14.0 Compliance
14.1 What is the planned frequency of the audits and are audits by other bodies acceptable in their place?
You should expect an annual audit which will be specific to ILA Scotland and audits by other bodies will not be acceptable.
14.2 Who will be undertaking the audits?
ILA Scotland compliance monitoring staff will undertake the audits, checking for specific ILA Scotland procedures / requirements.
14.3 What documentation is required, and for how long must it be kept for audit purposes?
The key documentation required for audit purposes is confirmation of payment of personal contribution, the Learning Token, and, any supporting information, such as financial transactions that would enable the ILA Scotland Compliance Monitoring Staff to verify compliance with the scheme rules. This documentation must be kept for 6 years (electronic copies are acceptable). For ILA500, colleges and universities must keep a copy of the learner’s Award Notice for 6 years.
14.4 The Learning Provider Payment Agreement for ILA Scotland says that we must maintain all records and books of account for a period of at least 6 years after the date of termination or expiry of the Agreement. The Operational Rules and Supplementary Guidance for Learning Providers, however, seem to say that we must retain documents for 6 years only from when a claim was made. This seems inconsistent, so how long do we need to retain ILA Scotland records?
There are 2 separate elements to this. The ILA Scotland Operational Rules specify the retention of evidence, i.e. the actual papers (e.g. signed enrolment forms, copy receipts, Learning Tokens, etc.), in respect of claims, for 6 years from the date of the claims. The Learning Provider Payment Agreement, on the other hand, requires that you must retain "records and books of account recording all receipts and expenditure of monies paid to [you]" under the scheme (i.e. ledgers, accounts, etc.), for 6 years from when the Agreement ends. Therefore, in most cases, once the specified time period has elapsed, it will be permissible to dispose of documentary evidence relating to individual claims while retaining the related financial records.
14.5 Do providers need ‘paper’ documents or will electronic records suffice?
For ILA Scotland purposes, providers are required to maintain sufficient data to enable effective audit. Initially, this data may be in paper or electronic format.
14.6 Do we have to report on the degree of completion for each learner?
While you don’t need to specifically report the degree of completion for each learner, as quality learning providers, we would expect that records of this nature would typically be kept as part of the existing quality procedures. Using this information, ongoing learner tracking by ILA Scotland staff will be undertaken to ensure consistency across all Learning Providers.
14.7 Are there procedures in place to deter and / or detect unscrupulous learning providers claiming for courses not actually being undertaken, or from registering ‘ghost learners’?
Yes, a range of security measures are in place to detect inappropriate activities by learning providers. You are required to fully comply with the scheme’s Operational Rules and will be monitored in a number of ways including, but not limited to, the following:
• Planned and ad hoc compliances audits, including visits to your premises
• Follow-up on feedback received through learner surveys and course feedback forms
• Investigation and review of formal complaints
ILA Scotland has established a robust set of processes and procedures to ensure learners are fully protected. These are outlined in the Operational Rules and Supplementary Guidance and in the Learning Provider Registration Agreement which must be completed and signed by all ILA Scotland registered learning providers.