Audit Report Association of Chartered Certified Accountants (ACCA) 26 August 2015
Contents 1 Background 1 1.1 Scope 1 1.2 Audit Report and Action Plan Timescales 2 1.3 Summary of Audit Issues and Recommendations 3 1.4 Risk Rating of Issues 5 2 Detail of Audit Issues and Recommendations 6 2.1 Issues 6 2.2 Recommendations 7 3 Acceptance of Audit Findings 9 Scottish Qualifications Authority 2015 (Version 5)
1 Background This was the second audit of the Association of Chartered Certified Accountants (ACCA) since it was approved as an awarding body by SQA Accreditation on 11 January 2012. ACCA is a globally-recognised awarding body, dealing with accountancy qualifications. ACCA is a designated Professional Body under the Financial Services and Markets Act. ACCA s headquarters are in London with the principal administrative office in Glasgow. 1.1 Scope SQA Accreditation carries out quality assurance activity in line with its Quality Assurance of Approved Awarding Bodies Policy. This states the type and frequency of our quality assurance activities, describes our reporting procedures and indicates how the awarding body s Quality Enhancement Rating is calculated. As this was a full audit of ACCA, all regulatory requirements were included within the scope of the audit. Our quality assurance activities are conducted on a sampling basis and, consequently, not all aspects of the awarding body s systems, procedures and performance have been considered in this report to the same depth. The audit was designed to ensure ACCA complies with SQA Accreditation s regulatory requirements namely: SQA Accreditation s Regulatory Principles (2014) all Regulatory Principles Directives the awarding body s Accreditation Licence Awarding body documentation considered for review by the Audit Team includes all documents banked on ACCA s Quickr Place at the time of audit and information supplied to support audit activity. Restricted or commercially sensitive information gathered during SQA Accreditation s quality assurance activities is treated in the strictest confidence. Scottish Qualifications Authority 2015 (Version 5) 1
1.2 Audit Report and Action Plan Timescales ACCA audit date: 26 August 2015 Audit Report approved by Accreditation Co-ordination Group on: 6 October 2015 Audit Report to be signed by ACCA: 17 November 2015 Action Plan to be e-mailed to regulation@sqa.org.uk by ACCA: 17 November 2015 The process will apply in relation to the timescales specified above: The awarding body will be sent two signed copies of the Audit Report by post. The awarding body must sign both copies of the Audit Report and return one by post to SQA Accreditation in accordance with the timescale specified above. The awarding body will also be e-mailed a copy of the Audit Report (for information only) and an electronic copy of the Action Plan. The awarding body must complete and return the Action Plan in accordance with the timescale specified above and e-mail this in Microsoft Word format to regulation@sqa.org.uk. SQA Accreditation will confirm when the Action Plan is appropriate to address the Issues and present it to Accreditation Co-ordination Group (ACG) for approval. Following approval by ACG, the awarding body will be sent two signed copies of the approved Action Plan by post. The awarding body must sign both copies of the Action Plan and return one by post to SQA Accreditation. The findings of this Audit Report and the associated Action Plan will be published on SQA Accreditation s website following signed agreement. SQA Accreditation will continually monitor progress towards completion of the proposed actions identified in the Action Plan and update the awarding body s Quality Enhancement Rating as appropriate. Scottish Qualifications Authority 2015 (Version 5) 2
1.3 Summary of Audit Issues and Recommendations An Issue has been recorded where evidence shows that the awarding body is not compliant with SQA Accreditation s regulatory requirements. The awarding body must address the Issues and specify corrective and preventative measures to address them through its Action Plan. The Action Plan is e-mailed to ACCA as a separate document to the Audit Report, and must be submitted to SQA Accreditation in accordance with the timescale specified in 1.2. As a result of the audit and post-audit activities, three Issues have been recorded and six Recommendations have been noted. Issue Detail of Issue recorded Risk rating 1. Principles 2 and 3 Limitation of candidate choice in receiving SQA accredited qualifications, due to certification being based on their postcode. Medium 2. Principle 5 Clarity of information provided to candidates regarding the correct regulator of accredited qualifications. Medium 3. Principle 5 Clarity of information provided to Approved Learning Partners (ALP) regarding the relationship between ACCA, SQA Accreditation, SQA accredited qualifications and Modern Apprenticeships (MA). Medium A Recommendation has been noted where SQA Accreditation considers there is potential for improvement. The awarding body is advised to address any Recommendations noted as good practice. However, measures to correct or prevent these are not mandatory and therefore do not form part of the Action Plan. Recommendation Detail of Recommendation noted 1. Principle 3 The awarding body should establish and monitor changes to the SSC and NOS development where it informs future qualification development. 2. Principles 5 It is recommended ACCA update their FAQ section to help clarify the difference between member and affiliate, particularly in regard to who is able to re-sit an examination. Scottish Qualifications Authority 2015 (Version 5) 3
3. Principle 6 It is recommended that ACCA review the accuracy of registration and certification figures and provide data which matches the accredited qualifications rather than reflecting the number of learners registering for a suite of qualifications. 4. Principle 9 It is recommended that the written process for qualification development be amended to properly reflect each stage in seeking qualification accreditation. 5. Principle 11 It is recommended that ACCA update their Equal Opportunities policy to bring into line with the Equality Act 2010. 6. Principle 12 It is recommended that ACCA clarify SQA Accreditation s position with regards to complaints on their website. Scottish Qualifications Authority 2015 (Version 5) 4
1.4 Risk Rating of Issues SQA Accreditation assigns a rating to each Issue recorded, depending on the impact on or risk to the awarding body s operations, its SQA accredited qualifications and/or the learner. Issues recorded during the audit will count towards ACCA s Quality Enhancement Rating which will, in turn, contribute towards future quality assurance activity. Further detail on how the Quality Enhancement Rating is calculated can be found on the SQA Accreditation website. http://accreditation.sqa.org.uk/accreditation/regulation/quality_assurance/quality_enhance ment_rating Scottish Qualifications Authority 2015 (Version 5) 5
2 Detail of Audit Issues and Recommendations The following sections detail Issues recorded and Recommendations noted against SQA Accreditation s regulatory requirements. 2.1 Issues Regulatory Principle 2. The awarding body shall ensure it has the necessary resources to effectively carry out its operational functions to meet regulatory requirements. Regulatory Principle 3. The awarding body shall have clearly defined business planning processes which show evidence of management commitment, decision making and ongoing review. The Accreditation Auditor has concerns with regards to the current systems operated by ACCA in the Registration and Certification of SQA Accredited qualifications. The Accreditation Auditor understands that the hard-coded internal systems do not allow for candidates or ACCA staff to select the accredited qualification they wish to receive either at registration or certification. Nor is there a clear indication of what accredited qualification a candidate will receive, alongside receiving the ACCA qualification. The ACCA representatives described that this happens at the point of candidate certification: upon inputting their postcode, the system determines the accredited qualification the candidate receives. Therefore, a candidate with a Scottish postcode will receive an SQA accredited qualification. Thus may be potentially limiting candidate choice in whether they receive SCQF or QCF accredited qualifications. This has been recorded as Issue 1. Regulatory Principle 5. The awarding body shall provide clear information on its procedures, products and services and ensure that they are accurate and appropriate to SQA accredited qualifications. During the audit, it was demonstrated to the Accreditation Auditor that no internal process existed for staff to identify the appropriate regulator details that could be provided to candidates who wish to escalate a complaint. Current practice is that all UK regulators contact details are provided to candidates, which leads the candidates to e-mail all regulators noting their complaint. This may be confusing to candidates, as they are not being directed to the relevant regulator to contact. It also leaves the regulator in doubt as to whether the complaint is relevant to them. Again, the ACCA staff whose remit includes dealing with communication from the regulator regarding a candidate complaint had no process in place to check and determine whether the candidate received SQA accredited qualifications. This has been recorded as Issue 2. Prior to the audit an issue had arisen with regards to an ACCA Approved Learning Partner (ALP) being confused with regards to how candidates fulfilled the criteria for obtaining the Modern Apprenticeship (MA) and in general the relationship between ACCA, SQA Scottish Qualifications Authority 2015 (Version 5) 6
Accreditation, SQA Accredited qualifications and the MA. Moreover, the Accreditation Auditor is concerned that as the system is hard-coded based on postcode registration, a candidate potentially after completing the exams, assuming they are completing an MA and are subsequently issued with a QCF certificate, as opposed to the required SCQF certificate, the ALP would be unable to complete their funding drawdown from SDS. This has been recorded as Issue 3. 2.2 Recommendations Regulatory Principle 3. The awarding body shall have clearly defined business planning processes which show evidence of management commitment, decision making and ongoing review. Discussion took place between awarding body representatives and Accreditation Auditors regarding the situation of SSCs and NOS development. It was noted that the potential changes did not appear on their risk register. Awarding body representatives confirmed that they did not consider any potential changes to impact on ACCA and were happy with what currently stands. The Accreditation Auditors recommend that the awarding body should establish and monitor changes to the SSC and NOS development where it informs future qualification development. This has been noted as Recommendation 1. Regulatory Principle 5. The awarding body shall provide clear information on its procedures, products and services and ensure that they are accurate and appropriate to SQA accredited qualifications. Prior to the audit the Accreditation Auditor found evidence that candidates may become confused with regards to the status of being a member or being an affiliate. This is particularly pertinent to who can re-sit exams having passed the exam previously. It is recommended that the awarding body update their FAQ section to help clarify this and prevent any possible confusion. This has been noted as Recommendation 2. Regulatory Principle 6. The awarding body and its providers shall maintain accurate documents, records and data. Prior to the audit ACCA provided registration and certification figures for accredited qualifications. The figures showed uniform numbers of registrations and a low number of certifications. It was clarified at the audit that the figures provided represent the number of individuals who signed up to ACCA as Foundation Level or ACCA qualification candidates. ACCA registers each candidate for a suite of qualifications as opposed to specific accredited qualifications. It is recommended that the awarding body consider how to provide more accurate figures for each accredited qualification in the future. Scottish Qualifications Authority 2015 (Version 5) 7
This has been noted as Recommendation 3. Regulatory Principle 9. The awarding body shall ensure that it has robust systems and processes for the identification, design, development, implementation and review of qualifications, which meet the needs of users. Prior to the audit, the awarding body provided on Quickr the internal process document for qualification development. The document did not list the stages in seeking qualification accreditation and/or credit rating where appropriate from SQA Accreditation or relevant regulators. There was evidence on the day of the audit that this is taken into consideration by staff. Therefore, it is recommended that the written process be amended to properly reflect each stage of the aforementioned. This has been noted as Recommendation 4. Regulatory Principle 11. The awarding body shall ensure that its qualifications and their assessment are inclusive and accessible to learners. The Accreditation Auditors noted that the awarding body Equal Opportunities policy was somewhat inaccurate with regards to the protected characteristics listed. It is recommended that ACCA update its policy to either reference the Equality Act 2010 and remove the listing of protected characteristics or, where it is decided to omit reference to the Act, list every protected characteristic required by the Equality Act. This has been noted as Recommendation 5. Regulatory Principle 12. The awarding body and its providers shall have open and transparent systems to manage complaints. Prior to the audit, the Accreditation Auditor noted that the area of the awarding body website headed Unhappy with the service you have received states that ACCA s regulators welcome feedback from customers who reside inside and outside the UK. Subsequently SQA Accreditation is listed. SQA Accreditation does not consider complaints from those outside the UK. Therefore, it is recommended that ACCA, remove this statement or reword it to clarify SQA Accreditation s position with regards to complaints. This has been noted as Recommendation 6. Scottish Qualifications Authority 2015 (Version 5) 8
3 Acceptance of Audit Findings For and on behalf of the ACCA: For and on behalf of SQA Accreditation: Print name. Print name Signature Signature Designation Designation Date Date. Scottish Qualifications Authority 2015 (Version 5) 9