Great tip. Thanks, Kathleen.
Barbara - I completely agree. The challenge is sometimes HOW to present findings without coming across in an accusatory manner. Do you have a strategy for how to present findings to come across in your positive manner?
This is also my philosophy. Having created the internal audit procedures, I was careful to always approach issues with a non-accusatory approach. If the employees perceive you as being on their side, helping them to do the best job they can, everyone wins. The point is to resolve non-compliance, not to get people in trouble...
Linda - I like the idea of 100% compliance everyday. It makes for much easier preparation when there is a regulatory visit.
We were recently reviewed by acics, and worked to prepare for that visit. We decided that our four schools would work toward 100% compliance everyday. We send regional staff members out to campuses to randomly review files in each dept.....and try to coordinate this effort.
DeMario - I like your comment about a "pattern of compliance". It's that consistency that can make a difference - even if there were problems before a certain time, a pattern of compliance since that point can be helpful and convincing to auditors. Staff availability is also critical - having done audits, nothing is worse than not being able to get questions answered if the "person who knows" is unavailable.
In an ideal world Compliance should be a major part of the day to day operations. School policies and accreditation standards should be followed at all times. If this is truly the case then, preparation will be minimal. On the contrary, from my experience, circumstances can position you in uncompromising situation at times which may go against policy or accreditation standards. With that being said, it is imperative to maintain appropriate, detailed and organized documentation to show a pattern of compliance. I would ensure the documentation would be available for review and I would guarantee that the appropriate staff would be available to answer any questions the auditing team may have.
Kristina - I completely agree that the key to compliance is making sure your daily operations support compliance. I also think that it's important to prepare for the actual audit (when they are known in advance) by ensuring materials needed by the visiting team are easily accessible and organized and that individuals responsible for information during the audit are informed and block their time accordingly.
The only way to be prepared for a known audit, or any audit, is to be in compliance every day. If you are compliant daily, then preparation for an upcoming audit and the audit itself will go much more smoothly.
The first step I would take is looking for the guidelines for the audit/review. What items are required in the meeting room? What do I need to submit prior to the visit/audit? What am I finding as I prepare the items for the visit team? If it is an academic audit, I have all the academic files pulled: active; inactive; graduates; and withdrawn students. I assemble a team that I trust to organize the files in the order of the checksheet. We identify any items that are missing, if applicable, and gather what can be gathered. I look for things that I have seen missing in the past. We double-check all clinical/externship paperwork.
At the same time, I have the Human Resource Director pull all the faculty and staff files. We designate someone to audit the faculty files and look for missing official transcripts, employment paperwork, or evidence of faculty development or the plan itself. Then, the items are prioritized and delegated to someone to gather, if any items are missing.
All the documents for the meeting room need to be prepared in a way that makes everything easy to find for the auditors or visit team. All binders need to be clearly labeled. Files need to be organized consistently. Items that everyone on the visit team will need should be copied and placed at each seat. A computer person needs to be on hand to help with laptop issues or printing needs the day(s) of the visit.
The other steps depend on the type of the visit and the needs.
I agree that one should always be prepared for an aduit and work as if the aduitor is doing a visit evey week. I also think one way to prepare is to have peers review each others work.
Jane - One of the things to consider with the sample files is how the auditor(s) select the records for the sample. Depending on the purpose and scope of the audit, there may be a "targeted" sample whereby the auditor has already identified a potential problem and wants to dig deeper. Or, it can be a random sample for a general type of audit.
A school should review each of the departments that could fall under the audit review process - admissions, financial aid, academics and placement. The review could include policies and procedures and also a sampling of student academic and financial aid files, a sampling of refunds and title iv awards, a sampling of placement and completion results.
We create audit teams to go around to visit the campuses and conduct compliance examinations of the respective areas; admissions, financial aid, academics, etc.
I think the only way to be prepared for an audit, is to always practice being compliant. Review your work periodically, to see if you are "Following the Rules"
Kathleen - I think you are right that "keeping all departments on their toes" by knowing there is a continuous review process can help drive a compliant culture. Thanks for sharing.
Compliance needs to be a daily objective for every department within the school so you are always prepared for an audit. But proper training must be done so this can occur. It is up to the Director of the school and Director of Financial Aid to train their staff properly and then to monintor diligently. I find that it works best to be reviewing files on an on-going basis so by the end of the year I have already completed an internal audit. At my campus I usually have a week within a term period that things slow down, so I use that time to pull files. This keeps all departments on their toes knowing that I am constantly reviewing.
Right now we are in the final stage of a DOE audit – our first “real†audit since we began a little over a year ago to receive Title IV funds. (The audit the year before involved only a handful of students.) Our challenge in preparing for the audit was that we weren't sure what to expect. What we found out from an outside mock audit, from a representative from the DOE, and from the auditors themselves (who were here two weeks ago) was that we do indeed have a lot to learn. Even though it was a lot of work, this process has been good for us in that we have a much better idea what to expect for the next audit. Our goal now is to put well-thought-out procedures in place which will “catch†areas of noncompliance before they become entrenched habits that are hard to break. I'm working on establishing an internal audit chart that will cover all compliance areas in a one-year time span and incorporate requirements from the DOE, our accrediting agency, and our state certification board.
I like the way you state this, Myung. The common goal concept is a great perspective and approach to the audit process. In addition to the auditors needing this approach vs. the "gotcha" style, the campus operational management also needs to embrace the process. I sometimes see campuses trying to "hide" the facts, even if they are in compliance, rather than making internal audits collaborative. It may sound idealistic but, I have seen great examples of collaboration whereby the audit outcomes lead to progressive improvements that benefit all.
I think that if auditors demonstrated having the same goals as the campus reviewed, audits would be a much more simple process. However, like you said, some auditors do take a "gotcha" approach which makes the process that much more stressful. Therefore, I can't help but feel that some (and I stress the word "some") auditors aren't on the same team reaching for the same goals. The education sector is such an important one because we work towards enhancing people's lives. I think in this respect, auditors and campuses should work together towards finding things that may improve the quality of education provided to students.
