include, for example, content on

the proper conduct of a sting operation and trends in placard

misuse. e deputy chief of Investigations agreed that it would be

beneﬁcial to reach out to parking enforcement agencies to educate

them about parking placard enforcement and DMV investigations

operations and said that Investigations would begin doing so.

One way DMV could assist local parking enforcement oﬃcials

would be to inform them of the ability to increase revenue for

enforcement. State law allows local governments to pass ordinances

to increase penalties for placard misuse by per citation, as long

as the localities use the revenue generated to increase enforcement

eﬀorts related to placards or to parking designated for people with

disabilities. For example, localities could spend more money on staﬀ

or technology speciﬁcally for placard enforcement. Oﬃcials at all

six cities stated that they do not make use of this provision in state

law, and most were not aware of theprovision.

The majority of parking

enforcement oﬃcials we

interviewed wanted more guidance

and training from Investigations.

California State Auditor Report 2016-121

April 2017

Without making use of this provision, the cities are missing out on

revenue to increase placard enforcement. For example, an LADOT

senior traﬃc supervisor reported that the city issued almost

,citations in . If Los Angeles increased its placard misuse

penalty by the additional , it might have raised nearly ,

in additional revenue for placard enforcement. In addition,

increasing penalties for placard misuse could increase the deterrent

eﬀect those penalties have on people who misuse placards. As part

of its guidance to local parking enforcement oﬃcials, DMV could

inform them of the ability to increase revenue from citations issued

for placard misuse.

DMV Did Not Track When It Canceled Misused Placards That

Enforcement Oﬃcials Have Seized

DMV does not have procedures in place to ensure that enforcement

oﬃcials submit information regarding seized placards or to

ensure that it is canceling such placards in a timely manner. When

enforcement oﬃcials seize placards, state law requires the agencies

to notify DMV of the seized placard numbers. State law then

requires DMV to cancel the seized placards. However, there is no

statutory time frame for canceling seized placards, nor is there a

deadline by which these agencies must notify DMV of the seized

placard numbers. Nevertheless, timeliness is important. Until

DMV cancels a placard in its registration system, the holder may

report that placard as lost or stolen and receive a new onewithout

the need for a new medical certiﬁcation. Five of the sixlocal

enforcement agencies we contacted provided us with placard

numbers they recently seized because of misuse and sent to DMV

for cancellation. DMV canceled  of them. In one instance,

DMVdid not receive the placard number or cancel the placard,

and the holder was able to receive a replacement. e enforcement

oﬃcials send only the seized placard numbers to DMV for

cancellation; once DMV cancelstheplacards, the local enforcement

agency is expected to destroy thephysicalplacards.

Until very recently, DMV did not track how long it takes to cancel

a seized placard. According to desk procedures provided to

DMV staﬀ, DMV must cancel seized placards within  hours of

receipt. We reviewed  placard numbers DMV had received from

local enforcement agencies from January , the earliest date

thatDMV had such records available, through September . In

all cases DMV had canceled them; however, DMV staﬀ entered

the date the individual was cited by the enforcement oﬃcials asthe

cancellation date, preventing us from determining whether DMV

canceled them within  hours. According to the registration

division chief, staﬀ record the citation date as the cancellation date

so activity on the record can clearly be identiﬁed as having occurred

Until very recently, DMV did not

track how long it takes to cancel a

seizedplacard.

45California State Auditor Report 2016-121

April 2017

after the date enforcement oﬃcials seized the placard for misuse,

which can be useful for them or others to investigate the individual

misusing the placard. After we brought this to DMV’s attention

in March , the chief of the Registration Services Branch

(registration branch chief) explained that, beginning immediately,

staﬀ would track the date placards were canceled in a spreadsheet

separate from DMV’s registration database.

Delays by local enforcement oﬃcials and confusion over where

to send placard cancellations compound the lack of timely

cancellation. Of the  cancellations we reviewed, in four instances

DMV recorded that it received the cancellation requests more

than days after the placard holders had been cited for misuse.

According to a training schedule provided by DMV, it sporadically

provides to enforcement oﬃcials training materials that convey the

need for timely submission of placard cancellation requests.

Further, DMV receives cancellation requests by mail, fax, or email,

but there has been confusion over where to send the requests.

For example, the assistant director of the enforcement division

at SFMTA stated that staﬀ were not informed when the unit that

processes cancellation requests moved, and the agency continued

for several months to send placard cancellation requests to

the wrong fax number. Also, we observed one instance where

SantaCruz sent a cancellation request for a placard and DMV

never received it. According to the registration branch chief, the

entity sent the request for cancellation to the wrong address. DMV

maintains two fax numbers to which local enforcement agencies

may send cancellation requests, but one is not located within

the unit processing the requests. According to the registration

branch chief, DMV wanted to keep both lines active in case a local

entity did not know about the new fax number. Nevertheless,

this requires a staﬀ person to remember to go to another unit on

another ﬂoor of the building to periodically check the fax machine.

Finally, DMV informed us that email requests for cancellations

go to speciﬁc individuals. is could cause delays in canceling

placards if theseindividuals choose to leave their employment with

DMV or are on extended leave. We asked DMV whether it had

considered maintaining dedicated fax numbers and email addresses

for placard cancellations. e registration division chief stated that

DMV would consider implementing such tools. Further, he stated

that DMV maintains an email distribution list of enforcement

oﬃcials with which DMV has contact and that it could use to

communicate such information. Without regular communication

with local enforcement agencies regarding the need for timeliness

in submitting cancellation requests or where to send such requests,

DMV risks allowing individuals caught misusing placards to obtain

a replacement instead of having to apply for a new placard and

submit a new certiﬁcation of disability.

DMV receives cancellation requests

by mail, fax, or email, but there has

been confusion over where to send

the requests.

California State Auditor Report 2016-121

April 2017

DMV Could Take Additional Steps to Mitigate Placard Misuse

To further combat misuse, DMV could take steps to make it

easierto return placards if found or if they are no longer needed

and to raise public awareness of the penalties and eﬀects of placard

misuse. We reviewed transactions related to  placards from

DMV’s registration system to identify any data entry errors and

found that more than half of the transactions were for placard

holders who reported the placard as lost. However, as noted earlier,

when DMV cancels a placard in its database, the placard itself

remains physically in circulation and anyone can continue to use

the canceled, invalid placard. Similarly, when DMV mistakenly

renews placards of deceased people, as we discussed in Chapter,

those placards are in circulation and available for misuse unless

returned to DMV. However, DMV does not currently print a return

mailing address on placards, making it diﬃcult for those who

ﬁnd lost placards to know where to send them. Federal regulation

requires DMV to include certain information on placards, including

the International Symbol of Access, but this does not prevent

DMV from including a return mailing address. According to its

registration division chief, DMV did not identify this as a potential

method for reducing placards in circulation, but agreed the idea

isfeasible.

DMV also does not perform public outreach to raise awareness

about the eﬀect that placard misuse has on people with disabilities.

Public awareness campaigns are a useful tool for informing people

of the consequences of certain unlawful activities. For example, the

California Oﬃce of Traﬃc Safety’s It’s Not Worth It campaign warns

of the consequences of distracted driving from using cell phones

and texting. Additionally, other jurisdictions have developed public

awareness campaigns. e state of Colorado’s Advisory Council for

Persons with Disabilities has a campaign called Excuses vs. Reasons

that, according to its website, was born out of extensive research

underscoring the need for more information on the challenges

people with disabilities face when attempting to park in designated

parking spaces. By using real excuses cited by nondisabled people,

the campaign promotes the fact that “No Plates. No Placard. No

Parking” is a right all drivers should defend. e city of Phoenix,

Arizona, has an outreach eﬀort called the Save Our Space Parking

Campaign, which publishes a brochure describing the eﬀects

that taking parking from a person with disabilities could have.

According to a city representative, the brochures are distributed

to local oﬃces that serve people with disabilities. Both of these

eﬀorts provide examples of ways to reach out to more people and

encourage them to think twice before parking in a designated

parking space or misusing a placard that does not belong to

them. DMV’s registration division chief told us that a coordinated

outreach campaign has not been implemented in the past. Afterwe

DMV does not perform public

outreach to raise awareness about

the eﬀect that placard misuse has

on people with disabilities.

47California State Auditor Report 2016-121

April 2017

brought the outreach campaigns of Phoenix and Colorado to

DMV’s attention, he stated that DMV will initiate an outreach

campaign in the coming ﬁscal year.

Recommendations

DMV

To better deter placard abuse, by September  DMV should

establish reasonable goals regarding the number of sting operations

each of its district oﬃces should conduct each quarter. If competing

priorities require a district oﬃce to miss its goal for a given quarter,

Investigations should document its justiﬁcation for missing the

goal. Further, Investigations should monitor its district oﬃces’

eﬀectiveness in meeting the quarterly goals.

To help ensure that DMV’s sting operations are an eﬀective

deterrent to placard misuse, beginning immediately DMV should

regularly publicize the results of all of its sting operations through

local and statewide media, on its website, and in materials

distributed to the public at its ﬁeld oﬃces.

To properly equip its employees with the knowledge

necessary to identify and report potential fraud indicators in

placard applications, DMV should provide employees who

processapplications with training speciﬁc to the types of fraud

thatcan occur in an application. is training should be provided

by December  and every other year thereafter.

To encourage reporting of allegations of placard abuse,

Investigations should amend its policy to accept complaints by

telephone and online by June  and display the instructions for

doing so prominently on its website.

To better track the time needed to investigate placard-related cases,

Investigations should immediately require investigators to indicate

in Investigations’ database that cases are closed upon concluding

the investigation and to continue to track the court’s adjudication of

each case.

To better monitor the results of its enforcement operations,

Investigations should provide training and guidance to

itsinvestigators on how to use and consistently enter case

disposition information into its database, and it should train its

supervisors to regularly follow up with investigators to ensure

thatthey do so.

California State Auditor Report 2016-121

April 2017

To better equip local parking enforcement oﬃcials to promptly

identify invalid placards, by December  DMV should develop

and implement an application, database, or other technology

that will allow non-sworn parking enforcement oﬃcials to have

immediate access to information on placard status.

To aid local placard enforcement eﬀorts, by September 

DMV should develop guidance and training regarding strategies

to combat placard misuse and notify local parking enforcement

oﬃcials that the DMV guidance and training is available. As part of

these eﬀorts, DMV should include information on state law related

to increasing citation penalties to fund enforcement eﬀorts.

To track its eﬀectiveness at canceling seized placards, DMV should

continue its new practice of keeping a record of the date staﬀ take

action to cancel a placard and assess whether DMV is meeting its

goal of canceling seized placards within  hours of receipt.

To provide local enforcement agencies with an eﬀective way to

submit placard cancellation requests, DMV should immediately

establish a dedicated fax number, a dedicated email address, and a

speciﬁc mailing address to receive such cancellations. DMVshould

communicate this information to local parking enforcement by

July  and should develop a schedule for communicating this

information to local parking enforcement in the future. By July

and periodically thereafter, DMV should inform local parking

enforcement of the need to submit information on seized placards

quickly in order to prevent the holder or someone else from

requesting a replacement placard without having to submit a new

medicalcertiﬁcation.

To reduce the risk of placard misuse, DMV should update its

placards to indicate a return address if found or if the placard

holder is deceased. DMV should prepare this update for the

permanent placards it will issue in  that will expire in .

To raise public awareness about parking for people with disabilities

in California and deter placard misuse, by September  DMV

should develop a plan for conducting a public outreach campaign

about the eﬀect that placard misuse has on people with disabilities

and the penalties for misusing a placard.

49California State Auditor Report 2016-121

April 2017

We conducted this audit under the authority vested in the California State Auditor by Section

et seq. of the California Government Code and according to generally accepted government auditing

standards. ose standards require that we plan and perform the audit to obtain suﬃcient, appropriate

evidence to provide a reasonable basis for our ﬁndings and conclusions based on our audit objectives

speciﬁed in the Scope and Methodology section of the report. We believe that the evidence obtained

provides a reasonable basis for our ﬁndings and conclusions based on our audit objectives.

Respectfully submitted,

ELAINE M. HOWLE, CPA

State Auditor

Date: April , 

Staﬀ: Laura G. Kearney, Audit Principal

John Lewis, MPA

Jim Adams, MPP

Sarah Flower

Amanda Millen, MBA

IT Audits: Michelle J. Baur, CISA, Audit Principal

Lindsay M. Harris, MBA, CISA

Shauna M. Pellman, MPPA, CIA

Legal Counsel: Heather Kendrick, Sr. Staﬀ Counsel

For questions regarding the contents of this report, please contact

Margarita Fernández, Chief of Public Aﬀairs, at ...

50 California State Auditor Report 2016-121

April 2017

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51California State Auditor Report 2016-121

April 2017

Appendix A

A COMPARISON BETWEEN PARKING BENEFITS FOR

PEOPLE WITH DISABILITIES IN CALIFORNIA AND

SELECTOTHER STATES

To understand how disabled person parking beneﬁts might

diﬀer in other states, we selected nine states to review, as listed

in TableA on the following page. We selected neighbor states

as well as larger states and others for geographic diversity. As

TableA shows, California and one other state we reviewed do not

require placard holders to periodically reapply for disabled parking

placards or plates. Further, several states we reviewed oﬀer free

metered parking with varying or no time restrictions. Additionally

two states—Illinois and Michigan—have established two-tiered

systems.In both of these states, all individuals with placards may

park in specially designated disabled spaces; however, to receive free

parking in metered spaces, individuals must have a disability that

limits their ability to use a parking meter.

52 California State Auditor Report 2016-121

April 2017

Table A

A Comparison of Selected Disabled Person Parking Policies in California and Other States

PARKING BENEFITS FOR PEOPLE WITH DISABILITIES HOLDING APPROPRIATE PLACARDS OR OTHER PERMITS

STATE

PERIODIC REAPPLICATION

REQUIREMENTS FOR

PERMANENT PLACARDS

THE STATE EXEMPTS PERSONS WITH DISABILITIES

FROMPARKING METER FEES*

DISABLED PERSON MUST ABIDE

BY TIME RESTRICTIONS

DISABLED PERSON MAY

PARK IN DESIGNATED

PARKING SPACES

California

Yes No Yes

Florida Yes

(up to 4 years)

†

Yes May park up to four

hours in metered spaces;

however, local ordinances

may extend that time.

Yes

Illinois

‡

Yes

(4 years)

†

Fee-exempt placard holders only. No time restrictions for

fee-exempt placard holders

at meters with time limits of

more than 30 minutes.

Yes

Massachusetts No Yes No Yes

Michigan

‡

Yes

(4 years)

Fee-exempt permit holders only. Yes Yes

Nevada Yes

(10 years)

No May park up to fourhours

in time-restricted spaces.

Yes

North Carolina Yes

(5 years)

†

No No Yes

Oregon Yes

(up to 8 years)

†

Free metered parking for wheelchair users in zones

with time limits above 30 minutes. Local parking

authorities may allow other disabled parking

permit holders the same free meterprivileges.

No time restrictions for

zones with limits greater

than 30 minutes.

Yes

Pennsylvania Yes

(5 years)

No, although upon expiration of the meter, a

one-hour grace period is allowed before a citation

is issued. Persons with disabilities not paying

a meter upon arrival will be cited without the

graceperiod.

May park up to one hour

longer than posted time

limits except where local

ordinances accommodate

heavytraﬃc.

Yes

Washington Yes

(5 years)

†

Yes No. Local jurisdictions may

impose time limits of no

less than four hours.

Yes

Sources: California State Auditor’s analysis of laws and other publicly available information for the selected states as well as interviews with oﬃcials from

Illinois, Michigan, and Oregon.

* Localities in states without a statewide exemption of parking meter fees may nevertheless have such an exemption.

†

Requires recertiﬁcation of the disability.

‡

States employing a two-tiered system for placards require that individuals must have qualifying physical limitations, such as an inability to handle coins

because of limited motor control in both hands, to be entitled to free, unlimited metered parking. These are fee-exempt placard holders. Other disabled

individuals may use designated parking spaces, but do not receive free parking without consideration of time limits.

53California State Auditor Report 2016-121

April 2017

Appendix B

DISABLED PERSON PARKING PLACARD ABUSE

CASES INVESTIGATED BY THE DEPARTMENT OF

MOTOR VEHICLES’ INVESTIGATIONS UNIT,

FISCAL YEARS 2013–14 THROUGH 2015–16

e Joint Legislative Audit Committee asked the California State

Auditor to evaluate the extent to which the Department of Motor

Vehicles (DMV) investigates placard-related complaints. As described

in the Introduction, DMV’s Investigations Unit (Investigations)

receives complaints from external parties, such as the public or law

enforcement, but the majority of the cases it reviews are self-initiated

and are a result of sting operations that itconducts.

Table B presents information we obtained and reviewed from

Investigations’ database. e table summarizes, by ﬁscal year, the

numberof cases Investigations initiated through sting operations and

those it initiated based on a complaint from an external party. Further, the

table shows the outcomes for each of the cases that Investigations initiated,

listed according to the ﬁscalyear in which DMV initiated thecase.

Table B

Investigations Initiated by the DMV’s Investigations Unit

Fiscal Years 2013–14 Through2015–16

FISCAL YEARS

2013–14 2014–15 2015–16

TOTAL

EXTERNAL

COMPLAINTS

INITIATED BY

DMV’S

INVESTIGATIONS

DIVISION

EXTERNAL

COMPLAINTS

INITIATED BY

DMV’S

INVESTIGATIONS

DIVISION

EXTERNAL

COMPLAINTS

INITIATED BY

DMV’S

INVESTIGATIONS

DIVISION

Total cases initiated 142 683 160 1,046 178 979 3,188

Total cases opened for investigation 122 676 138 1,032 150 964 3,082

CASE OUTCOMES

Cases still open or in review as of

August 18, 2016*

3 63 6 112 57 418 659

Closed—no investigation or no violation 51 14 76 18 54 39 252

Closed—warning issued 47 119 25 177 46 94 508

Closed—conviction 21 305 9 461 9 227 1,032

Closed—dismissed 4 116 6 147 2 117 392

Closed—other

†

16 66 39 131 11 84 347

Totals

‡

142 683 161 1,046 179 979 3,190

Source: California State Auditor’s analysis of data from the DMV’s investigations database, as ofAugust 18, 2016.

* According to a deputy chief in Investigations, some of these cases are still open because of DMV’s policy that investigators should not close cases

untilthey have been adjudicated. In cases open longer than one year, the investigation is likely complete but the investigator has not obtained the

courtadjudication in order to close the case.

†

Includes cases not prosecuted due to statute of limitations, cases the local district attorney rejected, duplicate cases, and cases with an unknown

disposition due to inconsistencies in outcome reporting.

‡

The table shows 3,188 cases initiated but provides case statuses for 3,190 cases. This is because Investigations’ data set containing information

on closedcases contained two more closed cases than the data set containing all entered cases. DMV was unable to provide a reason for this

discrepancy, and the diﬀerence is not signiﬁcant.

54 California State Auditor Report 2016-121

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55California State Auditor Report 2016-121

April 2017

Appendix C

SCOPE AND METHODOLOGY

e Joint Legislative Audit Committee (Audit Committee)

directedthe California State Auditor to perform an audit of the

Department of Motor Vehicles’ (DMV) disabled person parking

placard program, including reviews of medical certiﬁcations,

identiﬁed and canceled placards belonging to deceased individuals,

and investigated placard-related complaints. Table C. lists the

objectives that the Audit Committee approved and summarizes

themethods we used to address those objectives.

Table C.1

Audit Objectives and the Methods Used to Address Them

AUDIT OBJECTIVE METHOD

1 Review and evaluate the laws, rules,

and regulations signiﬁcant to the

audit objectives.

Reviewed relevant state laws and regulations.

2 For a selection of issued or renewed

placards over the past three ﬁscal

years, determine thefollowing:

• To review the Department of Motor Vehicles’ (DMV) program for issuing disabled person parking

placards (placards) and disabled person or disabled veteran license plates (plates), we selected

a random sample from a population of the more than 1.4 million original plate and placard

applications DMV approved from July 2013 through June 2016, the most recently completed

threeﬁscal years. We used a 95 percent conﬁdence interval and a 10 percent precision rate to

determine an appropriate sample size of 96 applications. In some cases, we were able to conduct

analyses on DMV’s data for the entire population of placards and plates, and chose to do so rather

than rely on our sample. We note those instances in the audit objectives that follow.

• Analyzed data from DMV’s Vehicle/Vessel Registration Master File (registration system) to

determine whether any placard holders had more than one active, permanent placard as of

June30, 2016, the midpoint of the two-year period for permanent placards beginning July2015.

 a. Whether the applicant has been

issued more than one placard

during the same two-year

period the initial placard is, or

was, in force.

 b. Whether the name and

signature of the medical

provider who certiﬁed the

qualifying disease or disability

matches information on

ﬁle with the applicable

licensingboard.

Using the representative sample described in Objective 2a, we compared the medical providers’

signatures on the applications with signatures on ﬁle with the appropriate Department of Consumer

Aﬀairs’ healing arts boards (health boards).

 c. Whether substantiating

information retained by the

medical provider who signed

the placard application

certiﬁcation matches the

statutory deﬁnition of a

disabled person.

As we discuss in Chapter 1, state and federal law prevent DMV and the health boards from obtaining

and reviewing information on patient diagnoses without obtaining patient consent, unless the

applicable health board issues an investigative subpoena or obtains an otherwise valid legal order.

Thus, we were unable to review substantiating information retained by the medical providers. As

an alternative, we worked with the applicable health boards to have their medical experts review

the disability certiﬁcations on our representative sample of applications to determine whether the

information met requirements in state law.

 d. The number and percentage

of placard holders who are

deceased by comparing the

database of active placard

holders with the California

Department of Public Health’s

(Public Health) Oﬃce of Vital

Records’ deceased persons data.

• Reviewed DMV’s process for conducting a monthly comparison between Public Health’s data

and DMV’s data to identify deceased placard holders. Further, using data from DMV’s registration

system, determined whether those identiﬁed as deceased through this comparison from July2013

through December 2014 were issued new permanent placards with an expiration date of

June30,2017. We chose December 31, 2014, as the cutoﬀ date because the earliest DMV would

have issued a permanent placard with an expiration date of June 30, 2017, was January 1, 2015.

We have reasonable assurance that DMV’s processes work as expected.

continued on next page . . .

56 California State Auditor Report 2016-121

April 2017

AUDIT OBJECTIVE METHOD

• As we note in Chapter 1, the U.S. Social Security Administration also maintains a database, known

as the Death Master File (master ﬁle), of the deceased that has diﬀerent sources for its data. To

better assess whether DMV is identifying deceased placard holders, we compared DMV’s data

tothe master ﬁle.

• DMV identiﬁed three placard holders in our sample of 96 applications as deceased. The deaths

occurred after they applied for placards.

• Identiﬁed the number of individuals with active permanent placards who were age 100 or older as

of June 30, 2016, and compared the number to census data.

 e. How many placards have

remained in circulation after

a report by local authorities

that a placard was conﬁscated,

a report that a placard was

stolen, a conviction for misuse

of a placard, or other evidence

that a placard was used or

obtainedfraudulently.

• Reviewed data from the investigations database in DMV’s Investigations Unit (Investigations)

and found that DMV had no record of complaints or investigations on the placards in our

representative sample.

• Determined that none of the placards in our sample appeared within DMV’s records of placards

seized by local authorities.

• In Objective 7, we reviewed DMV’s activities related to placards seized by enforcement oﬃcials.

3 Provide a breakdown of certiﬁcations

by medical provider type over the

past three ﬁscal years. Over that same

time period, determine the number

of fraudulently obtained placards by

type of certiﬁcation.

Identiﬁed the type of medical provider certifying disabilities on the applications in our representative

sample. DMV does not always capture in its registration system information necessary to identify

the type of medical provider. Therefore, we could not provide a breakdown of provider type based

on the population as a whole. In Chapter 1, we discuss how this limits DMV’s ability to detect fraud.

Further, although we found irregularities in some applications in our sample and reported them to

Investigations, we did not deﬁnitively identify fraud.

4 Determine the extent to which the

DMV compares its placard holder

data against deceased persons data

and thereby withholds renewals for

deceased placard holders.

The procedures we performed that are described in Objective 2d also address this objective.

5 Examine the extent to which the DMV

makes placard holder information

available to eligible law enforcement

and parking control agencies.

Determine how promptly this

information is made available.

• Reviewed DMV processes for receiving and responding to information requests from law

enforcement, parking enforcement, and government agencies.

• Reviewed a selection of 24 information requests DMV responded to by mail to determine how

promptly DMV responded to those requests. Based on available information, we determined DMV

generally met established goals—up to 10 days for standard requests and less than seven days for

rush requests—for responding to requests.

• Reviewed DMV data on call waiting times for DMV’s law enforcement call center.

• Interviewed parking enforcement oﬃcials in six cities regarding the manner in which they

obtain access to DMV’s placard information and their satisfaction with the ease of access to that

information. We selected the six cities—Berkeley, Fresno, Los Angeles, Sacramento, San Francisco,

and Santa Cruz—based on population, geographic location, and our perception of limited parking.

6 Over the past three ﬁscal years,

determine the number of

replacement placards DMV issued

to replace reportedly lost or stolen

placards and whether it appropriately

canceled placards being replaced

before issuing a replacement.

Analyzed data from DMV’s registration system to identify permanent placards that DMV replaced for

any reason, including those reported as lost or stolen, and calculated the number of replacements per

individual from July 2013 through June 2016. We determined that when DMV issues a replacement, it

cancels the placard holder’s previous placard.

7 For the past three ﬁscal years,

determine how often and how

quickly the DMV canceled placards

conﬁscated by local authorities.

• Interviewed DMV management to document the process DMV uses to receive information from

enforcement oﬃcials regarding seized placards and to cancel those placards.

• Reviewed tracking spreadsheets DMV used to record its activities related to seized placards.

• Reviewed a selection of 15 placard cancellation requests DMV received from January 2015 through

September 2016. DMV had not retained original information from enforcement oﬃcials before

January 2015, and thus we had to limit our review to this time period.

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AUDIT OBJECTIVE METHOD

8 Examine how readily accessible,

up-to-date, and accurate DMV’s

placard information is to local

authorities, particularly for placards

reported as lost, stolen, surrendered,

canceled, revoked, expired, or

issued to someone appearing in the

deceased persons database.

• Interviewed local parking enforcement oﬃcials and in Objective 5 identiﬁed methods DMV uses to

make information available to them.

• Assessed the accessibility and timeliness of this information in Objective 5.

9 Evaluate the extent to which

DMV investigates placard-related

complaints and makes corresponding

updates to its database, particularly

for placards that may have been

fraudulently obtained or erroneously

issued, that were inappropriately

lent or sold to another individual, or

that were fraudulently duplicated

ordisplayed.

• Reviewed DMV’s process for receiving and investigating complaints of placard misuse and fraud.

• Reviewed cases from DMV’s investigations database coded as being speciﬁcally related to placard

abuse and initiated from July 2013 through June 2016. Using this data, we determined the

number of complaints and DMV-initiated cases DMV investigated, as well as the outcomes of those

investigations.

• Judgmentally selected and reviewed six of DMV’s placard misuse operations—sting operations—

including the scope, results, and costs for each operation.

• In Objective 7, reviewed how DMV responds to requests for canceling seized placards, including

those seized by Investigations.

10 Review and assess any other issues

that are signiﬁcant to the audit.

• To identify possible best practices, judgmentally selected nine states and researched laws, policies,

and procedures for their respective disabled person placard programs.

• Interviewed parking enforcement oﬃcials in the six cities we selected to address Objective 5 to

identify the tactics those cities employ for combating placard misuse and to determine the extent

to which the cities work with DMV to identify placard misuse.

Sources: California State Auditor’s analysis of Joint Legislative Audit Committee audit request number 2016-121, planning documents, and analysis of

information and documentation identiﬁed in the table column titled Method.

Assessment of Data Reliability

In performing this audit, we obtained electronic data ﬁles extracted

from the information systems listed in Table C. on the following

page. e U.S. Government Accountability Oﬃce, whose standards

we are statutorily required to follow, requires us to assess the

suﬃciency and appropriateness of computer-processed information

that we use to support ﬁndings, conclusions, or recommendations.

Table C. describes the analyses we conducted using data from

these information systems, our methods for testing, and the

results of our assessments. Although these determinations may

aﬀect the precision of the numbers we present, there is suﬃcient

evidence in total to support our audit ﬁndings, conclusions,

andrecommendations.

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Table C.2

Methods Used to Assess Data Reliability

INFORMATION SYSTEM PURPOSE METHODS AND RESULTS CONCLUSION

Department of Motor

Vehicles (DMV)

Vehicle/Vessel

Registration Master

File (registration

system) as of

August9, 2016

To select a random sample

of original applications for

disabled person parking

placards (placards) and disabled

person or disabled veteran

license plates (plates) approved

from July 1, 2013, through

June30,2016, for review.

• We performed data-set veriﬁcation procedures and electronic

testing of key data elements, and we did not identify any

signiﬁcant issues.

• This purpose did not require a data reliability assessment.

Instead, we gained assurance that the population was

complete. To test the completeness of DMV’s registration

system, we haphazardly selected 29 placard or plate numbers

from an independent information system. We then traced

these placard or plate numbers to the registration system and

found the data to be complete.

Complete for this

audit purpose.

To calculate the number of

placards and plates active as of

June 30, 2016.

To determine the median age of

individuals with placards active

as of June 30, 2016.

To identify the names and

birthdates of individuals with

permanent placards active as of

June 30, 2016.

To identify select placards

and plates associated with

individuals DMV determined

were deceased.

To quantify the number of

individuals age 100 or older with

permanent placards active as of

June 30, 2016.

To identify replacements of

permanent placards that DMV

issued, and to calculate the

number of these replacements

per individual, from July 2013

through June 2016.

To detect individuals with more

than one permanent placard

active as of June 30, 2016.

To determine whether DMV

referenced medical provider

license numbers in its

registration system for select

placards or plates.

• We performed data-set veriﬁcation procedures and electronic

testing of key data elements, and we did not identify any

signiﬁcant issues.

• The registration system is a partially paperless system. For

example, DMV automated the renewal of permanent placards

and a process to identify permanent placards associated with

individuals that are deceased. Thus, some transactions did

not have supporting documentation available for review.

Alternatively, we could have reviewed the adequacy of

selected application controls, but we determined that this

level of review was cost-prohibitive.

• To gain some assurance of the accuracy of DMV’s registration

system transactions with supporting documentation, we

traced key data elements to supporting documentation for

a selection of 29 permanent placard transactions during the

period July 2013 through June 2016, and we found no errors.

• To gain some assurance of the completeness of the data, we

haphazardly selected 29 placard or plate numbers from an

independent information system and traced these numbers

to the registration system. We identiﬁed no exceptions

through this testing.

Undetermined

reliability for the

purposes of this

audit. Although this

determination may

aﬀect the precision

of the numbers we

present, suﬃcient

evidence exists in

total to support

our audit ﬁndings,

conclusions, and

recommendations.

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INFORMATION SYSTEM PURPOSE METHODS AND RESULTS CONCLUSION

U.S. Social Security

Administration

(Social Security)

Death Master File

(master ﬁle) as of

September 30, 2016

To determine the death dates

recorded for names and

birthdates associated with

permanent placards.

• We performed data-set veriﬁcation procedures and electronic

testing of key data elements, and found no errors.

• Social Security does not guarantee the accuracy of the master

ﬁle; however, we did not perform accuracy and completeness

testing of its data because the source documents that support

this data are maintained by the U.S. Government, and our

access statute does not compel the U.S. Government to provide

us records.

Undetermined

reliability for the

purpose of this

audit. Although this

determination may

aﬀect the precision

of the numbers we

present, suﬃcient

evidence exists in

total to support

our audit ﬁndings,

conclusions, and

recommendations.

Data extracted from

DMV’s investigations

database related

to cases focused

speciﬁcally on

placard abuse that

were initiated from

July 2013 through

June2016.

To calculate the number

of investigations and

theirdispositions.

To make a selection of

investigations focused

on placards opened

fromJanuary1,2013,

throughJune 30, 2016.

To review the processes

and timeliness of DMV’s

Investigations Unit related

to tracking investigations

from thepoint of receipt of

a complaint to case closure,

and tracking dispositions

ofinvestigations.

We performed data-set veriﬁcation procedures and electronic

testing of key data elements, and did not identify any issues.

We did not conduct accuracy or completeness testing on these

data because the source documents required for this testing are

stored at various locations throughout the State, making such

testing cost-prohibitive.

Undetermined

reliability for the

purposes of this

audit. Although this

determination may

aﬀect the precision

of the numbers we

present, suﬃcient

evidence exists in

total to support

our audit ﬁndings,

conclusions, and

recommendations.

Excel spreadsheets

DMV uses to track

information received

from enforcement

oﬃcials related to

placards the oﬃcials

seized and DMV

canceled in 2016.

To determine the number of

placards enforcement oﬃcials

seized and reported to DMV and

the number of those that DMV

had recorded as lost or stolen.

We performed data-set veriﬁcation procedures and found no

errors. Further, we performed electronic testing and found

nosigniﬁcant errors. We did not perform accuracy testing. We

also obtained reasonable assurance that the spreadsheets were

complete by requesting information on seized placards from

sixlocal parking enforcement oﬃcials. We noted that DMV

recorded it had received 43 of the 44 placards we reviewed.

There is no evidence DMV ever received the 44th placard, and

therefore we did not expect it to be in the spreadsheet.

Undetermined

reliability for the

purpose of this

audit. Although this

determination may

aﬀect the precision

of the numbers we

present, suﬃcient

evidence exists in

total to support

our audit ﬁndings,

conclusions, and

recommendations.

Source: California State Auditor’s analysis of various documents, interviews, or data from the entities listed in the table.

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