Compliance and size of career school
Do you think that small schools - less than 250 students - should be subject to the same burden of regulatory requirements as larger schools? Schools with larger / multiple campuses typically have corporate compliance staff therby creating a competitive advantage against a smaller school which does not have the resouces for such a staff.
Jane - My personal opinion is that all schools should maintain standards of compliance. But, to your point, large school systems have different staffing resources to fulfill internal audit and compliance responsibilities. Having worked at a variety of sizes of schools, I have seen different task assignments to achieve compliant operations. Specifically, I have seen compliance responsibilities shared between heads of financial aid and academics or divided in a manner suitable for the particular method of operations. Some schools use some method of outsourcing to support compliance efforts - either by having a third party FA servicer to ensure compliance with relevant DOE regulations. Others hire a consultant to conduct internal reviews and/or to assist with external communications/submissions/reports for the myriad of regulatory bodies. I am convinced that if schools have a strong registrar in the academics area and a solid head of financial aid, those two roles can drive and maintain a compliant institution, regardless of the size.
I believe that small schools should be subject to regulatory requirements as a large school. Schools have to look ahead at their growth potential. It is easier to get into the habit of doing things "by the book" from the beginning rather that change later on.
Excellent point, Patricia. Establishing a habit is part of creating the compliant culture and it is easier to stay on top of things when the school size is small. However, some feedback I have received is that the small schools have challenges due to limited staffing to get things done in a timely manner when they are wearing multiple hats. Any suggestions from anyone out there on how to handle the broader responsibilities that typically come with being in a small school environment?
Larger schools with multiple campuses do have corporate staff that are available to assist; however, I don't see this as an ufair advantage. It easier to keep small schools compliant because there is less room for error and it is easier to maintain tighter control.
Shannon - This is good to hear. A lot of people from smaller schools have indicated shortage of staff, time, etc. I think either way - small or large - it's important to ensure there are enough resources to maintain the proper level of control.
What I would like to add is that hence all schools should comply with the same regulations, governing bodies, which usually have a pier review, should be responsible and diligent to review schools by interpreting the regulations commensurate to the school size. Sometimes, piers review schools of much smaller scale and expect the small school to comply at the level of a larger school. Compliance sometimes is not as objective; regulations are sometimes vague and it is left to the interpretation of the reader, therefore there are always different ways to comply with a requirement depending on the situation or school size.
Even within regulatory entities, reviewers/auditors may interpret requirements differently. I agree that while there are different ways to comply, it is imperative that the schools be prepared to justify/defend their interpretation. Even so, there is risk of being cited but, if a policy has been implemented consistently with a "defendable" interpretation, the risk is typically reduced.
I have owned a small school for 12 years and I think we should have the same regulations as any other school. The regulations are for the protection of both the consumer and the school. It is a challenge to meet those regulations, but as a small school owner the only option is to do much of the work yourself with the help of a great staff. Outsourcing is expensive for many small schools. I tried hiring a financial aid servicer when we first started in the Title IV program. The owner is held responsible regardless of who is in charge, so it is better to have complete control over the financial operations of the school so that refunds and returns are done timely, and funds from financial aid arrive timely for the students and for the efficient operation of the school.
Joyce - thanks for your insight as a school owner. I would be curious to see/hear from others on their experiences with FA servicers. I agree that the school is ultimately responsible but, I see many schools use servicers and many tell me they do it to "sleep better at night" knowing the servicer is watching the compliance side. However, the servicer is relying on data provided by the school. Does anyone out there have any feedback on this topic regarding the pros and/or cons of using an FA servicer?
I agree that even smaller schools with less than 250 students should be subject to the sames rules and regulations. The procedures and policies should be written and well documented to allow uniformity and also ease of transition of new employees.
Internal audits should be done each quarter to ensure compliance for each department. Assistance can be provided by external certified public accountants if needed.
I work with a school that has many branches of different sizes and each branch has always tried to remain compliant as a branch. I have recently been appointed to direct the compliance issue at all locations, and I was so happy to see how well this concept was embraced by the directors at each branch. I have visited with each location, and there are two things that I agree with: everything should be well documented ("if it's not documented, it didn't happen") and internal audits shoudl be done quarterly.
Thanks, Marjorie. I like hearing positive stories where things are working well and that compliance efforts are embraced by the directors.
For me, having worked in both small and large schools, I think it is easier for smaller schools to manage the compliance process. Fewer students and a smaller staff allows for everyone involved to know each student and each student's circumstances more intimately. Therefore, the margin of error is naturally going to be lower. So, with that said, smaller schools being subject to the same burden of regulatory requirements shouldn't be difficult at all. The larger schools with multiple campuses need corporate compliance because of sheer numbers and volume! I definitely don't see that as a competitive edge, but a functional necessity. If anything, a smaller school with a knowledgeable well trained staff has the edge in my opinion.
I think that smaller schools should be held at the same regulatory requirement as larger schools because it creates uniformity across the board instead of having one set of rules for us and another set for them. Different compliance procedures may also create that 'grey area' where some institutions starts to interpret the rules as it relates to them plus because there is always the potential for growth overtime, it seems like the best decision would be to implement one standard rule for every school.
I believe that all schools, no matter the size, should be held to the same regulatory requirements. Isn't the main objective of compliance for the benefit of the consumer? When a student attends an accredited school, whether large or small, they should feel secure that there are processes in place to ensure that the school is being held accountable to follow proper protocol.
As a school owner / administrator I believe that all schools should be held to the same set of standards. I think that it is easier for a small school such as mine because I personally know and understand each student as well as staff. If there is a problem then I know about it immediately. This helps to keep control of the suitation. It is difficult at times to "wear this many hats" but I believe very neccesary.
Gloria,
I agree that there are benefits of a small school but, it is hard to stay on top of everything for multiple departments and regulations.
Traci Lee
Regulation requirements should be standard regardless of an institutions size. It removes any ambiguity about what may or may not apply to a particuliar institution. Therefore, less confusion ensures for a more successful audit.
Compliance standards need to be uniform regardless of school size. I have been at tiny schools where compliance would be easy because there was no outside financial aid to track/refund and we had good teamwork to review catalog/policies/curriculum/website/advertising for consistency. We kept it simple. I am now at a college program with a staff that is out of my authority who will be part of the self-study but they have been through this multiple times for the accrediting agencies of other programs, so the only thing I hear is "Why don't the accrediting agencies use the same forms and timelines?" That is a good question. My only worry here is that if they are undergoing a review by another agency, they may back-burner my requests and I will not submit in a timely way. Just my fear, really unfounded here.
