The higher education industry encounters close scrutiny by lawmakers and the media, turning
compliance into an ongoing challenge. Monitoring call centers and online brand presence
in consideration of program integrity regulations–including gainful employment, TCPA and
misrepresentation rules–requires significant human and technology investments.
To help ensure you’re monitoring your brand as efficiently and effectively as possible, DMS developed the following list of compliance best practices.
Your compliance team is your front line in protecting your brand against
compliance risk, and your first responsibility is to make sure your team
knows every aspect of your portfolio.
While you want consistency in content knowledge and procedure, you don’t want to hire a bunch of robots. Diversity in learning styles, communication, approach and background will make your team stronger as each person will bring a different perspective and uniquely contribute to your compliance efforts.
Unique requirements necessitate multiple procedures and processes. Utilize quick-glance sheets to enhance your monitoring efforts by breaking down the vital details of procedures, examples of compliance issues and legislative or best practice references.
Invest in continuous learning with your team by participating in conferences, classes, webinars, articles and blog posts. Calibration sessions with your team can provide occasions to pause and evaluate your processes while encouraging open discussion. Finally, challenge each member to regularly look for process enhancements and present new ideas to help the team reach their greatest potential.
Before you start working with a vendor, agency or compliance provider,
make sure you set guidelines regarding your brand’s standards and your
expectations. All parties need to be fully aware of the potential impact
of a compliance risk, including remediation guidelines, processes and
timelines for resolution.
Save these guidelines and all related documents, including fact sheets and program information, in a central repository. Accessibility helps your team to resolve issues quickly.
Provide all partners with relevant information before the working relationship begins. See the chart below for examples, including the compliance standards of Sparkroom, a division of DMS.
|Example of Compliance Standards & Expectations||Sparkroom Compliance Standards|
|Brand guidelines, including global exceptions||TCPA language and opt-in always required; vendor exceptions also detailed|
|Examples of communication pieces and reporting||Provide samples of email communication templates|
At a minimum, all violations receive a credit per inquiry
Evaluation of performance process
Share reporting of compliance violations; review trends and potentially escalating issues
Pro Tip: It is standard to request call recordings for all inquiries generated. A vendor should be able to provide every call recording you request for review, whether the request is related to compliance, quality or any other factor. If a vendor isn’t willing to provide you with your call recordings, this might be a sign of trouble to come.
A system for broad and real-time communication will also help with efficiency. Look for something that allows changes to be effectively communicated to all parties, while also tracking remediation steps taken.
Just like you want your vendors to know your brand’s guidelines and expectations, you should know the same for your vendors. At the beginning and at regular intervals during your relationship (quarterly is recommended), ask your vendors the following questions:
This process allows you to select the vendors that best match your brand’s
standards. Sometimes you can work with a vendor to alter their practices
to match your needs. If this isn’t possible, you’ll need to evaluate potential
risks and determine whether or not the vendor’s performance (or expected
performance) warrants them being on your campaign.
Knowing vendor processes can also help you anticipate performance results and better prioritize your own compliance efforts. For instance, although you always want to be monitoring calls from all vendors, if you’re facing a capacity issue, you may be able to listen to a smaller ratio of calls from a trusted vendor that you know monitors calls on their end and has strict compliance guidelines that are in line with your own.
If you have multiple systems but nothing to connect them, your compliance efforts may suffer in the following ways:
To help overcome errors such as the ones listed on the prior page, unique identifiers
like lead and campaign identification numbers, are critical when utilizing multiple
systems for your compliance monitoring. These unique numbers allow you
to match data across systems.
When working with vendors, supply them with specific instructions regarding the information you need provided when they post data to your system. Make sure each vendor’s unique identifier is something that can stay with them for the long term, despite campaign changes you have along the way.
To verify that your unique identifiers are working to link data across systems, simply ensure names and phone numbers match what is communicated in the call recording. Finally, track the volume you are receiving from vendors to verify it matches the data you have in your CRM. This will allow you to uncover posting and/or delivery issues and quickly work to resolve any disconnects.
Working in real time allows for closer monitoring of vendors because remedial action can take place immediately. This timely resolution minimizes the impact on your business.
Real-time tracking helps support:
Example of real-time monitoring:
Your team is reviewing calls for a vendor and you notice they have flagged calls
for the missing language, “the call may be monitored or recorded.” You alert
the vendor that they have multiple violations for the same compliance issue
and ask them to take immediate remedial action to fix the issue. Based on their
response, you can make a decision regarding whether or not to continue using
In this same scenario, if calls were reviewed on delay, the information can effectively impact the vendor performance moving forward. The downside is that the knowledge of compliance issues is based on old data. You’ve moved on to a new month and the issue is potentially still impacting your campaign.
For efficient compliance monitoring, you need to create a standard system of reporting for all your vendors. This will give you a consistent framework for gathering necessary data and making recommendations to those evaluating your vendor performance.
The following key performance indicators and data should be included in your standard monitoring report to help minimize compliance risks while refining your compliance practices and standards:
When reviewing your compliance monitoring report, your team should be able to:
It is important to address high-level risk as quickly as possible. Prioritize, but don’t disregard, low-level risk spread across multiple vendors and channels. Look specifically at quality versus quantity for each vendor, both in terms of compliance and campaign performance, when determining remediation and areas of improvement. When you’re making requests of vendors, make sure to provide them with a list that is in priority order. If you want action taken right away on a particular item, place it at the top of the list.
Pro Tip: In some instances, you may need to customize your report to allow for extra details that would otherwise be excluded. If you find yourself in this situation, determine which option (standard or customized reporting) will provide your team and all your partners with the best source of information.
A good compliance process incorporates regular internal and external reviews of data. This should happen both at the end of a monitoring period and potentially during an audit. Vendors should be shown data to address compliance issues, but also to adjust to trends and potential future issues.
As part of your reviews with vendors, you’ll want to discuss common roadblocks and misperceptions including:
Compliance monitoring results should also be regularly shared with business partners, especially those managing your inquiry generation campaigns, to:
Lastly, make sure to share data across your entire compliance monitoring team to evaluate procedures and optimize the process, including potentially adding missing steps or removing steps that are unnecessary or needlessly complicated.
This is all about working smarter, not harder. The technology used for your compliance monitoring might be cutting edge, but its effectiveness is only as strong as the intelligence it is provided. If the data input in your system is not accurate, the results of your compliance monitoring will not be either.
Pro Tip: Sometimes it is more efficient to require a phrase to be present on a landing page versus searching for a potentially incompliant term. For example, if you are currently searching for the term “financial aid,” your system will flag both “financial aid is available to those who qualify” and “financial aid is available to all who apply” However, if you make “financial aid is available to those who qualify” a required term in your system, it will flag every landing page that does not include this precise language while minimizing the number of false positives.
Overwhelmed? EMAIL SALES@THEDMSGRP.COM TO SEE HOW WE CAN SUPPORT YOUR COMPLIANCE MONITORING.
Last Updated May 2015