Office of the Child Advocate - Finding 4

The Office of the Child Advocate Did Not Have Evidence That Some Deliverables From Its Interdepartmental Service Agreements Were Completed.

Overview

OCA was responsible for funding, creating, and monitoring a total of 39 contract deliverables outlined in seven interdepartmental service agreements (ISAs), which were created to fulfill OCA’s enacted budgetary language for fiscal years 2020, 2021, and 2022. However, OCA was unable to provide evidence that 11 out of the 39 deliverables outlined in its ISAs with the University of Massachusetts (UMass) Chan Medical School and the UMass Boston Behavioral Health Integrated Resources for Children (BIRCh) Project were completed.

The following table summarizes the four ISAs and the 11 deliverables that were missing evidence of completion.

Fiscal Year	Project Name (ISA identification Number)	Missing Evidence of Completing ISA Deliverables
2022	Transition Age Youth (TAY) Roadmap (FY20UMASSPPHS009TAY9)	Evidence for creating a task force to lead recommendations for TAY cross-agency collaboration and practices
2022	Trainings for Paraprofessionals and Mentors (ISAOCAK12BIRCHUMB22A)	Evidence of collaboration with one or two school districts to implement a pilot program of training with paraprofessionals
2022	Center on Child Wellbeing and Trauma (CCWT) (ISAOCAMMDCS016UMS22A)	Evidence for facilitating bimonthly (every other month) meetings on cross-agency collaboration and practice Evidence of developing implementation materials Evidence for developing a finance sustainability strategy
2022	Trauma and Resilience (ISAOCA4PPHS022UMS21A)	Evidence for disseminating findings from the previous phase of the Worcester Trauma and Resilience Collaborative (WTRC) project Evidence for developing an implementation plan for the next phase of the WTRC project Evidence of guidelines for communicating to key stakeholders Evidence for developing a dissemination strategy for training materials Evidence for developing a financing sustainability strategy for ongoing trauma work Evidence for completing additional work on racial trauma trainings

If OCA does not receive all deliverables outlined in the ISAs that it funds, then there is a potential waste of taxpayer dollars that could be used to provide other OCA services or fund other ISA projects.

Authoritative Guidance

The OCA’s enacted budgetary language for fiscal years 2020 through 2022 state that OCA was responsible for the following:

• ensuring effective cross-agency coordination of early childhood and school-aged student wellness efforts (fiscal years 2020, 2021, and 2022);
• establishing and overseeing the WTRC (fiscal years 2020, 2021, and 2022);
• expending the housing pilot program for TAY (fiscal years 2021 and 2022); and
• establishing a state CCWT (fiscal year 2022).

See Appendix A for more details on OCA’s enacted budgetary responsibilities.

In addition, the six ISAs that OCA monitored for fiscal year 2022 included the deliverables in the table below.

Fiscal Year	Project Name (ISA Identification Number)	Summary of ISA
2022	TAY Roadmap (FY20UMASSPPHS009TAY9)	UMass Chan Medical School was responsible for implementing a roadmap for TAY, which consisted of collaborating with other agencies involved in TAY work and creating an implementation plan.
2022	TAY Pilot Evaluation (ISAOCA4PPHS024UMS21A)	UMass Chan Medical School was responsible for conducting focus group interviews, training pilot providers on data collection, and submitting various interim pilot reports.
2022	TAY Pilot Expansion (ISAOCATAYPILOTEHS22A)	The Executive Office of Health and Human Services contracted with youth services providers to offer youths a number of different state services, including access to emergency housing, case management services, and referrals to health services and employment support.
2022	Trainings for Paraprofessionals and Mentors (ISAOCAK12BIRCHUMB22A)	The UMass Boston BIRCh Project was responsible for supporting OCA’s cross-agency collaboration effort that focuses on supporting students’ wellbeing following the COVID-19 pandemic. Deliverables include reaching out to community agencies and school districts to share the 10-module training curriculum and collaborating with school districts to implement a pilot of live training and coaching with paraprofessionals.
2022	CCWT (ISAOCAMMDCS016UMS22A)	UMass Chan Medical School was responsible for developing and implementing CCWT. Key deliverables included leading a stakeholder engagement meeting, creating a project plan and logical model, hiring staff members, conducting outreach activities in Worcester, and launching an official website for the center.
2022	Trauma and Resilience (ISAOCA4PPHS022UMS21A)	UMass Chan Medical School was responsible for launching the next phase of the WTRC. Key deliverables included developing an implementation plan, sharing trauma and equity training materials with Worcester Public Schools, and evaluating the impact of the training.

See Appendix B for more details on the ISA deliverables that OCA monitored.

Reasons for Condition

For the fiscal year 2022 TAY Roadmap program with UMass Chan Medical School, OCA explained in an email on October 5, 2022 that the agency had to shift the focus from creating a task force to creating an emergency response for Department of Children and Families youths who have recently left the Department of Children and Families’ foster care voluntarily and who were at risk of homelessness because of the COVID-19 pandemic. In addition, OCA told us in an email on July 11, 2023 that it verbally agreed to changes with UMass Chan Medical School during check-in meetings.

For the fiscal year 2022 Trainings for Paraprofessionals and Mentors program with the UMass Boston BIRCh Project, OCA told us in an email on October 5, 2022 that the UMass Boston BIRCh Project did conduct an initial outreach with school districts but later found that, “due to school bandwidth challenges, this was not possible to implement” in the fiscal year 2022. As a result, OCA verbally approved the change of the ISA deliverable to create “outreach strategies designed to push potential users toward our online offerings. . . . The ISA was not amended to reflect the oral direction given.”

For the fiscal year 2022 CCWT program with UMass Chan Medical School, OCA decided it was no longer necessary to hold cross-agency meetings every other month. OCA also did not require UMass Chan Medical School to prepare a sustainability strategy for financing CCWT’s operations, as required in the ISA. According to an email OCA sent us on September 5, 2023, the Legislature provided OCA with sufficient funding for CCTW, so financial sustainability planning was no longer needed. OCA informed us that it amended the ISA deliverables with UMass Chan Medical School verbally. However, OCA did not provide us with evidence that these verbal amendments occurred.

For the fiscal year 2022 Trauma and Resilience program with UMass Chan Medical School, OCA told us in an email on November 2, 2022 that it did not require UMass Chan Medical School to create a formal implementation plan for the WTRC in fiscal year 2021 because OCA expected that the direction of the project may change frequently. Instead, OCA’s director of strategic initiatives approved each WTRC stage through phone calls and emails. OCA and UMass Chan Medical School amended the ISA verbally and did not document those changes. Furthermore, OCA explained that it did not have written policies and procedures for communicating with and reporting to key stakeholders. OCA told us the following in an email on October 18, 2022:

Meetings are regularly scheduled with government stakeholders and many of the advocacy groups [and] trade associations. Since many of these stakeholders also sit on the various boards, task forces, and commissions run by the OCA, there is very frequent communication.

Recommendations

1. OCA should document all information regarding OCA deliverables, including any amendments to previously established ISAs.
2. 2.    OCA should develop, document, and implement policies and procedures to monitor the progress of ISA deliverables.

Auditee’s Response

The OCA acknowledges and appreciates this finding. With regards to the specific ISAs reviewed under this audit, the OCA is confident that the Commonwealth received sufficient and appropriate deliverables from each ISA to achieve the overall project goals because we managed each of these contracts very closely, holding regular project planning and deliverable review meetings with each contractor. We acknowledge, however, that amendments of deliverables in an Interdepartmental Service Agreement (ISA) should be documented in writing rather than solely discussed verbally with the project team. We are in the process of developing written policies and procedures regarding the creation, amendment, and closing of ISAs. These policies and procedures are to include, at minimum, expectations for appropriate documentation of 1) time frames of the agreement, 2) financial obligations of each agency, 3) buyer responsibilities, seller responsibilities, and joint responsibilities, and 4) Identification of the person(s) accountable for the execution of the ISA for both agencies. These policies and procedures will be written in accordance with Comptroller policy and relevant Commonwealth regulations.

Auditor’s Reply

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

Date published:	October 7, 2024