Process Specification

This page explains the ACV's proposal in plain language, defines the process counties would be required to establish, and identifies the minimum requirements that may need to appear in statute. It is not intended to present final bill language. Its purpose is to support legislative review of which requirements should be codified in Arizona law and which operating details should remain within county policy and procedure.

Arizona Revised Statutes should require the outcome. County procedures should explain the method.

This page explains the type of information expected in implementing procedures so the proposed bill can be appropriately worded.

Background

Why this work began. After the 2020 election, the initial question was straightforward: Where were the documented Lessons Learned and Corrective Actions following an election conducted under unprecedented pandemic conditions?

Professional experience in contract compliance and corrective action provided a clear expectation of what to look for. Government contracts typically define responsibilities, remedies, oversight provisions, and what should happen when problems occur. In reviewing county election contracts, provisions were identified addressing matters such as termination for convenience, inspection, Corrective Action, and Lessons Learned. Those provisions showed that the concepts were already recognized within the contract framework.

What was not apparent was a documented trail showing what problems had been identified, what had been learned from them, what corrective actions had been taken, and whether those corrective actions had been verified.

That became the first identified problem. If a significant event occurs and the governing contract contemplates Lessons Learned and Corrective Action, there should be a way to determine whether those processes occurred, what actions resulted, and whether the corrective actions were effective.

As the review expanded through public records requests, contract analysis, and efforts to bring documented concerns to county government, a broader governance gap became clear: the county complaint framework did not provide a required end-to-end path for a citizen to submit a significant compliance concern and have it formally received, reviewed, determined, corrected when warranted, verified, monitored when appropriate, and closed.

The larger issue was no longer one election or one contract. The issue was the absence of a required end-to-end compliance review and corrective action process for significant citizen-reported concerns involving county government.

This proposal is not based on an assumption that the citizen is right or that government is wrong. It is based on the need for a fair, documented process that determines the answer and brings the matter to resolution.

Existing Gap for Complaints

A.R.S. § 11-1608 addresses county complaint procedures, including receipt of complaints, reasonable timeframes, and an appeal process. The proposed change is intended to add the missing compliance-management lifecycle: qualified review, documented determination, investigation when warranted, corrective action for confirmed deficiencies, verification, monitoring when appropriate, and formal closure with the citizen.

Proposal in Plain English

Proposal in One Sentence

When a citizen brings county government a documented concern about a possible violation or deviation from an applicable law, statute, contract requirement involving public funds, procurement requirement, policy, procedure, ethics requirement, internal control, grant condition, or other enforceable obligation, the county must have a defined process to receive it, review it, make a written determination, correct a confirmed deficiency when warranted, verify the correction, and formally close the matter.

Easy to Understand Process

• Citizen submits a documented concern.
• County acknowledges it and assigns a tracking number.
• A qualified Compliance Officer or designated compliance function reviews the concern.
• The county makes a documented determination.
  • If no violation or deficiency is found, the county explains the determination and closes the matter.
  • If a violation or deficiency is found, the county investigates as needed, determines the cause, establishes corrective action, verifies that the correction worked, monitors when appropriate, and formally closes the matter.
• The citizen receives a written closure response.

What this proposal does not do

• It does not assume that every citizen complaint is valid.
• It does not require a full investigation of every submission.
• It does not replace existing elected officials, auditors, investigators, procurement offices, legal authorities, or other county departments.
• It does not require the Legislature to write every operating detail into statute.

Legislative Design

Statute versus County Procedure?

The central legislative design question is: How should Arizona law establish the mandatory outcomes and minimum requirements of this process while allowing each county to develop the detailed operating procedures needed to implement it?

Simple distinction:

• The LAW should establish the mandatory minimums — the “shall” requirements.
• The COUNTY PROCEDURE should explain how county employees carry those requirements out in practice.

Law should establish the minimum duty	County procedure should explain the operating detail
County must establish and publish the process.	Where the form is located, how it is submitted, and who enters it into the system.
County must acknowledge receipt and track the matter.	Tracking-number format, database fields, acknowledgement template, and internal routing.
County must provide a qualified compliance review.	Reviewer qualifications, conflict checks, review checklist, and risk categories.
County must issue a documented determination.	Determination template, approval levels, and required supporting documentation.
County must investigate when the review shows investigation is warranted.	Investigation plan, interviews, document requests, evidence standards, and case-file instructions.
County must require corrective action when a deficiency is confirmed.	CAP form, required fields, responsible owner, due dates, status meetings, and escalation.
County must verify corrective action before closure.	Who may verify, evidence required, testing method, and rework if verification fails.
County must communicate closure to the citizen.	Closure-letter format, delivery method, supporting summary, and appeal instructions.
County must retain records and report on process health.	Retention workflow, dashboard fields, metrics, report format, and reporting calendar.

Proposed Statutory Floor

Minimum Requirements the Law Should Consider Requiring

This section is a specification for legislative counsel. It is not intended to be final bill language. Legislative review is needed to determine which requirements must appear in statute to make the process meaningful and enforceable and which may appropriately remain in county policy and procedure.

1. Establishment and publication

The Board of Supervisors shall establish, maintain, and publish a countywide Citizen Compliance Review and Corrective Action process that is available for significant citizen-reported compliance concerns.

2. Defined ownership

The county shall identify the office or qualified function responsible for receiving, tracking, assigning, and overseeing matters through formal closure.

3. Acknowledgement and tracking

The county shall acknowledge receipt of a submission and assign a tracking number or other unique case identifier.

4. Compliance review

A qualified Compliance Officer or designated compliance function shall review the submission and supporting information to determine scope, applicable requirements, significance, ownership, and whether further investigation is warranted.

5. Written determination

The county shall produce a documented determination explaining whether the concern is unsubstantiated, outside jurisdiction, already resolved, requires referral, or identifies a potential or confirmed deficiency requiring further action.

6. Investigation when warranted

When the compliance review identifies a matter requiring additional fact-finding, the county shall conduct or assign an investigation appropriate to the significance and risk of the concern.

7. Corrective action when a deficiency is confirmed

When a violation, control deficiency, contract deviation, or other material deficiency is substantiated, the county shall establish and track corrective action with an accountable owner and planned completion date.

8. Verification before closure

Corrective action shall not be considered complete solely because the responsible department reports completion. The county shall require documented verification that the corrective action was implemented and was effective before formal closure.

9. Monitoring when appropriate

For significant or recurring issues, the process shall include follow-up monitoring sufficient to determine whether the corrective action remains effective and recurrence has been reduced.

10. Written citizen response and formal closure

The citizen shall receive a written disposition or closure response that explains the outcome to the extent permitted by law and identifies any available appeal or reconsideration path.

11. Records

The county shall preserve sufficient records to show intake, review, disposition, corrective action, verification, and closure in accordance with applicable public-records and retention requirements.

12. Process reporting and accountability

The Board of Supervisors shall receive periodic reporting on the health of the process, such as volume, aging, disposition, corrective actions, overdue items, repeat issues, and closure status, without disclosing protected information.

13. Existing processes may remain

Specialized complaint or investigative processes may remain in place. The countywide process should serve as a safety net and routing mechanism when a citizen does not know where to go or when a matter crosses departments.

14. Independence and conflicts

The process should include a mechanism to avoid assigning final review or verification to a person whose own actions are the subject of the concern. Legislative review should determine the minimum level of independence or conflict protection that must be stated in statute.

Model County Procedure

The Instructions the Law Should Drive

The following model operating procedure illustrates the process the statute is intended to require counties to establish. It is intentionally more detailed than bill language. Its purpose is to show the operational outcome that legislation should produce while leaving counties flexibility to tailor forms, systems, staffing, and internal workflow.

Step 1 — Receive the citizen concern

Provide one clearly published county entry point for complaints, concerns, and documented compliance issues that do not fit a known specialized process.

Allow the citizen to identify the county action or inaction, the requirement they believe may apply, the facts they know, the supporting documents they have, prior contacts, and the remedy or resolution they are seeking.

Do not require the citizen to prove a legal violation before the county accepts the concern for review.

Step 2 — Create the case record and tracking number

Create a case record immediately upon receipt.

Assign a unique tracking number.

Record the date received, citizen contact information, subject, department or departments involved, and supporting documents.

Send the citizen an acknowledgement explaining what happens next and when the next update should be expected.

Step 3 — Screen for scope, urgency, and routing

Determine whether the matter belongs in an existing specialized process, such as procurement, human resources, law enforcement, elections, environmental services, or another established channel.

If it belongs elsewhere, make the referral; do not simply tell the citizen to start over.

Identify urgent safety, legal, financial, records-preservation, cybersecurity, or public-service risks that may require immediate containment or escalation.

Check for obvious conflicts of interest before assigning the reviewer.

Step 4 — Assign a qualified Compliance Officer or compliance reviewer

Assign a reviewer with sufficient independence, subject-matter access, and authority to evaluate the concern.

Identify one accountable case owner even when several departments are involved.

The case owner remains responsible for status, coordination, citizen communication, and closure even when work is assigned to others.

Step 5 — Perform the Compliance Review

Clarify the condition: What is the citizen saying happened or may be happening?

Identify the criteria: What law, statute, contract requirement, procurement requirement, policy, procedure, ethics requirement, internal control, grant condition, or other obligation may apply?

Consider the effect: Why does the issue matter and what could be the impact?

Assess risk and significance: How serious is the potential issue and how quickly should it be addressed?

Identify the responsible organization and whether enough information exists to make a determination or whether further investigation is required.

Step 6 — Make the initial written determination

No further action: the available information does not support a violation or deficiency.

Need more information: request specific additional information from the citizen or county personnel.

Refer: another established process has jurisdiction, but the referral is documented and tracked.

Investigate: the concern has sufficient merit, significance, or uncertainty to require fact-finding.

Immediate corrective or containment action: the risk is significant enough that protective action should begin before the full investigation is complete.

Step 7 — Conduct the investigation when warranted

Define the investigation question before collecting evidence.

Gather relevant records, contracts, policies, procedures, system information, interviews, and other evidence.

Document facts that support and do not support the concern.

Separate fact-finding from conclusions.

Determine whether the applicable requirement was met, not met, or cannot be determined from available evidence.

Document the investigation result and any limitations.

Step 8 — Determine cause and extent when a deficiency is found

Identify why the deficiency occurred, not just what happened.

Determine whether the issue is isolated or may exist elsewhere.

Identify failed or missing controls, unclear ownership, training problems, documentation gaps, technology issues, vendor issues, or other contributing causes as applicable.

Evaluate whether immediate containment is needed while a permanent correction is developed.

Step 9 — Establish the Corrective Action Plan (CAP)

Create a CAP for each substantiated deficiency that requires correction.

Each corrective action should identify the action, responsible owner, due date, required evidence, and how effectiveness will be verified.

Address the cause of the problem, not only the visible symptom.

Assign one accountable CAP owner or project manager when multiple actions or departments are involved.

Track overdue actions and escalate when deadlines are missed.

Step 10 — Implement and track corrective actions

Responsible departments complete the assigned actions and submit objective evidence of completion.

The case owner keeps the CAP current and documents status changes, delays, revised dates, and reasons for changes.

The citizen may receive status updates appropriate to the case without disclosure of protected information.

Step 11 — Verify the correction

Verification asks a different question from implementation: Did the correction actually work?

Review completion evidence, test the changed control or process when appropriate, and confirm the original deficiency has been addressed.

The verifier should be sufficiently independent from the person who implemented the corrective action.

If verification fails, reopen or revise the corrective action rather than closing the case.

Step 12 — Monitor when needed

For significant, systemic, or recurring issues, establish a monitoring period or follow-up check.

Confirm that the correction continues to work and the issue has not recurred.

Document monitoring results in the case record.

Step 13 — Close the matter

Confirm all required investigation, corrective action, verification, and monitoring steps are complete.

Prepare a closure summary stating what was reviewed, the determination, actions taken when applicable, and the basis for closure.

Provide the citizen a written closure response to the extent allowed by law.

Identify any appeal, reconsideration, or alternate remedy that remains available.

Step 14 — Use the information to improve county governance

Track trends, recurring causes, repeated departments or processes, overdue corrective actions, and systemic issues.

Use aggregated information to improve policies, procedures, training, contracts, controls, and management oversight.

Report process health and significant trends to the Board of Supervisors on a defined schedule.

Plain-Language Definitions

Compliance Review: A structured first review that asks: Is there a credible compliance issue here, what requirement applies, how significant is it, who owns it, and what should happen next? A Compliance Review is not automatically a full investigation.

Investigation: The fact-finding process used when more information is needed to determine what actually happened and whether a violation or deficiency exists.

Corrective Action Plan (CAP): The documented plan used after a deficiency is confirmed. It identifies what will be fixed, why the problem happened, who owns the correction, when it will be completed, and how the county will verify that the correction worked.

Root Cause: The underlying reason the problem occurred. Fixing only the visible symptom may allow the problem to return.

Verification: Independent or sufficiently objective evidence that the corrective action was actually implemented and addressed the deficiency.

Monitoring: A later check to make sure the correction continues to work and the problem has not returned.

Formal Closure: The documented point at which the county has completed the required review and, when applicable, corrective action, verification, and monitoring, and communicates the disposition to the citizen.

What This Process Accomplishes

Citizens know where to bring significant compliance concerns.

Government has a defined receiver instead of relying on the citizen to find the right office.

A qualified person determines whether the concern has merit instead of assuming either side is correct.

Departments retain their subject-matter authority, but one process provides ownership and continuity across departments.

Confirmed deficiencies lead to tracked corrective action rather than stopping at an acknowledgement or investigation report.

Corrections are verified before the matter is closed.

Government can identify recurring problems and learn from them.

Citizens receive a documented answer, and government employees are protected from unsupported allegations by an objective review process.

How a County Pilot Could Help

A limited county pilot could test the operating procedure before statewide legislation is finalized. The pilot would not need to resolve every legislative question. It could demonstrate the workflow, forms, case ownership, review criteria, CAP tracking, verification, citizen communication, and reporting needed to make the process work in practice.

The results of a pilot could help legislative counsel distinguish between the minimum statutory requirements every county must meet and the detailed procedures counties should be free to tailor to their own organization.

Legislative Drafting Questions

1. What minimum requirements must be written into statute so a county cannot satisfy the law with only an intake mailbox, a response deadline, and an appeal process?

2. Which requirements should be mandatory statewide, and which should be left to county policy and procedure?

3. Who should the statute make accountable for establishing the process — the Board of Supervisors, County Manager, a compliance function, or another office?

4. Does the statute need to require a “Compliance Officer,” or is it better to require a qualified and sufficiently independent “compliance function” so counties can use different organizational structures?

5. How should the law describe independence or conflict-of-interest protections when the concern involves the department or official that would normally review it?

6. Should the law establish minimum response or milestone timeframes, or should timeframes be established by county procedure subject to a statutory reasonableness standard?

7. What must the law say about written determinations, corrective action, verification, monitoring, and formal closure?

8. Should the law require periodic Board reporting and public aggregate reporting on process health?

9. How should the law preserve existing specialized complaint and investigative processes while making the new process a countywide safety net?

10. Would revising A.R.S. § 11-1608 be the best legislative vehicle, or would a new section be cleaner?

11. What language is necessary to make the requirements enforceable without creating a new state bureaucracy?

12. If a county pilots this procedure, what elements should be documented so the pilot can inform bill drafting?

Purpose of Legislative Review

This specification is not intended to present final bill language. Its purpose is to define the process outcome that legislation should require and identify the minimum elements necessary to make that process meaningful and enforceable. Legislative review is requested to determine which requirements should be codified in Arizona law and which operational details should remain within county policy and procedure.

Conclusion

The law should require the outcome. The county procedure should explain the method. A citizen should be able to submit a documented concern and know that someone qualified will review it, make a determination, require corrective action when warranted, verify the correction, and formally close the matter. The process should be fair to the citizen and fair to government. That is the minimum outcome the legislation should require.