How to Detect Control Failures Before They Become SACS-210 Findings

SACS-210 findings can often be prevented when institutions identify weaknesses in their internal controls before they become significant compliance concerns. Regular monitoring, accurate documentation, control testing, and timely corrective action can help colleges and universities maintain a stronger compliance environment. Effective SACS-210 Compliance Support can further help institutions evaluate their processes, identify gaps, and prepare evidence that demonstrates consistent compliance.

What Are SACS-210 Control Failures?

Control failures occur when an established process does not operate as designed or does not adequately address an identified risk. A control may fail because it was never properly implemented, performed inconsistently, poorly documented, or not updated when institutional processes changed.

For institutions preparing for accreditation reviews, recognizing these weaknesses early is essential. A minor exception that remains unresolved can develop into a recurring issue and potentially contribute to a SACS-210 compliance finding.

Examples of control failures may include:

• Missing approvals or authorizations

• Incomplete compliance documentation

• Inconsistent policy implementation

• Outdated procedures

• Unresolved audit exceptions

• Inadequate monitoring processes

• Incorrect or outdated records

• Unclear control responsibilities

• Failure to document corrective actions

The key is to identify these warning signs before they become recurring or systemic problems.

1. Monitor Repeated Exceptions

One of the clearest warning signs of an internal control failure is a pattern of repeated exceptions.

A single missing signature or approval may be an isolated mistake. However, if similar issues occur repeatedly, the organization should investigate the underlying process.

Institutions should maintain an exception log that tracks:

• Type of control failure

• Date of occurrence

• Department or process involved

• Person responsible

• Root cause

• Corrective action

• Resolution date

• Recurrence of the issue

Regularly reviewing this information can help compliance teams identify trends before they develop into larger problems.

2. Perform Regular Internal Control Testing

Policies alone do not demonstrate effective compliance. Institutions need evidence that their controls are operating consistently.

Internal control testing can involve reviewing a sample of transactions, examining approval records, checking access permissions, verifying reconciliations, or confirming that required reviews occurred within established timelines.

Every control test should answer three questions:

1. Was the control performed?

2. Was it performed correctly?

3. Is there sufficient evidence to demonstrate that it was performed?

This approach helps organizations identify weaknesses while there is still time to correct them.

3. Identify Documentation Gaps

Documentation plays an important role in demonstrating compliance. Even when a control is performed correctly, insufficient evidence can make it difficult to demonstrate that the process was followed.

Institutions should periodically evaluate whether compliance documentation is:

• Complete

• Accurate

• Current

• Properly approved

• Consistently maintained

• Easily accessible

• Aligned with institutional policies

Missing records, inconsistent forms, undocumented approvals, and unclear filing practices can all be warning signs.

Creating standardized documentation procedures can significantly reduce these risks.

4. Compare Policies With Actual Practices

A common source of compliance problems is the gap between what a policy says and what employees actually do.

For example, an institutional policy may require a quarterly review, while employees have gradually adopted an annual review process. Similarly, a policy may require documented approval, but employees may rely on informal verbal authorization.

These differences should be identified through regular policy and procedure reviews.

Process walkthroughs and employee interviews can help determine whether operational practices match documented requirements. If the process has legitimately changed, the institution should determine whether the policy needs to be updated or whether employees need additional training.

5. Review Controls After Organizational Changes

Internal controls can become ineffective when an institution experiences significant changes.

Staff turnover, new technology, organizational restructuring, new vendors, changes in responsibilities, and updated institutional procedures can all introduce new risks.

For example, if an employee responsible for a critical compliance review leaves the institution, the organization must ensure that responsibility has been formally reassigned.

After significant changes, review:

• Control ownership

• Approval responsibilities

• System access

• Documentation requirements

• Review schedules

• Reporting processes

• Backup responsibilities

This proactive approach helps ensure that controls remain effective as the institution evolves.

6. Establish Clear Control Ownership

Every important internal control should have a clearly identified owner.

The control owner should understand what needs to be done, when it needs to be completed, what evidence must be retained, and what action should be taken when an exception occurs.

Unclear ownership can create gaps because employees may assume someone else is responsible.

Institutions should document control responsibilities and establish backup personnel for critical processes. Cross-training can also help maintain continuity when staff members are unavailable or roles change.

7. Investigate the Root Cause of Control Failures

Correcting an individual error does not necessarily resolve the underlying control weakness.

For example, if a required approval was missed, obtaining the approval afterward may correct that transaction. However, management should also determine why the approval was missed.

Consider questions such as:

• Was the requirement clearly communicated?

• Was the employee adequately trained?

• Was the procedure easy to follow?

• Was responsibility clearly assigned?

• Did the technology or workflow contribute to the problem?

• Was the control being monitored?

• Have similar failures occurred before?

Root-cause analysis helps institutions address the source of a problem instead of repeatedly correcting the same symptom.

8. Track Key Compliance Indicators

Institutions can strengthen SACS-210 compliance monitoring by tracking key performance and risk indicators.

Useful indicators may include:

• Number of unresolved exceptions

• Overdue control reviews

• Missing approvals

• Reconciliation discrepancies

• Access violations

• Incomplete documentation

• Overdue corrective actions

• Policies awaiting review or update

A simple compliance dashboard can give leadership an overview of emerging risks and highlight areas requiring attention.

The objective is not to create unnecessary administrative work. Instead, monitoring should provide timely information that supports informed decision-making.

9. Document Corrective Actions

When a control failure is identified, the institution should document how it was addressed.

A strong corrective action plan should identify:

• The control weakness

• Root cause

• Corrective action

• Responsible individual or department

• Completion deadline

• Supporting evidence

• Verification process

After corrective action is completed, the institution should verify that the solution is working as intended.

This creates a continuous improvement cycle:

Identify → Analyze → Correct → Verify → Monitor

Maintaining evidence of this process can also demonstrate that the institution actively manages identified weaknesses.

10. Make Compliance Monitoring Continuous

One of the most effective ways to reduce the risk of SACS-210 findings is to make internal control monitoring an ongoing activity.

Waiting until an accreditation review is approaching can leave institutions with limited time to identify and correct weaknesses. Continuous monitoring allows compliance teams and institutional leadership to address problems while they are still manageable.

Regular reviews should become part of normal institutional operations rather than a one-time accreditation preparation exercise.

Conclusion

Preventing control failures requires more than having policies in place. Institutions must verify that controls are properly designed, consistently implemented, adequately documented, and regularly reviewed.

By monitoring exceptions, testing internal controls, identifying documentation gaps, reviewing policy-practice differences, assigning clear ownership, and addressing root causes, institutions can detect potential weaknesses before they become significant compliance concerns.

A proactive SACS-210 compliance strategy helps create a culture of accountability and continuous improvement. Instead of reacting to findings after they occur, institutions can use ongoing monitoring to identify risks early, strengthen internal processes, and maintain reliable evidence of compliance.

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