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.
I think it would be: same “audit†less stress.
Operating in compliance doesn't necessary means to know everything.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
He who fails to plan , plans to fail. We have been audited on several occasions and our experience tells us that we must forever be vigilent. We have internal requirements mandated by policy that helps us to be prepared no matter who may walk in our door unexpectedly.
Greg - Lessons learned typically lead to better planning. Hopefully, thru these discussions, we get to learn from each others' lessons as well as our own.
Most accrediting agencies will announce their schedule to the school if they are up for a visit. This allows the school to review their Institutional Assessment Plan to ensure that compliance measures are enforced. All to common though, schools develop Institutional Assessment Plans for their scheduled visit and never look back. The Institutional Assessment Plan should be a living document which allows the school to monitor their compliance on a daily, weekly or monthly basis
Well stated, James. I have seen many of these plans that are in a beautiful binder, perfectly labeled and indexed, and sadly collecting dust. Or, managers know about it but, the employees responsible for performing certain items are unaware of such plan when asked.
Are you sure it is a last minute scramble to have things in order or a last minute scramble to double (triple) check everything one last time before the audit?
So what steps do you take to ensure that this is done?
In the past, I have implemented self audits of all functional areas on a regular basis. This allows for us to be able to spot check at any time and make sure we are well prepared for any audit at any time.
Good point - hopefully, it's the double/triple check but, I have seen occasions when the scramble includes more than that...
We strive to always operate in compliance and DOCUMENT everything. We feel that if you can backup what you say, you will always be prepared for the audit.
