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Merit Appeals Board <br />MS. MATHEWS: Okay. <br />CHR. CABANAS: Are there questions from anyone? <br />MS. DE SOTO: Yes, I have one. <br />CHR. CABANAS: Go ahead. <br />November 19, 2021 <br />MS. DE SOTO: And so, if you do receive the identity of the complainant, how will that be <br />documented in the report that you'll be publishing. <br />MR. BENNER: So, we only—we wouldn't take the name of the individual. If they want to <br />leave a phone number that we might be able to follow-up with, that would be acceptable but <br />we're not going to take the name of the individual. <br />So, it would just be citizen, employee, or whatever category we're able to assign to that, that we <br />know. <br />MS. DE SOTO: Okay. And is the—do you have investigative procedures developed that can <br />lower the threshold? Because in my experience with whistleblower hotlines what happens is that <br />people lean towards a whistleblower line because they want to stay anonymous, because they're <br />already uncomfortable and afraid of something. <br />And due to that, they tend to obscure certain details. And they may leave out the piece you do <br />need to say, "Yes, that's in our jurisdiction" or "Yes, that rises to a threshold of concern that <br />violates policy or law." <br />Is there some sort of practice in place that will say, "If we have a repeat complaint that doesn't <br />rise, yes, we will investigate it regardless." <br />MR. BENNER: Yeah. So, it's kind of an—we're kind of in an odd place with this because we <br />don't like to use the term in auditing that we conduct investigations. But the term also is <br />somewhat applicable to this process because, if we do a full audit, then it has to be a Yellow <br />Book compliant GAGAS audit. <br />And doing a, sort of, tactical review—an investigation—we can publish a one to two -paged <br />document without having to go through those steps and without having to meet, maybe, that <br />threshold. <br />Ultimately, we're still putting it through the access of likelihood an impact when we're looking <br />at this. So, there—but in terms of—is this worth adding to our annual audit plan? No, we could <br />act on these and conduct investigations independent of that work plan. <br />Page 25 <br />