Massachusetts audit recommends improvements to management of police officer training records, certification process

BOSTON — Fulfilling a commitment made in her Social Justice & Equity Audit Plan, the State Auditor’s Office has conducted an audit of the Municipal Police Training Committee to examine whether it developed and implemented trainings consistent with the 2018 Criminal Justice Reform Act and the 2020 Police Reform Law. The audit reviewed the period of January 1, 2021, through December 31, 2022.

The MPTC exists within the Executive Office of Public Safety and Security. Its mission is to set the police training standards for all law enforcement officers certified by the Massachusetts Peace Officer Standards and Training Commission, and to develop, deliver, and maintain a record of that training for over 23,000 police officers (municipal, Massachusetts Bay Transportation Authority, environmental, campus, hospitals), deputy sheriffs, harbormasters, constables, and other personnel who perform police duties and functions in the Commonwealth.

The audit found MPTC did not sufficiently ensure that training academies delivered a standardized recruit officer course curriculum, as required. By not consistently delivering a standardized training curriculum, MPTC provided inadequate assurance that all police officers in the Commonwealth have been exposed to the concepts, skills, and tactics that have been determined to be critical for effective policing by the law and MPTC.

The State Auditor’s Office stated that this may lead to inconsistent law enforcement practices, which may jeopardize the safety of the public and police officers, because law enforcement officers may not be properly equipped to perform their jobs safely and effectively. This also could create financial risk for municipalities that employ officers who are insufficiently trained.

Moreover, the audit found MPTC did not ensure that all ROCs were taught by certified instructors. Without proper certification, instructors may lack the expertise or experience necessary to effectively teach the concepts, skills, and tactics that MPTC has determined to be critical for effective policing. This could lead to variations in the instruction that police officers receive, potentially impacting their ability to perform their jobs safely and effectively.

The audit also found MPTC’s internal control plan was not updated annually, and did not address the impact of COVID-19 on its operations, in accordance with guidance issued by the Office of the Comptroller of the Commonwealth. An ICP identifies objectives and risks and identifies control activities to mitigate risks that might prevent an agency from accomplishing its objectives, in service to the public. Without updating its ICP, MPTC may not identify and/or mitigate all the risks, including those that resulted from the pandemic.

In addition, during the course of the audit, an issue was identified regarding MPTC’s management of police officer training records.

Although MPTC maintained its hard-copy training records in a locked room at their headquarters, it did not maintain an access log to track who accessed the room, when, and for what purpose(s). Some training records appeared to be stored in haphazard fashion – stacked on metal cabinets, without any apparent filing and retrieval method in place. In addition, there were several instances during the audit where hard-copy training records requested to perform our audit work were either missing, not readily available, not properly filed, incompletely prepared or were not certified when required.

The State Auditor’s Office went on to say that it is critical that MPTC maintain a complete, accurate, and secure training record-keeping system. Without an organized record-keeping system, which would include a formal access log, training records are more vulnerable to inappropriate and/or unauthorized access. This compromises the integrity of the records and could lead to: (1) officers attending training where the physical record becomes lost, destroyed or misfiled, resulting in their failing to receive appropriate credit for training, or (2) officers being inappropriately certified or appearing to have completed training they never received. Additionally, in the event there is a dispute regarding the integrity of training records, the lack of an effective record-keeping system makes it more difficult to resolve these issues definitively.

“The Municipal Police Training Committee plays a critical role in the public safety of our Commonwealth, establishing police training standards and maintaining records of that training,” said Auditor DiZoglio. “Our audit has identified areas for improvement at the MPTC to ensure increased accountability in its training, certification and record-keeping processes. MPTC’s new leadership fully cooperated with our audit team and has committed to addressing these issues. As is customary, we will revisit these findings to track progress as part of our post-audit review process in roughly six months.”