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Report Calls for ED to Revamp Audit, Program Review Processes

By Brittany Hackett, Communications Staff

The current practice for audit and program reviews is a "lost opportunity" for the Department of Education (ED) and needs to be revamped into a more meaningful tool for federal oversight, according to a new report from the Center for American Progress (CAP).

Using over 6,000 pages of previously unreleased audit documents, the report's authors — Robert Shireman, a senior fellow at the Century Foundation, and Elizabeth Baylor and Ben Miller of the Center for American Progress — analyze how the current audit and program review process operates and what is most often uncovered, as well as how the process can be improved.

Overall, the authors determined that the processes related to audits and program reviews "must be substantially restructured," particularly in light of the collapse of Corinthian Colleges. The reviews for Corinthian and other schools, the authors note, were not "designed in a way that would capture evidence that a school is lying to or misleading students, failing to counsel them about their aid, or otherwise behaving in ways that lack integrity."

Rather, the audit and program reviews focus on bookkeeping questions largely related to the incorrect award of federal financial aid funds, and miss the mark on questions related to the fairness and honesty of a college’s marketing, enrollment, and institutional lending practices.

Calling this practice "a lost opportunity," the report's authors call for a shift in the approach and tactics ED uses for program reviews and nonfederal audit processes, including making the identification of misrepresentation "a core part" of the processes.

The recommendations in the report related to program reviews include:

  • Making program reviews about performance, not compliance;
  • Considering where oversight fits relative to other functions of Federal Student Aid (FSA);
  • Establishing special teams that monitor recruiting and advertising;
  • Rewarding staff for identifying misrepresentation and other non-dollar-based findings;
  • Devoting greater time and training of staff to reviews;
  • Aligning the scope of the review with the problems that triggered them;
  • Making information sharing between program reviewers and other investigating entities a permanent practice; and 
  • Restoring the independence of the program review process.

The recommendation related to improving nonfederal audits include:

  • Requiring auditors to certify there are no problems with bigger-picture issues;
  • Requiring backup documentation or key elements;
  • Increasing the capacity of the Office of the Inspector General (OIG) to review audits;
  • Requiring that all audits be published online; and
  • Updating the nonfederal audit guide.

"To keep colleges on their toes, those institutions must know that anything can be examined; that every recruiting call, any advertisement, all enrollment, attendance, and course records, and every employee training session could be reviewed; and that any findings of note — whether it has clearly stepped over a line or the practice simply reflects poorly on the institution — will be reported," the authors wrote in the report.

"Getting audits and program reviews to the point where they can better serve as a deterrent and early detection system warrants establishing new incentives and requirements for both auditors and reviewers that encourage them to scan and test for problems that do not necessarily show up through formulas and worksheets," they conclude.

 

Publication Date: 4/15/2016


Peter G | 4/18/2016 6:11:06 PM

"Rewarding staff for identifying misrepresentation and other non-dollar-based findings;"

That suggestion makes me leery for the same reason the Department prohibits direct incentives-based compensation of admissions/financial aid staff.

Why change the compensation structure at all? Just make it clear that objective assessment of xyz areas is a key component of the job on which one's salary relies.

James C | 4/15/2016 9:33:59 AM

I hope they also make it so it doesn't take 2-3 years to receive a preliminary report back from your program review.

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