Overview
The Massachusetts Cultural Council (MCC) did not ensure that local cultural councils (LCCs) complied with the annual reporting requirements outlined in MCC’s “Local Cultural Council Program Guidelines.” According to the guidelines, LCCs must submit their annual reports (which include priorities and guidelines) by August 31, their grant financial reports by October 17, and their annual reports by January 17 of each year.
For the audit period, we selected a random, nonstatistical sample of 35 out of the 329 LCCs, and we found instances where LCCs did not comply with the guidelines. The table below shows the number of LCCs that were late submitting their reports during fiscal years 2023 and 2024.
| Reports | Fiscal Year 2023 | Fiscal Year 2024 |
|---|---|---|
| Number of LCCs late in submitting their priorities and guidelines by August 31 (out of a total sample of 35 for each fiscal year) | 31 (89%) | 1 (3%) |
| Number of LCCs late in submitting their grant financial report by October 17 (out of a total sample of 35 for each fiscal year) | 21 (60%) | 20 (57%) |
| Number of LCCs late in submitting their annual grant decision by January 17 (out of a total sample of 35 for each fiscal year) | 10 (29%) | 12 (34%) |
According to MCC officials, MCC works with LCCs to ensure that the final annual reports are completed by January 17 by providing assistance to LCCs. This assistance includes recruiting and maintaining at least five active members, electing officers, and providing training to LCC members in accurate recordkeeping and their duties as LCC members.
Additionally, we found that MCC disbursed funds to a particular LCC two days before the submission of its annual report. This timing raises concerns about MCC’s oversight of the disbursement of funds, as it had not yet received, and therefore had not yet reviewed, the report before releasing the funding.
If MCC does not ensure that LCCs meet deadlines, it increases the risk of public funds being used for activities not related to arts, humanities, and sciences, which could undermine MCC’s commitment to promoting cultural activities. MCC’s enforcement of its “Local Cultural Council Program Guidelines” is also important to LCCs, because noncompliance of LCCs could put their funding at risk.
MCC’s disbursement of grant funding before the LCC submitted its annual report also may have allowed the LCC to use the grant funding without proper accountability or adherence to the intended financial guidelines.
Authoritative Guidance
According to MCC’s fiscal years 2023 and 2024 “Local Cultural Council Program Guidelines,”
LCC Annual Report. Each year LCCs are required to complete an Annual Report which consists of 3 parts . . .
- Council Priorities & Local Guidelines. . . . Annually, by August 31 LCCs must update their council priorities, guidelines . . .
- Financial Report. . . . The deadline for LCCs to input the information from their LCC Account Form and calculate their amount available for granting is October 17. . . .
- Grant Decisions Report. . . . All LCCs complete and submit their Grant Decision Report, the final component of the Annual Report, to [MCC] through the online grants management system no later than January 17. . . .
Assuring Compliance with Local Cultural Council Duties. The fundamental operations of LCCs are reviewed and approved by [MCC] on an annual basis before funds are released. [MCC] staff will check the following before releasing funds:
- The Annual Report to [MCC] was submitted by the reporting deadline January 17.
- All funds from the current year were granted.
Reasons for Issue
According to MCC officials, the LCC program is operated by volunteers from their communities and must maintain at least five active members, which some LCCs do not always have. LCCs that have fewer than five active members can be delayed in submitting these reports by MCC’s deadlines. Further, MCC stated in a response it sent to our office on August 27, 2025:
Guided by statute [MCC’s] role is to provide guidance, advice, and assistance to LCCs until compliance is achieved, and then to certify grant payments. The statue is clear: the Council’s responsibility is to ensure that program requirements are met and that public funds are used responsibly in every community. The statute emphasizes substantive compliance—verifying that councils have the required membership, financial accountability, public process, and adherence to guidelines—over the rigid enforcement of a single final report deadline.
Regarding the one payment made two days before the LCC submitted its annual report, MCC officials stated that this was due to an administrative error. This administrative error reportedly occurred during the transition from a manual to an electronic signature process in fiscal year 2024.
Recommendations
- MCC should ensure that LCCs comply with annual reporting requirements.
- MCC should consistently assist all LCCs with recruiting and maintaining at least five active members, electing officers, and providing training to LCC members to help with the submission of annual reports until LCCs are at 100% compliance with submission deadlines.
- MCC should ensure that disbursement of funds is made only after LCCs submit their annual reports.
Auditee’s Response
[MCC’s response to our recommendation that MCC should ensure that LCCs comply with annual reporting requirements.] [MCC] ensures 100% of Local Cultural Councils are in full compliance with the program guidelines each year. [MCC] is proud of its record of ensuring every community benefits from the program each year and believes this program thrives through partnership with cities and towns. While the auditor acknowledges that LCCs are volunteer, municipal boards, the suggestion that “compliance with reporting deadlines” is only met if 100% of the 329 LCC to meet all three staggered reporting deadlines each year ignores the reality that there are many factors, outside the control of [MCC] and the Local Cultural Councils that prevent on time submission at each step of the reporting process. [MCC] uses the multistep reporting process to track and support LCCs that are facing challenges and has chosen to work with LCCs until they are in compliance rather than taking a punitive approach of denying funding to those LCCs that are late.
[MCC’s response to our recommendation that MCC should consistently assist all LCCs with recruiting and maintaining at least five active members, electing officers, and providing training to LCC members to help with the submission of annual reports until LCCs are at 100% compliance with the submission deadlines.] [MCC] does and will continue to “consistently assist all LCCs” through compliance and all aspects of the program. [MCC] does this by assigning 6 program officers to LCCs across the state focusing on two fronts, the LCCs themselves, and their municipalities. For LCCs the team offers two monthly newsletters, an online basics training module for all new and current members, 3 to 6 grant cycle webinars a year that provide additional training and information, scheduled outreach around issues based on data in the system focused on the grant cycle but monitored year-round, regular office hours, convenings, site visits, in-person guidelines trainings for new LCCs or LCCs that are having a challenging cycle, thousands of calls/emails to LCC members across the state answering questions an providing guidance. For municipalities the team sends annual emails and reminders to municipal fiscal staff regarding contracting and the financial reporting requirement, has created and promotes a municipal guide and municipal financial officer guide to support local administration of the program, offers webinars and trainings in partnership with Mass Municipal Association to increase the understanding of and support of Local Cultural Councils, and exchanges hundreds of individual calls and emails with municipal staff supporting the reporting and contracting process.
[MCC’s response to our recommendation that MCC should ensure that disbursement of funds is made only after LCCs submit their annual reports.] Since the audit period, LCC Allocation contracts are now completed through e-signature . . . documents. This new system ensures LCCs that are not ready to pay are held out of fiscal’s normal contracting process. These changes should prevent/reduce any instances of payments accidentally being made prior to the completion of the LCCs reporting.
Auditor’s Reply
We acknowledge MCC’s efforts to ensure that all LCCs meet reporting requirements, including implementing the e-signature process and expanding training and support for councils and municipalities. While MCC achieves compliance, we emphasize the importance of meeting reporting deadlines on time to ensure that public funds are not used for activities unrelated to arts, humanities, and sciences. Continued monitoring and targeted assistance of LCCs that consistently face challenges are recommended to achieve full and timely compliance across all councils.
As part of our post-audit review process, we will follow up on this matter in approximately six months.
| Date published: | November 26, 2025 |
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