Controls and the control environment for Awarding Organisations 

Writing this I reflect on a productive Governing Body meeting with a client where we talked a lot about the controls that were in place to support compliance without using the ‘control’ word. So, what are controls and are they important?  Condition A5.2(e) is where ‘internal control’ gets a mention, however, Ofqual guidance in this area doesn’t say anything much to help us unpick it.

The idea of controls comes from the financial audit, internal audit and risk management disciplines. There is plenty of complex literature on the subject, but for me the simplest way to define controls is to give some examples. At the basic level the policies and procedures we have in the AO represent controls as they define the rules and principles, what we do, when we do it, who does it, etc. It’s about having in place things that provide a discipline that we respect and follow in an area; compared to a situation where there are no rules and random approaches that would lead to irregular and non-standard outcomes. 

The problem with controls though is they are not controls if they are not being observed. For example, where policy and procedures that are not being followed. Sometimes it can because staff and management don’t know they exist or they are ignored, don’t understand them, or just don’t think they are important. If you unpick that:

• don’t know they exist or are ignored – maybe they were never covered in staff induction, or initial training; or they are just stuck on the shelf, or used a door wedge?

• don’t understand them – training on them was insufficient?

• don’t think they are important – nobody asks about, or mentions them.

In any of the above scenarios the thing that is failing is usually not staff but the control environment. Disregard for management, poor supervision, lack of management support and direction are aspects of the control environment that may be failing, or may not exist in the above scenarios. Poor culture or ethics can also lead to failings in controls too. Things are usually complex and is not about one specific issues or failing.

In a short piece, there is a lot more that can’t be said. But getting back to the simple: I hope this piece gives a window on controls and the control environment. 

Heather Venis

Principal, Awarding First

Heather@awardingfirst.co.uk

Providing independent and objective evaluation, audits and reports on AO controls and their effectiveness