Overview
The Military Division of the Commonwealth (MIL) did not ensure that the data from the Massachusetts National Guard Tuition System was reliable and did not retain adequate source documents for tuition reimbursement. Specifically, we found omissions within the data in the tuition system, multiple approved certificates of eligibility for individual Guard members for a single semester, and missing documentation for reimbursement requests. Further, MIL’s processes for applying for and approving tuition reimbursements appeared to be inconsistent.
During our review, we found omissions within the data in the National Guard Tuition System. Specifically, we discovered 464 records that had been deleted.
Additionally, the National Guard Tuition System allows Guard members to apply for multiple certificates of eligibility for the same semester to add or drop courses; however, the processes to apply for courses and to approve those applications are inconsistent. The following is one example of such a process inconsistency: sometimes, after a certificate was approved, a Guard member would realize that they applied for an incorrect number of credits. Sometimes when this would occur, MIL would instruct the Guard member to apply for a new certificate for only the additional number of credits, then MIL would approve both certificates so that their combined total would end up being the correct number of credits.
Alternatively, MIL would sometimes instruct the Guard member to apply for a new certificate for the total, correct number of credits, and then MIL would approve both certificates so that their combined total would end up being an incorrect number of credits. Specifically, we identified at least 450 occurrences in which MIL approved two certificates for a Guard member for a single semester and at least 30 occurrences in which MIL approved three certificates for a Guard member for a single semester. Certificates were also approved for semesters that had already ended. For example, we noted 19 instances in which MIL approved certificates that were requested during the audit period for semesters that had already ended between fall 2017 and spring 2019. By approving multiple certificates per semester for an individual Guard member, inaccuracies in Guard members’ credit balances occurred. Guard members have a lifetime total maximum benefit of 130 college credits, so inaccurate credit balances could prevent Guard members from using the full benefits to which they are entitled because of their service.
Finally, for 4 of the 50 certificate approvals that we sampled, MIL could not provide source documents, such as approved certificates of eligibility or reimbursement request forms from the state colleges and universities. Also, there were discrepancies between the Massachusetts National Guard Tuition system data and the source documents for 13 of these 50 certificate approvals. For example, we identified approved certificates in the tuition system that listed a different number of credits from what was reflected on the reimbursement forms submitted by state colleges and universities.
Because of unreliable data in the Massachusetts National Guard Tuition System, MIL may not be able to ensure the accuracy of the credits that National Guard members use. Additionally, it may not be able to ensure that it avoids overpaying the state colleges and universities for duplicate reimbursement forms.
Authoritative Guidance
Section 19 of Chapter 15A of the Massachusetts General Laws states that the Commonwealth must provide and administer a tuition and fee waiver program for members of the Massachusetts National Guard and should establish guidelines to manage the program.
Line Item 8700-1150 of the Commonwealth’s budget for fiscal year 2022 states, “For reimbursement of the costs of the national guard tuition and fee waivers under section 19 of chapter 15A of the General Laws . . . according to procedures and regulations promulgated by the military division.”
The fiscal year 2020, 2021, and 2022 state budgets had the same requirements regarding this area.
Reasons for Noncompliance
Neither MIL nor the information system company that hosts the tuition system could explain who deleted the transactions or how this occurred. Further, neither party was aware of these deleted transactions until we brought the issue to their attention.
MIL has insufficient internal controls over the certificate of eligibility application approval process and, further, does not always follow these controls. The MIL “Tuition System User Manual” does not provide detailed instructions or have policies and procedures for the employee reviewing the certificate regarding how to process courses that are added or dropped and which certificates should be denied, revoked, or approved.
MIL does not reconcile the reimbursement forms received from the state colleges and universities to its own data contained in the Massachusetts National Guard Tuition System to ensure the accuracy of the reimbursement forms.
MIL also does not routinely reconcile of the credits used by National Guard members to the data in the Massachusetts National Guard Tuition System. Instead, MIL only reconciles these when a Guard member questions the accuracy of their credits in the tuition system.
Finally, MIL told us it can override Massachusetts Management Accounting and Reporting System (MMARS) controls. For example, management told us that an invoice for tuition reimbursement to a state college or university could not be duplicated in MMARS because MMARS flags any duplicate invoice numbers. However, they told us that they have the ability to add a character to the end of the invoice number so that MMARS will allow the payment in a situation like this to be processed.
Recommendations
- MIL should strengthen and follow its internal controls for the Massachusetts National Guard Tuition System and for the tuition and fee waiver process to ensure that it is operating as intended. Specifically, MIL should strengthen internal controls to ensure that it does the following:
- Prevents anyone from deleting records in MIL’s National Guard Tuition System without MIL’s approval, which should only occur through a documented process and
- Requires routine reconciliations between MIL’s National Guard Tuition System and the information provided by the state colleges or universities to ensure that the reimbursements are accurate and not duplicative.
- MIL should create policies and procedures for the denial, revocation, and approval of certificates of eligibility. MIL should train its employees on these policies and procedures to ensure that MIL employees consistently follow the process.
- MIL should maintain all records provided by state colleges and universities, including approved certificates of eligibility and reimbursement request forms.
- MIL should not override system controls in MMARS by adding characters to the end of invoice numbers.
Auditee’s Response
The MIL accepts [the Office of the State Auditor’s] findings. The loss of electronic records occurred during a software migration period. However, the department will look beyond the singular incident to develop policies and software system implementation to prevent the loss of electronic records.
- The department is working with the software vendor and Army National Guard Education Center to add/implement software system control so that no record can be deleted. The Army National Guard Education Center will only be able to disable a record containing uncorrectable information.
- The department has implemented an internal policy that requires pre & post software migration data audits. The data must match. It will be a standard performance matrix for the software vendor to receive full payment on system migration and upgrade. Furthermore, the department will ensure the software vendor performs successful data backup before the software system upgrade by performing the same pre & post-backup data audit.
- A comprehensive software system security policy is being worked on among MIL, the Army National Guard Education Center, and the software vendor. . . .
The department is hiring or assigning 1 additional [full-time employee] to perform routine reconciliation between the National Guard Tuition System and the billing information provided by state colleges and universities. The frequency of the reconciliation will be no less than monthly. . . .
The department will work closely with the eligibility determination entity, the Army National Guard Education Center, to develop a written policy to ensure the accuracy of the approval/denial/revocation determination. . . .
The department follows the Commonwealth of Massachusetts record retention policy. The very few paper records misplaced and lost during the pandemic are not acceptable. The fiscal staff will continue to receive records retention training annually, and internal random audits will be performed at least once a year. . . .
This [overriding system controls in MMARS] is a state-wide issue that every department will encounter daily, as the department has no control over a vendor or a state college/university’s schematic of the invoice number. Some invoices will bear no invoice number, such as utility bills. Some companies will use an invoice number more than 30 characters long that exceeds the maximum [number] of characters that the state accounting system will accept. All of these do not relieve the department’s financial obligation to make payment per invoice. The state comptroller’s office allows the department to add additional information to the invoice number. This ability is given to all state departments, not just MIL. . . .
The department does recognize the confusion and the auditing difficulties. The MIL has and will continue broadcasting the necessity of using [one] unique invoice [number] per invoice to all state colleges/universities. The department will communicate to all state colleges/universities that a duplicated invoice [number] will minimally delay the reimbursement speed. The MIL will have to perform internal research every time a duplicated invoice [number] on a new invoice is received.
Auditor’s Reply
Based on MIL’s response, it is taking measures to address our concerns regarding this matter.
| Date published: | January 10, 2024 |
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