Mary,
Compliance audits are a good tool to insure a college's administrative capability; however, it is important that college does their own internal review periodically to insure no areas of non-compliance. I often recommend that the staff bi-annually or quarterly to sample their student files and review internal procedures.
Chyrl
The school must write a response and Corrective Action Plan for the several noncompliance findings. It is time consuming, not mentioning the credibility the school is going lose.
I agree that it can be time consuming to formulate a corrective action plan and make sure that it is followed. Also, depending on the number and nature of noncompliance issues, it can cause other compliance audits.
A corrective action plan will have to be submitted. Based on this the DOE will decide if Title IV funds will need to be returned.
Janele,
You response it correct about the results of a compliance audit. The institution will be given the opportunity to remedy any issues; however, it is important for an institution to have policies and procedures in place to prevent issues. It is important for each memeber of the institution's management team to understand and adhere to the policies and procedures.
Thanks, Chyrl
This is a very good point about how findings and then the subsequent corrective plans can affect all departments of a school. We try to make sure all departments have a responsibility in correcting errors if they are found.
Kim,
Involving all departments in the corrective action plan is an excellent idea. It is important that all departments are involved in the resolution of findings and that each one acts upon the corrective actions.
Thanks, Chyrl
In some sense I agree with the statement "It is important for each member of the institution's management team to understand and adhere to the policies and procedures." I am just not sure how easliy it is accomplished. It is one thing for the Financial Aid Department to understand and adhere to policies, but I think it asking a lot to expect all members of the management team to be knowledgable.
I do not currently work in Financial Aid, and I am taking this class in an affort to become more knowledgable, but I doubt I will ever have a true understanding of cash management, or accounting etc....
In my opinion, the problem with having several non-compliance findings are two-fold. Firstly, it will bring about the need for corrective actions (and possibly require a return of funds, or even lead to criminal investigations). Secondly it will probably result financial aid officers being asked to resign so that they can be replaced by more competent alternatives.
Valerie,
There is a gre deal of informtion to learn related to each aspect of an institution. I definitey understand why you might not agree with the statement; however, the entire management team has a responsible to adere to the Policies and Procedures of the institution to insure compliance.
Thanks, Chyrl
Valerie,
In some cases your scenarios are correct; however, most non-compliance will result in less drastic measures. Non-compliance findings my result in reconstructions (which can be costly to the institution), fines, repayment with interest/penalty), and loss of eligibility to offer TIV funds. Institutions should inspect the work being done in all areas to prevent non-compliance.
Thanks, Chyrl
You're correct. Compliance audit does put more work on the SFA department which will reflect any issues/findings the auditors find that will affect Title IV eligibility.
I think the hardest part is for departments to work together and implementing corrective action plan that will not create a repeat finding.
Athena,
It is difficult to coordinate corrective action across departmental lines; however, the overall success of the institution and students should enable all departments to come together to resolve issues. I recommend that institutions do their own internal reviews periodically to ensure compliance.
Sincerely, Chyrl
I think we should be more proactive from the beginning and not wait to be reactive once the problem is here.
Marlene,
I agree. When it comes to compliance it is best to attack it each day. Insure that your files are 100% accurate. Have others in the office check behind each other to guarantee that files are complete and accurate.
Sincerely,
Chyrl
Correct, I believe this to be a systemic problem. The solution has to come from the top down.
Unfortunately, there are times when schools will try to use a "band-aid" approach and reorganize individual departments (i.e., try to find scapegoats). The sooner the ownership/executive management realizes it is an issue that effects the entire institution as a whole, the sooner these problems can be resolved.
By the way, sometimes people view audits and program reviews as a bad thing. Since they're in the same category as death and taxes, let's embrace what they have to offer and look at it as an opportunity to improve. Might as well, right?
Carmen,
Great attitude. I always view audits and reviews as an opportunity for growth. Colleges should always be looking for methods to improve and audits are a good tool for measurement and growth. Your approach is right on the mark
Sincerely, Chyrl
I agree that all departments should be involved in the corrective action plan. It takes all departments to run a school, therefore, all departments should take some responsibility in correcting its mistakes and work collectively on its weaknesses. Afterall, that's part of what they call as "teamwork."
Having several noncompliance finding should motive the staff to learn and understand the laws of the compliance. Further training would be recommended.
Shawn,
The described method can be a hard lesson to learn but many of us in this field had to learn through "fire." Whenever you discover an area of non-compliance the best course of action is a plan on how to correct going forward and what is needed to clean up any issues of the past.
Sincerely,
Chyrl Ayers
