Overview
The Department of Transitional Assistance (DTA) did not consistently provide Employment Development Plans (EDPs) for participants in the Transitional Aid to Families with Dependent Children (TAFDC) Pathways to Work (PTW) programs. Specifically, out of our random, statistical sample of 60 participants from a population of 27,166 participants enrolled in the TAFDC PTW programs, DTA could not provide us with finalized EDPs for 3 participants between July 1, 2021 and June 30, 2023. We projected the test results from our sample of 60 participants to the total population, and we are 95% confident that DTA did not provide EDPs for at least 285 participants who enrolled in TADFC PTW programs during the audit period.
If DTA does not provide participants with EDPs, then there is a risk that some individuals may be placed in programs that do not meet their needs. This can result in an ineffective use of resources and funding, ultimately undermining the program’s objectives and wasting valuable financial support that could have been directed toward more suitable programs for participants. It is essential for DTA to ensure that participants receive comprehensive and tailored EDPs to optimize their outcomes and effectively use available funding.
Authoritative Guidance
According to Section 707.110(A)(1) of Title 106 of the Code of Massachusetts Regulations (CMR),
An EDP will be completed every year for:
(a) a grantee who the Department determines must participate in an Employment Services Program (ESP) component because there are available component slots;
(b) a grantee who volunteers to participate in ESP;
(c) all teen parents who have not graduated from high school or do not have a [high school equivalent test] certificate;
(d) a grantee needing support services to work or to participate in ESP or in a self-initiated program not funded by ESP as provided in 106 CMR 707.120;
(e) a dependent child 16 or 17 years of age who is not in school and must participate in the ESP Educational Component;
(f) a grantee or an ineligible grantee . . . referred to community service who:
1. volunteers to participate in community service;
2. is mandated to participate in community service because he or she did not meet the participation requirements of another ESP component or
3. needs support services to participate in community service;
(g) a grantee participating in the Full Employment Program; and
(h) any other grantee who the Department determines needs an EDP.
Reasons for Issue
DTA officials stated that its full engagement workers (FEWs) provided EDPs for the three participants we identified during audit testing; however, the finalized EDPs for the participants were not properly stored within the Benefit Eligibility and Control Online Network (BEACON) system.
Recommendations
- DTA should consistently provide EDPs for all TAFDC PTW program participants.
- DTA should ensure that its FEWs follow DTA policies and procedures when developing and maintaining EDPs for participants.
- DTA should implement monitoring controls to ensure that each participant’s file includes all required documents that should be stored within the BEACON system.
Auditee’s Response
DTA agrees with [the Office of the State Auditor’s (OSA’s)] first recommendation that it should consistently provide [Employment Development Plans (EDPs)] for TAFDC PTW participants, because it believes these are a critical component of transitioning clients to self-sufficiency.
. . . Please note EDPs are now referred to as Pathways to Work plans. For the purposes of this response, DTA will refer to them as EDPs because that is how the OSA refers to them in its draft report. . . .
An Employment Development Plan (EDP) is used by DTA staff to document activities that prepare a client to engage in work, creates referrals to employment and training programs, and details the services DTA will provide to support training and transition to work. An EDP is created through interactive dialogue between the client and the caseworker, and reflects their mutual understanding of the best way to transition the client to stable, meaningful employment. While it is highly unlikely that the failure to provide a participant with an EDP would lead to clients being placed in programs that do not fit their needs, DTA agrees that it must provide complete and individualized EDPs to TAFDC PTW participants.
In fact, DTA does provide EDPs to all clients who meet the requirements of 106 CMR 707.110(A)(1), and DTA disputes the OSA finding that it did not always do so. As DTA previously informed OSA, DTA provided EDPs to all sixty of the participants in OSA’s sample. However, for three of the sixty participants sampled, the EDP was not properly stored in the Benefit Eligibility and Control Online Network (BEACON), DTA’s case management system. Accordingly, DTA disagrees with the OSA’s extrapolated finding that DTA did not provide EDPs for at least 285 participants during the audit period.
Specifically with regard to the three participants at issue, the Department had temporary procedures in place for processing EDPs during the COVID-19 public health emergency, which coincided with the audit period. These temporary procedures stipulated a signature was not required on the EDP and the EDP only had to be approved (and stored in BEACON) when enrollment in an activity was confirmed. For two of the EDPs in OSA’s sample, the EDP was created in BEACON but not stored due to case worker confusion about how to complete the EDP when no signature was required. For the third case, the client was not actively enrolled in an activity, so the EDP had been created but not stored in BEACON. While it is unfortunate the three EDPs in OSA’s sample were not stored in BEACON, those EDPs were created and discussed with the client, and DTA thus disputes OSA’s finding that TAFDC PTW participants were not provided with an EDP during the audit period.
With regard to OSA’s second recommendation, DTA agrees it is critical that its FEWs follow DTA policies and procedures when developing and maintaining EDPs. Engagement staff, which includes FEWs and Self Sufficiency Specialists (SSS), are directed to use the Pathways to Work workflow in BEACON to document planning activities, create program referrals, and approve EDPs developed with clients. After an EDP is completed, DTA engagement staff are required to track monthly participation for the duration of the EDP.
DTA requires its engagement staff, including FEWs, to maintain an understanding of all DTA policies and procedures, including those relating to EDPs. FEWs participate in Economic Assistance training and then their on-the-job training in local offices is specific to their role. FEWs have monthly meetings with their supervisors to ask questions and to review new guidance. Supervisors are required to review all FEW case work that results in a major case change in relation to the client’s EDP, and to provide final sign off on FEW cases. If a client is sanctioned for not completing an EDP, the supervisor must complete a comprehensive review of the case and verify all required components. Through this review process of FEW case work supervisors ensure all relevant EDP related procedures are followed, and FEWs are evaluated on this basis.
DTA agrees with OSA’s third recommendation that it must ensure each participant’s file includes all required documents. DTA understands the importance of complete client case files. In order to ensure client case files are complete, DTA programs controls into BEACON. Today, when an EDP is completed, it is automatically printed and mailed to the client and a copy is automatically entered into BEACON where it is viewable by DTA staff. Clients can view their EDP on DTA Connect. DTA is confident that with temporary COVID procedures no longer in place all EDPs are now properly stored in BEACON.
Auditor’s Reply
We acknowledge DTA’s response and its stated commitment to providing complete and individualized EDPs for all TAFDC PTW participants. DTA states that EDPs were created for all 60 sampled participants, and that the absence of three EDPs in the BEACON system was solely due to a storage issue. However, when the audit team requested the EDPs for these three participants, DTA was unable to provide this documentation, regardless of where it was stored. Therefore, we were unable to determine whether these three participants received EDPs as required by the CMR. Our projection of the sample results to the population is consistent with standard audit methodology.
In response to DTA’s temporary COVID-19 procedures, we incorporated them into our audit plan. Throughout the audit period, DTA did not have adequate controls in place to ensure that EDPs were consistently stored, documented, and accessible during the audit period.
We appreciate DTA’s efforts in providing training and supervision and implementing automatic storage and mailing functions in the BEACON system. Based on its response, DTA is taking measures to address our concerns in this area. We will review progress on this matter as part of our post-audit review process in approximately six months.
| Date published: | January 30, 2026 |
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