Overview
EEC did not ensure that funded programs submitted corrective action plans within 14 days of EEC identifying noncompliance with EEC Essentials training. (See the "EEC Essentials Training for Funded Programs” section of this report for more information.) Specifically, 26 (52%) of the 50 programs did not address their noncompliance in a timely manner. Untimely corrective action plan submissions ranged from 2 days to 121 days beyond the 14-day requirement, with an average of 54 days. We identified the following issues with these 26 programs:
- Twenty-two (85%) of the programs did not address EEC Essentials training noncompliance in a timely manner;
- Two (8%) of the programs did not address EEC Essentials training noncompliance in a timely manner for only one of the two years identified as noncompliant; and
- Two (8%) of the programs did not address EEC Essentials training noncompliance in a timely manner for both years identified as noncompliant.19
Additionally, EEC accepted corrective action plans from funded programs without requiring evidence that EEC Essentials training was completed.
The absence of EEC enforcement in requiring corrective action plans in a timely manner, and EEC’s acceptance of corrected plans without evidence that the training had actually been completed, may compromise the effectiveness of EEC Essentials training. This may lead to ongoing noncompliance, potentially endangering children in EEC care.
Authoritative Guidance
The EEC Essentials Training Requirements and Applicability Policy, effective October 1, 2019, states,
Individuals working with children in Funded Programs are required to be trained in . . . EEC Essentials topics. . . .
Failure to complete all required EEC Essentials trainings in accordance with this policy may result in . . . [the program being] required to complete and submit to [EEC] a corrective action plan within 14 days documenting the program’s plan to come into compliance with the EEC Essentials training requirements.
We believe it is a best practice to require evidence, such as verifiable and credible sources, when a funded program submits a corrective action plan and to ensure that the information provided is accurate, reliable, and traceable to its origin.
Reasons for Noncompliance
EEC told us that the delays in submitting corrective action plans were primarily because of programs reopening after the COVID-19 lockdown, which required time for schools to onboard staff members and complete initial planning. Additionally, EEC told us that for funded programs closed during the summer break, programs did not provide responses to the corrective action plan until they reopened at the beginning of the school year.
Recommendations
- EEC should develop policies for funded programs to follow during and after a state of emergency.
- Because individuals working in funded programs can complete the training online, EEC should ensure that programs follow the 14-day requirements during a state of emergency and under normal conditions.
Auditee’s Response
EEC recognizes the importance of corrective action plans for noncompliant funded programs.
During the COVID-19 pandemic, EEC granted funded programs extensions on a case-by-case basis to respond to corrective action plans due to the complexities of operating funded programs within school settings during the public health emergency.
Due to the COVID-19 pandemic, the Governor issued an Emergency Order closing all schools in Massachusetts on March 24, 2020. Schools returned to in-person learning between April and June 2021. Delays in responding to corrective action plans were predominately due to the reopening of programs, where EEC provided schools time to onboard staff and implement processes to prepare schools for reopening. Fifteen (15) visits occurred during March, April and May 2021. Ten (10) visits occurred in June 2021 and two (2) visits occurred in July 2021.
After the 14-day period lapsed, EEC, through LEAD, continued to send reminder emails to notify the funded programs that their responses were late. Funded programs are closed for the summer months. Typically, programs provide a response to the corrective action plan when the program reopens at the beginning of the school year. No corrective action plans are missing, and all trainings were completed.
Additionally, during the audit period, funded programs had monitors to ensure compliance with corrective action plans. In March 2024, EEC licensing staff was trained on working with funded programs and EEC now manages this task.
Auditor’s Reply
EEC states the COVID-19 pandemic and the associated school closures presented significant challenges for both EEC and the programs it oversees However, the audit period spanned from January 1, 2021, through December 31, 2022. While schools began returning to in-person learning between April and June 2021, the delay in submitting corrective action plans persisted well beyond this period. This indicates that, despite the initial reopening phase, substantial delays continued throughout the audit period.
EEC’s response references specific visits and dates during which these visits occurred. However, our finding focused on the timeliness of corrective action plan submissions and the lack of required evidence of training completion, not on the timing or frequency of site visits. Further, a corrective action plan is only required after EEC conducts a site visit and identifies a program’s noncompliance with EEC Essentials training. Thus, EEC was able to conduct site visits for the exceptions we identified, and these site visits are not in dispute. While citing these visits may provide context, EEC does not address the core issues identified in our exceptions.
EEC further states that after the 14-day period lapsed, it continued to send reminder emails to notify funded programs that their responses were late. The effectiveness of these reminders is questionable given the extent and frequency of the delays we observed.
Finally, our finding also highlights that EEC accepted corrective action plans without requiring evidence that the EEC Essentials training was completed. We believe it is a best practice to require verifiable evidence—such as completion certificates or training logs—when a funded program submits a corrective action plan. Accepting plans without such evidence compromises the effectiveness of the training program and could potentially endanger children in EEC care due to unaddressed noncompliance.
| Date published: | November 25, 2024 |
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