Overview
During the audit period, DESE did not effectively collaborate with the Massachusetts Commission on LGBTQ Youth to fulfill key responsibilities outlined in the MOU between the two agencies, effective September 18, 2013. Specifically, we found the following:
- DESE did not issue the required annual communication to school leaders on creating safe and supportive environments for LGBTQ students.
- DESE did not deliver the required biennial presentation on LGBTQ youth to the Board of Elementary and Secondary Education.
- DESE did not ensure that all school districts received training for the Safe Schools Program for LGBTQ Students (SSP), including some that had requested it.
As a result, school personnel members may not have had the guidance, training, or support needed to create safe and inclusive environments for LGBTQ students, potentially limiting the impact of statewide efforts to address the needs of this population.
The Department of Elementary and Secondary Education did not issue the required annual communication to school leaders on creating safe and supportive environments for LGBTQ students.
DESE did not develop or distribute the required annual communication to school superintendents and principals in calendar year 2023, as outlined in the MOU between it and the Massachusetts Commission on LGBTQ Youth. The last communication before this lapse was issued on February 17, 2022. The annual communication resumed in October 2024.
Without annual communication from DESE, school superintendents and principals may not have current guidance and awareness of resources available to support LGBTQ students. This lack of communication could limit the ability to create safe and supportive school environments for LGBTQ students.
Authoritative Guidance
According to the MOU between DESE and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013,
DESE and the Commission hereby agree that they will:
Section 1. Collaboratively develop an annual communication to school superintendents and principals to encourage schools to be proactive in creating safe school environments and identifying services and resources available to provide support and assistance for LBGT youth.
The Department of Elementary and Secondary Education did not deliver the required biennial presentation on LGBTQ youth to the Board of Elementary and Secondary Education.
DESE did not deliver the biennial presentation on LGBTQ youth to the Board of Elementary and Secondary Education during the audit period, as is required, according to the MOU between the two agencies. The most recent biennial presentation was delivered in April 2024 (after the end of the audit period), with the prior presentation occurring on June 27, 2017.
If DESE does not deliver this presentation to the Board of Elementary and Secondary Education, then trustees may lack current information and an awareness of the needs of LGBTQ youth. This lack may hinder informed decision-making, limit the board’s ability to advocate for necessary resources, and reduce the effectiveness of policies aimed at improving the safety and well-being of LGBTQ students in Massachusetts schools.
Authoritative Guidance
According to the MOU between DESE and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013,
DESE and the Commission hereby agree that they will: . . .
Section 2. Jointly develop and deliver a presentation on LGBT youth to the Board of Elementary and Secondary Education at least every 24 months that will include information such as the [Massachusetts] Youth Risk Behavior Survey data and our collaborative efforts through this Memorandum of Understanding (“MOU”).
The Department of Elementary and Secondary Education did not ensure that all school districts received training for the Safe Schools Program for LGBTQ Students, including some that had requested it.
During the audit period, only 146 (37%) of the 397 school districts in Massachusetts received SSP training. The remaining 251 (63%) school districts did not receive any SSP training. Among those school districts that did not receive training, we found the following:
- that 34 (14%) school districts actively requested SSP training but did not receive it and
- that 217 (87%) school districts neither requested nor received SSP training.
If DESE does not ensure that all school districts receive training for the SSP program, then school personnel members may not receive the necessary knowledge and tools to support LGBTQ students effectively. This may contribute to uneven implementation of inclusive practices across school districts and may hinder efforts to ensure safe and supportive school environments for all students.
Authoritative Guidance
According to the Massachusetts Commission on LGBTQ Youth’s Report & Recommendations for Fiscal Year 2022 (as well as the same report for fiscal year 2023),
The goals of the Safe Schools Program for LGBTQ Students are to:
- Increase the capacity of DESE and its units to better support LGBTQ students and inform policies impacting LGBTQ students;
- Increase knowledge, develop empathy and build skills of school personnel, student leaders, Gender and Sexuality Alliances (GSAs), and community members;
- Support the social and emotional well-being of LGBTQ students;
- Create and sustain safe and supportive school environments for LGBTQ students;
- Support parents, guardians, families, and community members;
- Provide leadership development and networking opportunities for students; and
- Reduce health disparities for LGBTQ students.
As part of its Report & Recommendations for Fiscal Year 2022 (as well as the same report for fiscal year 2023), the Massachusetts Commission on LGBTQ Youth recommended that it and DESE collaborate to strengthen both (1) their own internal and (2) school district–level capacity for training and professional development regarding issues specifically concerning LGBTQ youth.
Reasons for Issue
According to DESE officials, during the latter part of the audit period, the SSP experienced significant personnel transitions, which included the departure of four full-time personnel members, which included key program leadership. This turnover substantially reduced program capacity at a critical time for follow-up activities and coordination of training efforts. DESE officials identified these personnel changes as the primary cause of several issues that arose during the audit period, including (1) the lapse in issuing the 2023 annual communication to school leaders on creating safe and supportive environments for LGBTQ students and (2) the nondelivery of the biennial presentation on LGBTQ youth to the Board of Elementary and Secondary Education. After the previous program director left (which happened early in the audit period), a new program director was not onboarded until August 2023, shortly after the conclusion of the audit period, further impacting the program’s inability to meet its obligations in a timely manner.
In addition, DESE did not develop, document, or implement monitoring controls to ensure that requirements outlined in the MOU between it and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013, were consistently met. For example, DESE was unable to provide documentation, such as agendas, minutes, attendance records, or any other records, to demonstrate that quarterly joint meetings between senior DESE and Massachusetts Commission on LGBTQ Youth personnel members, required under the MOU, had occurred during the audit period.
According to DESE officials, several factors contributed to the inability to deliver training to school districts that had requested it. In some cases, leaders from school districts or schools expressed initial interest, but DESE was unable to finalize the training due to shifting priorities, scheduling conflicts, or leadership changes. Additionally, although in-person learning resumed statewide in spring 2021 (after having switched to remote or hybrid learning models, due to the COVID-19 pandemic), many school districts continued to limit in-person gatherings well into the 2021–2022 school year due to ongoing COVID-19 precautions, which disrupted training logistics.
DESE officials stated that leaders from school districts and schools often face competing professional development priorities and may engage only when responding to a specific issue, local concern, or request for technical assistance. Some school districts may use alternative resources for LGBTQ-related training, such as regional collaboratives or internal efforts concerning diversity, equity, and inclusiveness issues, while others may not prioritize such training in the absence of visible advocacy or incidents, which is why proactive outreach concerning these trainings is so important for DESE to oversee.
Recommendations
- DESE should develop, document, and implement monitoring controls to ensure that all key deliverables outlined in the MOU between it and the Massachusetts Commission on LGBTQ Youth, effective September 18, 2013, (such as the annual communication to school leaders on creating safe and supportive environments for LGBTQ students and the biennial presentation on LGBTQ youth to the Board of Elementary and Secondary Education) are completed.
- DESE should oversee school districts’ proactive outreach concerning LGBTQ-related training and collaborate with the Massachusetts Commission on LGBTQ Youth to enhance awareness of SSP training and its value across school districts.
- DESE should assess current barriers to SSP training delivery and explore ways to reach more school districts, particularly those that have expressed interest but have not received training.
- DESE should maintain comprehensive documentation for all quarterly joint meetings with the Massachusetts Commission on LGBTQ Youth, including agendas, minutes, and attendance records, to better track and monitor progress on issues identified in this report and other areas needing improvement.
Auditee’s Response
DESE remains focused on ensuring that all school communities have access to high-quality training and resources that foster safe, supportive, and inclusive environments for LGBTQ students. DESE appreciates the Auditor’s review and recommendations related to the Safe Schools Program for LGBTQ Students (SSP). . . .
DESE recognizes that during the audit period, there were instances where districts that expressed interest in SSP training did not ultimately receive it. While staffing transitions and the COVID-19 pandemic created challenges, DESE acknowledges the importance of strengthening systems for following up on training requests, holding joint meetings with the Massachusetts Commission on LGBTQ Youth (Commission), and issuing annual communications. These are key components of DESE’s work, and DESE is working to enhance our consistency in these areas.
DESE agrees on the importance of ensuring that key deliverables outlined in the MOU with the Commission are completed consistently. Moving forward, DESE will develop and document internal processes to monitor and track completion of these deliverables, including the annual communication to school leaders and the biennial presentation to the Board of Elementary and Secondary Education. DESE sent the communication in 2022 and resumed the annual communication in October 2024. DESE plans to issue a communication for the 2025-26 school year, consistent with the terms of the MOU. The most recent biennial presentation was in April 2024.
With respect to training, DESE does not have oversight authority to require school districts to proactively offer LGBTQ-related training, but DESE recognizes its leadership role in promoting safe and supportive school environments. DESE will continue to collaborate closely with the Commission to improve outreach efforts and ensure districts understand the value of SSP training. DESE will also explore additional strategies to elevate awareness of available training opportunities among district and school leaders.
DESE acknowledges the need to understand and address barriers that may prevent districts from accessing SSP training. The agency will work with the Commission to evaluate factors contributing to these challenges and explore opportunities to reach more school districts, with particular attention to those that have expressed interest but have not yet participated in training.
With respect to documentation, DESE supports maintaining documentation of the quarterly joint meetings with the Commission called for in the MOU to improve continuity and accountability. DESE will implement practices to ensure that meeting records are prepared, retained, and used as a tool for tracking progress on shared priorities. DESE is committed to improving communication, consistency, and access to support.
Auditor’s Reply
Based on its response, DESE is taking measures to address our concerns regarding this matter. As part of our post-audit review process, we will follow up on this matter in approximately six months.
See Appendix B for more information on program improvements that DESE made and reported to us.
| Date published: | August 26, 2025 |
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