USAC's latest News Brief shoots the HATS program in the foot. Under the "Helping Applicants To Succeed (HATS) Program Update" section, the first thing they do is list the goals of the Extended Outreach Site Visit (EOSV) program. I don't have time to read paragraphs, so I skipped right to the bullet points, naturally thinking I was reading about the HATS program. So when I got to the 4th point, my eyes popped. Then I went back and read the text and realized that they were talking about EOSV. Of course, I only realized that because I know "site visits" is a phrase tightly tied to EOSV in the USAC lexicon.
So here's what a typical applicant is going to read from that section: "Helping Applicants To Succeed (HATS) blah blah blah support blah blah education blah blah best practices blah blah compliance reeer [rewind noise] COMPLIANCE. Oh man, a new type of audit." Done reading.
The #1 problem for the HATS program is that it looks like an audit: the same company that does the EOSV (which is an audit, whatever else it is), comes out and looks at your past funding requests. USAC should be going all out to dissociate HATS from EOSV (and PIA and all the other types of audits). The two should not be mentioned in the same News Brief.
The other thing USAC needs to do is say flat out: "HATS personnel do not send any information about an applicant back to USAC." That should be the policy. A general report about the reasons that applicants fail would be good, but no information about individual applicants should reach USAC. As it stands now, if a rule violation is discovered during a HATS visit, USAC can't just ignore it. So an applicant that is already bloodied by PIA could get kicked while its down.
During the USAC training this year, we were asked to talk up the HATS program. Sorry, no can do. All I need is for me to advise some school to take a HATS visit, and some mistake they've made gets back to USAC and they get a COMAD, and my name is mud.
If you think a site visit is an audit, you obviously haven't been through an audit by USAC's internal auditors. The biggest difference is dealing with Bearing Point for 2-3 hours, or dealing with USAC or KPMG auditors for 1-2 weeks on-site (not to mention the follow-up once they leave).
ReplyDeleteYou're right that a site visit is nothing like a full-blown audit, but it is a lesser audit. To my mind, even PIA is an audit. (In fact, I've had more than one applicant tell me that PIA is worse than an audit.)
ReplyDelete