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Audit Audit of the Executive Office of Elder Affairs

This audit examines EOEA's process for screening, investigating, documenting, and reporting incidents of elder abuse. It looks at the period of July 1, 2015 through June 30, 2017.

Binder organization: Office of the State Auditor
Date published: October 9, 2018

Executive Summary

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of the Executive Office of Elder Affairs’ (EOEA’s) Protective Services Program for the period July 1, 2015 through June 30, 2017. In this performance audit, we examined EOEA’s process for screening, investigating, documenting, and reporting incidents of elder abuse.

Below is a summary of our findings and recommendations, with links to each page listed.

Finding 1

EOEA and its designated protective-service agencies (PSAs) did not always report incidents of abuse to district attorneys’ (DAs’) offices for investigation.

Recommendations

  1. EOEA should develop a guidance manual addressing documentation practices for DA referral and reporting to reflect the requirements of Section 5.18(2)(e) of Title 651 of the Code of Massachusetts Regulations.
  2. EOEA should establish monitoring controls to ensure that each person involved in the DA referral process complies with its policies and procedures for reporting incidents of alleged abuse to DAs’ offices. In particular, during its designation review process, it should evaluate whether PSAs are referring incidents of alleged abuse to DAs’ offices as required.
  3. EOEA should schedule regular meetings with DAs’ offices to ensure that reportable conditions that warrant DA referral are reported.

Finding 2

EOEA did not always properly document the processing of abuse reports in its Adult Protective Services (APS) system.

Recommendations

  1. EOEA should implement policies and procedures that include better documentation practices in APS. The policies should also communicate clear personnel responsibilities in APS for each investigation and should include the necessary steps for manually linking abuse reports to corresponding investigations.
  2. PSA supervisors should document their screening decision rationales in APS and assign a PSA case manager or second PSA supervisor to review each decision before the initiation of an investigation if it is screened in, or an expungement if it is screened out, by the supervisor.

Finding 3

EOEA’s APS system controls need improvement.

Recommendations

  1. EOEA should screen and approve new users’ access to APS.
  2. EOEA should establish and implement written system security access policies and procedures, within a control plan, that are specific to employees using APS and include, but are not limited to, the following:
    a. approval of access to APS for new users before new accounts are created and use of APS is granted
    b. access controls that address entry into the system via password login, as well as lockout of APS users after shorter periods of inactivity
    c. monitoring of user activity and oversight of intake and investigation logs

 

Post-Audit Action

In a written response to this report, the Secretary of EOEA indicated that a number of improvements had been, and would continue to be, made in the area of protective services, including the following:

  • Improved case completion compliance. In the spring of 2016, EOEA piloted a change requiring that any extensions to required investigation deadlines be approved by EOEA, whereas previously the designated protective services agencies (PSAs) alone would self-approve such extensions.
  • Strengthened program integrity measures. Beginning in November of 2016, EOEA introduced a program integrity initiative where funding to PSAs would be withheld for non-compliance with certain regulatory and contractual requirements. The program initially focused on screening procedures, and was expanded in January 2017 to cover key components of Protective Services.
  • Strengthened regulatory framework. Beginning in January 2017, EOEA modified program regulations that previously required PSAs to obtain an elder’s consent to proceed with investigations. EOEA also rescinded a sub-regulatory guidance document issued over a decade ago that required PSAs to obtain an elder’s consent prior to communicating with collateral contacts. These directives were delivered to PSAs during a statewide training in February 2017 with full implementation and codification later that year.
  • The launch of a Central Intake Unit. On June 30, 2017, EOEA launched a Central Intake Unit that provides capacity for 100% capture of all protective services reports at a central location. The implementation of centralized intake was designed to simplify the initial reporting process (moving from 21 different phone numbers to one number 24/7/365) and to capture efficiencies of scale. This enabled EOEA to redirect substantial resources to screening, investigation, and the provision of ongoing services when indicated thereby reducing the risk of abuse.        
  • The implementation of a new decisional capacity tool. In October 2017, EOEA implemented a decisional capacity screening instrument for use by PSAs (the Interview of Decisional Abilities or IDA). Massachusetts is the first [protective-service] program in the country to implement the use of this cutting edge tool statewide. The tool is used to determine if an individual has decisional capacity to refuse intervention. A group of clinicians and researchers from the University of Pennsylvania, Weill Cornell Medical College, and the New York City Elder Abuse Center developed the IDA tool. It is specifically designed for use by [protective-service] workers to assess decisional capacity in the field. Since EOEA launched this project, the University of Southern California, home of the National Center on Elder Abuse, received a grant from the federal government to implement the tool in CA, Vermont, Tennessee, and Georgia have also reached out to EOEA about implementing the tool in their states.
  • Improved access to services. By November 2017, EOEA had fully implemented a requirement that all appropriate substantiated investigations are opened for Ongoing Services (i.e. meet with elder, develop service plan, communicate with collateral contacts).
  • Improved workforce training. With the support of a grant from the federal Administration for Community Living . . . EOEA is strengthening the Protective Services workforce by training the entire workforce in 2018 and 2019 using a newly developed, comprehensive, Protective Services curriculum.
  • Increased funding. The funding for the Protective Services Program has increased every year since 2015.

A PDF copy of the audit of the Executive Office of Elder Affairs is available here.

List of Abbreviations

ACL

Audit Command Language

APS

Adult Protective Services

CIU

Centralized Intake Unit

CMR

Code of Massachusetts Regulations

DA

district attorney

EOEA

Executive Office of Elder Affairs

OSA

Office of the State Auditor

PSA

protective-service agency

Contact

Phone

Fax

(617) 727-3014

Address

Massachusetts State House
Room 230
Boston, MA 02133
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