Brown

I. FACTS AND PROCEDURAL BACKGROUND1

A. Brown’s Employment with the County Brown began working for the County in 1996. In 2011, she moved to in-home supportive services (IHSS) where she worked as a program service aide until her retirement in 2022. The County’s IHSS program provides eligible residents with in-home supportive services such as paramedical services, personal care services, transportation to medical appointments, and housekeeping. Brown worked in IHSS’s “[a]pplications [r]eadiness” unit, providing administrative support to applicants seeking to obtain IHSS services. Brown’s manager in the applications readiness unit, Inessa Christy, distributed referrals for IHSS as equally as possible among the six program service aides who worked in the unit. The program service aides were responsible for collecting and verifying the referral applicant’s demographic information and health certification attesting to the need for in- home supportive services. Christy, the eligibility work supervisor, managed the applications readiness unit at all relevant times, except for a period from October 2017 to October 2018. Christy reported to Kingston Lum, a social services program manager…