By Dr. Franklin Carvajal, Candidate for Culver City Council
Culver City asks employees and residents to report suspected fraud, waste, and abuse. But after someone makes a report, how does the public know whether the system accomplished anything?
Was the allegation substantiated? Was money recovered? Were procedures changed? Who investigated—and could that person act independently?
Resident Les Greenberg’s October 21 email raises these questions about the City’s Fraud, Waste and Abuse program. His concerns deserve a public response.
A hotline can receive complaints and close files. An effective oversight system must also demonstrate that it protects public resources.
What the records show
According to Greenberg, the City responded to Public Records Act request 26-1211 by providing dates and classifications for 73 hotline reports covering April 2020 through October 5, 2026.
The accompanying analysis shows 22 report entries in 2026 through October 5, including 11 classified as fraud. Earlier years had between zero and two fraud-classified entries annually. Waste/Abuse was the largest standardized category overall, with 12 entries.
Seven entries concerning alleged falsification of contracts or records were dated May 1–4, 2026.
These numbers warrant questions, but they do not establish that fraud occurred. Reports are allegations. Some entries have identical dates and descriptions, and the spreadsheet lacks case identifiers that would distinguish separate complaints from duplicate records.
The public needs enough information to understand what these numbers represent—and what happened afterward.
Why must residents request information that belongs in regular reports?
Greenberg argues that the City’s quarterly reports fail to follow Council Policy 4210. In his published analysis, he identifies policy language requiring quarterly reporting about the types of issues received while protecting confidential case information.
The City’s September 30, 2026 report includes a table called “Cases by Category.” However, its categories describe routing and responsibility: matters requiring department action, review by a department or another agency, or review by the Internal Audit Manager. They do not explain whether the underlying allegations concerned contracts, conflicts of interest, wasteful spending, or other misconduct.
That distinction matters. Knowing where a complaint went does not tell residents what kind of problem was reported.
The City should explain how these reports satisfy its policy. If they fall short, it should improve them.
Confidentiality needs a clear explanation
Greenberg also recounts an exchange at the September 10, 2025 Finance Advisory Committee meeting. According to his transcription, the Internal Audit Manager declined to describe the kinds of cases received and answered “No” when asked whether the records were subject to public records disclosure.
Greenberg says the City later provided dates and complaint categories without claiming confidentiality.
The City should explain that apparent discrepancy.
Protecting whistleblowers and people accused of wrongdoing is essential. Greenberg argues that those protections do not justify withholding general complaint categories. His interpretation deserves a specific response identifying what must remain confidential and why.
The release of a category list does not establish that every investigative record is public. It does show why a broad statement about nondisclosure needs clarification.
If the committee received inaccurate guidance, the City should correct the record.
Independent management matters
I support independent management of the Fraud, Waste and Abuse program.
An investigator must be able to examine a complaint without interference from someone whose conduct is under review. When allegations involve senior management, the reporting structure becomes especially important.
Who selects the investigator? Who controls the scope of the review? Who decides that the response is sufficient? Who checks whether corrective action actually happened?
The City should establish a clear process for referring complaints outside the management chain when a conflict exists. Residents should be able to understand that process before a sensitive complaint arises.
Qualifications deserve a direct answer
Greenberg also questions the Internal Audit Manager’s professional qualifications. His published analysis states that the manager’s public profile listed no audit certification as of late September 2026. That observation does not establish that the manager lacks certification or is unqualified. The City should resolve the question by disclosing the relevant credentials, investigative training, and auditing experience.
What qualifications does the position require? What qualifications does the current manager hold? How do they meet the City’s Internal Audit Framework?
These are reasonable questions about a position entrusted with protecting public resources.
“Closed” needs an explanation
A closed complaint could mean that an allegation was substantiated, unsupported, referred elsewhere, or consolidated with another case. Those outcomes have different meanings.
The September 30 quarterly report says three cases were investigated and closed, but it does not explain their findings or any corrective action.
That omission does not prove nothing happened. It prevents residents from evaluating what happened.
As a Council member, I would seek reporting that explains complaint types, findings, investigation timelines, financial recoveries, and corrective measures wherever disclosure is appropriate. I would also seek independent review when conflicts arise and follow-up to determine whether promised improvements were completed.
Greenberg’s request for another Finance Advisory Committee discussion deserves a response. So does his request for a meeting.
People who report suspected wrongdoing contribute to accountable government. The City should honor that contribution through qualified oversight, meaningful independence, compliance with its reporting policy, and clear explanations of results.
When public resources are at stake, “Closed” should be followed by an explanation.


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