Overview
SCSD did not ensure that all vocational instructors met or were working toward the certifications required by the Commonwealth’s Department of Elementary and Secondary Education. Specifically, 6 (60%) out of the 10 vocational program instructors employed by SCSD did not have or were not working toward the required Voc Tech Teacher license required for courses they instructed.
By not ensuring that its vocational instructors have the required certifications to instruct their respective courses, SCSD may not be in compliance with state regulation. Additionally, this potentially impacts the ability of SCSD’s sentenced inmates enrolled in these courses seeking to gain employment and maintain jobs in these fields after their reentry. Additionally, inmates may face a higher risk of accidents or injuries if their instructors are not fully trained in the proper procedures for vocational education.
Authoritative Guidance
According to 103 CMR 936.02(3),
The county correctional facility shall ensure that all academic and vocational education personnel meet certification requirements as stipulated by the Commonwealth’s [Department of Elementary and Secondary Education] or are working toward said certification.
Reasons for Issue
SCSD officials stated that they consider work experience the most important qualifying measures for vocational instructors. We note that these certifications are required by state regulation, which SCSD is required to follow.
Recommendation
SCSD should establish policies and procedures, including monitoring controls, to ensure that all SCSD educational and vocational instructors have or are working toward certifications required by the Commonwealth’s Department of Elementary and Secondary Education for the respective courses that they teach.
Auditee’s Response
In an effort to cultivate a diverse workforce the department is in agreement with the governor’s executive order that a skills based hiring process is appropriate at this time. The department focuses primarily on an applicant’s skills, knowledge, and abilities rather than educational credentials alone.
The department’s vocational programing is set up as a pre apprenticeship type program and as such the department finds that applicants/employees with the appropriate work history and skills would be able to instruct such programs. However, the department ensures that a properly trained and certified person is instructing any course or course section where a student may receive a state or federally recognized certification such ServeSafe, OSHA [which stands for Occupational Safety and Health Administration] 10, and [the Occupational Safety and Health Administration’s OSHA] 30 certifications.
Auditor’s Reply
SCSD cites the Governor’s Executive Order 627, which focuses on the skills and abilities of applicants. However, we are auditing to the standards set forth in 103 CMR 936.02(3), which requires “all academic and vocational education personnel [to] meet certification requirements as stipulated by the Commonwealth’s [Department of Elementary and Secondary Education].”
While ensuring that the skills and abilities of applicants are prioritized is a noble goal, and makes absolute sense, it does not nullify the existing state regulation that stipulates certain requirements must still be met in order to provide education and training in these instances. If SCSD believes the current regulation conflicts with its ability to prioritize factors put forth in Executive Order 627, SCSD should contact the Governor and the Legislature to address its concerns and highlight its stated challenges.
| Date published: | December 24, 2025 |
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