Massachusetts Life Sciences Center - Finding 1

The Massachusetts Life Sciences Center Did Not Ensure That All Interns Who Participated in the High School Apprenticeship Challenge Were Eligible To Do So.

Overview

The Massachusetts Life Sciences Center (MLSC) did not ensure that all interns met the eligibility criteria for the High School Apprenticeship Challenge (HSAC). During our testing, we found that 2 interns out of the 40 interns tested (5%) were students who did not meet any of MLSC’s eligibility criteria (see the “Authoritative Guidance” section below for more information).

Despite MLSC’s discovery that two ineligible students were part of the program, MLSC still fulfilled the agreements with the host organizations and provided reimbursement for the cost of these two students’ internships.

The HSAC exists to fund paid internships for underrepresented and low-income high school students in Massachusetts. The eligibility criteria set by MLSC are meant to ensure that only underrepresented and low-income students participate in the HSAC program. Without uniform enforcement of these requirements, students who do not meet the criteria (and therefore are not likely to be part of the population of underrepresented and low-income high school students) can benefit from the HSAC program. This consumes resources that are dedicated to the students this program is intended to serve, potentially displacing eligible students in order to serve ineligible ones. 

Authoritative Guidance

MLSC’s eligibility requirements state the following:

• [The following regards the intern:] Enrolled in or have recently graduated from a school that meets at least one of the following descriptions:
  • Vocational technical high school as determined by Chapter 74 of the General Laws of Massachusetts or a comprehensive public high school with a life sciences Chapter 74 program.
  • Public high school (including charter) located in one of the following “Gateway Cities” as determined by Section 3A of Chapter 23A of the General Laws of Massachusetts: Attleboro, Barnstable, Brockton, Chelsea, Chicopee, Everett, Fall River, Fitchburg, Haverhill, Holyoke, Lawrence, Leominster, Lowell, Lynn, Malden, Methuen, New Bedford, Peabody, Pittsfield, Quincy, Revere, Salem, Springfield, Taunton, and Westfield, and Worcester.
  • Public high school (including charter) with a student population of at least 25 percent classified as “low income” by the Massachusetts Department of Elementary and Secondary Education. . . .

OR

• Enrolled in the [Metropolitan Council for Educational Opportunity] program.

Reasons for Issue

According to MLSC management, the host organizations hired ineligible interns through their own independent outreach and application processes, and submitted the intern information to MLSC for reimbursement after the internships were completed or nearly completed.³⁴ MLSC, upon reviewing the submitted information and learning that these interns were ineligible for the HSAC program only after the internships were completed or nearly completed, elected to reimburse the host organizations.

Recommendations

1. MLSC should ensure that all students apply through the centralized MLSC Application system.
2. MLSC should ensure that students are sufficiently screened for eligibility before being allowed to participate in an internship through the HSAC program. 

Auditee’s Response

1. Beginning in 2024, MLSC requires that all interns complete an MLSC application regardless of host organization or recruitment method. MLSC staff reviews applications and confirms applicant eligibility prior to Agreement execution and disbursement of funds.
2. As stated above, beginning in 2024 MLSC requires that all interns complete an MLSC application for screening and eligibility review by MLSC staff before HSAC program participation.

Auditor’s Reply

Based on its response, MLSC has taken 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.

34.    During the audit period, and especially earlier in the audit period, host organizations had much greater freedom to perform their own independent outreach when selecting students for internships. As a result, host organizations would, according to MLSC management, sometimes adopt their own application processes for selecting interns. This was the case with the two identified interns in the finding. Because of these independent outreach and application processes, some host organizations were unaware of the requirements students had to meet in order to be admitted into the HSAC program.

Date published:	June 12, 2025