Audit of the Massachusetts Cultural Council
June 16, 2022 · Massachusetts Cultural Council · Read the full official report on mass.gov ↗
Published June 16, 2022 Audit covers March 1, 2020 – March 31, 2021 Under Suzanne M. Bump · 2011–2023
source
“MCC awarded $39,000 to 26 ineligible applicants.”
Read the plain-English breakdown
This is a state performance audit of the Massachusetts Cultural Council covering March 1, 2020 through March 31, 2021, with some individual artist grants reviewed through June 30, 2021.
“This report details the audit objectives, scope, methodology, findings, and recommendations for the audit period, March 1, 2020 through March 31, 2021.”
Auditors wanted to see whether MCC followed the rules when handling COVID relief grants, updated its internal controls for the pandemic, and made sure employees took required cybersecurity training.
“The purpose of our audit was to determine the following:”
The audit matters because public relief money was supposed to reach eligible artists and cultural nonprofits, but weak checking increased the risk that some money went to the wrong people or organizations.
“As a result, there is a higher-than-acceptable risk that grants were awarded to ineligible applicants.”
For an ordinary Massachusetts resident, this report is about whether taxpayer-backed cultural relief funds were handled fairly, documented properly, and protected by basic agency controls.
“The absence of an up-to-date ICP may hinder MCC’s effective and efficient achievement of its mission and objectives.”
The auditor told MCC to tighten its procedures: require proof before awarding grants, follow or amend agreements properly, update internal controls when big changes happen, and assign responsibility for cybersecurity training compliance.
“MCC should establish policies and procedures to ensure that supporting documentation is provided to prove eligibility before it awards grants.”
The audit is significant because the mistakes may have meant that eligible cultural nonprofits missed out on money that instead went elsewhere.
“As a result of this issue, eligible cultural NPOs that could have been awarded full or partial grant funding from this $39,000 may have been denied grants.”
MCC is the Massachusetts Cultural Council. An ISA is an agreement between state agencies. A cultural NPO is a cultural nonprofit organization, such as an arts, humanities, or science organization with nonprofit tax status.
“The ISA partnered MCC with the state Executive Office of Housing and Economic Development (EOHED) to issue grants to selected cultural NPOs using the aforesaid $10,000,000.”
2 figure(s) pending source verification - not shown
What the Auditor checked
- Did not comply Did MCC administer funding from its appropriations and donations for the fiscal year 2020 and fiscal year 2021 COVID-19 Relief Fund for Individual Artists in accordance with its grant guidelines?
- Did not comply Did MCC administer funding from the Cultural Organization Economic Recovery Program in accordance with its grant guidelines and its interdepartmental service agreement (ISA) with the Executive Office for Administration and Finance?
- Did not comply Did MCC update its internal control plan (ICP) as required by the Office of the Comptroller of the Commonwealth’s (CTR’s) guidance dated September 30, 2020?
- Did not comply Did MCC employees receive cybersecurity awareness training in accordance with Section 6.1.1 of the Executive Office of Technology Services and Security’s (EOTSS’s) Acceptable Use of Technology Policy IS.002, effective October 15, 2018, and Section 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010, effective October 15, 2018?
What the Auditor found
Why it matters: There was a higher-than-acceptable risk that grants were awarded to ineligible applicants.
Standard: Fiscal year 2020 COVID-19 Relief Fund for Individual Artists grant guidelines, Gary Knisely and Varian Foundation grant guidelines, fiscal year 2021 COVID-19 Relief Fund for Individual Artists grant guidelines, and Massachusetts Department of Revenue full-year resident definition. ( Fiscal year 2020 COVID-19 Relief Fund for Individual Artists grant guidelines; Massachusetts tax code full-year resident definition )
1 recommendation
- MCC should establish policies and procedures to ensure that supporting documentation is provided to prove eligibility before it awards grants.
Agency response & Auditor reply
Agency: "The Council acknowledges that it did not independently verify all of the information submitted by grant applicants to these emergency relief programs but believes its procedures were appropriate and necessary in the circumstances—especially given the nature of the funding crisis for the cultural sector caused by the pandemic and the need to respond to the emergency in haste (as noted in the surveys detailing the effects of the pandemic on the sector which are cited in the draft report)."
Auditor: "OSA believes MCC could have reviewed this documentation for the selected grantees before approving the grants."
Why it matters: Eligible cultural nonprofit organizations may have been denied full or partial grant funding.
Standard: The interdepartmental service agreement with the Executive Office for Administration and Finance and Section 6.03(3)(e) of Title 815 of the Code of Massachusetts Regulations. ( Section 6.03(3)(e) of Title 815 of the Code of Massachusetts Regulations; Interdepartmental service agreement between MCC and EOAF )
2 recommendations
- MCC should stay informed of the requirements of its ISAs.
- MCC should establish policies and procedures to ensure that future ISAs are followed or properly amended and communicate the policies and procedures to all employees who are responsible for ISAs.
Agency response & Auditor reply
Agency: "Mass Cultural Council agrees that it did not obtain an amendment to interdepartmental service agreement (ISA) regarding usage of the leftover $39,400 of CARES Act funds from the [Cultural Organization Economic Recovery Program] (0.394% of a program allocation totaling $10 million) to support its FY21 Individual Artist Relief Program."
Auditor: "Based on its response, MCC is taking measures to address our concerns on this matter."
Why it matters: The absence of an up-to-date internal control plan may hinder MCC’s effective and efficient achievement of its mission and objectives.
Standard: Office of the Comptroller of the Commonwealth’s “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020. ( CTR’s “COVID-19 Pandemic Response Internal Controls Guidance,” dated September 30, 2020 )
1 recommendation
- MCC should establish policies and procedures, including a monitoring component, to ensure that its ICP is updated when significant changes occur.agency: agreed
Agency response & Auditor reply
Agency: "[MCC] concurs in this finding."
Auditor: "Based on its response, MCC is taking measures to address our concerns on this matter."
Why it matters: A lack of training may lead to user error and compromise the integrity and security of protected information in MCC’s information technology systems.
Standard: MCC Employee Handbook FY2020, EOTSS Acceptable Use of Information Technology Policy IS.002 Section 6.1.1, and EOTSS Information Security Risk Management Standard IS.010 Section 6.2.4. ( Section 6.1.1 of EOTSS’s Acceptable Use of Information Technology Policy IS.002; Section 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 )
2 recommendations
- MCC should establish policies and procedures to ensure that all employees complete annual cybersecurity awareness training.agency: agreed
- MCC should assign an employee to be responsible for ensuring that the agency complies with EOTSS’s cybersecurity awareness training policy.agency: agreed
Agency response & Auditor reply
Agency: "[MCC] concurs in this finding that staff had not undergone cybersecurity training during the audit period."
Auditor: "Based on its response, MCC is taking measures to address our concerns on this matter."
More audits of this entity
Other Office of the State Auditor reports on Massachusetts Cultural Council .
- Massachusetts Cultural Council-Examination of Annual Internal Control QuestionnaireOther · October 3, 2016
- Audit of the Massachusetts Cultural Council (November 26, 2025)Other · November 26, 2025