Overview
For the period January 1, 2021 through December 31, 2021, MCSW did not consistently track the completion of Conflict of Interest Law training requirements.
For the period January 1, 2022 through December 31, 2023, MCSW could not provide the required Conflict of Interest Law training certificates for 5 out of 20 MCSW commissioners sampled. Of the 15 commissioners who provided the certificates of completion, 10 did not complete them within the required 30 days of qualifying for office.
Without completing the training, commissioners could inadvertently commit ethical violations, potentially negatively impacting the reputation and effectiveness of MCSW.
Authoritative Guidance
Section 28 of Chapter 268A of the General Laws states, “Every state, county, and municipal employee shall, within 30 days after becoming such an employee, and every 2 years thereafter, complete the online training program.”
Reasons for Issue
MCSW told us that the issue was because of the commissioners’ oversight in providing the Conflict of Interest Law training certificates. MCSW did not have internal controls to ensure that newly appointed and reappointed commissioners completed training in the required time frame and submitted the evidence of completion to them.
Recommendation
MCSW should implement monitoring controls to ensure that it adheres to its policies and procedures and complies with the Conflict of Interest Law training requirements.
Auditee’s Response
MCSW has transitioned Conflict of Interest (COI) Training & Tracking to the new State Ethics Learning Platform . . . necessitating an update to the MCSW Ethics Training Policy. This policy now directs new and reappointed commissioners to the State Ethics Online portal to complete their COI requirements. Commissioners receive a welcome letter at the time of appointment and reappointment outlining next steps, including getting sworn in and completing ethics training for open meeting law and conflict of interest. In June 2024, MCSW received and approved a revised Policy Manual, which includes the Ethics Training Policy, and requested commissioners sign a receipt of the revised manual. Completion of these requirements is now tracked on the State Ethics Online Training Platform by MCSW staff and reviewed regularly.
Auditor’s Reply
Based on its response, MCSW 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.
| Date published: | December 27, 2024 |
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