Audit of the State Ethics Commission (December 24, 2025)
December 24, 2025 · State Ethics Commission · Read the full official report on mass.gov ↗
source
“SEC should update its internal control plan (ICP) annually, as required by the Office of the Comptroller of the Commonwealth’s (CTR’s) Internal Control Guide.”
Read the plain-English breakdown
This is a performance audit of the Massachusetts State Ethics Commission covering July 1, 2022 through June 30, 2024.
“In accordance with Section 12 of Chapter 11 of the Massachusetts General Laws, the Office of the State Auditor has conducted a performance audit of certain activities of the State Ethics Commission (SEC) for the period July 1, 2022 through June 30, 2024.”
Auditors checked whether the commission handled required financial filings, complaint reviews, and advisory opinions on time and according to its rules.
“Below is a list of our audit objectives, indicating each question we intended our audit to answer and the conclusion we reached regarding each objective.”
The commission helps keep state and county government ethical by giving advice, collecting financial disclosures, and enforcing conflict-of-interest rules.
“The State Ethics Commission serves the public by fostering integrity in government.”
As a resident, this matters because public employees and officials are supposed to disclose financial interests, and the public can seek ethics forms, complaints, or advice through the commission.
“You can contact the Commission to obtain legal advice, file a complaint, obtain a statement of financial interest or conflict of interest law disclosure form, or complete statutory conflict of interest law requirements.”
Auditors did not report problems with the main tested work on filings, complaint reviews, or advisory opinions; the reported issue was about keeping internal controls and procedures up to date.
“We did not identify any significant exceptions in our testing that must be reported under generally accepted government auditing standards.”
The auditor plans to check back in about six months to see whether the commission has addressed the internal control issue.
“We intend to follow up on this matter during our post-audit review in approximately six months.”
The finding matters because outdated internal controls and procedures can make agency work less consistent and raise compliance risks, even if auditors did not find failures in the tested program work.
“If SEC does not annually review, and update as needed, its ICP and other policies and procedures, then SEC staff members may not have clear guidance, leading to inconsistent practices, inefficiencies, and a higher risk of noncompliance with laws and regulations.”
An SFI is a Statement of Financial Interests: a required disclosure that can include income range, investments, property, gifts, and similar financial information.
“SFIs include the filer’s salary (reported within a range), business holdings, government securities, stocks, bonds, other financial investments, real estate holdings and mortgages, gifts, honoraria, and reimbursements from certain sources exceeding $100 in a calendar year.”
What the Auditor checked
- Complied To what extent did SEC ensure that Statements of Financial Interests (SFIs) were filed on time and completed in accordance with Sections 3(f), 5(a)–(c), and 5(g)(10) of Chapter 268B of the General Laws?
- Complied Did SEC conduct initial staff reviews of violations involving conflicts of interest and the filing of SFIs in a timely manner in accordance with its internal practices?
- Complied Did SEC issue advisory opinions in a timely manner in accordance with its internal practices?
What the Auditor found
Why it matters: Staff may lack clear guidance, leading to inconsistent practices, inefficiencies, higher noncompliance risk, weaker training and accountability, and reduced continuity of operations.
Standard: Chapter 647 of the Acts of 1989; the Office of the Comptroller of the Commonwealth's Internal Controls Policy; and the Office of the Comptroller of the Commonwealth's Internal Control Guide. ( Chapter 647 of the Acts of 1989; Office of the Comptroller of the Commonwealth Internal Controls Policy; Office of the Comptroller of the Commonwealth Internal Control Guide )
1 recommendation
- SEC should establish and implement a formal process to review and update its ICP and policies and procedures, including documenting annual reviews.agency: agreed
Agency response & Auditor reply
Agency: "The SEC agrees with the finding that it did not update its internal control plan (ICP) annually."
Auditor: "Based on its response, it appears that SEC is taking steps to address these concerns."
More audits of this entity
Other Office of the State Auditor reports on State Ethics Commission .
- Audit of the State Ethics Commission (SEC)Authority / Commission · May 22, 2020
- State Ethics Commission-Examination of Annual Internal Control QuestionnaireAuthority / Commission · April 21, 2016