Campus Compliance Audits

Potential Testing Areas

TEST AREA / RECOMMENDED TESTING METHOD OPTIONS/COMMENTS
General Institutional Requirements
Institutional Effectiveness /
  • Verify that a plan is documented.
  • Test plan objectives as desired.
  • If institution is on “reporting” for areas of deficiency, test to ensure reports are submitted timely and that items indicated on plan are actually in place.

Structure and Governance /
  • Clearly stated in catalog
Note: Auditors should understand fully the legal structure of entities and the institutional structure as it relates to OPE ID’s for effective testing in other key areas.
Reporting /
  • Ensure that external reports are submitted timely.
  • Test for accuracy of a sampling of data provided in reports. Require back up data supporting key numbers reported.

Financial Stability /
  • Request evidence of financial stability of the company.

Disclosures /
  • Test to ensure that disclosures for employees and students are available upon request and published/distributed as required.

FERPA and Privacy /
  • Review institution’s policy regarding this matter and test accordingly.
  • “Mystery inquire” about a student’s records to test school’s enforcement of privacy.
  • Interview employees to see if they know what can and cannot be released without consent.

Document Retention /
  • Interview employees regarding policy on destruction of records and measure against regulatory bodies.
  • Identify documents that should be purged and test to see that they are not on file.
  • Review process for identifying documents to purge.

Campus Approvals /
  • Request current Participation Agreements and ECARs. Ensure that all locations and programs are listed if Title IV funds are being disbursed.

Human Resources
Compliance with all relevant labor laws /
  • Key areas to test include: FLSA statuses (exempt vs. non-exempt), EEOC (discrimination in hiring, promotions, etc.), ADA considerations, COBRA – timeliness of notification to ex-employees, harassment – policy in place regarding all types of harassment (not just sexual) and opportunities to report and have allegations investigated.

Compensation within regulatory guidelines /
  • Key areas include compensation to employees in admissions, enrollment and financial aid positions.

Admissions representatives licensed, if required /
  • Check for evidence of licenses on file for all practicing representatives based on state requirements.

Employees meet relevant qualification requirements /
  • For positions where specific qualifications are required, check for evidence of credential on file.

Faculty credentials /
  • In keeping with regulatory guidelines – match by course/program as required.
  • Supporting documentation available – official evidence of credential(s) earned.
  • Ensure required documentation is on file including resumes, data sheets, transcripts, job descriptions, etc. based on relevant regulations.

Faculty course load /
  • Ensure that the amount of courses a faculty is teaching is within regulatory guidelines (typically programmatic and accrediting body regulations).

Ratio of full-time to part-time faculty acceptable /
  • Compare actual ratio to any regulatory body requirements – typically the institutional and programmatic accrediting agencies.

Training/development opportunities provided for staff and faculty as required /
  • Check for evidence of training and development (in-service) typically required for key management employees and faculty.

Employees maintain memberships and certifications as required /
  • Check requirements and compare evidence of current memberships and certifications as required.

I-9s on file /
  • Test sample of current and former employee files for evidence of I-9s on file.

Facilities
Approved by all relevant regulatory bodies /
  • Check local requirements and test accordingly.

In compliance with all fire, safety and sanitation requirements /
  • Verify evidence of compliance with appropriate agencies.
  • As you tour building, verify that fire extinguishers are not expired.

In compliance with accessibility requirements. /
  • Perform general check for provision of accommodations for disabled persons. Parking, ramps, elevators, restroom stalls and wide doors are the basics.
  • Review process for reviewing and providing for reasonable accommodations.

Appropriate for type of instruction /
  • Programmatic requirements should be reviewed and verified.

Classrooms appropriate for volume of occupants /
  • Occupancy limits are sometimes posted. Verify against class counts for classrooms and/or perform visual check.

Equipment and furniture appropriate for type and volume of occupants. /
  • During tour, note any concerns and research for any potential violations.

Recruitment/Admissions
Recruitment efforts not misleading/embellished
(Communications between employees and prospective students) /
  • Mystery shop
  • Review scripts used for training/during calls/interviews with prospects.

Recruitment materials not misleading/embellished
(Advertisements) /
  • Determine if documents were “approved” internally based on company approval process (if any).
  • Check to see that all advertisements (print, web, audio and video) are in compliance with all regulations. (most regulatory bodies have checklists – most include the following at a minimum)
  • Factual – no hyperbole/superlatives
  • Reference to training versus job availability
  • Appropriate references to accreditation and approval bodies (institutional, state, and programmatic)
  • Includes institutional name prominently
  • Location information as required (full address for most)
  • Testimonials factual and documented with approval by author
  • References to Title IV funding include reference to availability only if qualified

Incentive compensation /
  • Policy review
  • Review payroll records – flag major changes from one period to the next; review for detail.

Referral incentives appropriate. /
  • Review current regulatory guidelines (have changed several times over a relatively short period of time).
  • Request list of all payments made that are coded to this type of transaction. Review for compliance with above guidelines.

Consistency in docs – enrollment agreement, Catalog, transcript /
  • Select sample. Pull files to review enrollment agreement; compare to catalog in effect at time of enrollment, request transcript from system of record. All should match.
  • May also choose to compare catalog program info to that approved by all regulatory bodies.

Enrollment agreements/incentives /
  • Ensure enrollment agreements contain information required by regulatory bodies. Most national accrediting agencies have a checklist specific to enrollment agreement requirements.
  • Ensure enrollment agreement accurately reflects what should be included for the program. Make sure incentives are within regulatory guidelines and that agreement clearly reflects such.

Quotas/pressure /
  • Interview admissions/enrollment representatives.
  • Determine if statistics reveal unusually high volume of early drops, high cancel rates, low retention rates.
  • Perform statistical analysis to determine how entrance exam scores relate to student success/completion.
  • Determine if rate of enrollment volume approaching start is unusually high.

Admissions Policies /
  • Either using system data and/or file contents, determine if students have the documentation to support program eligibility. (Proof of HS/GED, entrance exam scores, etc.)

Catalog /
  • Review against accrediting body checklist. (Typically a lengthy list – often included as an addendum to regulatory guidelines/standards).

Tuition discounts /
  • Review tuition adjustments posted to sample students’ accounts (or using system generated report for larger population testing). Identify reason for adjustments. Determine if each adjustment is appropriate and if it was properly documented.

Disabled students /
  • There are two points on this – first, is to make sure students are not admitted that have a disability that would prevent them from being successful in the program and/or in the career field. On the other hand, admissions should not discriminate if the disability will not impact student and career success and if reasonable accommodations can be made to assist the student. From a testing perspective, this is a difficult area to audit. Ask for procedures for identifying students who require accommodations and requirements for admission that involve standards relative to physical and mental abilities. Interview admissions and academic employees (including faculty) to identify any exposure in this area.
  • Proactive suggestion: Create standards for each program based on bona fide requirements.

Disclosure requirements /
  • Identify disclosure requirements based on regulations for school. Request proof of providing such to students and request to view the disclosure documents.

Placement test /
  • If advanced placement or remedial courses are offered based on assessment results, audit files or system in data for test scores. Ensure students reviewed were appropriately scheduled based on their assessment results.

Entrance tests /
  • If entrance tests are required, check exam scores in database and/or pull files to validate that they meet minimum requirements for admittance into relevant program.

Background checks/drug screens /
  • If required, validate that such are on file for a sample of students.

Student testimonials/endorsements /
  • Verify that signed releases are on file
  • For some regulatory bodies, only graduates may provide. Verify graduate status of individuals quoted.

3rd party contract recruiters, how and where /
  • Ensure any outsourced recruiting activities (i.e. lead generation, referrals) are in compliance with specific regulations for location of recruitment activities, compensation for services rendered and how prospects are approached.

Not guaranteed FA and job /
  • Interview students
  • Review admissions scripts
  • Mystery shop

Placement/retentionrates /
  • Where required, ensure that rates are accurate and provided to enrollees per guidelines.
  • Ensure that any references to rates are within regulatory guidelines for your institution – typically includes accrediting body and state requirements.

Non-discrimination /
  • Review documents that include demographic information. Ensure that these are not used as a basis for admitting students.

Grievance procedure /
  • Verify that a grievance procedure is published for students and that it meets regulatory guidelines.
  • Request list of students who have filed grievances. Review files for documentation relative to the grievance filed.

Foreign students /
  • Ensure that foreign student requirements met including:
a)Eligibility – proof of prior education w/English translation and interpretation, if necessary.
b)Visa requirements met
c)English fluency
  • Verify that tracking methods are in place to report foreign student enrollment figures accordingly.

Academics
Student recordkeeping /
  • Ensure that published policies are consistent in the various places they are noted. (i.e. compare catalog, student handbooks, forms, syllabi, etc.). Note the following key areas for consistency:
  • SAP
  • Transfer credit
  • Attendance
  • Grades
  • Select sample of students or pull data report for sample period. Test for the following:
  • Attendance posted with accuracy and timeliness.
  • Grades posted with accuracy and timeliness.
  • Grade assignments appropriate.
  • In keeping with published grade scale. (Any grades issued that are not in catalog AND on transcript fee should be noted).
  • No evidence of grade inflation.
  • Transfer credits awarded and documented appropriately.
  • Test outs or experiential credits awarded and documented appropriately.
  • Transcript content matches grade scale and relevant standards and program content as stated in the catalog and on the relevant enrollment agreement.
  • Status changes processed timely.

Enrolled students never attending class /
  • Using list of students identified as “new starts” (or equivalent terminology) from last start date, request attendance records. Note any students indicated as a start that do not have attendance posted.

All approvals in place – e-app / See General Institutional Requirements Section
Instructor qualifications / See Human Resources Section
Lesson plans, syllabus approval /
  • Select sample of classes offered during current term. Request syllabi and lesson plans in accordance with regulatory requirements.

Leaves of absence /
  • Review policy as stated in the catalog. Ensure policy is within regulatory guidelines.
  • Select sample (or entire) group of students who have taken LOA within certain period of time. Using sample, review for the following:
  • Complies with institutional policy.
  • Does not exceed 180 day requirement
  • Returns dated in accordance with policy to return at point of departure
  • Documentation on file supporting “reasonable” expectation to return.

Satisfactory Academic Progress (SAP) /
  • Verify that policy is stated in catalog.
  • Ensure that policy includes required components.
  • Select sample of students (or complete group cohort) who have hit the timeframe for SAP review. Test against the following.
  • Timing of measurements appropriate.
  • Qualitative measurement (to reach minimum GPA at graduation).
  • Quantitative measurement (prevent exceeding maximum time frame).
  • Applied to all students (not just Title IV recipients).
  • Probation guidelines enforced.
  • Grades applied according to policy (i.e. withdrawals, repeat coursework, leaves, pass/fail vs. letter grades, course incompletes, etc.).
  • Enforcement based on policy including SAP status for students approved to return after withdrawal period.

Contact hours for courses /
  • Observe class start times and end times to ensure classes are conducted for time listed in schedules (if relevant).

Pre-requisites /
  • Select sampling of student transcripts. Ensure pre-requisites were enforced based on course completion dates.

Class size limits /
  • Review regulatory requirements (most institutional and programmatic agencies have guidelines). Request rosters or report showing volume of students in each course to compare to restrictions.

Document retention / See General Institutional Requirements Section
Language proficiency / See Admissions Section
International students – SEVIS / See Admissions Section
Student services – ATB mandates /
  • Review regulatory requirements. Ensure that staffing includes Student Services representatives in accordance with guidelines.

Student evaluations of courses and instructors /
  • Request access to evaluations maintained on file. Determine frequency of evaluations.

OSHA requirements / See General Institutional Requirements Section
FERPA/Campus Crime stats / See General Institutional Requirements Section
Faculty development/continuing Ed / See Human Resources Section
Advisory Boards /
  • Ensure that advisory boards in existence and meeting regularly as evidenced by minutes/notes.

Library/Resource Center /
  • Review regulations and visually verify that resource center and appropriate type and volume of resources are accessible to students.

Curricula /
  • Verify that curricula offered is approved (approval notification on file) and in keeping with all regulatory requirements (including programmatic approval bodies, where applicable).
  • Units of conversion appropriate (credit-to-clock; clock-to-credit) based on mix of lecture, lab, and practical components.
  • Program lengths acceptable.
  • Credential awarded acceptable.

Copyright/Software Licensing /
  • Request to see documentation supporting volume of software licenses in use.
  • Observe work areas to identify any possible breaches to copyright laws.

Financial Aid
Discrepancies in file documents – multiple files /
  • Look for changes (white out, crossed out info, erasures, etc.) Compare documents. Any discrepancies should be clarified in additional supporting documentation.

Financial records (ledger) maintained for each student. /
  • Request sample of student ledgers. Review to ensure that each clearly show charges, payments and balance.

Financial aid awards /
  • Verify that award decisions are made by appropriate employees.
  • Ensure award letters are issued within guidelines.

Tuition and fees /
  • Review sample of students within same enrollment period. Review to check for consistency for all enrollees within effective period of rates.
  • Review guidelines on charges and ensure that school is charging in accordance with requirements. (i.e. fixed rate for program, etc.)

Title IV eligibility requirements met. /
  • Accurate cost of attendance (COA).
  • Accurate Expected Family Contribution (EFC).

Institutional Scholarships/Grants documented and awarded appropriately. /
  • Request listing of all institutional scholarship and grant recipients.
  • Ensure all are appropriately published and information readily available/provided to all students.
  • Audit sampling (or all if small number) of recipients to determine if selection criteria was administered accordingly.

Default Management /
  • Select files of dropped and graduated students. Ensure that evidence of entrance and exit counseling is contained within files. (Note dates to see if counseling was conducted timely).
  • Check default rates for last three years to identify any trends which may warrant intervention.

Lender Notification /
  • Request proof of notification to lenders for students who fall below half-time enrollment status.

Professional Judgment /
  • Request files of students for whom professional judgment decisions were exercised. Validate that documentation on file supports sound decision making. (Particular area of focus has been dependency overrides).

C codes verified /
  • Review sampling of files that had c-codes and verify that they were properly cleared prior to disbursement of awards.

Appropriate signatures on documents /
  • Review sampling of files. Check for signatures based on dependency and marital status. (Check for student, spouse and parent signatures as required).

Verification /
  • Select sample of students selected for verification. Validate that deadlines are set for concluding verification. Determine enforcement of procedure in place if verification is not concluded.

Non-selected students don’t have information in file that was not used for verification /
  • Particularly a risk area in campuses where prospects are asked to bring in tax information during initial visit. Select files that were NOT flagged for verification. If tax information is contained in file, determine how/if this documentation was used.

Admissions requirements met – HS/GED, etc. /
  • Previously listed in Admissions section.

Disbursements /
  • Test sample of disbursements for the following:
  • Timing
  • Appropriate amounts
  • Student eligibility met
  • Units earned/attempted
  • SAP requirements met
  • Verification concluded, if selected.

Refunds /
  • Refund policy within regulatory guidelines and stated in catalog.
  • Test sample of dropped students. Determine if refunds were made with accuracy and timeliness. Include test for 30 day issuance of refund and 45 day clearance of payment.

Non-citizen eligibility /
  • Select sample (or all if small number) of non-citizens. Ensure documentation is on file in compliance with Federal guidelines for eligible non-citizens.

Satisfactory Academic Progress (SAP) / See Academics Section
Date of Determination (DOD) /
  • Select sample of students or pull report from system. Test by calculating the days between last date of attendance and date of determination. Compare to catalog policy on attendance guidelines related to institution initiated withdrawals.
  • Identify students who requested withdrawal and ensure that DOD aligns with their request date.

Credit balances /
  • Select sample of students with credit balances for a prior date. Determine if balance was released timely (stipend) or that authorization to retain funds was on file for student.

Separation of duties /
  • Interview staff, review processes and procedures; verify that signatures relate to appropriate titles/departments supporting guidelines.

IPEDS, SSCR and other external reports /
  • Check for submission of such reports. Verify timeliness of submission. Verify accuracy of content by requesting supporting data files/reports.

FERPA / See General Institution Requirements Section
Federal Work Study /
  • Areas to test include:
  • Community service requirements met
  • Family literacy requirement met
  • Timesheets accurate and signed
  • Off campus agreements maintained
  • Responsibilities within guidelines

90/10 Guidelines /
  • Request documentation supporting last reported 90/10 calculation. Verify that correct formula was used including how various fund sources were applied to the calculation.

Placement
Verification of employment /
  • Documentation validating such verification should be on file (hard file and/or electronically).

Employer satisfaction surveys /
  • Request evidence of surveys – review for frequency of surveys.

Authenticity of placement documents /
  • Review documents – ensure graduate signatures are in place where required.
  • If exit documents required, ensure on file and within appropriate timeline (not just a mass collected recently).
  • Ensure that other documents are in place as required.
  • Waivers – for reasons deemed legitimate for the regulator with supporting documentation as required.
  • Proof of continuing education or military duty if required.

Graduate surveys /
  • Request evidence of surveys – review for frequency of surveys.

Placement rates/methodology, appropriate for each state and/or accrediting body /
  • Review relevant guidelines and formulas for reporting placement rates. Ensure definitions of each category were accurately considered and that placement rates are accurate based on the definitions and formula calculations.
  • Ensure that date of placement is in compliance with guidelines based on graduation date.

Externship sites /
  • Determine if evidence is on file verifying the quantity and quality of sites used for externships.

Reporting salaries /
  • If salary reporting is required, verify accuracy of most recent reporting period against documentation contained within files and through phone verification with employers and/or graduates.

Length of internship/externship, %, length /
  • Ensure that percentage of program spent in internship is in compliance with regulatory bodies (usually institutional accreditation and programmatic agencies).

Collection of documentation of attendance at internship /
  • Validate that process in place to gather and report student attendance at internship is reasonable and consistent with guidelines and program completion requirements.

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