Audit of the Massachusetts School Building Authority Objectives, Scope, and Methodology

An overview of the purpose and process of auditing the Massachusetts School Building Authority.

Overview

In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor (OSA) has conducted a performance audit of certain activities of the Massachusetts School Building Authority (MSBA) for the period July 1, 2022 through June 30, 2024. When examining MSBA’s verification of Green Schools Program building commitments, we extended the audit period to January 1, 2020 through December 31, 2024 to account for the multiyear nature of Core Program projects and to include a larger number of projects that had reached completion and received final grant payments.

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 MSBA ensure that school districts that committed to green building standards under its Green Schools Program had fulfilled those commitments before MSBA disbursed final grant payments?	Yes
Did MSBA develop and implement written policies and procedures for evaluating and prioritizing Statements of Interest (SOIs) submitted by school districts for its Core Program and Accelerated Repair Program (ARP), as recommended by the prior OSA audit (Audit No. 2022-1461-3A)?	Yes

To accomplish our audit objectives, we gained an understanding of MSBA’s internal control environment relevant to our objectives by reviewing applicable policies and procedures and by interviewing MSBA officials. We evaluated the design and implementation of the internal controls related to our audit objectives. We also tested the operating effectiveness of controls over the approval of final grant payments for Core Program projects by MSBA’s board of directors. In performing our work, we found that MSBA has not updated its internal control plan since 2018 (see Finding 2).

To obtain sufficient, appropriate evidence to address our audit objectives, we performed the procedures described below.

Verification of Green Schools Program Commitments

To determine whether MSBA ensured that school districts that committed to green building standards under its Green Schools Program fulfilled those commitments before MSBA disbursed final grant payments, we obtained a list of all 44 Core Program projects that received a final grant payment between January 1, 2020 and December 31, 2024 from MSBA’s Pro-Pay system.⁸ For each of the 44 projects, we determined whether MSBA conducted a final audit of the project, with the final audit report approved by MSBA’s board of directors, and whether all required Green Schools Program documentation was submitted and reviewed by MSBA before it disbursed the final grant payment. We examined documentation to determine whether each district completed and submitted certain required closeout materials, including a Certificate of Green Schools Program Achievement; a Northeast Collaborative for High Performance Schools (NE-CHPS) or Leadership in Energy and Environmental Design scorecard; and official certification letters or emails from NE-CHPS or the US Green Building Council, where applicable. We compared the green building standards achieved to those agreed upon in the approved Project Scope and Budget Agreement and identified any discrepancies or deviations from the original sustainability commitments. If the agreed-upon green standard was not achieved, we determined whether the final payment was appropriately adjusted in accordance with MSBA guidelines.

We did not identify any exceptions in our testing. Therefore, we concluded that, during the audit period, MSBA ensured that school districts that committed to green building standards under its Green Schools Program fulfilled those commitments before MSBA disbursed the final grant payments.

SOI Evaluation and Prioritization Policies and Procedures

During our prior audit (Audit No. 2022-1461-3A), we found that, although MSBA had established a process to evaluate and prioritize SOIs that school districts submit to its Core Program and ARP for grant funding, it had not established written policies and procedures that described how to conduct various aspects of this process. To determine whether MSBA had addressed this prior finding, we interviewed MSBA officials to discuss whether written policies and procedures had been developed since the prior audit. During these meetings, MSBA officials informed us that the agency had developed SOI Operations Manuals for both the Core Program and the ARP. These manuals outline the various steps of the SOI evaluation and prioritization process. We conducted walkthroughs with MSBA staff members who were responsible for evaluating SOIs for the 2023 Core Program and 2022 ARP,⁹ during which MSBA staff members demonstrated the prioritization and evaluation processes and the tools they used to evaluate and prioritize each SOI MSBA received. Finally, we assessed whether the 2023 Core Program and the 2022 ARP evaluation processes reflected the steps outlined in the SOI Operations Manuals and, therefore, the implementation of formalized policies and procedures, as recommended in the prior OSA audit.

We did not identify any exceptions in our testing. Therefore, we concluded that, during the audit period, MSBA developed and implemented written policies and procedures for evaluating and prioritizing SOIs submitted by school districts for its Core Program and ARP, as recommended by the prior OSA audit.

In the course of our audit work, we found that MSBA did not submit required annual reports on the condition and improvement needs of school buildings to the Governor and the designated legislative committees. See Finding 1 for more information.

Data Reliability Assessment

To determine the reliability of the list of Core Program final grant payments that we obtained from MSBA’s Pro-Pay system, we conducted interviews and system walkthroughs with MSBA management and staff members who were knowledgeable about and responsible for overseeing the data. We also observed MSBA staff members extract the data directly from the Pro-Pay system to ensure its completeness. We tested the data to ensure that it did not contain duplicate records, missing values in necessary data fields, and data corresponding to dates outside the audit period. We selected a random sample of 5 out of 44 projects that received a final grant payment and traced key data points, including district name, payment date, payment amount, and the board of directors’ approval date, to source documentation to verify accuracy. Additionally, we reviewed MSBA board of directors meeting memoranda to ensure completeness of Core Program final grant payments by confirming that no districts with projects listed as having received final audit approval were missing from our list. Further, we tested access controls over the Pro-Pay system.

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

8.    Pro-Pay is the progress payment system that MSBA uses to receive, review, and approve reimbursement requests submitted by school districts.

9.    There was a temporary, one-year pause to the ARP in 2023. Accordingly, for the purposes of this audit, we reviewed the 2022 ARP process. Projects were approved for invitation at MSBA’s October 2022 board of directors meeting, which fell within the audit period.

Date published:	December 24, 2025