Audit of the Commonwealth Corporation Overview of Audited Entity

This section describes the makeup and responsibilities of the Commonwealth Corporation.

Overview

Commonwealth Corporation (CommCorp) is a quasi-public workforce development agency overseen by the Executive Office of Labor and Workforce Development. Section 64 of Chapter 365 of the Acts of 1996 established CommCorp (which was originally known as the Corporation for Business, Work and Learning until the Legislature approved its name change in September 2004) by merging two former Massachusetts nonprofit organizations (the Industrial Service Program and the Bay State Skills Corporation). CommCorp administers several workforce and youth development programs through partnerships with businesses, educators, and other workforce organizations across the Commonwealth.

According to its website, “Commonwealth Corporation fosters workforce equity in Massachusetts by delivering innovative and collaborative professional development solutions that help diverse communities and employers succeed.”

CommCorp is governed by a 19-member board of directors, which is chaired by the Secretary of the Executive Office of Labor and Workforce Development. Under the direction of the board of directors, CommCorp’s president and chief executive officer manages all of CommCorp’s programs and divisions. During the audit period, CommCorp employed 148 individuals.

YouthWorks

On behalf of the Executive Office of Labor and Workforce Development, CommCorp is responsible for the administration and oversight of YouthWorks, which is a state-funded program that, through training and paid temporary work opportunities, helps young people¹ living in low-income communities across Massachusetts find and retain employment. CommCorp partners with the 16 MassHire Workforce Development Boards² across the Commonwealth to administer YouthWorks. According to CommCorp’s YouthWorks frequently asked questions document, YouthWorks program participants gain jobs in many different areas of business, including administrative support, childcare, care for older people, landscaping, and retail. In addition to work opportunities, YouthWorks program participants receive work-readiness training in soft skills (e.g., collaboration, communication, and dependability) as part of CommCorp’s Signal Success curriculum, which YouthWorks grant recipients use throughout all YouthWorks programs.

CommCorp’s Request for Proposals for the YouthWorks Year-Round Program for 2021–2022, which outlines requirements for YouthWorks grant recipients, states,

The YouthWorks program aims to improve the employability of youth placed at risk by offering them structured work and learning opportunities through subsidized employment and supporting activities. The anticipated outcome of YouthWorks is to provide young people with the skills, experience, and networks to be able to secure employment in the unsubsidized labor market.

According to the Commonwealth’s Fiscal Year 2022 Final Budget, the Commonwealth funds YouthWorks through an annual appropriation “for a youth-at-risk program targeted at reducing juvenile delinquency and youth and young adult homelessness in high-risk areas.” The appropriations were $20,000,000 and $24,000,000 for fiscal years 2021 and 2022, respectively.

YouthWorks offers cycle 1 (which took place from July through August during the audit period) and cycle 2 (which took place from September through June during the audit period), and program participants are able to participate in multiple program cycles. During the audit period, CommCorp enrolled 8,547 program participants in one or more program cycles, translating to 10,280 program participant spots filled by YouthWorks’s program participants during fiscal years 2021 and 2022 (see table below).

MassHire Workforce Development Board	Number of Filled Participant Spots	Number of Served Program Participants
Berkshire	147	111
Boston	2,632	2,244
Bristol	441	379
Cape and Islands	58	43
Central Region	804	672
Franklin Hampshire	88	76
Greater Brockton	320	270
Greater Lowell	388	316
Greater New Bedford	555	434
Hampden County	1,378	1,107
Merrimack Valley	544	453
Metro North	1,349	1,098
Metro South/West	281	239
North Central	261	228
North Shore	648	531
South Shore	386	346
Total	10,280	8,547

CommCorp does not provide support to program participants directly. Instead, CommCorp provides grants, oversight, administrative support, and technical support to the different MassHire Workforce Development Boards, each of which then administers its own YouthWorks program by partnering with nonprofit organizations, cities and towns, and businesses. Each YouthWorks grant recipient³ directly recruits, trains, and places YouthWorks program participants in various available positions with partnering businesses.

The table below shows the funding amounts that CommCorp distributed to its YouthWorks grant recipients during the audit period.

	Fiscal Year 2021		Fiscal Year 2022
MassHire Workforce Development Board	Cycle 1	Cycle 2	Cycle 1	Cycle 2
Berkshire	$188,300	$119,778	$235,500	$75,940
Boston	3,202,827	578,671	3,711,480	319,000
Bristol	704,276	166,861	901,180	215,236
Cape and Islands	135,626	87,778	172,700	75,940
Central Region	905,926	431,212	1,136,680	273,592
Franklin Hampshire	101,882	137,429	144,440	93,511
Greater Brockton	479,208	188,708	621,720	148,088
Greater Lowell	581,422	302,556	722,200	175,068
Greater New Bedford	606,131	185,556	763,020	183,860
Hampden County	1,826,035	548,963	2,267,080	319,000
Merrimack Valley	869,025	293,551	1,108,420	264,800
Metro North	1,051,405	314,259	1,306,240	314,000
Metro South/West	228,616	137,756	351,680	107,964
North Central	401,148	123,708	496,120	118,712
North Shore	748,345	287,407	960,840	228,424
South Shore	442,724	123,708	568,340	134,296
Subtotal*	$12,472,896	$4,027,900	$15,467,640	$3,047,431
Grand Total	$16,500,796		$18,515,071

*  Discrepancy in total is due to rounding.

YouthWorks Program Participant Eligibility and Reporting

Program Participant Eligibility

YouthWorks program participants need to meet the eligibility requirements in three main categories: age, income, and risk factors. To be eligible for the program, a program participant must be between the ages of 14 and 21 at least part of the time during a program cycle.⁴ In addition, the program participant’s family income for the six months before the requested program cycle cannot exceed 200% of the federal poverty guidelines. Lastly, in “an effort to strategically target high-needs youth,” as stated in CommCorp’s YouthWorks “Program Administration and Management Guide,” program participants should be individuals experiencing one or more of the risk factors that can be found in the table below.

YouthWorks grant recipients are responsible for verifying and documenting program participant eligibility. CommCorp’s YouthWorks “Program Administration and Management Guide” for fiscal year 2022 provided the following guidance table on potential ways that YouthWorks grant recipients could fulfill their requirement to document program participants’ risk factor eligibility.

Risk Factor Definition	Acceptable Documentation
A history of juvenile delinquency . . .	Court and police records, letter of parole, letter from probation officer or [a Department of Youth Services] caseworker or referral from community-based organization with proven capacity for servicing gang-involved youth
Poor academic performance or [having left the education system without a degree]	School records such as grades or [Massachusetts Comprehensive Assessment System] results, attendance . . . letter from school; for out-of-school youth, school records dated in the prior two years could be used as well as local assessment such as the [Tests of Adult Basic Education]
[Experiencing] homelessness . . .	Written statement from an individual providing temporary residence, letter from shelter or [one of the Executive Office of Health and Human Services’ (EOHHS’s) agencies]
Having aged out of foster care, or being close to aging out of foster care	Court documents or letter from EOHHS agency
Being the child of a single parent	Applicant statement of household size
Having a disability or [functional] needs	School records, medical records, observable condition, or letter from social service agency
Lack of fluency in English, or being a documented immigrant	School records, teacher or community-based-organization referral, or local assessment of English-language proficiency
Being a [teenager and a parent]	Birth certificate, school records, referral or letter from social services agency

Source: CommCorp’s YouthWorks “Program Administration and Management Guide” for fiscal year 2022

In addition to the risk factors in the table above, income is also a risk factor that is addressed within CommCorp’s YouthWorks “Program Administration and Management Guide.” According to this guide, acceptable documentation for income include, “For youth enrolled in public school, evidence that the school has determined a student’s eligibility for a ‘reduced price lunch,’ or ‘free lunch.’” For youth who are not in school, YouthWorks grant recipients can accept program participants’ self-attested statements of household income and size. However, “income documentation is not required for youth who are documented as [experiencing homelessness], in foster care, or for youth with disabilities.”

During the COVID-19 pandemic, if COVID-19 affected a program participant’s family, then CommCorp also included this situation as an acceptable risk factor when YouthWorks grant recipients determined a program participant’s eligibility.

Reporting

YouthWorks grant recipients enter all program participant information (e.g., name, age, risk factors, Social Security numbers, and information related to the program participant’s corresponding program) into CommCorp’s YouthWorks database.⁵ According to CommCorp’s YouthWorks “Program Administration and Management Guide,”

Grantees are required to report individual YouthWorks participant record data, including participant social security numbers that will enable the state to develop program profiles, statistical reports on the characteristics of participating youth and employers, and calculate data on program wage levels as part of the process of reporting program outcomes to the Massachusetts Legislature. All grantees must make sure that data is entered or uploaded to the YouthWorks database.

YouthWorks grant recipients either upload documentation to support program participant eligibility directly to the YouthWorks database, or store documentation internally on a network drive or as hardcopy files. CommCorp uses the information in the YouthWorks database to report the following information to the Massachusetts Legislature: the number of young people the program served, these young people’s demographic information, and the types of job industries in which the program has placed these young people. The YouthWorks database is also connected to and shares data with the Massachusetts Department of Elementary and Secondary Education’s Connecting Activities program database.⁶

YouthWorks Performance Assessment

The Workforce Innovation and Opportunity Act (WIOA) is a 2014 federal law governing employment and training programs. WIOA requires the US Department of Labor and the US Department of Education to implement a performance accountability system across the six WIOA-designated core programs (one of which involves youth programs). This performance accountability system established common indicators of performance in areas such as employment and earnings.

WIOA requires workforce development programs to evaluate the effectiveness of their efforts to achieve positive outcomes for their program participants. As a best practice for measuring employment outcome data of workforce development programs (such as YouthWorks), WIOA promotes matching program participant information (such as Social Security numbers) to unemployment insurance data (such as quarterly wage records) that states collect to administer unemployment benefits. This method allows CommCorp to track and evaluate the employment status and earnings of program participants upon their completion of the YouthWorks program cycles in which they participated.

The versions of CommCorp’s YouthWorks “Program Administration and Management Guide” that were in effect during the audit period also required YouthWorks grant recipients to collect the employment outcome data corresponding to YouthWorks program participants.

Cybersecurity Awareness Training

The Executive Office of Technology Services and Security (EOTSS) has established policies and procedures that apply to all Commonwealth agencies within the executive branch. EOTSS recommends, but does not require, non-executive branch agencies to follow these policies and procedures. Section 6.2 of EOTSS’s Information Security Risk Management Standard IS.010 states,

The objective of the Commonwealth information security training is to educate users on their responsibility to help protect the confidentiality, availability and integrity of the Commonwealth’s information assets. Commonwealth Offices and Agencies must ensure that all personnel are trained on all relevant rules and regulations for cybersecurity.

To ensure that employees are clear on their responsibilities, EOTSS’s policies require that all employees in state executive agencies complete a cybersecurity awareness course every year. All newly hired employees must complete an initial security awareness training course within 30 days of their orientation.

Although CommCorp is not required to follow this standard, since it is not an executive branch agency, EOTSS still recommends that non-executive branch agencies follow these standards. We also consider it a best practice. According to the Office of the Comptroller of the Commonwealth’s website, EOTSS’s Enterprise Information Security Policies and Standards “are the default standard for non-Executive departments who have not adopted comparable cyber and data security standards as part of their Internal Control Plan.”

1.   According to CommCorp’s YouthWorks “Program Administration and Management Guide” for fiscal years 2021 and 2022, individuals between the ages of 14 and 21 are eligible to participate in the program.

2.   According to the Executive Office of Labor and Workforce Development’s 2022 MassHire Annual Report, part of the workforce development system in Massachusetts is made up of 16 MassHire Workforce Development Boards, which create local employment programs to assist those both seeking and offering jobs.

3.   For the purposes of this audit report, we use the term YouthWorks grant recipient to refer to MassHire Workforce Development Boards and their partners (unless stated otherwise).

4.   Beginning in fiscal year 2023, which was after the audit period, individuals between the ages of 14 and 25 were eligible to participate in CommCorp’s YouthWorks program.

5.   CommCorp’s YouthWorks database helps YouthWorks grant recipients manage and report on their YouthWorks programs. All YouthWorks grant recipients use the YouthWorks database to record program participant–level demographic information. YouthWorks grant recipients also use the database to compile reports (e.g., employer lists, training dates, and enrollment and completion status by program participant), which they are required to submit to the Executive Office of Labor and Workforce Development and the Massachusetts Legislature.

6.   The Massachusetts Department of Elementary and Secondary Education’s Connecting Activities program is a school-based program that gives employment experience to Massachusetts students between ninth grade and twelfth grade.

Date published:	July 9, 2024