Plans, self-evaluation and the compliance job

We are still in January (just) so it still feels legitimate to talk about compliance plans for 2016. Plans can start and finish when you like of course. So let's start here. One of the first things I like to put in is approximately what date the annual statement of compliance (SoC) will go into Ofqual and then work backwards a couple of months to factor in a self-evaluation exercise and timings that fit around when governing body meetings will be happening to report in on the exercise.

In 2015 evidently there was some very mixed activity on self-evaluation, and possibly no self-evaluation for some AOs. Why do I say that? For me the report that came out of Ofqual last week ‘Statements of Compliance’ shouted out their lack of confidence in both statements and processes AOs followed in making their SoC.  If Ofqual are planning follow up for as many as 47 AOs - that's almost 1 in 3 – and believe 23 AOs made inaccurate statements (based on evidence they hold) they must have some serious doubts about compliance monitoring, how AO governing bodies are engaged and the oversight in place.

Getting back to self-evaluation, the benchmarking research I did 2 years ago on the subject I found AO’s practices were hugely varied: no surprise. What staff got involved (levels and seniority), the business functions included in any exercise, recording tools, use of consultants, etc showed no similar patterns. But one thing all the AOs involved in the research confirmed was good engagement with their governing body. There was some good ideas and approaches in AO practices that were shared in the research too.

One thing that has changed - Ofqual now don't ask for information on the self-evaluation process. I wonder if that signaled that self-evaluation was therefore not important or needed? A cause of SOCs being less trustworthy? Whatever your view I like to encourage both ongoing compliance monitoring and an annual self-evaluation exercise. Depending on the size and complexity of the AO more or less evaluation and time for any exercises may be needed of course.

Back to the plan. Let's put in it a policy review, sometime each month to look at various policy and procedures - prioritise data protection, conflicts of interest, gifts and hospitality, qualification design, development and review procedure, and malpractice and maladministration. Then some time for sorting out the file sharing and document control. A day a month on risk, updating the register, spending time with teams to help them assess and address risk. Governing body meetings, preparing reports for those. The self-evaluation. Update the plan for provision and complete the TQT (total qualification time) and credit rating exercise; making sure qualification specifications and website information is updated. Carry out regulatory reviews within 3 of the AO functions. That looks like a full year. If you have an audit from Ofqual, well, who needs holiday?!

The job of compliance is growing. I think about compliance as maintaining standards and making things the best you can. Each team and staff member have a stake in maintaining standards and raising quality so by default they are involved in compliance – with the benchmark being Ofqual’s Conditions of Recognition. Communication on this is the key. Good luck with the plan.

Heather Venis, Principal of Awarding First

See my earlier guidance on self-evaluation – see 5th August and 23rd June

For independent and objective support with your self-evaluation and compliance plan give me a call on 0789 479 6262 or email heather@awardingfirst.co.uk