Massachusetts State Lottery Commission - Finding 5

The Lottery did not maintain an accurate record of the suspension history of its sales agents, affecting the evaluation, monitoring, and potential future enforcement of any violations by those agents.

Overview

The Lottery did not always maintain an accurate record of the suspension history of its sales agents. Specifically, we found that the Lottery recorded incorrect reason codes for violations for 9 of the 20 sampled sales agents. Furthermore, for 2 of these sales agents, the Lottery did not record any comments on the sales agents’ records in the central gaming system. Additionally, the Lottery suspended 1 sales agent for a different suspension (as documented in the central gaming system) than what was communicated in its suspension implementation letter to the sales agent.

If the Lottery fails to maintain accurate records of its sales agents’ suspension histories, it may struggle to effectively evaluate or monitor any violations by those agents who have suspensions. This lack of reliable information hinders the Lottery’s ability to assess the overall number and severity of violations associated with each sales agent. Consequently, the Lottery may make incorrect decisions because it is missing crucial information that could impact the public, such as a licensed sales agent continuing to operate despite being barred from selling lottery products. These inaccuracies could also lead to inappropriate future enforcement against sales agents whose first violation is thought to be a repeat violation, or whose repeat violation is thought to be their first of that kind. 

Authoritative Guidance

According to Section 5.3 of the Lottery’s “Licensing Department Procedures,”

  • The licensing representative will change the agent's status to Inactive with the appropriate reason code in the [central gaming system] on Day 1 of the suspension and add a comment to the Agent's record.
  • The Licensing representative will change the agent's status to Active in the [central gaming system] on the final day of the suspension.

Reasons for Issue

The Lottery’s “Licensing Department Procedures” do not have specific instructions, such as providing clear guidance on which reason code applies to which suspension type and what information should be included in the comments.

Recommendations

  1. The Lottery should consistently review and update its “Licensing Department Procedures” to include details about assigning appropriate reason codes and comments to its suspended sales agents’ files within the central gaming system.
  2. The Lottery should implement a review process to ensure that the appropriate reason codes, comments, and suspension periods are documented in its central gaming system when suspending its sales agents. 

Auditee’s Response

  • In July 2025, the Lottery’s Licensing procedure was updated to incorporate an enhanced process for handling DOR suspensions. The updated process includes explicit instructions for entering the suspension dates and reason codes into the Lottery’s [central gaming] system. Additionally, an email communication has been incorporated into the Lottery’s process to enable affected [Massachusetts State Lottery Commission] departments to review suspension details for accuracy in a more efficient and effective manner. 

Auditor’s Reply

We commend the Lottery’s efforts to update its “Licensing Department Procedures” to improve data entry, accuracy, and communication related to the suspension of sales agents. Based on its response, the Lottery is taking measures to address our concerns in this area. We will review progress on this issue as part of our post-audit review process in approximately six months.

Date published: November 26, 2025

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