Overview
RCC did not have the Sex Offender Registry Board (SORB) conduct Sex Offender Registry Information (SORI) checks for 13 of the 19 RLTAC employees we selected for inspection who should have had such checks. Two of these employees were hired before the audit period. (The issue of not conducting SORI checks was also discussed in our prior report.) The other 11 were hired during the audit period.
This issue may increase the risk that RLTAC employees with sex offender records could have unsupervised contact with children, elderly people, or people with disabilities at RLTAC. Additionally, RCC is not compliant with its internal policy regarding SORI checks.
Authoritative Guidance
The HR “CORI/SORI Policy” from RCC’s website states,
Students and employees participating in an academic, community or clinical program that involves the potential for unsupervised contact with children, the disabled, or the elderly, are required to undergo a Criminal Offender Record Information (CORI) check and/or a Sex Offender Registry Information (SORI) check. Students found to have certain criminal convictions or pending criminal actions will be presumed ineligible to participate in such activities. Applicants with CORI and/or SORI records may be denied college employment under certain circumstances. The College’s access to CORI and SORI records is authorized by the Commonwealth’s Criminal History Systems Board pursuant to Massachusetts General Laws, and regulations issued by the Executive Office of Health and Human Services.
Reasons for Issue
RCC officials told us the former RCC HR staff member who was in charge of this task could not explain why these 13 SORI checks had not been conducted. However, a possible cause for this issue is the staff turnover that occurred during fiscal years 2018 and 2019, which included the HR assistant director who was in charge of submitting SORI checks.
Recommendation
RCC should ensure that SORI checks are conducted for all RLTAC employees and for all newly hired RLTAC employees from now on.
Auditee’s Response
It is College policy that all new RCC employees have both CORI and SORI checks completed as part of the conditions of hire. While the College acknowledges that the previous HR staff were not consistent in processing SORI checks on an annual basis for returning RLTAC event staff, once alerted to the issue, the College asked SORB to run SORI checks on all the event staff who were missing those checks at hire. Although this was after the fact, all staff came back with clean SORI checks.
The current RCC HR staff is aware of the requirement to run SORI checks on all new hires, regardless of if individuals are long-term temporary staff returning for each event season or new to the College.
Auditor’s Reply
Based on its response, RCC is taking measures to address our concerns on this matter.
Auditee’s Response—General Comments
RCC provided general responses along with its comments on the audit findings. Specifically, it indicated that it had worked to address the issues identified in OSA’s prior audit of RLTAC (No. 2012-0204-3S). It indicated that it had uncovered additional problems with RLTAC’s operation and turned these problems over to the state Attorney General and Inspector General.
Additionally, RCC stated,
RCC’s president, directed and assisted by the Board of Trustees, has addressed these matters as knowledge of the issues, time, and resources have allowed. The timing of this audit occurred when the College was taking corrective actions, making necessary staff changes, and working within systems to negotiate changes. In addition, the College experienced a flood due to a weather-related burst pipe in its administrative building in January of 2018. As a result, college documents were packed and stored to preserve them from water damage, sometimes in an unsystematic manner, by staff members no longer employed by the College. The repairs to the building were only completed this spring and staff began to move back into these spaces in May 2021. The College continues to return stored documents to the correct offices.
Last, RCC has been severely impacted by staff turnover in the areas key to this audit. Senior administrators including the Vice President of Finance, the Comptroller, the Payroll Manager, the Executive Director of HR, the Vice President of Instruction, and the Dean of Students have left the College, often without notice or proper transition. Additionally, several support staff in all of these areas have resigned, retired, or have become ill and are on extended sick leaves. While the College has hired new staff and has made every effort to identify documents needed by the audit team, the flood and staff turnover caused challenges in accessing the documents needed by the auditing team.
| Date published: | October 28, 2021 |
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