Audit Release: Energy Trust Administrative Costs are Generally Reasonable, but the Public Utility Commission Can Improve Oversight of These Costs

Report Highlights

The Oregon Public Utility Commission (PUC) has designed controls to ensure administrative and program support costs at Energy Trust of Oregon are reasonable. Energy Trust is a nonprofit organization and is not subject to state administrative cost requirements. However, PUC could strengthen its oversight of Energy Trust administrative costs by more clearly defining what constitutes reasonable costs, revising key performance metrics, and clarifying financial reporting requirements.


Energy Trust is a nonprofit organization funded by a grant agreement with PUC to develop and administer energy efficiency and renewable energy programs in certain utility service territories in Oregon. The grant funding comes from three separate charges on bills of customers of electric and natural gas utilities regulated by PUC.


The purpose of the audit was to determine whether Energy Trust administrative costs are reasonable and whether PUC has reasonable controls in place to oversee Energy Trust’s administrative costs.

Key Findings

  1. Energy Trust complies with PUC’s administrative cost control requirements. We found these controls to be reasonable, and Energy Trust has consistently spent below the established administrative cost cap of 8% of revenue per year. However, Energy Trust’s administrative costs increased from $1.6 million to $10.1 million between 2002 and 2017, as its annual revenues increased from $30.6 million to $194.2 million during the same period. Improved oversight could help PUC better ensure that Energy Trust makes reasonable administrative spending decisions.
  2. We determined Energy Trust’s administrative costs are generally reasonable. However, we identified a small percentage of questionable administrative costs that do not align with state agency standards or the grant guidelines that govern Energy Trust operations. PUC could improve its oversight by providing guidance for acceptable administrative costs.
  3. Increased clarity and detail in financial reporting would improve transparency and stakeholder oversight. PUC monitors Energy Trust’s administrative costs through an enforced spending cap and public budget and reporting processes. Revised reporting methodologies would increase the transparency of Energy Trust’s administrative costs and spending trends.


Our report includes recommendations to PUC regarding the clarity of its grant agreement with Energy Trust, revision of performance metrics, and reporting of administrative costs.

PUC generally agreed with our recommendations. The agency’s response can be found at the end of the report.

Read the full report here.

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DHS – Aging and People with Disabilities: Consumer-Employed Provider Program Needs Immediate Action to Ensure In-Home Care Consumers Receive Required Care and Services

Report Highlights

The Secretary of State’s Audits Division found that the Aging and People with Disabilities (APD) program should take immediate action to address gaps in program design and oversight in order to improve the safety and well-being of participants in the Consumer-Employed Provider (CEP) program.

Read full report here.


Oregon is a leader in providing in-home long- term care options for older adults and people with disabilities. The most used in-home care program is the Consumer-Employed Provider program, which positions consumers as employers of their homecare worker.


The purpose of this audit was to assess the policies and processes used by APD to ensure the needs of consumers in the CEP program are met.

Key Findings

The effectiveness of the Consumer-Employed Provider program is dependent on the consumer, the case manager, and the homecare worker. If each is capable, competent, and supported in their role, the current model can be successful. Our audit found:

1. Some consumers are not receiving the support necessary to ensure required employer duties are being performed, which adds to case managers’ and homecare workers’ responsibilities.
2. Case managers are not consistently contacting consumers, or monitoring services consumers receive due to excessive workloads.
3. Agency requirements do not ensure that homecare workers are prepared to provide the care and assistance consumers need.
4. Due to current data collection and utilization practices, it is difficult for APD to determine if consumers are safe and receiving the care and services they need.
5. Current deficiencies in the program may put consumers’ health and well-being at risk and keep the program from operating as intended.

To reach our findings, we conducted interviews and case file reviews, collected and analyzed CEP consumer data, and researched federal and state standards.


The report includes recommendations to improve Consumer-Employed Provider program implementation and support. Recommendations include consistently following existing monitoring policies, addressing case managers’ excessive workload and responsibilities, and providing more support to consumers and homecare workers.
The Department generally agreed with our findings and recommendations. Its response can be found at the end of the report.

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Oregon Department of Agriculture: Improved management practices, use of resources could help Food Safety Program achieve its mission

Executive Summary

The Oregon Department of Agriculture’s (ODA) Food Safety Program is struggling with a backlog of establishments needing inspection. This backlog was caused by an increase in the number of licensed businesses and complexity of business practices, and an inspection staff busy with other duties. By implementing stronger management practices, making better use of data, and more strategically deploying its resources, the program can reduce its backlog of inspections, better achieve its mission of preventing the spread of foodborne illness, and prepare for more regulatory challenges in the near future.

Read the full report here.

The Food Safety Program has an inspection backlog

According to ODA, a backlogged firm is one that is three or more months late for an inspection. We found that, as of October 2016, 2,841 firms were late for an inspection.

Inspectors have not kept up with this workload in part because the number of licensed businesses has been steadily increasing for the last 10 years. There are now more than 12,000 licensees needing regular inspection by the Food Safety Program.

Inspectors are also spending significant amounts of time on duties that are not related to inspections, such as attending training courses in specialized license types or answering licensee questions on the phone. Management has established goals for how much time inspectors should be spending on inspection-related tasks, but it is not clear these goals are being met.

Federal grants, contracts take time away from inspections

Many firms in Oregon are subject to inspection not only by ODA, but also by the federal Food and Drug Administration, or FDA. The Food Safety Program has a contract with FDA to conduct some of these inspections in exchange for reimbursement. Currently, ODA conducts 500 contract inspections each year, one of the highest contract workloads in the country. These inspections take significantly longer than a routine ODA inspection.

ODA’s Food Safety Program was one of the first in the country to enroll in the federal Manufactured Food Regulatory Program Standards, or MFRPS. Through MFRPS, the program has developed policies and procedures related to enforcement actions, responding to food-related illness, and training. This work has taken time away from conducting food safety inspections and was one of the factors contributing to the backlog.

Staff turnover is a challenge

Since 2006, 28 inspectors have either left the agency or retired. Retiring inspectors often take decades of expertise and experience with them. Hiring and training new staff to replace them is time-intensive. And there is no formal succession plan to prepare for their departure.

Turnover has been especially challenging for the program’s two field operations managers, who are responsible for supervising inspectors. ODA has struggled to keep people in these two positions.

The program uses a tool from FDA that allows food safety regulatory programs to calculate the number of inspectors required to manage the workload. But we found the Food Safety Program was incorrectly using this tool and may not have an accurate estimate of its own staffing needs.

The program needs more management oversight

More oversight of food safety inspectors is needed to ensure the quality and consistency of inspections. Field operations managers only review the inspection reports of new inspectors while they are trained. Although field operations managers are expected to supervise inspectors in the field, this is not happening because managers are busy with office work.

Management could offer more guidance to help inspectors be more consistent in their interactions with licensees. Currently, inspectors are inconsistent in how they issue enforcement actions and how much time they spend explaining the rules and regulations to food establishments.

The program is also at risk of overlooking some businesses that are operating without a license. Currently, ODA relies on new businesses to contact them to obtain a license. But for businesses that may not, there is no formal policy or procedure to proactively identify them.

The program could benefit from better use of data

We found the Food Safety Program is missing several opportunities to use data to help make decisions.

Although management can access the program’s Be Food Safe database to see how many firms are overdue for an inspection, they have not been consistently tracking and storing these data. Keeping track of these numbers could be helpful in identifying patterns and strategies to reduce the backlog.

Some data are not being kept in the most efficient form for analysis. Inspectors fill out daily paper reports of how they spend their hours, but management does not analyze these. By keeping these data in a digital format that can be easily accessed, and regularly analyzing them, management could identify how staff spend their time and look for opportunities for improvement.

We also found that the program could benefit from a designated data analysis position. Managers say they do not have time to collect and analyze data because of their other responsibilities. By having someone whose role is primarily data analysis, the program could benefit from this data without compromising these other duties.


To work toward the goal of reducing the backlog of inspections, we recommend ODA reconsider some of its workload, provide more guidance to inspectors, and better track and analyze data to inform these decisions. To help the program better achieve its mission, we recommend ODA develop policies and procedures to improve oversight of inspectors and develop partnerships with other agencies. And to address some of the staffing challenges, we recommend the program use data to analyze its staffing needs and develop a succession plan for retiring inspectors. Our specific recommendations can be found on page 22 of the report.

Agency Response

The full agency response can be found at the end of the report.


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Oregon Department of Education: Clearer Communication, Consistent Use of Results and an Ongoing Commitment to Improvement Could Help Address Testing Concerns

Executive Summary

Our audit responds to House Bill 2713 (2015), developed with input from the State Auditor. It called for a Secretary of State audit to review the impacts of the statewide summative assessment on Oregon’s public schools, and make recommendations for improvement.

Through a series of surveys, site visits and interviews, we learned many schools faced challenges in the first year of administering the new Smarter Balanced test, including adjusting to the demands on staff and school resources. Some reported fewer challenges in the second year.

Some educators are concerned that certain student populations may experience more negative impacts than others. Some also told us that a more comprehensive assessment system would be useful.

Read full report here.

Oregon introduced Smarter Balanced in 2015

The Smarter Balanced assessment is a new test introduced by the Oregon Department of Education to all public schools in the spring of 2015. Smarter Balanced tests 3rd – 8th graders and 11th graders in math and English language arts near the end of the school year. The test assesses students’ progress toward meeting Oregon’s college- and career-ready standards, the Common Core State Standards. Smarter Balanced requires more time and depth of knowledge than the previous test.

There is not clear agreement on the test’s purpose

The Smarter Balanced test is intended to provide a measure for accountability, data to identify achievement gaps, and information about whether students meet standards overall, and many value these purposes. We also heard from educators who feel the test should be more useful in the classroom. However, other tools may be better suited for that purpose. The Oregon Department of Education could take a more active role in communicating about the test’s purpose.

The results of the test are not used consistently

Schools, school districts and the state use Smarter Balanced test results inconsistently, and sometimes not at all. Educators told us that it would be easier to use results if they received them sooner. Many reported that additional guidance on how to use results would be helpful. Some also reported that a more comprehensive assessment system would be useful.

Many reported test administration challenges

Educators described schoolwide challenges in the first year of administering Smarter Balanced. Testing did not just affect the classrooms that were actively testing, but could also place additional staffing and resource demands on the entire school. However, some said there were fewer challenges in the second year.

Testing took away from other duties of school and school district personnel. Some schools hired additional staff or substitutes specifically for testing. Testing also tied up computer labs for months at some schools. Time spent taking and preparing for the test took away from instruction time.

Some student populations may experience more negative impacts than others

Standardized testing may affect certain student groups more than others. Despite having accommodations, we heard concerns that the test’s greater use of technology and language may increase the risk that some students will not be able to demonstrate their abilities accurately. Students who take longer to complete the assessment may miss more instruction time.

Students in special education, English Language Learners, and students with less exposure to technology and typing may be particularly affected.


We recommend that the Oregon Department of Education improve communication, foster consistent use of results and continue its commitment to improve test administration. Our specific recommendations can be found on page 18 of the report.

Agency Response

The full agency response can be found at the end of the report.

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