City of Sacramento
City Council - 5PM Report
915 I Street Sacramento, CA 95814
www.cityofsacramento.org
File ID: 2025-00689 3/18/2025 Consent Item 10.
City Auditor’s Whistleblower Hotline Activity Report for the Period July 2024 through December 2024
File ID: 2025-00689
Location: Citywide
Recommendation: Pass a Motion approving the City Auditor’s Whistleblower Hotline Activity Report for the Period July 2024 through December 2024.
Contact: Farishta Ahrary, City Auditor, (916) 808-7266, [email protected], Office of the City Auditor
Presenter: None
Attachments:
1-Description/Analysis
2-City Auditor’s Whistleblower Hotline Activity Report for the Period July 2024 through December 2024
Description/Analysis
Issue Detail: According to the City Council Rules of Procedures, the Budget and Audit Committee shall receive, review and forward to the Council as appropriate, reports, recommendations, and updates from the City Auditor. This report documents the City Auditor’s Whistleblower Hotline Activity Report for the Period July 2024 through December 2024.
Policy Considerations: The City Auditor’s presentation of the City Auditor’s Whistleblower Hotline Activity Report is consistent with the Mayor and City Council’s intent to have an independent audit function for the City of Sacramento.
Economic Impacts: None.
Environmental Considerations: None.
Sustainability: None.
File ID: 2025-00689 3/18/2025 Consent Item 10.
Commission/Committee Action: On February 25, 2025, the Budget and Audit Committee passed a motion to accept the City Auditor’s Whistleblower Hotline Activity Report for the Period July 2024 through December 2024 and to forward to the City Council for approval.
Rationale for Recommendation: This staff report provides the City Council with information that may be used to meet its responsibility to provide oversight and supervision of the City Auditor.
Financial Considerations: The costs of the City Auditor’s Whistleblower Hotline Activity Report were funded out of the Office of the City Auditor Budget.
Local Business Enterprise (LBE): No goods or services are being purchased as a result of this report.
City Auditor’s Whistleblower
Hotline Activity Report:
July - December 2024
Farishta Ahrary, City Auditor
Investigative Audits Division February 2025 Report # 2024/25-09
2 Our Mission
To provide a catalyst for improvements of municipal operations and promote a credible, efficient, effective, equitable, fair, focused, transparent, and fully accountable City government.
Our Vision
To improve City services by providing independent, objective, and reliable information regarding the City’s ability to meet its goals and objectives and establish an adequate system of internal controls, root out improper governmental activities (i.e., fraud, waste, or abuse), and address racial, gender, and ethnic inequities.
Suggest an Audit
The Office of the City Auditor conducts performance audits of the City of Sacramento's operations to determine whether these operations and programs are operating efficiently and effectively. If you would like to offer ideas for audits to save the City money, increase revenues, or improve the efficiency and effectiveness of City operations and programs, please fill out our online form:
https://forms.cityofsacramento.org/f/Suggest_an_Audit_Form
Whistleblower Hotline
In the interest of public accountability and being responsible stewards of public funds, the City has established a whistleblower hotline. The hotline protects the anonymity of those leaving tips to the extent permitted by law. The service is available 24 hours a day, 7 days week, 365 days per year.
Through this service, all phone calls and emails will be received anonymously by third party staff.
Report online at http://www.cityofsacramento.ethicspoint.com or call toll-free: 888-245-8859.
The City of Sacramento’s Office of the City Auditor can be contacted by phone at 916-808-1166 or at the address below:
915 I Street
MC09100
Historic City Hall, Floor 2
Sacramento, CA 95814
3 Contents
Whistleblower Infographic ........................................................................................................................... 4 Whistleblower Hotline Program ................................................................................................................... 5 Contact the City’s Whistleblower Hotline ................................................................................................. 5 Whistleblower Protection Policy........................................................................................................... 5 The City Auditor’s Independence, Authority, and Responsibility ............................................................. 6 Understanding the Investigative Audit and Referral Process ................................................................... 7 Allegations Covered by Other City Departments .................................................................................. 7 Allegations Covered by Non-City Agencies ........................................................................................... 7 Whistleblower Procedures Prioritize High-Risk Allegations ................................................................. 8 Whistleblower Hotline Dashboards .......................................................................................................... 9 Status of Investigations ................................................................................................................................. 9 The Number of Whistleblower Complaints has Remained Steady ........................................................... 9 78 Cases Were Closed During the Period ............................................................................................... 10 Appendix A: Contact Information for Various City Departments ............................................................... 13 Appendix B: Contact Information for Various Non-City Agencies .............................................................. 14 Whistleblower Infographic
5 Whistleblower Hotline Program
The City Auditor’s Whistleblower Hotline promotes good government by providing City employees and members of the public with a way to report allegations of improper government activities (i.e. fraud, waste, or abuse). California Government Code 53087.6 defines fraud, waste, or abuse in the context of a Whistleblower program as
“any activity by a local agency or employee that is undertaken in the performance of the employee’s official duties, including activities deemed to be outside the scope of his or her employment, that is in violation of any local, state, or federal law or regulation relating to corruption, malfeasance, bribery, theft of government property, fraudulent claims, fraud, coercion, conversion, malicious prosecution, misuse of government property, or willful omission to perform duty, is economically wasteful, or involves gross misconduct.”
This report contains the disposition of alleged improper government activity reported through the City’s Whistleblower Hotline; disposition is listed for cases that were closed during the reporting period.
Additionally, this report provides a high-level description of how the City’s Whistleblower Hotline operates; additional details can be found in the City Auditor’s Policies and Procedures Manual. 1 Contact the City’s Whistleblower Hotline
City staff or members of the public may submit reports by calling the Whistleblower Hotline’s toll-free number 1-888-245-8859 or online at www.cityofsacramento.ethicspoint.com. Individuals may also submit whistleblower reports directly to any staff member in the Office of the City Auditor2 in person, over the phone, by voicemail, by e-mail, or by mail. Individuals who provide whistleblower information will have their identity kept confidential to the extent permitted by law unless the individual waives confidentiality in writing.
Sacramento Office of the City Auditor
915 "I" Street
Historic City Hall, 2nd floor
Sacramento, CA 95814
Whistleblower Protection Policy
The City’s Whistleblower Protection Policy states “No City official or employee shall take retaliatory action against any employee who, in good faith, has made a complaint or allegation concerning improper governmental action.” The policy defines retaliatory action as “any adverse change in an employee employment status or the terms and conditions of employment resulting from an employee’s good faith complaint or allegation of an improper governmental action.”
1 https://www.cityofsacramento.gov/content/dam/portal/auditor/Policies-and- Procedures/City%20Auditor%27s%20Policies%20and%20Procedures.pdf 2 https://www.cityofsacramento.gov/auditor/what-we-do/contact-us
6 The City Auditor’s Independence, Authority, and Responsibility The City Auditor reports directly to the Mayor and City Council, and is independent of other City departments and agencies. This independence reduces the threat of coercion, influence, or conflict of interest during investigative audits.
California Government Code Section 53087.6 allows local governments to create whistleblower hotlines.
Under this authority, City Code 2.18.050 establishes the City Auditor’s responsibility to manage the City’s Whistleblower Hotline and determine if allegations of fraud, waste, abuse, or illegal acts need further investigation. Key points of Government Code section 53087.6 are outlined in Exhibit 1.
Exhibit 1: Key Points of California Government Code 53087.6
Key Points of California Government Code 53087.6
The City Auditor shall obtain approval from City Council before establishing a whistleblower hotline.
This approval was obtained from the Sacramento City Council in March 2012.
The hotline is used to receive calls from people who have information regarding fraud, waste, or abuse.
The City Auditor may refer calls received on the hotline to the appropriate government authority for review and investigation.
During the initial review of calls received, the City Auditor (or the appropriate government authority to whom the call is referred) shall hold in confidence information disclosed through the hotline. This includes the identities of the callers disclosing information and the people identified by the callers.
Upon receiving specific information that an employee has engaged in an improper government activity, the City Auditor may conduct an investigative audit.
The identity of the individuals providing information that initiated the investigative audit shall not be disclosed without their written permission, unless the disclosures are to law enforcement agencies conducting criminal investigations.
The investigative audit shall be kept confidential except to issue a substantiated investigative audit report or to release findings from completed investigative audits that are deemed necessary to serve the interests of the public.
The identities of individuals reporting the improper government activities and the subject employees investigated shall be kept confidential to the extent permitted by law.
The City Auditor may provide a substantiated investigative audit report and other information (including subject employee identities) to appointing authorities for disciplinary purposes.
7 Understanding the Investigative Audit and Referral Process While State law sets certain requirements for establishing and managing a whistleblower hotline, local auditors have broad discretion in how to operate their programs. The Office of the City Auditor thoroughly reviews each allegation submitted through the Whistleblower Hotline and determines the appropriate avenue for resolution. While this may result in office staff conducting investigative audits, in certain circumstances, it may instead be appropriate to refer allegations to other City departments for investigation.
Upon completion of an investigative audit which substantiates an allegation, an investigative summary will be prepared for inclusion in the semi-annual Whistleblower Activity Report. State law mandates that, even in the event of a substantiated allegation, personnel information is to remain confidential.
Allegations Covered by Other City Departments
The intent of establishing a Whistleblower Hotline is not to replace or limit other reporting options, as some allegations are more appropriately investigated by other City departments or offices. For example, many Human Resources-related issues should be reported to the appropriate Human Resources staff; labor grievances, allegations of workplace discrimination, and workers’ compensation claims should be reported using City procedures established for that purpose. Similarly, complainants may need to report legal issues to the City Attorney’s Office or code enforcement violations to the Community Development Department.
As appropriate, the City Auditor will refer cases to other City departments or offices.3 However, it may still be appropriate for staff to gather initial information to better understand issues involved and to review the outcomes, responses, and investigation documents from other City departments or offices to ensure the allegations were addressed.
Allegations Covered by Non-City Agencies
By nature of being the State Capitol as well as the County Seat, the City of Sacramento is home to a large number of Federal, State, and County agencies. As a result, some complaints made to the City’s Whistleblower Hotline may be partly or solely related to government agencies external to the City of Sacramento.
Allegations involving an external government agency or employee will be referred in whole or in part to the most appropriate government entity.4 Complaint investigation services are available at many government agencies and may include fraud, waste, and abuse whistleblower programs, internal affairs programs, judicial oversight authorities, offices of professional responsibility, etc.
3 See Appendix A for contact information for various City departments and divisions, such as the Equal Employment Office, Labor Relations Division, the Risk Management Division, the City Attorney’s Office, and the Sacramento Ethics Commission.
4 See Appendix B for contact information for various government agencies such as the California State Auditor, the Sacramento County Auditor-Controller, and the California Office of the Attorney General.
8 Whistleblower Procedures Prioritize High-Risk Allegations Due to the limited staff in the Office of the City Auditor and the Office’s chief responsibility to conduct performance audits, research, and analysis in accordance with the City Council-approved workplan, conducting full investigative audits of all allegations is not feasible. Instead, the City Auditor applies a risk-based approach to investigate whistleblower allegations to focus investigative efforts on those allegations that represent the greatest risk or loss to the City. The following guidance applies when rating allegations:
High Priority
Allegations may be considered high priority if they include a health, safety, or welfare concern, loss5 to the City of more than $75,000, criminal activity resulting in a loss of at least $400, high-level involvement, collusion of multiple wrongdoers, major department-wide issue, or need for immediate action to stop a potentially major issue. Addressing these items could take priority over other investigations and audits, at the City Auditor’s discretion.
Medium Priority
This category includes loss to the City of more than $25,000, abuse of authority, medium to low-level employee involvement, minor department-wide issues, or patterns of small problems that could become serious when summed. Some medium-priority items could be referred to a department for their review.
Low Priority
This category includes loss to the City of less than $25,000, isolated instances of time abuse, wasteful practices that would lead to limited gains in efficiencies if corrected, or allegations that lack credibility and evidence. The office would aim to investigate items in this category, but may not do so because of limited resources. However, if the same or similar issues were reported multiple times, low-priority items may become a higher priority. Additionally, some low-priority allegations could be referred to a department for their review.
Unrelated to the City
Some allegations received through the Whistleblower Hotline do not involve City of Sacramento departments or employees. The Office of the City Auditor assesses these allegations for any City involvement. If no City involvement can be determined, those allegations are closed as “Unrelated to the City”; some allegations not related to the City are referred to other jurisdictions.
5 Loss could entail actual or potential loss of money, waste, or inefficiencies.
9 Whistleblower Hotline Dashboards
The Office of the City Auditor maintains several Whistleblower Hotline dashboards on its public website.
City Officials and the public can use these dashboards to see statistics on the types of cases received through the City’s Whistleblower Hotline, the disposition of closed cases, brief descriptions of substantiated cases, actions taken as a result of substantiated cases, and the monetary benefit of the hotline. The dashboards are typically updated semi-annually with the release of each Whistleblower Hotline Activity Report and can be found at:
https://www.cityofsacramento.gov/auditor/our-
reports/whistleblower-activity
Status of Investigations
The Number of Whistleblower Complaints has Remained Steady Since the hotline’s inception in 2012, the Office of the City Auditor has received more than 1,900 complaints. Use of the City Auditor’s Whistleblower Hotline grew significantly in the first few years and has been steady since 2014. Exhibit 2 illustrates the number of allegations received per year since the program’s inception.
Exhibit 2: Whistleblower Allegations Received Per Year
10 78 Cases Were Closed During the Period
At the beginning of the July 2024 through December 2024 reporting period, the Office of the City Auditor had 11 open cases. During this reporting period, 90 new cases were received by the hotline, and the Office of the City Auditor processed and closed 78 cases; 23 cases remained open at the end of the reporting period. Exhibit 3 illustrates the number of closed cases during the period by primary type of allegation.
Exhibit 3: 78 Closed Cases by Primary Type of Allegation
Exhibit 4 provides the primary type of allegation, priority, and disposition of the 78 cases closed during the period.
Exhibit 4: 78 Closed Cases Details Table
Case # Primary Type of Allegation Priority Disposition
1800 Procurement of Goods or Services Issues Low Unsubstantiated 1827 Abuse of Position or Authority Low Informational Referral 1846 Violate City Policy, Local, State, or Federal Law Low Informational Referral 1848 Fraud Low Informational Referral
1849 Contested City Charges Low Informational Referral
1851 Insufficient Action by City Low Not Enough Information Provided 1852 Unrelated to the City Unrelated to the City Unrelated to the City 1853 Insufficient Action by City Low Informational Referral 1854 Unrelated to the City Unrelated to the City Unrelated to the City 1855 Payroll and Timecard Issues Low Unsubstantiated
1856 Insufficient Action by City Low Unsubstantiated
1857 Not Enough Information Provided Low Not Enough Information Provided 1858 Unrelated to the City Unrelated to the City Unrelated to the City 1859 Unrelated to the City Unrelated to the City Unrelated to the City
11 Case # Primary Type of Allegation Priority Disposition 1860 Insufficient Action by City Low Informational Referral 1861 311 Low Resolved Prior To or During Investigation
1862 Safety and Sanitation Issues Low Informational Referral 1863 Employee Relations Low Informational Referral
1864 Employee Relations Low Informational Referral
1865 Unrelated to the City Unrelated to the City Unrelated to the City 1866 Unrelated to the City Unrelated to the City Unrelated to the City 1867 Contested City Charges Low Unsubstantiated
1868 Unrelated to the City Unrelated to the City Unrelated to the City 1869 Payroll and Timecard Issues Low Not Enough Information Provided 1870 Not Enough Information Provided Low Test
1871 Not Enough Information Provided Low Unsubstantiated 1873 311 Low Informational Referral
1874 Violate City Policy, Local, State, or Federal Law Low Informational Referral 1875 Safety and Sanitation Issues Low Informational Referral 1876 Violate City Policy, Local, State, or Federal Law Low Informational Referral 1877 Unrelated to the City Unrelated to the City Unrelated to the City 1878 Unrelated to the City Unrelated to the City Unrelated to the City 1879 Safety and Sanitation Issues Low Informational Referral 1880 Insufficient Action by City Low Informational Referral 1881 Unrelated to the City Unrelated to the City Unrelated to the City 1882 Safety and Sanitation Issues Low Informational Referral 1883 Safety and Sanitation Issues Low Unsubstantiated
1884 Unrelated to the City Unrelated to the City Unrelated to the City 1885 Payroll and Timecard Issues Low Informational Referral 1886 311 Low Informational Referral
1887 Unrelated to the City Unrelated to the City Unrelated to the City 1888 Internal Control Issues Low Informational Referral 1889 Conflict of Interest Low Informational Referral
1890 Unrelated to the City Unrelated to the City Unrelated to the City 1891 Insufficient Action by City Low Informational Referral 1892 Unrelated to the City Unrelated to the City Unrelated to the City 1893 Safety and Sanitation Issues Low Informational Referral 1894 Unrelated to the City Unrelated to the City Unrelated to the City 1895 311 Low Informational Referral
1896 Not Enough Information Provided Low Not Enough Information Provided 1897 Safety and Sanitation Issues Low Duplicate
1898 Employee Relations Low Informational Referral
1899 Safety and Sanitation Issues Low Not Enough Information Provided 1900 Unrelated to the City Unrelated to the City Unrelated to the City
12 Case # Primary Type of Allegation Priority Disposition 1901 Unrelated to the City Unrelated to the City Unrelated to the City 1902 Employee Relations Low Informational Referral
1903 Safety and Sanitation Issues Medium Informational Referral 1904 Safety and Sanitation Issues High Informational Referral 1905 Unrelated to the City Unrelated to the City Unrelated to the City 1906 Abuse of Position or Authority Low Informational Referral 1908 Employee Relations Low Informational Referral
1909 Safety and Sanitation Issues Low Informational Referral 1910 Employee Relations Low Informational Referral
1911 Unrelated to the City Unrelated to the City Unrelated to the City 1912 Unrelated to the City Unrelated to the City Unrelated to the City 1913 Unrelated to the City Unrelated to the City Unrelated to the City 1914 Theft of Goods or Services Low Informational Referral 1915 Violate City Policy, Local, State, or Federal Law Low Informational Referral 1916 Theft of Goods or Services Low Informational Referral 1917 Unrelated to the City Unrelated to the City Unrelated to the City 1918 Employee Relations Low Informational Referral
1921 Unrelated to the City Unrelated to the City Unrelated to the City 1922 Safety and Sanitation Issues Low Informational Referral 1924 Safety and Sanitation Issues Low Unsubstantiated
1925 Violate City Policy, Local, State, or Federal Law Low Informational Referral 1928 Employee Relations Low Informational Referral
1929 Unrelated to the City Unrelated to the City Unrelated to the City 1932 Violate City Policy, Local, State, or Federal Law Low Informational Referral
13 Appendix A: Contact Information for Various City Departments
• Risk Management for workers’ compensation information:
916-808-5741
https://www.cityofsacramento.gov/HR
• Risk Management for environmental health and safety programs like OSHA and DOT compliance:
916-808-5278
https://www.cityofsacramento.gov/HR
• Risk Management for liability claims:
916-960-0980
https://www.cityofsacramento.gov/HR/hr-documents-resources
• Labor Relations for union grievance procedures:
916-808-5424
https://www.cityofsacramento.gov/HR/hr-documents-resources
• Equal Employment Opportunity for the grievance procedures alleging discrimination:
916-808-5825
https://www.cityofsacramento.gov/HR/equal-employment-opportunity
• Other Human Resources related issues:
916-808-5731
https://www.cityofsacramento.gov/HR
• City Attorney:
916-808-5346
https://www.cityofsacramento.gov/attorney
• Code Enforcement for neighborhood code, housing and dangerous buildings, business compliance, landscape requirements, rental house standards, and anti-graffiti:
311 or 916-808-5011 (inside City limits)
916-264-5011 (outside of City limits)
https://www.cityofsacramento.gov/information-technology/311
• Sacramento Ethics Commission:
916-808-7200
https://www.cityofsacramento.gov/clerk/good-governance-and-compliance/filing-an-ethics- complaint
• Police for non-emergencies:
916-808-5471
https://www.cityofsacramento.gov/police
14 Appendix B: Contact Information for Various Non-City Agencies
Jurisdiction Organization Reporting Methods
County of Sacramento County Auditor-
Controller
Fraud Hotline 916-874-7822
[email protected]
Fraud Hotline - Confidential
County of Sacramento
10481 Armstrong Ave., Mather, CA 95655
https://www.saccounty.gov/Government/Pages/F
raudHotline.aspx
State of California California State
Auditor
Whistleblower
Hotline
800-952-5665
Investigations
California State Auditor
P.O. Box 1019 Sacramento, CA 95812
http://www.bsa.ca.gov/hotline/filecomp
Health, Safety, and
other complaints
against employers
US Department
of Labor (OSHA)
Whistleblower
Hotline
800-321-OSHA (6742)
https://www.whistleblowers.gov/
Consumer Complaints
Against a Business
California Office
of the Attorney
General
Comment/
Complaint Form
https://oag.ca.gov/contact/consumer-complaint-
against-business-or-company
Consumer Complaints
Against a Business
Better Business
Bureau
Complaints https://www.bbb.org/file-a-complaint
California Attorneys State Bar of
California
Complaints 800-843-9053
http://www.calbar.ca.gov/Public/Complaints-
Claims
California Judges Commission on
Judicial
Performance
Complaints Commission on Judicial Performance
455 Golden Gate Avenue, Suite 14400
San Francisco, California 94102
http://cjp.ca.gov/file_a_complaint/