Overview
During the audit period, CommCorp did not ensure that YouthWorks grant recipients obtained documentation that supported YouthWorks program participant eligibility and accurately recorded program participant information. Out of our sample of 100 YouthWorks participant spots filled, YouthWorks grant recipients were unable to provide documentation that supported one or more eligibility requirements for 34 of these participant spots. Specifically, we found the following: 10 instances where YouthWorks grant recipients could not provide documentation supporting a program participant’s age, 24 instances where YouthWorks grant recipients could not provide documentation supporting a program participant’s family income, and 5 instances where YouthWorks grant recipients could not provide documentation supporting a program participant’s risk factor.
In addition, we found 7 instances where a YouthWorks grant recipient did not record a program participant’s risk factor in the YouthWorks database, even though these program participants’ files had adequate documentation to support recording this information in the YouthWorks database.
Furthermore, YouthWorks grant recipients did not consistently and/or accurately document Social Security numbers for YouthWorks program participants. From our sample of 100 YouthWorks participant spots filled, we found the following types and numbers of issues regarding Social Security numbers that YouthWorks grant recipients recorded (or did not record) in the YouthWorks database:
- YouthWorks grant recipients had 4 instances of missing documentation for recorded Social Security numbers;
- YouthWorks grant recipients had 3 instances of incorrectly recorded Social Security numbers; and
- YouthWorks grant recipients had 18 instances of no recorded Social Security numbers.
In addition to our original test using our sample of 100 YouthWorks participant spots filled, we also identified an additional 1,603 instances where YouthWorks grant recipients did not record the Social Security number of an individual who participated in one or more YouthWorks program cycles during the audit period.
If CommCorp does not ensure that YouthWorks grant recipients obtain documentation that supports program participant eligibility, then not only is it possible that YouthWorks funding may be used to pay wages and/or provide services to ineligible individuals, but it is also possible that YouthWorks funding may not reach the individuals for whom it was intended.
In addition, if CommCorp does not ensure that YouthWorks grant recipients accurately record program participant information, then it cannot use the information in its YouthWorks database to evaluate the overall success of YouthWorks, nor can it report accurate information regarding YouthWorks to the Massachusetts Legislature and the Massachusetts Department of Elementary and Secondary Education.
Authoritative Guidance
CommCorp provides guidance to YouthWorks grant recipients regarding program participant eligibility requirements in its annual YouthWorks “Program Administration and Management Guide.” See the “Program Participant Eligibility” section of the Overview for a detailed explanation about this guidance and how it relates to this finding.
CommCorp’s YouthWorks “Program Administration and Management Guide” for fiscal years 2021 and 2022 also states,
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.
Reasons for Issue
CommCorp had not developed and implemented monitoring controls to ensure that YouthWorks grant recipients obtain documentation that supports program participant eligibility and accurately record program participant information in the YouthWorks database.
Recommendations
- CommCorp should develop and implement monitoring controls to ensure that YouthWorks grant recipients obtain documentation to support program participant eligibility and accurately record program participant information in the YouthWorks database.
- CommCorp should review program participant Social Security numbers that are recorded in the YouthWorks database and correct any incomplete or inaccurate numbers.
Auditee’s Response
CommCorp’s YouthWorks program experienced tremendous changes during the audit period, which coincided with the Governor’s Declared State of Emergency in response to the COVID-19 pandemic. These changes included a complete program overhaul, transitioning from an in-person summer jobs program pre-pandemic, to a fully remote year-round program. In addition to the program re-design, there was significant staff turnover on the YouthWorks team during the audit period that presented further challenges with regard to consistent enforcement of established program protocols, policies, and procedures.
YouthWorks is in the final stages of developing a new secure database, which will be implemented on June 10, 2024. That database will have robust internal controls and safeguards to ensure that all required participant data is collected, and any required eligibility data (e.g., Social Security Numbers) not fully or correctly entered into the database will serve as a barrier to complete program enrollment. The new database will also ensure more complete and program and participant data, as a participant profile cannot be completed until all required data is entered. CommCorp is also in the process of revitalizing both its program design and related review metrics to ensure that these changes are fully implemented by the start of the next program cycle (contracts beginning on or after May 15, 2024).
Prior to the audit review period, the YouthWorks team completed site visits and related file reviews and desk audits. During the audit period, this practice was suspended as CommCorp modified its program design and worked to prioritize staff and program participant safety and comply with COVID-19 related safety requirements. CommCorp will be returning to this practice during the next program cycle (summer 2024) and will also be conducting random site visits and related monitoring to ensure that collected data is complete and accurate.
Auditor’s Reply
Based on its response, CommCorp is taking measures to address our concerns on this matter.
| Date published: | July 9, 2024 |
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