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Accountability

Published Date: April 01, 2016
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Monitoring, Auditing, and Remedial Action

AUTHORITY

Income and Employment Supports Act, Part 3
Training Provider Regulation

INTENT

The Government of Alberta conducts monitors and audits to ensure expectations as stated in the Income and Employment Supports Act and related regulations, policies and procedures are being followed.

This policy is specific to tuition-based training provider activities.

Contract-based training provider activities are monitored and audited in accordance with the Contract Management Policy and Procedures Manual.

POLICY

Monitoring

What is it: Monitoring is the process of reviewing tuition-based training provider activities and gathering information to ensure that the quality and quantity of services are delivered in accordance with Government of Alberta program objectives and requirements. 

Who completes the monitoring: Monitors are completed by Government of Alberta Authorized Officials.

Frequency: Monitors will occur as outlined in regional monitoring plans and may change through an ongoing risk assessment. In addition, monitors may occur as a follow up to an audit to ensure training providers are complying with their Post Audit Action Plan.

Purpose of Monitoring: To determine whether the obligations and expectations  of training providers are being met and, if applicable to ensure compliance with the Post Audit Action Plan.

Outcome of Monitoring: During the monitoring process, areas for improvement may be identified. The Authorized Official will work with the training provider to resolve identified issues. In the event an issue cannot be resolved it will be escalated to a Regional Manager and a special audit may be requested, which will be conducted by Internal Audit unit. In some situations immediate action may be required depending on the severity of the issue.

Escalation Process:

  1. When a special audit is recommended, the Regional Manager notifies the Manager Internal Audit unit and the Manager of the Employment and Training Operations unit of the issue and requests an audit.
  2. The Authorized Official and the Auditor will meet to confirm specific areas of focus for the audit.
  3. The Authorized Official notifies the training provider and sets up an Entry meeting with the training provider (See audit process).


Some situations may require the Government of Alberta to take immediate action. In these cases, the Authorized Official will notify their Regional Director immediately of the situation, who will determine the appropriate course of action with the Director.

Scheduled Audits

Who completes the Audit: Government of Alberta Internal Auditors

Frequency: Tuition-based training providers will be audited not less than once every three to five years,  based on the annual audit risk assessment completed. Additional audits may be conducted based on referrals from Delivery Services and the Employment and Training Operations unit.

What are they looking for: Scheduled audits will mainly focus on the following:

  1. Training Providers Attendance Policy and application of Attendance Policy. 
  2. Accurate and timely reporting of learners who never attended or have been withdrawn from training.
  3. Repayment of tuition fees for learners who never attended or withdrew and for payments that have been made in excess of the amount owing. 
  4. Staff qualifications, instructor capability, and facility.
  5. Maintenance and security of records


Audit Process

There will be an Entry meeting between the Government of Alberta (represented by Audit), the Authorized Official, and the training provider. The Government of Alberta Auditor will do sampling and collect data as required.

Auditor will draft their findings and share the Draft Audit report with the training provider, the Authorized Official and Regional Management and the Employment and Training Operations unit for feedback.

Auditor will incorporate applicable feedback into the Draft Audit report and schedule an exit meeting with the training provider.

The exit meeting involves the Auditor, Authorized Official, and the training provider for a discussion of the Draft. The Audit findings will be discussed and if applicable, a Post Audit Action Plan will be created. 

Auditor will finalize and issue the Audit Report, and if applicable, create a Post Audit Action Plan.

The Post Audit Action Plan will identify the issue(s), the steps that will be taken to rectify the issues(s), and the associated timelines.  In the event a Post Audit Action Plan cannot be agreed upon, the Government of Alberta will consider the training provider to be non-compliant and may take remedial action.

Post-Audit

The Authorized Official will follow up with the training provider based on the timelines identified in the Post Audit Action Plan to ensure compliance. In addition, the Auditor will follow up with the Authorized Official.

If the training provider has complied with all requirements in the Post Audit Action Plan, the Government of Alberta will issue a letter to the training provider to confirm the expected results have been achieved and the Post Audit Action Plan is complete.

If the training provider does not comply with the Post Audit Action Plan, the Government of Alberta may consider them to be non-compliant and may take remedial action.

Remedial Action Process

  1. Non Compliance: The Remedial Action Process will begin when the Government of Alberta considers a training provider to be non-compliant. Non-compliance is defined as being when:  the training provider does not agree with the Post Audit Action Plan, or, the training provider fails to comply with the corrective action outlined in the mutually agreed upon Post Audit Action Plan. 
  2. Issuing a Notice to Comply Letter (Letter 1): When the region is of the opinion that the training provider is non-compliant, the region will contact Employment and Training Operations who will deliver a Notice to Comply letter to the training provider. This letter will be signed by the Executive Director and state: The term or condition(s) that the training provider is allegedly not complying with; Outline the steps in the remedial action process; and, From the time of receipt of the letter, provide the training provider with a period of time in which they must comply.
  3. Conduct a Follow Up: Authorized Official will monitor the training provider to determine if they have complied with the Notice to Comply letter in the required timeframe.  Employment and Training Operations will follow up with the Regional Manager upon the expiration of the timeframe. If the non-compliance issue has been rectified, no further action is required and Employment and Training Operations will issue a letter to the training provider to confirm the matter is concluded.  If the issue(s) have not been resolved, remedial action will be taken.
  4. Deciding Appropriate Remedial Action: If the training provider is still in non-compliance, the Executive Director will consult the Regional Director and Legal Services to determine what remedial action should be taken. This consultation will occur before issuing a Remedial Action letter.
    Note
    The Executive Director  has the authority to determine the appropriate remedial action(s) as listed in Section 22 of the Income and Employment Supports Act.
  5. Issuing a Remedial Action Letter (Letter 2): The Government of Alberta will send a Remedial Action letter to the training provider signed by the Executive Director. The letter will outline the remedial action to be taken and any applicable timelines. The remedial action, determined by the Executive Director, will be implemented.
  6. Implementation of Remedial Action: Delivery and Employment and Training Operations will work together to implement the remedial action. In some situations, immediate remedial action may be required depending on the severity of the issue.
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