MEP Did Not Properly Maintain Its Police Dispatch Records.

Audit found there were 1,961 instances in the dispatch records of officers not logging out for work shifts.

Overview

MEP did not ensure that its officers properly maintained their duty information in its dispatch records. Specifically, during our audit period, there were 1,961 instances in the dispatch records of officers not logging out for work shifts even though they had logged in as on duty at least 16.5 hours¹² earlier and were therefore not allowed to work any more hours that day. In more than 130 instances, officers were allowed to remain logged in from 100 hours to 369 hours without logging out or updating their duty status. In addition, although MEP officers are only allowed to start charging overtime when they arrive at their overtime work locations, not during their commutes, MEP never activated the Global Positioning System (GPS) tracking equipment it purchased and placed in each vehicle to ensure compliance with this requirement.

As a result of these issues, MEP cannot effectively track its officers’ vehicle locations or the hours worked by officers who do not properly record their duty information in the dispatch records. It therefore lacks documentation that could be used to substantiate the accuracy of the work hours, including overtime, that officers report on their timesheets.

Authoritative Guidance

Section 4 of MEP’s “IMC System Use” policy, dated March 1, 2018, states,

Officers and communication personnel are required to initiate and enter duty assignments, calls, incidents and arrests. Officers are to enter all information within the respective screen. . . .

4.1 Duty Status/Calls Officers and communications personnel shall:

4.1.1    At the beginning of shift, assign themselves to an on-duty status.

4.1.2    Update duty status by the officer through the course of the shift as needed.

4.1.3    Accurately indicate arrival, cleared status, and disposition of call(s) . . .

4.1.10   At the end of shift, indicate end of duty status.

The same requirement existed in the previous version of the policy, dated June 28, 2014.

In addition, Section 2.6.1 of MEP’s “MEP Overtime” policy states,

Start-time for computing MEP overtime will be from the officer’s arrival at the overtime location (i.e. specific park, forest, waterway, port, event location, city or town).

Reasons for Noncompliance

MEP’s policies and procedures did not include monitoring of officers to ensure that they properly maintained their duty information. MEP officials told us that they could not activate the GPS tracking equipment because the matter was subject to collective bargaining and MEP could not unilaterally activate the equipment.

Recommendation

MEP should enhance its policies and procedures, adding a monitoring component that requires a review of dispatch activity at officers’ homes, regular work locations, and overtime locations.

Auditee’s Response

This audit finding is based on 1,961 instances in which MEP officers may not have logged off the IMC system in a timely fashion. However, the IMC system is not used to pay overtime. The system used to pay overtime is the HR/CMS system. There is no connection between the IMC system and the HR/CMS payroll system. Accordingly, the time an officer is logged as "on duty" in the IMC system does not have any effect on the officer's earnings and the audit team does not suggest that there were any overpayments made as a result of this finding. The audit report also makes reference to the GPS systems installed in officers' cruisers. However, the MEP's agreement with the Union precludes use of GPS to "ensure compliance with [the travel time policy]."

While this finding does not relate to the distribution, authorization or payment of overtime (the objectives of the audit), it does correctly identify some of the symptoms of multiple known IT issues with the IMC system. In particular, network connectivity issues have repeatedly prevented the IMC system from receiving an officer's “log off” transmission. MEP continues to work to improve our IT system and seek to overcome the connectivity challenges associated with being a relatively small force spread across the Commonwealth. To address these IT challenges and strengthen existing procedures, MEP has implemented the following improvements:

• All MEP officers will be directed to review and understand current MEP policy requiring on-duty updates on the IMC system, and supervisors will be directed to monitor habitual non-compliance and take corrective measures as needed;
• Dispatchers have been reminded to monitor officers’ IMC status, and to make inquiries in the event an officer is logged on for extended periods;
• [The Commonwealth’s Executive Office of Energy and Environmental Affairs’ Information Technology Department, or EEA IT] has begun a full assessment of the IMC system to ascertain the reasons for technological glitches, including documentation and monitoring of IMC “crashes.” Recent improvements to the system include a system upgrade in October 2019, which has improved some of the connectivity issues. Further upgrades are planned for the Fall of 2020.
• EEA IT will move the physical infrastructure for the IMC system to [a Massachusetts Executive Office of Public Safety and Security] site in Chelsea in October 2020, which will reduce the amount of system down time.

Auditor’s Reply

IMC CAD is the agency system of record that is used to log officers’ time and attendance throughout their work shifts. Although there may be no direct connection between IMC CAD and HR/CMS, the information in IMC CAD is MEP’s primary source record that can be used to substantiate shift information; the hours, including overtime, worked by officers; and, to the extent possible, officers’ compliance with MEP’s overtime policies. Therefore, it is essential that MEP ensure that the information in IMC CAD is complete and accurate so that the hours that officers report on their timesheets can be independently substantiated. Further, because this is MEP’s source record and is used by its officers to document shift information and, in particular, overtime hours, it was related to OSA’s audit objective of ensuring that environmental police officer (EPO) overtime was authorized and provided in accordance with MEP overtime policy.

It should be noted that the network connectivity issues that MEP says exist in relation to the use of this system appear to be longstanding, as OSA’s testing identified issues with officers not logging out of their shifts as long ago as July 2016. In OSA’s opinion, given the importance of the information in this record, MEP should have attempted to address any issues it identified with this system in a more timely manner.

Based on its response, MEP is taking measures to address our concerns in this area.

12.    According to Article 26 of the unit 5 collective bargaining agreement, “No employee may work more than a total of sixteen and one-half (16.5) hours in any twenty-four (24) hour period. . . . No employee shall receive any compensation for any hours worked in excess of the limits . . . unless such hours of work have been approved, in writing, by the Director.”

Date published:	April 21, 2020