What Triggers a Compliance Monitoring Audit?
I am sure, there are many reasons why a Compliance Monitoring Audit (CMA) is triggered by ASQA. In my experience, there are three major reasons. At the start of the audit, the lead ASQA auditor informs you why they (the lead auditor and the supporting auditor) are there. Today I would like to share with you the reasons I came to know based on my CMA participation in 2019 alongside my clients. The reasons were:
- a complaint made by your student/student’s representative directly to ASQA,
- as directed by the Commissioner, due to an unsuccessful application made previously and/or
- for non-compliance identified through PRISMS.
Regardless of the reason, my job was to support my clients to better prepare for the upcoming audit and support them through the rectification process after the audit.
So, how can you avoid the surprise of receiving a CMA notification email?
Firstly, let’s talk about student compliant. For a student to make a complaint directly to ASQA, it is most likely that he/she has tried to resolve the matter with you. Whether the student contacts ASQA or the Overseas Student Ombudsman, one of the first questions the student will be asked is “have you tried to resolve the matter with the college?” as this is the procedure as per the National Standards – contacting the external party when an issue cannot be resolved by the internal complaints and appeal process. What this means is you are already aware of the issue. Therefore, assisting students to have a better experience in your college is not just good business practice but, it is also related to your compliance obligations.
Yes, there are situations where students’ requests are not entirely related to policy but are sometimes just common sense! For example, when I was running my own CRICOS college, I had a student who complained about not receiving a Certificate of Completion while the student had failed to meet both academic and attendance progress requirements. Of course, the student had expressed dissatisfaction with the college and we made sure we followed our Complaints and Appeal Policies and Procedures. We even created a special folder with all the relevant evidence that had been collected for this incident. So, when the Overseas Student Ombudsmen contacted us and wanted to see the relevant policies and procedures and the evidence, we were able to validate our reasons for why we could not issue a Certificate of Completion to the student. Likewise, ASQA wants to see how you dealt with the matter in terms of reviewing your policies and procedures, and the relevant evidence. ASQA is not coming to attack your college, its purpose is to ensure you are compliant and the student has not been disadvantaged.
To avoid a Compliance Monitoring Audit that could be triggered by a complaint from your student /student’s representative, make sure you have:
- the valid/current policies and procedures
- followed your policies and procedures
- all the required evidence
How about a CMA directed by the Commissioner? Well, this could happen because of a number of reasons. However, the experience I had was that it eventuated from an unsuccessful ASQA submission, that triggered the suspicion of compliance of current practice at the college. For example, when you submit documents for an addition to scope, you are submitting documents that reflect how the provider will run the new course. If ASQA can see that the documents submitted have not been properly formalised as per the current National Code and Standards, then those documents are giving ASQA an indication that the provider has compliance issues that need to be looked at in detail.
Would you rather avoid a CMA directed by the Commissioner? Well, ensure you get someone experienced to review your documents first before making the submission. Make sure your documents are updated. Even if you are an experienced person, it is always better to have another person look at it and then make any necessary improvements before you submit. Even though I am a consultant assisting CRICOS colleges, I make sure another consultant reviews the documents before we finalise the work for submission. Two heads are Better than One, so seek expert assistance to avoid possibly triggering an unnecessary audit.
How about the last reason, which is due to non-compliance as identified through PRISMS? We all know that the ESOS Agents monitor PRISMS. However, what exactly triggers an audit when a provider uses PRISMS? One particular experience enlightened me to the fact that it was the ESOS Act 2000 Section 19 (1) c, d, e, f. It states:
A registered provider must give the following information within the applicable number of days (the applicable number of days means 14 days or less for underage students and 31 days for adult students) after the event specified below occurs;
Section 19 (1)c: the prescribed information about an accepted student who does not begin his or her course when expected;
Section 19 (1) d: any termination of an accepted student’s studies (whether as a result of action by the student or the provider or otherwise) before the student’s course is completed;
Section 19 (1) e: any change in the identity or duration of an accepted student’s course;
Section 19 (1) f: any other prescribed matter relating to accepted students.
How well are your staff inputting/updating information in PRISMS? Perhaps you need to consider if further guidance or professional development activities for your staff are necessary. Additionally, is the ESOS Act Section 19 (1) included in your policies and procedures? It might be an opportune time to review!
Well! On behalf of CRICOS Consultancy, I wish you and your business all the best in 2020! Personally, I don’t necessarily view an audit as a negative thing. For me, an audit is an opportunity to make necessary improvements, conduct good practice and accelerate business growth. That is why my clients invite me to conduct an internal audit, even though there may be no official audit scheduled by ASQA. I hope the information I have shared with you today will help you spend more time on growing your business practice, and less time on stressing about audits!