I agree with you that following a compliant routine should be the way to stay on top of things. It seems that many schools still have to do the last minute scrambling to organize or structure files and records. In some cases, I have seen solid processes requesting documents up front but, without the discipline to ensure they are on file within a certain amount of time. For example, proof of staff and faculty credentials is often requested at the time of hire but, sometimes the documents are not received in a timely manner and this creates the "scramble factor" to follow up to get them before a visit.
I think first and foremost you must be compliant every day. Make sure all your files are up to date and make sure you are doing what you said you would do. If you follow the guide lines you don't have to scramble the week before your visit. You will know you have nothing to fear from an audit, because you do what you are supposed to do.
I also have a very small school but with no staff for help. I just have to be in compliance with everything all the time. Or they will shut me down. It's that simple.
Elizabeth - I completely agree with sharing audit scenarios with staff. A couple students had inquired about staff involvement with conducting the audits and the risk of independence in doing them that way. I shared the guest audit concept in response to that and a couple other messages. The ideal is to have both - staff involved and understanding the significance of audits but, independence to maintain the integrity of the review. I applaud you for your audit efforts in a small school as I know this is frequently ignored as a priority given staff limitations in a small campus.
We have a very small school with limited course offerings in one area of expertise only. While I understand your point on having a "guest" auditor I have found that by sharing audit scenarios with my staff they are more conscientious of the requirements of our school as well as the state.
Richard, I agree with everything you said. However, I've heard (many) examples of schools not affording their own employees the time needed to prepare and be available for an auditor. This is huge disadvantage for these schools! If an auditor is unable to reach a reliable and consistant contact person, who knows what could go unexplained and result in findings!
Dale, I want to be sure I understand your question. Some of the postings referenced incorporating campus based employees but, I thought the plan was not for them to audit their own campus but, other locations in the system. I was involved with internal audits where (as you may have read in the thread)we utilized guest audtitors from other campuses to conduct some of the audit tests. Guest auditors were "hand picked" based on their skills and professional traits. The tests we had guest auditors perform were very non-subjective but rather, quantitative in nature and the lead on the audit team reviewed the work closely. We never had an issue. But, if you are asking about campus based employees auditing their own campus, I would respond differently. While I think it's good for campuses to have their own compliance and quality checks in place, I do think it's best to have and independent team, although internal to the organization, conducting periodic reviews. I also think the reporting line of the internal audit team needs to support the concept of independence free of influence that could be construed as a conflict.
I have a comment on using the "Campus Based Employees" to conduct the audits. Do you feel that lack of independence becomes an issue?
Besides an internal audit, might anyone have a good outside auditing source to recommend? Seeking a firm which can simulate a rigorous DOE audit.
Rather than an internal audit team, has anyone tried hiring an outside accreditation consultant to do a regularly scheduled mock audit? Just wondering if it would be worth it to utilize a neutral 3rd party.
Seth - I agree with your areas of prep - and, it's also important to have the source data behind the statistics to be able to validate/prove the statistic. Additionally, since various regulatory bodies have differing formulas and timeframes for reporting statistics, it is necessary to understand and communicate which is being cited at any given time.
If I were on the receiving end of an audit, internal or external, I would certainly prepare as much in the way of data prior to the visit as possible. I would also be prepared to supplement any information presented, so that any questions could be clarified. For example, it would be necessary to have graduation and placement statistics, as well as employment verification worksheets, prepared if I knew an internal audit was aimed at the Career Services department.
I agree with this position every department, financial aid, adminsions office, scholarships and all departemnets they are in compliance with the regulations of the DOE and with the school policy.
It is important to prepare for the 100% of the scope.
Robert - you mention a key item - making sure all documents are available upon request. Failure to produce documents not only leads to findings but, also give cause for concern on the overall operations of the campus. Demonstrating the ability to provide info promptly gives auditors a sense that the campus is organized and operating smoothly.
With regard to your question on internal vs external, there are varying points of view but, if the appropriate structure is in place, an internal audit team can certainly be successful. There are various charter document samples on the web that outline some points to consider in structuring an internal audit department. I will try to review a few and post a couple to this forum for consideration.
Prepare to present to the Auditor the companies operating procedures, make sure that all documents are available upon request and that financial reports are completed. Is it really necessary to have a outside source doing the audit instead of someone from inside the company.
Cheryl - I will post some information on the guest auditor program this weekend. I think it's great to tie it into a leadership development program.
Traci-
I am interested in the "guest auditor" program as we are not quite ready to commit to a dedicated internal audit team. What were the criteria you used to determine who would be invited to participate?
My thought was to somehow tie it into a leadership development program. Participants in the program would be those who want to grow and develop their overall knowledge base of the industry, but who have had, perhaps, experience in only one or two operational areas. I would think that learning the audit process and conducting an audit would give the employee a solid overview and understanding of another operational area.
Traci - thank you those were great ideas. I will document the outcomes and also be diligent regarding sticking with my schedule.
Lori - Certainly it's nice to have a dedicated team from a resource perspective. However, I don't think it's bad to structure it the way you indicated. My main concern would be the risk of "higher priorities" causing you delays in actually getting to conduct the audits. The other factor to consider is the size of your organization. It's not unusual for companies to have a shared resource structure until they hit a certain size at which point a dedicated team seems warranted.
The audits themselves could be very successfully utilizing resources that really "know" the ins and outs. It's mostly the risk of distraction of day to day operations that would worry me in the big picture. I was in an environment recently where we did not have a dediciated team and that is exactly what happened and we delayed many of our audits from the original schedule. But if you can ensure that you will stick to an audit schedule without resources being pulled away, it could be successful. The bottom line is that it's better to do something than nothing. If for budgetary reasons, you structure it with resources that carry multiple responsibilities, I would suggest proceeding with it and documenting the beneficial outcomes in a way that may help you justify dedicated resources in the future if you experience the concern I have or if your institution grows to a size that warrants.
Traci: Do you feel it is important to have an dedicated internal audit team? We are struggling with the idea (and cost) of using a dedicated team. If we do, I will use your idea of incorporating campus based employees in some way -I think that will help them learn what is necessary and also give us (me) insight that we/I wouldn't already have. The impression I have gained from the responses here seem to indicate that a dedcated team is the way to go.
