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Audit of the Disabled Persons Protection Commission (DPPC)

June 16, 2021 · Disabled Persons Protection Commission · Read the full official report on mass.gov ↗

Published June 16, 2021 Audit covers July 1, 2017 – June 30, 2019 Under Suzanne M. Bump · 2011–2023

In plain English
The audit found that DPPC needed stronger follow-through on abuse investigations, including rights notices, deadlines, protective service plans, and tracking repeat alleged abusers.
source
“Below is a summary of our findings and recommendations, with links to each page listed.”
Read the plain-English breakdown
What is this?

This is a Massachusetts State Auditor performance audit of the Disabled Persons Protection Commission for July 1, 2017 through June 30, 2019.

“This report details the audit objectives, scope, methodology, findings, and recommendations for the audit period, July 1, 2017 through June 30, 2019.”
Why was it audited?

Auditors checked whether DPPC fixed issues from a prior audit and whether it was meeting key rules for abuse investigations and protective service plans.

“The objective of our audit was to follow up on the issues identified in our prior audit report (No. 2015-0046-3S) to determine what measures, if any, DPPC had taken to address them, as well as the adequacy of those measures.”
Why it matters

DPPC handles reports of abuse involving adults with disabilities, so delays or weak documentation can affect vulnerable people’s safety and accountability.

“DPPC received 11,900 and 13,102 abuse reports in fiscal years 2018 and 2019, respectively.”
What's in it for me?

If you or someone you know is an adult with a disability, this agency may be responsible for reviewing abuse reports and making sure protection steps are taken.

“Citizens and mandated reporters1 can submit abuse reports involving adults with disabilities through a 24-hour phone hotline that is operated by DPPC’s Intake Unit from 9:00 a.m. to 3:30 p.m. and by a DPPC-trained independent contractor after hours (from 3:30 p.m. to 9:00 a.m.).”
The bottom line

The audit says DPPC had problems ensuring alleged abusers were told their rights, finishing investigations on time, receiving final protection plans, and flagging repeat alleged abusers.

“DPPC did not always identify and properly document individuals who had been identified as alleged abusers in multiple reports.”
What happens next

The auditor recommended stronger monitoring controls and continued work with partner agencies so deadlines and documentation requirements are met.

“DPPC should continue to work with the Department of Developmental Services, the Department of Mental Health, and the Massachusetts Rehabilitation Commission to complete IRs for emergency cases within 24 hours, IRs for non-emergency cases within 10 days, and 19C reports within 30 days.”
Why it's significant

The report matters because the agency’s job is to protect adults with disabilities from caregiver abuse, and the audit found weaknesses in how that work was tracked and completed.

“According to its website, DPPC’s mission is “to protect adults with disabilities from the abusive acts or omissions of their caregivers through investigation, oversight, public awareness and prevention.””
Jargon, unpacked

A protective service plan is the written plan for what should happen after abuse is found, including steps to protect the victim from being abused again.

“A PSP includes an assessment of the abuse incident and recommendations to protect the victim from being abused again.”

What the Auditor checked

What the Auditor found

DPPC did not always ensure that alleged abusers were advised of their rights before interviews.
internal controlsrecordkeeping/documentation

Why it matters: There is inadequate assurance that alleged abusers were made aware of, and understood, their rights and legal obligations regarding investigations.

Standard: Section 5.02(2) of Title 118 of the Code of Massachusetts Regulations and DPPC investigation policy Invest-137. ( Section 5.02(2) of Title 118 of the Code of Massachusetts Regulations; DPPC investigation policy “Invest-137” )

1 recommendation
  • DPPC should enhance its policies and procedures by implementing effective monitoring controls to ensure that alleged abusers are made aware of their rights before being interviewed for abuse investigations.agency: disagreed
Agency response & Auditor reply
Agency: "First, DPPC reiterates from the previous audit (2015-0046- 3S) its disagreement with the audit’s characterization of the requirement of 118 CMR 5.02 (2)."
Auditor: "Based on its response, DPPC is taking measures to address our concerns on this matter."
DPPC did not always complete investigations on time or document reasons for delays.
reporting timelinessrecordkeeping/documentationinternal controlspublic safety

Why it matters: Delays can put victims at risk of further abuse and can delay remedial action plans.

Standard: 118 CMR 5.02(3)(a) and DPPC investigation policy Invest-109. ( 118 CMR 5.02(3)(a); DPPC investigation policy “Invest-109” )

2 recommendations
  • DPPC should enhance its policies and procedures by implementing effective monitoring controls to ensure that investigators complete IRs and 19C reports within the required timeframes and that when filing deadlines are not met, evidence of the reasons for the delay is documented, verified, and retained in case files.agency: partially agreed
  • DPPC should continue to work with DDS, DMH, and MRC to complete IRs for emergency cases within 24 hours, IRs for non-emergency cases within 10 days, and 19C reports within 30 days.agency: partially agreed
Agency response & Auditor reply
Agency: "DPPC accepts that it does not always complete its investigations within the required timeframes but disagrees with the finding that DPPC does not document the reason for doing so."
Auditor: "Based on its response, DPPC is taking measures to address our concerns on this matter."
DPPC did not consistently receive final protective service plans from providers on time.
vendor oversightreporting timelinessinternal controlspublic safety

Why it matters: Victims might have experienced delays in receiving recommended social services, counseling, and/or psychiatric services.

Standard: Section II(f) of DPPC oversight policy Oversight-308. ( Section II(f) of DPPC oversight policy “Oversight-308” )

1 recommendation
  • DPPC should implement effective monitoring controls within its policies and procedures to ensure that providers submit PSPs within required timeframes.
Agency response & Auditor reply
Agency: "Although PSPs are required in substantiated cases of abuse, the DPPC is dependent upon the [protective service, or PS] agencies to file the final plans with the DPPC and as a result, cannot and does not wait to ensure the safety of alleged victims in the interim."
Auditor: "Our concern is that DPPC has not implemented effective monitoring controls to ensure that providers submit PSPs to it within regulatory timeframes and in compliance with its policies and procedures."
DPPC did not always identify and document alleged abusers who appeared in multiple reports.
recordkeeping/documentationinternal controlspublic safety

Why it matters: Other agencies conducting investigations may not have had all the information necessary to conduct thorough and effective investigations.

Standard: Section B(3)(I)(7) of DPPC intake policy Intake-204. ( Section B(3)(I)(7) of DPPC intake policy “Intake-204” )

1 recommendation
  • DPPC should establish formal policies and procedures, and develop monitoring controls, to ensure that all staff members identify alleged abusers who have been involved with three or more reports of abuse and document this information in the “Other Pertinent Information” field of the Intake Abuse Form.agency: partially agreed
Agency response & Auditor reply
Agency: "To that end, DPPC appreciates the audit’s recommendation and will assess in what way we might more effectively ensure that this process is deeply embedded in the job function."
Auditor: "We acknowledge that DPPC is taking measures to address our concerns on this matter."

Prior findings revisited

Still a problem
"In our prior audit, we found that the Disabled Persons Protection Commission (DPPC) did not ensure that required forms were signed to document that alleged abusers were advised of their rights before being interviewed."
Still a problem
"Our prior audit revealed that, contrary to state regulations, DPPC did not always complete Initial Responses (IRs) and 19C reports within established timeframes."
Being worked on
"DPPC has made some improvements in the areas reviewed since our prior audit (No. 2015-0046-3S)."

More audits of this entity

Other Office of the State Auditor reports on Disabled Persons Protection Commission , including the prior audits referenced above.

See this entity's page with all 4 audits →