You bring up a good point - if you are following your policies and procedures but, they no longer adhere to the regulation, there is still a problem. Regulations are constantly changing and are also subject to "revised clarification" which sometime differs from when a regulation is initially put in place. While it is difficult to keep up, training workshops and summaries put forth by various entities may assist in highlighting key changes.
Preparation for an audit would include internal auditing that the respective departments are following the internal policies and procedures and also internal auditing that indeed the policies and procedures adhere to the appropriate regulatory bodies. An important proactive detail is that there should be continual review/attention given to any "changes" that are put forth in the regulations of these agencies over time and that internal policies are changed if need be to accomomdate the revised regulations.
Like most schools, I think, we have an audit every year. The auditor sends a list of documents to be sent prior to his arrival. There is also a list of documents to be examined by the auditor on the site visit. So basically all of those documents are placed in a notebook in an organized manner and the remainder of the audit involves the review of student files. So, of course, we strive to maintain those files in an orderly manner all year, but yes, we review the files again "just to verify" as much as possible. I think findings are detrimental to career schools, so if at all possible, I really want to avoid any finding on my audit report that goes to the state, the accrediting agency, and DOE.
Stacey - you are right, they almost always find something. A "pre-audit" can help - especially with overcoming some of the fears and stresses of employees going through an audit for the first time.
No matter how much you prepare, or think you prepare, they are always going to find something. There are a few things that you can do, one that has been very helpful to me is to hire an audit team to conduct the same audit that you are going to go through, especially if this is your first audit. It will relieve some pressures and help you to understand how it works and what they will be asking for. Depending on their findings you can then fix and develop a procedure for the uncompliant issues.
Mr. Counts is correct the most important part of preparing for audits announced or unannounced is, having an internal rotating audit program.
Internal audits of Financial Aid to ensure timely payouts, proper fiduciary responsibility and appropriate use of Title IV funds is paramount.
All too often those involved in audits don't think of the consequences until they are informed of an upcoming audit.
I agree with you Richard, constant monitoring and evaluation of existing policies and procedures is ideal to be certain that the instituion is in compliance.
Victor, very true. And, as noted on another recent post, early identification of problems allows the school to implement corrective actions PRIOR to the audit and, ideally, be able to prove that the problem has been resolved. I have seen auditors opt to "forgive" citations if the school has already implemented a "fix" that can be evidenced with results. And, even if they make the citation, the college is already implementing the action plan versus having to develop a plan. It's easier to respond with an existing plan that is already in place than to have to go step by step from scratch.
Excellent point, Julio - more and more, I have seen auditors "applaud" process improvement efforts which have been put in place prior to an audit, demonstrating that the company/college had an internal review process that successfully identified an issue and resolved it. The key to this is to do this far enough in advance of an audit to be able to demonstrate that the revised processes and procedures have, in fact, resulted in resolving the risk item/issue identified. If a new process has been put in place only recently, the auditor typically cannot validate that the matter is rectified.
I think for the most part every school department should be proactive in preparation for the inevitable audit/review. This should be an on-going process that allows time to identify and rectify problematic areas and implement changes. This will help to avoid any unnecessary madness on the eve or at the time of the audit/review.
I think it would be: same “audit†less stress.
Operating in compliance doesn't necessary means to know everything.
I have been on the receiving end of an audit many times. The first thing I would do is to review present policies and procedures. Then I would evaluate the processes of how the actions of those procedures take place to identify possible flaws in the system and draw a corrective action plan. Not always, but sometimes, if you demonstrate that you have already corrected what may come up in an audit as a finding, it may not constitute a finding and you might not be written up for it. And I think it is important to recognize that no one is perfect so there will be mistakes. The relevance is in them being isolated instances or reoccurring offenses, intended or not. And never forget that auditors are paid to find errors and improve the functioning of what they are auditing. So don't think they want to be out of a job because you are a good school. They will find, something. Sometimes is best to let them do just that.
Crhistine - Looking at your items from the eyes of an auditor is a great approach. What would you do if you find something unacceptable prior to the audit?
In preparing to be audited, I would do my best to ascertain the scope of the audit, then I would essentially perform my own "audit" of sorts prior to being audited in an effort to address issues that could be addressed proactively and to organize and prime staff for the actual audit. Generally, this is work that would/should be integrated into the regular function of any department that could be the subject of an audit anyway as part of normal business operations.
I would meet with all department managers and come up with a plan of what each department needs to review to make sure that we are being compliant in all areas. This way we would be prepared for the internal audit and we would hopefully have minimal findings, if any, in each department.
Shannon - two really important points in your comment: First, the dedicated team makes for emhpasizing this priority. Second, the variety of disciplines represented helps cover the vast areas that must be audited.
We use a dedicated team comprised of staff and faculty from a variety of disciplines for our audit team.
I agree with Bonnie. Preparation for an audit should never begin when you get notified that you will be audited--it's something that every member of every department needs to be striving for in their daily work.
Compliance every day is the key. Make unannounced "mini audits" by managers in each functional department. This keeps everyone's mind on compliance at all times!
Organization is the key. I would give thought ahead of time about what the autitors would be looking for and be prepared. I would make sure that all of my files were in order and that I knew where everything was.
