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DCAMM Did Not Maintain Adequate Documentation To Support All the Information in Its Annual Reports to the State Legislature.

Without adequate documentation the annual report was inaccurate.

Table of Contents


DCAMM did not maintain adequate documentation to support the information in its annual reports to the state Legislature for fiscal years 2019 and 2020. These reports include a section about DCAMM contractors’ compliance with the agency’s workforce participation goals for women and minorities.

As a result, the annual report was inaccurate. We performed a reconciliation of all the certified payroll data for fiscal year 2020. DCAMM’s annual report shows a total of 660,790 hours worked for that period, whereas our testing showed a total of 581,897, reflecting an overstatement of 78,893 hours by DCAMM for its construction and design contracts.

Authoritative Guidance

In its Internal Control Guide, issued in September 2007 and updated in June 2015, the Office of the Comptroller of the Commonwealth (CTR) stresses the importance of internal controls and the need for documentation.

The “Documentation” section of the 2007 Internal Control Guide states,

Documentation involves preserving evidence to substantiate a decision, event, transaction, or system. All documentation should be complete, accurate, and recorded timely.

Section 12.01 of the 2015 Internal Control Guide states,

Managers and other staff in key roles should document internal control, all transactions, and other significant events in a manner that allows the documentation to be readily available for examination.

Section A01-02 of the Massachusetts Statewide Records Retention Schedule states,

Annual and Summary Reports records. . . .

Documents the production of annual reports or other summary reports of agency business. Includes background support materials, statistical and other interim reports, unpublished reports, final products, and related correspondence.

A01-02(a):      Annual reports


A01-02(b):      Substantive support documentation for annual reports

Retain 3 years.

A01-02(c):      All other reports, published or unpublished, and substantive support materials

Retain until administrative use ceases. Permission from [the state Records Conservation Board] not required for destruction.

Reasons for Noncompliance

DCAMM lacked policies and procedures that required its staff to perform and retain regular reconciliations of its certified payroll data to ensure that it had the most complete and accurate data for its annual report.


DCAMM should develop policies and procedures that require its staff to perform and retain regular reconciliations of its certified payroll data to ensure completeness and accuracy.

Auditee’s Response

Certified payroll data for the Affirmative Marketing Program Annual Report was based upon a workforce report run on December 7, 2020 (“December 2020 Workforce Report”). The total hours reported in the December 2020 Workforce Report were 660,790 and were correct as of that date. Certified payroll data may be added and amended by the contractor after a report date. Subsequent reports will reflect such additions and amendments. DCAMM provided an updated workforce report to the [Office of the State Auditor] on April 28, 2021 (Doc. No. 84) which reflected 581,897 hours, but that report contained errors due to incorrect parameters. Therefore, DCAMM provided a corrected workforce report run on June 14, 2021 (“June 2021 Workforce Report”) (Doc. No. 100) and backup data (Doc. Nos. 103–106). A “walk-through” of the report and data was conducted with [Office of the State Auditor] staff on June 17, 2021. The total hours reported in the June 2021 Workforce Report, which include all additions and amendments through that date, were 693,338. Subsequent analysis by DCAMM using a special report requested from [the Labor Compliance Program Tracker, or LCPTracker] for this purpose in September of 2021 verified that 28,582 additional hours for [fiscal year] 2020 payrolls were submitted after December 7, 2020, the date the original December 2020 Workforce Report was run. After adjusting for the subsequent additions and amendments; there was a statistically small (1%) difference in expected values between the December 2020 and the September 2021 special report from [LCPTracker] which have been difficult to account for. We are continuing to work with [LCPTracker’s] technical team to address data anomalies going forward.

DCAMM has implemented the recommendation of the [Office of the State Auditor] by creating a detailed guide for quality assurance and generating and archiving backup reports for the [Affirmative Marketing Program] Annual Report. The guide will be provided to all DCAMM staff who participate in the generation of the [Affirmative Marketing Program] Annual Report, and will be regularly reviewed and updated.

Auditor’s Reply

Based on its response, DCAMM is taking measures to address our concerns on this matter.

Date published: February 23, 2022

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