Memorandum #215 Management of External Audits and Program Compliance Reviews

Originally issued: June 17, 2002

Revised: February 8, 2021; May 22, 2009

New Policy

The following procedures are to be employed in handling audits and other external reviews for financial, programmatic and information technology systems compliance with external regulations. Program accreditation/reaccreditation and other external program reviews not related to regulatory compliance are not included in these procedures.

1. The Program Manager, upon notice of audit or external review, will immediately inform the Program Manager's Supervisor, Area Vice President/Senior Staff Member, Controller, and Internal Auditor. If grant or other special funding is involved, the Office of Institutional Advancement should also be informed.
2. The Controller and Internal Auditor will meet with the Program Manager to review scope of audit and required preparation before external auditors/evaluators arrive on campus. If possible, the Controller and Internal Auditor will confirm institutional readiness for audit/review prior to its being scheduled.
3. Entrance interviews must be scheduled before any on-site work begins. The Controller and/or Internal Auditor will participate with the Program Manager and other key people in the entry interview to understand scope of the audit/review and help identify any College issues associated with providing records and documentation. The Controller and Internal Auditor will confirm institutional readiness for audit/review.
4. For all financial audits, the Controller's Office, in collaboration with the Program Manager and Internal Auditor, will coordinate the audit/review process including interview schedules and providing access to required documents. For some audits, e.g., the State reimbursement audit, some information may be provided in an electronic format to the auditors. It is the responsibility of the Controller, Internal Auditor and Program Manager to ensure that access to information is limited to that required to undertake the audit, and that there is no possibility that institutional data can be compromised during the audit. The audit coordination team will also ensure that all audits will be conducted in a manner that ensures that student and staff privacy rights are protected.
5. Audit/reviews, which are primarily programmatic in nature, will be coordinated by the Program Manager who will collaborate with the Controller and Internal Auditor to ensure appropriate staff interviews and access to documents are accomplished. Audits/reviews which result in recommendations to create or strengthen internal controls will have the results reported to the Audit Committee of the Board Trustees and management will provide progress updates to the Committee on any agreed-upon recommended actions until all are completed.
6. Under no circumstance will external auditors/reviewers be provided access to College records and staff without oversight by the Controller, Internal Auditor, and/or Program Manager. Throughout the audit process, it is expected that, if requested, all staff will be available for audit questions and responsive to requests for documentation.
7. Throughout the audit/review process, the Program Manager, the Internal Auditor and/or Controller will keep the President and Area Vice President informed on the progress of the review/audit and report on the issues which may have financial or programmatic implications.
8. Along with the Program Manager and other key staff, the Controller and/or Internal Auditor will attend the exit interview and ensure that the President and appropriate senior staff are made aware of all key findings.
9. Once the formal audit report is received, a College response, including a corrective action plan, will be developed by the Program Manager. The Program Manager will work with the Controller to develop the response if there are financial issues within the audit scope. The Internal Auditor, President and appropriate senior staff members will review the response before it is issued.
10. Audits with significant programmatic or financial implications, as determined by the President, will be reviewed by the appropriate Standing Committee of the Board for information purposes.