Common-sense tips to assist schools in establishing and maintaining a compliance-culture, assembled by Educational Advisors.
While the following is not a complete list of do’s and don’ts, it does provide a path to follow to ensure that your organization strives for a compliance culture.
Base business practices on the most stringent requirements you are governed by.
- Base your school policies, procedures, and minimum expectations on the agency that has the most stringent requirement for each area of the school.
- Agencies may include one or more of the following: Federal Title IV; Student Loan Providers; SEVP; Veteran Programs; Accreditation Agency for the School; Accreditation Agency for Program(s); State Licensure / Approval Agency for School and/or Program(s); National / State Program Specific Certification / Licensure for Graduates; Occupational Safety & Health Administration (OSHA); Human Resource Laws and Regulations; and, Workforce Investment Boards.
- Conduct a compliance review at minimum annually.
Embrace the industry through continuing education.
- Continuing Education includes instructional programs, attendance at conferences, seminars and workshops, or activity that brings participants up-to-date in a particular area of knowledge or skills.
- Continuing education shall involve all staff through in-services and/or professional development subjects based on their area of expertise.
- In-Service: Training focused on improving an employee’s performance within their position.
- Professional Development: Participation in activities that promote maintenance or furthering education in the area of expertise.
Do not recruit students already enrolled in another institution.
- Student recruitment activities shall not include recruitment of students attending other schools.
- Support the industry, there are plenty of potential students to go around.
Your integrity is based on behavior, not words.
- Provide clear expectations by demonstrating doing the “right” thing – based on adherence and supporting documentation that follows the most stringent regulatory requirements, facts, and best practices to promote the ethics and values of the school.
Honor and promote the success of your employees, students/graduates, advisory board members, and employers.
- Recognize the commitment, extra efforts, and input from employees, students/graduates, advisory board members, and employers by periodically documenting feedback (results of surveys) that states why or why not actions were taken as a result of feedback obtained.
- Periodically: At a minimum based on the most stringent regulatory agency governing the school or program.
Do not jump to conclusions. Gather all facts before making a decision.
- Take a step back – count to 10! There is always time to gather data and input, after removing the players from the situation, and before making a decision or providing feedback.
Do not make up data to meet requirements.
- Unethical behavior will cost you time, money, reputation, and your business. Maybe not tomorrow, next month, or next year….but no doubt soon!
Do not distribute copyrighted materials without written consent from the author/owner.
- Set aside time to research and gain approvals, as necessary, to distribute materials authored by an individual or group.
- Be aware:
- The internet is not a free for all.
- Educational materials are not exempt.
- Obtain written, not verbal authorization.
Do not use white-out to hide incorrect information.
- A favorite of compliance professionals, “Throw out the white out!” Promote transparency by documenting errors or a change with a line through the incorrect information, documenting next to the error the correct information, initialing and dating the correction. If the document is signed by more than one party, both parties must acknowledge by initialing and dating.
Ensure that student files communicate a student’s entire enrollment experience without having to ask an employee for an explanation – every file (to include employee files) should speak for itself.
And, our favorite… DOCUMENT, DOCUMENT, DOCUMENT!
- Assemble files by date, most recent document (on top) to oldest.
- Document each stage of the student’s experience, beginning with the time of enrollment, through the result of their withdrawal or graduation.
- Documents should evidence facts and outcomes, supporting the file’s contents.
- All blanks on any document need to be filled out – or acknowledged as to why the section is not completed.
- All required signatures and dates must be completed, and clearly identify the school representative who is documenting each part of the student’s experience.
Remember, if “it” is not documented, “it” did not happen.
California Bureau for Private Postsecondary Education (BPPE) Annual Report Submission Tips:
- Post all sections of the Annual Report to your website. Institution – Section 1, Program(s) – Section 2. Branches – Section 3, if applicable and Satellite(s) – Section 4, if applicable.
- SPFS must include all tables and all fields for all sections.
- Provide one link from your homepage, clearly and conspicuously displayed, leading to all Annual Report documents. Note: You may use the same link for the SPFS, Catalog and Annual Report.
- All verbatim statements required for the SPFS must be included in the SPFS as is.