Four Simple Strategies for Maintaining Compliance in Career Colleges
Maintaining compliance is a heavy lift for career colleges, but four simple strategies can help improve compliance in schools of every size.
Outside of student success, maintaining compliance is one of the most important focuses for career colleges. We talked with compliance leaders at our partner schools to learn some of their strategies for maintaining compliance. Four major themes emerged that make a positive impact on future audits. Here’s what they said.
Create Efficient and Timely Return to Title IV Process
In 2020, The Department of Education issued 850 findings for Return to Title IV delays and calculation errors. Some compliance issues are difficult to prevent, but ensuring accurate and timely R2T4 calculations is completely under administrative control and gets easier with the right tools and processes.
One of the most common delays and errors in the Return To Title IV process is the determination of a student’s last day attended (LDA). When a student is at risk, administrators keep a close watch on their attendance, examining attendance sheets as soon as they arrive. Unfortunately, sometimes attendance sheets don’t arrive until days after a student’s last day has passed, delaying the Return to Title IV process until days after the LDA.
Unitek, a California-based career education school, found that implementing a digital attendance solution was the most effective way to quickly and accurately determine LDA after receiving findings for delayed Return to Title IV.
According to Ena Hull, former SVP Compliance and Operations at Unitek and current COO at High Desert Medical College, a digital solution streamlined their process and significantly improved their Return To Title IV processes, eliminating R2T4-related findings. When students check in using their own devices, attendance data is automatically transferred to the SIS, eliminating the administrative burden on instructors. Instructors were pleased to have more time to focus on student success.
Ensure Your Data is Accurate and Verifiable
This one should be simple, right? But if you’re taking attendance on a pen and paper sheet, then manually entering it into the SIS, it’s vulnerable to fraud and human error. Plus, student and instructor signatures are often barely legible and can be difficult to compare side by side.
Auditors typically request a random sampling of student attendance data when completing an audit. Every piece of data must be 100% accurate and verifiable, and the most foolproof way to do that is through software. Software eliminates the human error that plagues manual attendance processes and reduces opportunities for fraud. Plus, software speeds up the audit process significantly. Instead of pulling dozens of paper files, administrators can generate an attendance report with the click of a button. Unlike hardware (a biometric scanner or card reader), software is easy to maintain and flexible in different environments.
Damon Fugett, Director of DeHart Technical School, recommends implementing an attendance software that verifies identity biometrically and automatically transfers data into the student portal. Before the pandemic, his school used a biometric scanner for in-person learning, but he wanted a solution that worked in different environments, including online and indoors/outdoors. Now, DeHart Tech uses an attendance solution with a Face/Fingerprint ID for online learning and QR-code for in-person learning.
“When I sit down with an accreditor who says prove to me that Tom Jones was here at 7:30, I show them Tom Jones ID, show them he’s set up on Face/Fingerprint ID and QR code using his ID and device, and show them that he clocked in from his device at this location at this time. I the easiest thing to set up, and I know it’s going to be accurate every single time,” said Damon.
Discover Fraud Before it Becomes a Compliance Issue
To an instructor, ending a night class 10-minutes early once a week may not seem like a big deal. However, it can open schools up to compliance issues and borrower’s defense claims. Sean Langford, internal auditor for Concorde Career Colleges, recommends tracking and monitoring when courses start and end. By understanding whether late starts or early dismissals are a trend or a one-off event, administrators can catch instructor fraud before it becomes a compliance issue.
Because Concorde instructors take attendance using CourseKey, they cannot falsify a class’s start or stop time. Students cannot check in until instructors start the session or check out until an instructor ends a session. Sean uses CourseKey’s automated “Attendances Deviating From Schedule” and “Adjustments Summary” reports to check for trends in attendance deviation and ensure instructors are not adjusting student time in bulk after a deviation.
React Quickly With Convenient Data
According to Sean, although a proactive approach to compliance is ideal, it isn’t always possible. When a compliance concern comes up unexpectedly, Sean recommends having convenient, verifiable data ready to show auditors and other interested parties. Having verified data in an SIS is a great start, but if you have to back that data up using hard copies, you’re stuck digging through files to resolve the problem. For example, Sean quickly puts fraudulent identity theft complaints to rest, sometimes through just one email, using verified student data stored in the cloud. Unfortunately, every industry has to deal with bad actors, but easily accessible data can protect your school and save your administrators time.
Make Compliance A Breeze
Many schools have implemented one or more of these solutions in part or full, but it’s critical to evaluate processes for improvement. Little things, like a real-time view into LDA, can add up when it comes to compliance and have a big impact on your audits.
Request a demo today if you’d like to learn more about how schools of all sizes use CourseKey to improve compliance.