Brockton Public Schools' Response to Massachusetts OIG Findings

Jeffrey S. Shapiro, Esq. Inspector General Commonwealth of Massachusetts 
Office of the Inspector General
One Ashburton Place, Room 1311
Boston, MA 02108
 

RE: Response to OIG Correspondence on Brockton Public Schools FY23 Budget Deficit 

Dear Inspector General Shapiro, 

On behalf of the City of Brockton and Brockton Public Schools (BPS), we acknowledge receipt of your letter dated December 3, 2025, regarding the Fiscal Year 2023 (FY23) budget deficit. We are grateful for the assistance provided by the Office of the Inspector General (OIG) for conducting a thorough review of our financial practices and issuing recommendations. 

The City of Brockton, Brockton School Committee and BPS leadership are acutely aware of the gravity of the findings issued by the OIG, and we remain steadfast in implementing the recommendations provided in your correspondence. We are pleased to be afforded the opportunity to demonstrate the progress that has been achieved to provide greater financial controls and oversight that addresses the substantial majority of OIG’s recommendations. 
 

In order to comply, we respectfully submit our response for your review and consideration.  It is our hope that our response will demonstrate our continued commitment to prudently exercising our charge as fiscal stewards for the City of Brockton. 

Recommendation 1. Set a “tone from the top” in (a) adopting budget management best practices and (b) adhering to budget policies in place;  
 

The Brockton Public Schools are aware of the importance of utilizing best practices.  To that end, the BPS has taken the following steps:  

• As stated in the Nystrom Beckman & Paris L.L.P. Independent Investigation Report of Brockton Public Schools FY23 Budget Deficit, a fundamental accounting practice is to generate a budget based upon the prior year’s actual expenditures, as previous expenditures are the best indicators for future spending.  This was accomplished whereby School Committee was provided a drilled down budget delineated by requested budget and actual costs to the best extent possible for previous years from 2022 through 2025 to provide a longitudinal view on spending patterns.  See Attachment #1
• Equally important is the work accomplished to submit a budget that provides more detailed and in-depth information.  For example, instead of one line in the budget that amounted to over $123 million for all teaching staff, there are now over 300 lines that denote the various positions by school and department in the new and improved version of the budget.  Similarly, the 199 account that served as a catchall budget line has been eliminated and new budget lines have been created that not only promote greater detail and transparency but are aligned to the DESE end-of-year report.  This change was a result of the recommendations provided in the Nystrom Beckman & Paris L.L.P. investigation.  See Attachment #2
• Our charge as stewards of the City does not end with solely generating and implementing work, but also in communicating and engaging all stakeholders in understanding the budget and how it impacts their roles as staff, children, and/or constituents.  To that end, we have presented various versions of the budget, specifically providing information on how the budget is calculated, detailed budget information, longitudinal comparisons, cost analysis, as well as budget improvements as part of the overall budget approval process. See Attachment #3 
• The district is updating the Chart of Accounts in MUNIS to align more closely with DESE reporting requirements and recognize best practices in governmental accounting. This modernization will strengthen financial transparency and internal fiscal controls by improving the consistency, clarity, and accuracy of how revenues and expenditures are recorded and reported. A standardized and well-structured Chart of Accounts will enable more effective monitoring of spending throughout the fiscal year, support more reliable and timely budget forecasting, and reduce the risk of misclassification or reporting errors. Most importantly, it will provide district leadership and the School Committee with clear, decision-ready financial information, enhancing oversight, accountability, and informed long-term financial planning. 
• The most compelling indicator that our practices are working to prevent overspending is the fact that we carried forward funds in the amount of $7,229,176 and $7,498,000 from FY25 and FY26 respectively. 

In summary, we are pleased to report that the Brockton Public Schools is on a path of meaningful improvement on how the budget is built and monitored so that it is more transparent, precise, and reflective of the operational needs of the district by utilizing data-informed decisions and best budget management practices.     

Recommendation 2. Establish a culture that encourages individual and collective action in bringing budgetary concerns to city leadership, BPS leadership, and the school committee; 

• In an effort to foster open lines of communication whereby issues can be raised and triaged by utilizing a multidisciplinary team approach, bi-weekly meetings have been held specifically to address fiscal matters with attendees consisting of the Mayor, Brockton School Committee Vice Chair, Superintendent, City CFO, City Solicitor, BPS CFO, BPS Compliance and Open Architects.  Some of the issues that had been identified and addressed via the bi-weekly meetings include but are not limited to Schedule 19, unpaid invoices, blanket purchase orders, circuit breaker usage, wage schedules, and updates to our joint financial online platform.   
• As per a Letter of Assurances submitted to the Massachusetts Department of Elementary and Secondary Education, BPS continues to meet monthly with the DESE finance team and also meets bi-monthly with the DESE finance team and City of Brockton officials in order to ensure that BPS and the City of Brockton are achieving collaboration and compliance.   
• Meetings held in isolation within the City of Brockton are neither effective nor transparent.  As municipal employees, we are held to account to ensure that taxpayer dollars are spent appropriately and transparently.  As such, regular meetings have occurred  with top staff at the Executive Office of Administration and Finance (A&F) and the Division of Local Services (DLS) within the Department of Revenue (DOR) to ensure that the City of Brockton and the Brockton Public Schools are aligned in their fiscal practices and are working towards better processes and procedures and greater sustainability over time.  In 2025, these meetings occurred on January 16, April 17, and August 28 and included updates, presentations and discussions. See Attachment #4
• As leaders of the City, we are responsible for raising tough and seldom times controversial questions as they relate to the budget so that we create the opportunity and space to rectify matters.  This was evidenced by a presentation to School Community outlining the financial challenges BPS was currently facing at the time along with proposed solutions with specific financial matters and examples.  See Attachment #5
• Attendant with any leadership position is the requirement to meaningfully reassess our operational processes and to generate innovative and create efficiencies all in an effort to leverage funds and human capital.  Part of this work was demonstrated in a presentation to City Council pertaining to the Transportation Budget.   Some examples of changes that yielded cost savings included changing the start time to a PreK school, deepening review of transportation invoices, and requesting new price quotes for out of district students by grouping the number of students transported by location and to the same out of district school.  See Attachment #6
• As indicated in the 2024 investigation, there was a recommendation that City officials, including the City Council, establish a collaborative working relationship with the School Committee, Superintendent, and School CFO to oversee school finances.  On behalf of the City, we are confident that we have established a relationship in the truest form of collaboration.  There are consistent meetings held between the school department and city hall leaders and departments, such as the Mayor, City Council members, and various city hall departments.  The most notable artifact and testament to this robust partnership between the school district and city hall is the generation and approval of the budget investment plan.  This plan provides the school district the opportunity to demonstrate substantial compliance with the contract process while bills and invoices continue to be paid as the district continues to hire procurement staff so that services can continue and the school district can continue to operate and serve students.  See Attachment #7

In short, the aforementioned addresses how we have made substantial gains on building a more detailed budget that is more reflective of past expenditures spanning the past several years.  We have also established and dedicated meeting times and spaces to cultivate the flow of information not only internally, but with our external partners to triage financial matters that need to be addressed. 

Recommendation 3. Require the school committee and BPS personnel holding budgetary responsibilities, including the superintendent, BPS CFO, deputy BPS CFO, and other finance staff, to take specialized training on their fiduciary obligations;  
 

• The BPS Finance Team has recommended that staff avail themselves of the free training opportunities offered through the Office of the Inspector General (OIG). A curated list of relevant courses from the OIG training catalog has been shared with members of the Finance Office. To date, one team member has completed an OIG course. The Finance Office will move forward with additional course recommendations and a formal professional development plan to ensure broader staff participation and completion of these trainings as part of individual professional growth goals. See Attachment #8
• The School Committee attended a Training Workshop on April 29, 2025. Open Architects presented a session focused specifically on the financial framework and implementation of the Brockton Public Schools budget. The training explained how the district’s budget is constructed, how revenues and expenditures are aligned with educational priorities, and how financial decisions flow from planning through execution and monitoring. It also included a detailed review of Chapter 70, Net School Spending (NSS) requirements, and Non-Net School Sending calculations, and a detailed review of Schedule 19.   Committee members were guided on how to read and interpret budget documents, understand variances and projections, and use financial information to support effective oversight, accountability, and informed policy and fiscal decisions throughout the year. See Attachment #9
• In order for the district to be positioned to be successful in implementing best practices as it relates to fiscal responsibility, the City and BPS has taken an innovative approach to determining positions that are tailored to meet our needs in terms of robust budget management as well as conducting oversight.  For example, the City Council approved an Assistant Auditor of Schools position that serves as the liaison between the City Auditor’s office and the school department to ensure proper account setup and management, compliance with journal entries, grant system development, financial oversight and risk management as well as other key responsibilities.  Another position that was created focused on fiscal compliance in the form of the Director of Strategy and Compliance to ensure fiscal compliance with both internal and external audits while working as a liaison with city hall.  Similarly, the Compliance Specialist position is charged with managing and developing budgets as well as monitoring expenditures and generating analysis and reports.  See Attachment #10  
• While creating financial positions is the foundational step to effectively managing the budget, relevant staff must be provided appropriate training to be best poised for success.  To that end, in just this past year, we have 3 staff that obtained their MCPPO certification, 1 staff who is currently enrolled and has passed 2 out of the requisite 3 courses to obtain their MCPPO certification, and 1 staff in the Superintendent’s office who will begin taking the courses.  Moreover, there have been 4 staff who obtained their School Business Administrator license.  See Attachment #11
   
• While it is critical for school committee and BPS personnel to appropriately uphold their budgetary responsibilities, another method to build in greater accountability is for leadership to be distributed and for budget creation to be a collaborative effort.  In the past, only two to three individuals held all the information and budgetary responsibility within the school system.  The FY26 budget was built by a larger group of individuals that included principals, department heads, directors, and coordinators.  Many of these individuals were seeing their department/school budgets for the first time.  Now they have been trained on how to view their own budgets and to track their school year spending over time.   

In order to provide effective and accurate budget management, the City and BPS have made key changes and investments to position the district and leverage human capital to continue to make substantial progress to enhance financial practices.   

Recommendation 4. Ensure that the school committee and BPS finance staff understand the BPS budget cycle and how to read and analyze budgetary documents;  

• The process for budget review and approval by the School Committee was iterative, taking place over the course of several meetings and weeks.  The document that was produced was more comprehensive and thorough than in years past and included year-over-year budgets and actuals so that School Committee members had the ability to better understand historical budgeting and expenditures to the best extent possible.  The document also included the salaries of all 3,000 employees in the district.  This allowed School Committee members the opportunity to ask questions, engage in meaningful discussions, and provide input that was then implemented into revised versions of the budget.  See Attachment #12
• To support not only School Committee and City Council but the entire Brockton school community in understanding the budget, a notable accomplishment was the creation of the budget book.  Not only does this include our budget detail and distribution, but it also provides tailored information for each school including their demographics, school initiatives and budget that allows for greater budget transparency as well as accountability.  Noteworthy budget analysis provided in the budget book includes:
• Line-by-line budget for schools and central administration departments so that all staff are aware of their budget, organization code, object code, position titles and their corresponding budget prior to the start of the next fiscal year in order to plan and budget accordingly that concurrently acts as a guardrail to prevent overspending 
• Explanation of how Net School Spend is calculated as well as historical NSS amounts  
• Budget comparison from last fiscal year to the current year disaggregated by Chapter 70, local aid, and Schedule 19 
• Drilled down analysis of Schedule 19 by category, such as municipal related costs, maintenance, pension contribution and health insurance by cost and percentage change 
• Detailed budget information that provides costs for special education tuition, charter school reimbursement as well as Non-Net School Spend 
• Information on a pilot where BPS is creating a budget dashboard that demonstrates budget changes and expenditures in real time 
• Comparison of per pupil spending of comparable districts 
• Breakdown of the largest cost drivers for BPS  
• Historical cost analysis of Special Education transportation and out-of-district special education tuition See Attachment #13 
• In order for School Committee to make an informed decision and to vote to approve use of carryforward funds, expenditure requests were submitted via a brief description, amount, budget account number and alignment to the district strategic objectives, illustrating the intentional paradigm shift of placing instructional priorities and students at the center of our budget.   See Attachment #14 

Recommendation 5. Strengthen controls by creating or amending existing fiscal policies to ensure clarity and consistency with applicable law. All fiscal policies concerning BPS should clearly define: a. Roles and responsibilities of the superintendent, the BPS CFO, other BPS finance staff, and the school committee, both in preparing and in administering the annual BPS budget; b. Roles and responsibilities of the mayor, the city CFO, and other city finance staff, both in preparing and administering the annual BPS budget; c. The reporting structure and procedures for staff members to raise budgetary concerns, including an alternative path should a concern remain unaddressed; d. Circumstances under which the BPS CFO is required to report information to the school committee and the mayor, including material changes in budget projections that result in a deficit; and e. Develop a clear alternative path if there is no response to budgetary concerns raised through the identified reporting structure;  

• As aforementioned in the response to recommendation 1 in the budget review and approval process, the Brockton School Committee also exercised their charge on overseeing the budget by reviewing the line-by-line budget prior to the meetings and asking questions regarding the budget.  The specific questions along with the responses were included in the slide deck for each subsequent School Committee meeting.  See Attachment #15
• In response to establishing guardrails to prevent overspending and allow the district to garner additional oversight, BPS implemented a revised and formalized process for the submission and approval of additional compensation requests.  This change not only focused on generating efficiencies but supports the district’s strategic vision while managing expenditures consistent with district- and school-level goals and available budget.  It also serves to replace the prior paper-based submissions with a centralized, automated pre-approval system, and strengthened internal controls by standardizing submissions, improving tracking, and ensuring that all requests are reviewed and approved or denied by appropriate administrative personnel prior to work being performed, with formal notifications and documentation maintained.  The system also captures centralized data on programs, positions, hours requested, and approval outcomes, enabling accurate monitoring, enhancing transparency and accountability, and supporting effective fiscal oversight and future budgeting and planning.  See Attachment #16
• Consistent with other comparable public school districts, the largest cost driver for the district consists of staffing and represents approximately 77% of the BPS budget.  As such, additional scrutiny and monitoring of positions must be conducted to prevent overspending.  To accomplish this, BPS also implemented the same centralized, automated submission and pre-approval process for Personnel Request forms, which are required when district leadership seeks to add, modify, or otherwise change positions.  This process replaced paper-based submissions and requires all personnel requests to be submitted electronically for administrative review prior to any staff hire.  The system maintains a complete and auditable record of each request, including position details, approvals or denials, and associated funding considerations and staff salaries that can be used to assist with ongoing oversight, compliance, and future budgeting and workforce planning.  See Attachment #17
• As part of Brockton Public Schools’ efforts to strengthen fiscal oversight, internal controls, and transparency, BPS has implemented two key grant-related control mechanisms: a comprehensive Grant Management Manual and a publicly accessible Grant Dashboard.  The grant manual establishes standardized procedures for the selection, approval, budgeting, procurement, monitoring, and close-out of all federal, state, and private grant funds and clearly delineates roles and responsibilities across the Superintendent’s Office, Grants Office, Business Office, Procurement, and grant facilitators, ensuring accountability at each stage of the grant cycle.  In accordance with 2 CFR Part 200, Massachusetts procurement law, and district financial policies, the manual requires the use of MUNIS reporting tools, including flexible period (flex) reports, to monitor expenditures, encumbrances, and remaining balances on an ongoing basis.  These controls were implemented to address prior gaps in clarity, documentation, and oversight identified in the BPS financial practices.  Moreover, BPS launched a live, publicly available Grant Dashboard that affords the community with a centralized view of grant funding received by BPS, including funding sources, award amounts, program areas, and high-level fiscal information. Taken collectively, the grants manual and dashboard represent deliberate corrective actions designed to strengthen budget controls, improve communication, and ensure that grant funds are managed in accordance with applicable laws, regulations, and best practices, all of which are the cornerstone tenets of the OIG recommendations.  See Attachment #18
• Last school year, BPS outlined a transfer procedure to be utilized with the school committee when transferring budgeted funds between accounts within the district’s budget to ensure fiscal responsibility, transparency, and compliance with legal and regulatory requirements.  While the school committee already had a policy that articulated their authority over their transfers, no procedures or steps had been outlined until last year. These procedures were implemented where transfers were required including but not limited to the transfers of $4.1 million approved by Brockton School Committee on February 20, 2025.  See Attachment #19 
• In accordance with MGL Ch. 41, § 56, BPS is implementing a pilot process for School Committee to review and approve warrants.  As the OIG is aware, this comprehensive review includes confirming that (1) the charges are correct, (2) the goods/services were ordered, (3) the goods/materials were delivered, and (4) the services were rendered. This requirement was reinforced by the Massachusetts Department of Revenue’s 2012 review and again in the 2024 financial audit. To meet this requirement, we are currently in the testing pilot phase whereby BPS is leveraging technology and generating efficiencies by using Python scripting, syncing Microsoft SharePoint and submission via DocuSign that is automated to run weekly.  Essentially, financial documentation that includes the requisition, purchase order, and invoice for services rendered and supplies received will be compiled into a single file and electronically routed to BPS leadership and the voted School Committee members reviewers for approval via electronic signature every week.  See Attachment #20
• A Transportation Roundtable consisting of the Mayor, City Chief of Staff, City CFO, City Council President, Superintendent, School Committee Vice Chair, and consultants such as Open Architects and Transportation Advisory Services met biweekly to problem solve concerns with transportation routing, costs, and contracts.  As a result of these meetings, an audit was conducted, improvements were made, and a transportation bid in the form of an Invitation for Formal Bid was initiated in accordance with Chapter 30B.  See Attachment #21
• A transportation Invitation for Formal Bid with a menu of options was created and posted by the school district last year. While none of the bids that were solicited last year prevailed, the bid is being revised to solicit bids this school year as well with the hopes of receiving proposals that are more competitive and cost efficient.  BPS has been simultaneously negotiating with the bus drivers’ union with the hopes of revising the agreement to include efficiency and cost-saving.  Furthermore, the Transportation Roundtable took an intentional approach when determining the components to be included in the Request for Proposal to ensure considerations impacting Non Net School Spending.   See Attachment #22

 
Recommendation 6. Review current BPS contracts to ensure that the contracts were properly procured and that monies have been appropriately encumbered, and establish a written process to similarly account for future contracts procured; and  

• In order to review the purchase order, or the purchase request, we met with department heads to review their request, as well as their past purchase history and to identify any future expenditures for this fiscal year.  From that discussion, we would then be able to identify next steps, such as whether we would need to obtain 3 quotes for future purposes or to obtain the requisite City of Brockton contract and any corresponding documents, such as appendices and the Certificate of Insurance. 
• Based upon the meetings, it was evident that systems needed to be generated to support staff through the contract process.  Equally apparent was the fact that we did not have a repository or central system or method to house all of the documents that we needed to submit to demonstrate compliance.  To that end, we developed a procurement form that guided staff through the process including providing the necessary documents that would need to be submitted.  
• The questions in the form would change based on the answers to previous questions.  For example, if you answered that you would like to purchase from an OSD state contract, then the next question would be to enter the state contract number.  If your answer to the previous question is that your purchase request exceeds 10,000, then the next question would ask you to upload 3 quotes as well as the City of Brockton contract.  
• Due to the fact that there are a substantial amount of contracts to generate, we created an automated contract generator form so that once a staff member completes the form with the necessary information, a City of Brockton contract is automatically generated and sent via email.  These contracts are then automatically synced into a repository.    
• Additionally, BPS has created a variety of resources to support staff navigating the purchasing process. The Procurement Resources page provides a roadmap for purchasing and the key documents you will need to fulfill requirements set forth by the state and the City of Brockton. See Attachment #23

Recommendation 7. Require all current and future school committee members within the first 30 days of their tenure to complete the “Boards and Commissions: Know Your Responsibilities” training offered by the OIG Academy. 
 

• As the OIG is aware, the remaining two offerings of the “Boards and Commissions: Know Your Responsibilities” training are currently only offered for March 11, 2026 and April 16, 2026.  All School Committee members have either registered for the course or are in the process of signing up to participate in the recommended course.  See Attachment #24

Conclusion 

In closing, the City of Brockton, the Brockton School Committee, and Brockton Public Schools acknowledge the seriousness of the FY23 budget deficit and the systemic shortcomings identified by the Office of the Inspector General.  We accept these findings as an opportunity to correct past deficiencies and to fundamentally strengthen our fiscal governance, internal controls, and culture of accountability. 

As outlined in this response, substantial and deliberate corrective actions have been implemented across all seven OIG recommendations.  These actions reflect a coordinated effort between City leadership, the School Committee, and BPS administration to establish clear roles and responsibilities, enhance transparency, modernize financial systems, strengthen procurement and contract oversight, expand training and professional development, and create durable processes that promote early identification and resolution of fiscal risks. The improvements to budget development, monitoring, reporting, and stakeholder engagement demonstrate a sustained commitment to best practices in public financial management. 

While we recognize that this work is ongoing and that continued vigilance is required to ensure long-term fiscal stability, the progress achieved to date represents a meaningful shift in how Brockton Public Schools plans, manages, and oversees its financial resources.  These reforms are designed not only to prevent a recurrence of the circumstances that led to the FY23 deficit, but also to support sound decision-making that prioritizes students, protects taxpayers, and ensures compliance with all applicable laws and regulations. 

We appreciate the guidance, oversight, and partnership of the Office of the Inspector General throughout this process. The City of Brockton and Brockton Public Schools remain fully committed to continued collaboration with the OIG and other state partners as we refine and institutionalize these reforms.  We respectfully submit this response for your review and welcome any additional feedback or recommendations as we continue this important work.