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.
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.
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.
Besides an internal audit, might anyone have a good outside auditing source to recommend? Seeking a firm which can simulate a rigorous DOE audit.
I have a comment on using the "Campus Based Employees" to conduct the audits. Do you feel that lack of independence becomes an issue?
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.
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!
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.
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.
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.
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 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 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.
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.
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.
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.
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.
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"
We create audit teams to go around to visit the campuses and conduct compliance examinations of the respective areas; admissions, financial aid, academics, etc.
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.
