Audit of the Department of Elementary and Secondary Education Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Department of Elementary and Secondary Education.

Overview

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 certain activities of the Department of Elementary and Secondary Education (DESE) for the period of July 1, 2021 through June 30, 2023.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Below is a list of our audit objectives, indicating each question we intended our audit to answer; the conclusion we reached regarding each objective; and, if applicable, where each objective is discussed in the audit findings.

Objective	Conclusion
Did DESE ensure that all special education complaints were investigated within the 60-day timeframe required by Section 300.152 of Title 34 of the Code of Federal Regulations (CFR) and that all appropriate corrective actions were implemented by school districts within the timeframes it established?	No; see Findings 2 and 3
To what extent did DESE collaborate with the Safe Schools Program for LGBTQ Students (SSP) to provide trainings for school district employees on LGBTQ issues, in accordance with the memorandum of understanding (MOU) between DESE and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013?	To an insufficient extent; see Finding 4
Did DESE investigate reports of alleged child abuse or neglect involving licensed educators that were referred by the Department of Children and Families (DCF), in accordance with the MOU between the two agencies that was effective September 15, 2020?	No; see Finding 1

To accomplish our audit objectives, we gained an understanding of DESE’s internal control environment relevant to our objectives by reviewing applicable policies and procedures, DESE’s internal control plan, and relevant MOUs, as well as by conducting interviews about and observations of the PRS online complaint portal, abuse and neglect reporting processes, and SSP processes with DESE management and employees. In addition, to obtain sufficient, appropriate evidence to address our audit objectives, we performed the procedures described below. 

Special Education Complaints

Timeliness of Investigations

To determine whether DESE ensured that all special education complaints were investigated within the 60-day timeframe required by 34 CFR 300.152, we took the following actions. First, we extracted a list of the total population of 1,877 special education complaints reported to DESE during the audit period from the Problem Resolution System (PRS) online complaint portal. From this list, we selected a random, statistical⁷ sample of 60 special education complaints, using a 95% confidence level,⁸ a 0% expected error rate,⁹ and a 5% tolerable error rate.¹⁰

For each of the special education complaints in our sample, we compared certain dates (i.e., those of complaint intakes; investigation extensions granted, if applicable; Letters of Finding; and Letters of Closure) within certain documentation (i.e., emails, Letters of Extension, Letters of Finding, Letters of Closure, and requests for documentation) to ensure that these dates matched the same dates recorded within the PRS online complaint portal.

We compared each intake date to the dates of the Letters of Finding and Letters of Closure to determine whether DESE completed each special education complaint investigation within the required 60-day timeframe. In instances where the 60-day timeframe was exceeded, we reviewed the case file and any related correspondence to determine whether the case file contained evidence of an extension. If such an extension existed, then we used the extension due date in our timeliness calculation.

For this aspect of our objective, we found certain issues during our testing. See Finding 2 for more information.

Implementation of Corrective Actions

To determine whether DESE ensured that all appropriate corrective actions were implemented by school districts within the timeframes it established, we took the following actions. From the list of 1,877 special education complaints, we identified the population of 629 complaints requiring corrective actions by either the school district or the school. From the list of 629 complaints requiring corrective actions, we selected a random, nonstatistical¹¹ sample of 50 complaints requiring corrective actions.

For each complaint requiring corrective actions in our sample, we compared certain dates (i.e., those of corrective action plans; DESE’s corrective action plan receipt; and investigation extensions granted, if applicable) within certain documentation (i.e., emails, Letters of Extension, Letters of Finding, Letters of Closure, and document request letters) to ensure that these dates matched the same dates recorded within the PRS online complaint portal.

We compared each corrective action plan’s original due date, as established by DESE, to the date on which the school district submitted its corrective action plan. In instances when the submission date exceeded the original due date, we reviewed the case file and any related correspondence to determine whether the case file contained evidence of an extension. If such an extension existed, then we used the extension due date in our timeliness calculation.

For this aspect of our objective, we found certain issues during our testing. See Finding 3 for more information.

SSP

To determine to what extent DESE collaborated with the SSP to provide trainings for school district employees on LGBTQ issues, in accordance with the MOU between DESE and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013, we took the following actions. First, we interviewed DESE management to understand the policies and procedures related to SSP training available during the audit period for school district personnel members. We also interviewed officials from the SSP to assess the level of coordination with DESE in delivering trainings to school districts. We obtained and analyzed a list of all 397 Massachusetts school districts in existence during the audit period and all 180 SSP training requests made during the audit period. For each school district, we reviewed and categorized training activity as follows:

• SSP training was requested and received;
• SSP training was requested but not received; and
• no SSP training was requested or received.

To determine whether the commitments outlined in the MOU between DESE and the Massachusetts Commission on LGBTQ Youth were fulfilled during the audit period, we requested the following documentation:

• the annual joint communication sent to school superintendents and principals encouraging supportive school climates and highlighting available resources;
• presentation documentation for the joint presentations made to the Board of Elementary and Secondary Education, including any materials summarizing (1) data from the Massachusetts Youth Risk Behavior Survey and (2) collaborative efforts under the MOU;
• records of quarterly meetings held between senior personnel members from DESE and the Massachusetts Commission on LGBTQ Youth to monitor the implementation of the MOU and to discuss potential future modifications.

For this objective, we found certain issues during our testing; namely, that 251 (63%) school districts out of 397 had not received SSP training. See Finding 4 for more information.

Investigation of Allegations of Child Abuse or Neglect

To determine whether DESE investigated reports of alleged child abuse or neglect involving licensed educators that were referred by DCF, in accordance with the MOU between the two agencies that was effective September 15, 2020, we took the following actions. First, we obtained spreadsheets listing 229 supported 51A and 51B reports¹² from DESE and 267 supported 51A and 51B reports from DCF. We interviewed DESE management and conducted a walkthrough of the intake and investigation process conducted by DESE’s Office of Professional Practice Investigations. We also requested from DESE’s Office of Professional Practice Investigations all case files and related documentation for the supported 51B reports to ascertain whether DESE completed an investigation corresponding to each report.

For this objective, we found certain issues during our testing; namely, that (1) DESE’s Office of Professional Practice Investigations did not open or track an investigation tied to the spreadsheet of supported 51B reports that DCF forwarded on July 20, 2023, and (2) DESE had no evidence of having compared its own list to DCF’s or of following up on the missing or incomplete information. See Finding 1 for more information.

We used a combination of statistical and nonstatistical sampling methods for testing. Where we used nonstatistical sampling methods, we did not project the results of our testing to any of the populations.

Data Reliability Assessment

Special Education Complaints

To determine the reliability of the complaint data within DESE’s complaint resolution system, we took the following actions. First, we interviewed personnel members from DESE and the Executive Office of Technology Services and Security who were knowledgeable about the data. We reviewed System and Organization Control Reports¹³ covering the audit period. In addition, we tested access controls and security management over DESE’s PRS online complaint portal. We tested the data to ensure that it did not contain certain dataset issues (i.e., duplicate records, missing values in necessary data fields, and data corresponding to dates outside the audit period).

SSP

We obtained a list of LGBTQ trainings hosted during the audit period from the SSP personnel members. We tested the list to ensure that it did not contain certain dataset issues (i.e., duplicate records, missing values in necessary data fields, and data corresponding to dates outside the audit period). We were unable to determine the completeness and accuracy of the list of LGBTQ trainings hosted during the audit period; however, this was the only source of information available to answer our audit objective.

We also obtained a list of all Massachusetts school districts from the DESE website. To assess this list’s reliability, we selected a random sample of 20 school districts from the list and traced the school district name and address to publicly available information on each school district’s website. We selected a different random sample of 20 school districts from a list we generated using a search engine made publicly available from the National Center for Education Statistics and determined whether the school districts were present in the list. Additionally, we tested the list to ensure that it did not contain certain dataset issues (i.e., duplicate records and missing values in necessary data fields).

Investigation of Allegations of Child Abuse or Neglect

We obtained Microsoft Excel spreadsheets of 51A and 51B reports from both DESE and DCF for incidents that occurred during the audit period. From these spreadsheets, we identified the records of reports that corresponded to only cases that resulted in needing 51B reports—DESE’s records showed 229 supported reports and DCF’s records showed 267 supported reports. We followed up with both DESE and DCF management to determine why these discrepancies existed. See Finding 1 for more information.

Based on the results of the data reliability assessment procedures described above, we determined that the information we obtained during the course of our audit was sufficiently reliable for the purposes of our audit.

7.    Auditors use statistical sampling to select items for audit testing when a population is large (usually over 1,000) and contains similar items. Auditors generally use a statistical software program to choose a random sample when sampling is used. The results of testing using statistical sampling, unlike those from judgmental sampling, can usually be used to make conclusions or projections about entire populations.

8.    Confidence level is a mathematically based measure of the auditor’s assurance that the sample results (statistic) are representative of the population (parameter), expressed as a percentage.

9.    Expected error rate is the number of errors that are expected in the population, expressed as a percentage. It is based on the auditor’s knowledge of factors such as prior year results, the understanding of controls gained in planning, or a probe sample.

10.    The tolerable error rate (which is expressed as a percentage) is the maximum error in the population that is acceptable while still using the sample to conclude that the results from the sample have achieved the objective.

11.    Auditors use nonstatistical sampling to select items for audit testing when a population is very small, the population items are not similar enough, or there are specific items in the population that the auditors want to review.

12.    A 51A or 51B report is considered supported when it is one in which DCF concludes that there is reasonable cause to believe that a child has been abused or neglected.

13.    A System and Organization Control report is a report issued by an independent contractor about a service organization’s systems relevant to security, availability, processing integrity, confidentiality, and/or privacy.

Date published:	August 26, 2025