Audit of the Massachusetts Board of Library Commissioners
July 10, 2018 · Massachusetts Board of Library Commissioners · Read the full official report on mass.gov ↗
source
“However, MBLC needs to improve its procedures for monitoring the LSTA Grants to States Program and the MPLCP and update its internal control plan.”
Read the plain-English breakdown
This is a state performance audit of the Massachusetts Board of Library Commissioners, covering how it managed selected library programs and grants from July 1, 2010 through September 30, 2012.
“This report details the audit objectives, scope, methodology, findings, and recommendations for the audit period, July 1, 2010 through September 30, 2012.”
Auditors reviewed whether the board properly oversaw library grants, construction funding, state aid, and related services, and whether it followed rules and had good controls.
“This audit was conducted in order to review and evaluate the Massachusetts Board of Library Commissioners’ (MBLC’s) administration and oversight of certain programs and services, including the Library Services and Technology Act (LSTA) Grants to States Program, the Massachusetts Public Library Construction Program (MPLCP), State Aid to Public Libraries, and the Massachusetts Library System, and to determine whether those programs and services were conducted in compliance with applicable laws and regulations and supported by effective internal controls.”
Public money was going into library construction and services, so weak oversight could mean delays, poor contractor choices, or funds not being properly tracked.
“Delayed reports reduce the relevance and usefulness of the information being reported and could reduce MBLC’s ability to make informed decisions about the grantees’ performance and adherence to grant agreement provisions and to ensure that MPLCP grant funds are being properly accounted for and appropriately spent.”
For residents, the point of these programs is better library access, improved library buildings, and support for local library services across Massachusetts.
“According to its website, MBLC has “the statutory authority and responsibility to organize, develop, coordinate and improve library services throughout the Commonwealth,” and its mission includes “[providing] every resident of the Commonwealth with full and equal access to library information resources regardless of geographic location, social or economic status, age, level of physical or intellectual ability, or cultural background.””
Auditors did not say the main grant programs were broken; they said several oversight practices needed tightening.
“Based on our audit, we have concluded that for the period July 1, 2010 through September 30, 2012, MBLC’s procedures for distributing State Aid to Public Libraries, awarding sub-grants to libraries under the LSTA Grants to States Program, and awarding grants under the MPLCP are effective.”
The board said it was changing rules and procedures, including requiring checks of contractor records and better documentation of grant monitoring.
“MBLC is in the process of drafting updates to 605 CMR 6 to require municipalities that have been awarded library construction grants to review the DCAMM contractor certification files of the lowest responsible, eligible bidders for general contract work before final contractor selection.”
The report is significant because it points to practical fixes that can help protect public funds and make sure library projects and grants are monitored well.
“Without an updated ICP, MBLC may not be able to ensure that it can achieve its objectives efficiently, effectively, and in compliance with applicable laws, regulations, grants, and contractual agreements and that its assets are properly safeguarded against loss, theft, and misuse.”
MPLCP means the state program that helps cities and towns build or renovate public libraries; LSTA is a federal grant program that supports library services; an internal control plan is the agency’s written system for managing risks and preventing errors or misuse.
“The MPLCP assists municipalities in developing public libraries through the renovation and expansion of existing library buildings or the construction of new facilities.”
1 figure(s) pending source verification - not shown
What the Auditor checked
- Complied Did MBLC's process for distributing State Aid to Public Libraries ensure that libraries complied with applicable laws and regulations in order to be considered for state aid?
- Partially Did MBLC's process for awarding sub-grants to libraries under the Library Services and Technology Act Grants to States Program and its monitoring procedures ensure compliance with applicable laws and regulations?
- Complied Did MBLC's process for awarding grants under the Massachusetts Public Library Construction Program have sufficient controls to ensure that funds were competitively awarded to eligible municipalities?
- Partially Did MBLC's monitoring of library construction projects ensure that funds were spent appropriately under the MPLCP and that projects were completed in a timely manner and in accordance with project plans and applicable laws, rules, and regulations?
- Complied Did the minimum financial commitment required of municipalities for projects funded under the MPLCP inhibit poorer municipalities from applying for funding, and what assistance did MBLC provide to poorer municipalities if they could not meet the minimum financial commitment?
- Complied Did MBLC exercise proper oversight of its sub-agency, the Massachusetts Library System?
What the Auditor found
Why it matters: Missing or delayed reports could prevent MBLC from receiving necessary project information and reduce its ability to make informed decisions about grantee performance, compliance, and use of grant funds.
Standard: Chapter 647 of the Acts of 1989; 605 CMR 6.05(2)(c); OSC procurement/contracts policy State Grants and Federal Sub-Grants ( Chapter 647 of the Acts of 1989; 605 CMR 6.05(2)(c); OSC procurement/contracts policy “State Grants and Federal Sub-Grants” )
2 recommendations
- MBLC should establish adequate controls over the administration of its monthly construction reports.agency: already implemented
- MBLC should consider establishing penalties for late or unsubmitted reports and timestamp the receipt of all reports.
Agency response & Auditor reply
Agency: "To ensure that all monthly reports are submitted and each is submitted on time, MPLCP is in the process of implementing new controls."
Auditor: "Based on its response, MBLC is taking measures to address our concerns on this matter."
Why it matters: Municipalities were more likely to select contractors with substandard past performance, increasing the risk of project delays, non-completion, and misuse of local and state dollars.
Standard: Chapter 149, Section 44D, of the Massachusetts General Laws ( Chapter 149, Section 44D, of the Massachusetts General Laws; Chapter 149, Section 44D(6), of the Massachusetts General Laws )
2 recommendations
- MBLC should require MPLCP grant recipients to review DCAMM’s contractor certification files for all potential bidders and use this information in their contractor-selection process.agency: already implemented
- MBLC could improve its oversight of these projects by requiring grant recipients to document their findings and conclusions when reviewing contractor certification files.agency: already implemented
Agency response & Auditor reply
Agency: "MBLC officials were aware of DCAMM evaluations of contractors and understood that as standard practice for municipalities to consult DCAMM evaluations in the process of evaluating the work of general contractors."
Auditor: "Based on its response, MBLC is taking measures to address our concerns on this matter."
Why it matters: There was inadequate assurance that libraries complied with sub-grant requirements and that MBLC administered and monitored sub-grants in accordance with federal requirements.
Standard: Office of Budget and Management Circular A-133 Compliance Supplement for 2013, Part 3 ( Office of Budget and Management Circular A-133 Compliance Supplement for 2013 )
1 recommendation
- MBLC should formally reflect its requirement to document site visits to sub-grant recipients in its written policies and procedures.agency: already implemented
Agency response & Auditor reply
Agency: "As of June 2013, MBLC requires its LSTA consultants to document site visits made to libraries that are LSTA sub-grant recipients on a designated site visit report form."
Auditor: "Based on its response, MBLC is taking measures to address our concerns on this matter."
Why it matters: MBLC may not be able to ensure that it achieves its objectives efficiently, effectively, and in compliance with requirements or that assets are protected against loss, theft, and misuse.
Standard: OSC Internal Control Guide ( OSC Internal Control Guide )
4 recommendations
- MBLC should prepare an updated ICP that includes and identifies all eight components of enterprise risk management in conformance with the latest OSC guidelines.
- MBLC should prepare an updated high-level summary of internal controls with cross-references to lower-level department policies, procedures, and the MBLC mission statement.
- MBLC should assess risks at each department and include significant risks, likelihood, impact, risk response, and mitigation plans in the ICP.
- MBLC should ensure that the ICQ submitted to OSC each year is accurate.
Agency response & Auditor reply
Agency: "In response to this matter, MBLC stated, “[MBLC] addresses and reviews its Internal Control Plan annually."
Auditor: "We continue to recommend that it document its reviews and updates."
Verified dollar findings
Estimated or sample-projected amounts - shown separately because they are not a hard-identified dollar figure.
Identified dollar findings that do not fall in a named band.
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