Quality versus compliance systems

Ross Woods, 2021

Regulators have used various approaches to institutional quality. They range from strictly compliance to quality. The characteristics of each are described below.

Compliance

At its most rigid, the regulator has a simple “Monkey see, monkey do” approach. It sets inflexible, detailed rules for exactly what must be done and how it must be done, including documentation. The documentation is required even if it is irrelevant to the institution’s purposes.

Some versions of compliance are less rigid. The regulator sets rules for specific purposes that must be achieved, but institutions are free to decide their own means or systems for achieving those purposes.

Here’s an interesting contrast.

  1. The AQTF 1 had a set of standards, and each standard had a series of criteria. Institutions had to comply with the standards as well as the criteria. In some unusual cases, institutions could meet all criteria but not the actual standard; that is, the methods for addressing criteria did not combine into a coherent system. This is best described in the adage, “Flour's good, sugar's good, eggs are good. But no cake.”
  2. The SRTO 2 is laid out in much the same way, with a set of standards, and a series of criteria for each standard. However, it defines compliance only as meeting all criteria, so that the “standards” themselves are no more than section headings.

Quality

The institution defines its own institutional purpose, and then focusses all its systems and activities on achieving that purpose. This has several implications:

  1. The institution must clearly define and articulate its purposes.
  2. Educational institutions often must clearly define and articulate a concept of academic rigor.
  3. The institution determines its own systems for achieving its purposes.
  4. Everything it does should contribute to achievement of its purposes.
  5. The only documentation it requires is that which helps it to achieve its purposes.
  6. The institution works hard to improve, and has extensive “review and improve” systems throughout its activities.
  7. In a college, you can attend some lectures and interview students. You might also interview staff and ask their opinions of the program and about any improvements they might want to make.

Here's another way to look at it. If the standard says that the institution must have a particular policy, it actually means that:

  1. The institution must have a policy.
  2. It can show why the policy is like it is (e.g. suited to context and perhaps any local laws).
  3. It can show how it implemented the policy. This can mean the auditor should ask:
    1. How did you distribute it?
    2. Did people understand it?
    3. Did people follow it?
    4. Did it achieve the intended outcome?
  4. It reviewed the policy to see whether or not it is effective and whether or not it needs any changes.

By contrast, in a strictly compliance framework with no related requirements, the institution only has to be able to show that it has the policy.

Hybrid “Quality and compliance”

Many regulators have a hybrid of both approaches. They have the characteristics of a quality system and also require purposes that institutions must achieve. They allow each institution to decide the means or systems it will employ to achieve those purposes.

Implications for auditing

Many regulators have a hybrid of both approaches. They have the characteristics of a quality system and also require purposes that institutions must achieve. They allow each institution to decide the means or systems it will employ to achieve those purposes.

In a “Monkey see, monkey do” approach, auditing is simple because requirements are prescribed in detail. The auditee either did or did not do the thing that is required.

In every other approach, auditing is a series of judgements. For example, the standards might a specific purpose that must be achieved, but not the means or systems to achieve it. Auditors must judge whether or not the purpose has been achieved. This is problematical when an auditor judges that an item is necessary but is not mentioned in the standard. This especially applies to documentation unless the standards specify documentation.

This need not be a serious problem if the regulator:

  1. avoids destructive confrontations,
  2. promotes improvement,
  3. has methods to help institutions to make corrections and achieve compliance, and
  4. is cautious about using audits as a tool of policing and punishment.

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1 AQTF: Australian Quality training Framework.
2 SRTO: Standards for Registered Training Organisation 2015.