Educational institutions have a fiduciary duty to ensure that proper policies, procedures and controls are in place to prevent inappropriate admission of students and to assure that scholarships, federal grants, and stipends are awarded only to students deserving of them. Colleges and universities will be scrutinized by their boards, students/families, donors and prospective students as to whether they have issues similar to the college admissions bribery and cheating scandal.
Hire independent trusted and experienced advisors to provide counsel, gain an understanding of the current state of your compliance and reporting system (if any), perform a risk assessment and design tests of controls and forensic accounting analysis in high risk areas.
Tone at the top can set a precedent for an ethical corporate culture, but a formal ethics program provides a clear framework for the organization’s expectations, policies and potential consequences. While compliance and ethics are the foundation of such programs, the pervasive threat of fraud makes it critical to also integrate fraud-focused initiatives into the program, including anti-fraud and whistleblower policies.
It is important to identify the essential steps your organization needs to take to develop a program that will foster ethical behavior, promote compliance and deter fraudulent activities by your employees. Areas of focus include:
This is not a one-off problem isolated to athletic recruiting but an institutional problem around ethics and lack of proper internal controls that has resulted in the following issues:
DGC is experienced, local and cost effective. If you would like to discuss how DGC can advise you on these matters, contact Elisabeth da Silva, CPA, CFF at 781-937-5792 or firstname.lastname@example.org. Elisabeth is a Partner in DGC’s Business Advisory practice.