Audit  Audit of the Department of Labor Standards—Division of Apprentice Standards

Finding 1

DAS did not ensure that its sponsors’ apprentice programs met established quality standards.

Recommendations

1. DAS should conduct quality assurance assessments (QAAs), using the “Apprenticeship Program Quality Assurance Assessment” form, after the first year of a sponsor’s apprentice program and at least once every five years thereafter.
2. DAS personnel responsible for conducting the QAAs should have the proper policies, procedures, and forms to complete them.
3. DAS management should identify existing financial resources that could be allocated to enable DAS to increase its number of compliance officers in order to conduct all required QAAs and, if necessary, should request additional funding from the Legislature for this purpose.
4. DAS should develop and implement written policies and procedures to schedule, conduct, and monitor the performance of QAAs.

Finding 2

DAS did not perform compliance reviews of apprentice program sponsors to ensure that they had developed and implemented affirmative action programs (AAPs) and met established hiring goals.

Recommendations

1. DAS should conduct affirmative action plan reviews every five years, and equal employment opportunity (EEO) compliance reviews annually, to ensure that sponsors are meeting the goals established in their affirmative action plans.
2. DAS should assess what additional resources, if any, it needs to perform its affirmative action plan reviews and EEO compliance reviews in accordance with applicable requirements and should seek to obtain these resources.
3. DAS should develop and implement written policies and procedures regarding conducting AAP and EEO reviews, as well as monitoring controls to ensure that these policies and procedures are adhered to.

Finding 3

DAS did not properly administer apprentice agreements.

Recommendations

1. DAS should develop a new apprentice agreement to include all requirements described in Section 26.06(4) of Title 454 of the Code of Massachusetts Regulations.
2. DAS management should develop monitoring controls to ensure that all regulatory requirements are included on the apprentice agreements and that program applicants and sponsors submit all required information.