Alabama State University Grading System Audit Report

Alabama State UniversityGrading System Audit Report Maureen O’Mara Carver AACRAO Senior Consultant August 4 - 6, 2008

Table of Contents Project Findings, Conclusions, and Recommendations General Observations Grade Entry and Oversight Degree/Graduation Audits Office of the Registrar: Structure and Staffing Records Management Use of Social Security Number Certifying Eligibility for Athletes Technology Suggested Next Steps Appendices Documents & Publications Provided Individuals and Groups Involved in the Consulting Visit Records Retention Schedule Records Retention Schedule Records Retention Schedule 2

Introduction • Dr. Bernadette Chapple, Center for Leadership and Public Policy at Alabama State University, contacted AACRAO Consulting to request an audit of Alabama State University’s (ASU) grading practices and security. Further clarification of the scope of the visit was discussed upon arrive at ASU. • AACRAO Senior Consultant Maureen O’Mara Carver visited Alabama State University on August 4, 5, and 6, 2008 to conduct the consultation. The consultant met with 15 ASU personnel during the visit to obtain as many perspectives as possible on issues outlined in the scope of work. A list of individuals interviewed is attached as Appendix B. • The consultant wishes to commend all the Alabama State University personnel who gave their valuable time to speak freely and candidly with the consultant. Several of the meetings actually ran over the scheduled amount of time due to interest of the participants. Everyone was cordial, frank, open, honest, and very hospitable, which helped to make the consultation visit productive and enjoyable.

Grade Entry and Oversight Observations It does not appear that a full audit of grades occurred after the unauthorized grade changes were detected. It was reported that only athletes’ grades were audited. It was reported that no grades were audited in the legacy systems. It is the belief of a number of ASU employees that …“No amount of security can prevent fraudulent activity; the integrity of the individual is paramount” The grade entry system and security in place at the time of the grade change fraud is not seen as a contributing factor to the fraud. Some employees believe that the problem was with one individual and that person is now gone. However, some employees believe that there was also a student worker responsible for changing some grades. 4

Grade Entry and Oversight Observations (continued) The Registrar reported that the unauthorized grade changes were found when the Degree Systems Auditor found grade differences when comparing recently run transcripts with transcripts run at an earlier time. Another employee reported that it was a coach that alerted the Registrar’s Office about the grade changes. At the time of unauthorized grade changes, the Registrar’s Office staff used the same generic log-in/user code to access the IA+ system and enter and/or change grades. This made it impossible to be certain which employee or employees were making the changes. When the fraud was discovered, the generic code was abandoned and the staff assigned individual log-in/user codes. After the new codes were implemented, the unauthorized grade changes continued and the changes were tracked to one individual in the Registrar’s Office. The individual transferred out of the Registrar’s Office to the Athletic Compliance Office. 5

Grade Entry and Oversight Observations (continued) Beginning last school year, the faculty started to enter grades on-line. Not all faculty members are entering grades on-line and the Registrar’s Office still enters those grades. A new system has been implemented to track grade changes. Now, grade changes made after grades are submitted and release to students are handled in the following manner: Professors submit a grade change form to the Registrar’s Office. Once the change is made the Professor is notified. Every two weeks to a month, a report is run so grade changes in IA+ can be checked against the grade change forms submitted by the professors. The MIS Analyst assigned to the Registrar’s Office is helping to enter grades. This employee is not a member of the Registrar’s Office staff. 6

Grade Entry and Oversight Recommendations Ultimately, the office of the Registrar exists to safeguard the integrity of the institution’s records and degrees. In order to protect the integrity of ASU’s records and degrees a number of steps need to be taken, the first of which is a more extensive audit of grade changes. In light of the known grade change fraud incidents for some athletes, it is imperative that a project be undertaken to conduct a full audit of all grade changes. This audit needs to look at both athletes and non-athletes. The current IA+ system must be included in the audit as well as the legacy system used prior to 2000. 7

Grade Entry and OversightRecommendations (continued) It is not enough to implement security measures in response to fraudulent activity. Not wishing to sound trite, but “An ounce of prevention is worth a pound of cure.” To discourage, and most importantly to detect possible improper access and modification of student records, a system needs to be in place before such activity occurs. It is recommended that the Registrar and other appropriate personnel receive training in security issues and best practices so that they can better anticipate and plan for the security of ASU’s student records. This training is vital as it will hopefully prevent any serious data security errors such as those that occurred with the use of a generic user code, and the random way in which the improper grade changes were detected. 8

Grade Entry and OversightRecommendations (continued) The process now in place in the Registrar’s Office to track grade changes is a great improvement. It is recommended that the process be periodically reviewed to ensure its efficacy and efficiency. It is further recommended that the faculty be strongly encouraged to enter their grades on-line. Written instructions and one-on-one help from the Registrar’s office will help with the transition. It is strongly recommended that the use of the MIS Analyst to help with entering grades be stopped immediately. There is no problem if the Analyst is helping to upload a file or run a batch process. It is not good practice to have the Analyst enter individual grades from Professors’ grade sheets. 9

Degree and Graduation AuditsObservations All graduation/degree audits are done by one staff member in the Registrar’s Office. Currently, all audits are being done by hand. There is some confusion as to which grades and courses count in certain situations and which classes to apply to the various degree requirements. As an example, in some majors in certain categories a student must earn a C or better grade, while in others a D grade is acceptable. The Course Catalog is not clear as to under what circumstances it is acceptable to apply a D grade toward degree credit. This is causing difficulty in completing degree audits and athletic compliance audits, and in some cases the lack of clear rules is causing inconsistency in the awarding of credit towards a degree. 10

Degree and Graduation AuditsObservations (continued) The staff reported a lack of a communication plan to convey degree requirement changes to the Registrar’s Office or the Athletic Compliance Office. ASU is in the process of implementing the On Course degree audit system. All degree programs are reported to be complete and ready to go with the exception of the Education Program. Roll-out for the program was reported to be within 4 to 8 months. The Registrar’s Office reported that more testing is needed to insure On Course is working properly. A new Course Catalog is due for publication in 6 to 8 weeks. The Registrar is in the process of proofing the catalog. 11

Degree and Graduation AuditsRecommendations It is not clear how well the On Course degree audit system is working and if any part of it is ready for implementation. Because the On Course system is essential to the use of the CAI compliance software, it is essential that ASU know when On Course will be ready and to also have assurances of its accuracy. To this end, the following steps need to be taken: MIS, the Registrar’s Office, and the consultant to the On Course project need to report on their understanding of the progress of the project. The consultant and MIS need to report on work completed and ready for roll-out. The Registrar needs to confirm that completed work reported by MIS and the consultant is producing an accurate degree audit. For any degree audits that are accurate the Registrar needs to sign-off as satisfied with the work. For any degree audit found not to be accurate, the Registrar needs to document the nature of the problem and report it to MIS and the consultant. 12

Degree and Graduation AuditsRecommendations (continued) If the problem cannot be corrected because of unclear degree requirements this needs to be documented and a request for clarification sent to the appropriate academic department. Clarifications from the departments need to be documented by the Registrar for use by the Degree Auditor and the Athletic Compliance Office, and also conveyed to MIS and the consultant. Additionally, all degree requirement clarifications/changes must be noted for inclusion in subsequent Course Catalogs, and updated immediately in any current on-line and hard copy information. Changes made to On Course by MIS and/or the consultant as a result of the degree requirements clarifications need to be tested by the Registrar’s Office and signed-off on or sent back for more work. As soon as a degree program audit is deemed to be working correctly it needs to be made available for use by the Registrar’s Office, the Compliance Office, academic advisors, departments, and students. 13

Office of the Registrar: Structure and Staffing Observations The Registrar’s Office staff reported a lack of team spirit, low morale, and a need for accountability. Two staff positions in Registrar’s Office are vacant. There are plans to add an Assistant Registrar to handle Athletic Compliance and oversee the On Course degree audit implementation, The position of Secretary to the Registrar is vacant. The Registrar’s Office staff expressed a desire for more privacy when dealing with sensitive student matters, especially when the students come to the office to talk with staff directly. 14

Office of the Registrar: Structure and Staffing Recommendations The Registrar’s staff has done a good job of delivering a high level of service to the ASU community, and should be commended for the work that they do. They have been able to perform all the essential duties of the office with an ever dwindling staff. Unfortunately, this is now beginning to cause feelings of frustration and resentment. In order to address the challenges that the staff are facing, and to take the office to the next level, it will be necessary to start thinking about the tasks that the office performs in a whole new way. As the Registrar’s Office contemplates creating new positions and hiring additional staff, it is recommended that a thorough analysis of the functions in the office be undertaken. Ideas for how to approach this process and steps to take along the way are outlined below. 15

Office of the Registrar: Structure and Staffing Recommendations (continued) Without the support of a well qualified staff, all of whom possess the requisite skills required for their job, it is not possible to successfully carry out the essential functions of the Registrar’s Office. Ronder Young, in The Registrar’s Guide, Evolving Best Practices in Records and Registration (2006) sums it up very well,“Increasing demands resulting from technological advances have not necessarily changed the core functions of the registrar, though they have significantly expanded the range of essential skills (e.g. web design and desktop publishing) which it is useful for staff within the office to possess (or at least be aware of). New expectations also have increased the need for training, instruction, and public relations campaigns to foster understanding and acceptance of what to some may seem radical changes.” 16

Office of the Registrar: Structure and Staffing Recommendations (continued) A common pitfall, when technology gets applied to formerly manual tasks, is to force the technology to replicate the manual processes. This is what has happened in this office. By viewing technology in a more transformative way, it will be possible to begin to re-imagine the structure and staffing of the office. This will require certain steps to be taken before the process of transformation can begin. In the recommendations that follow, tools to aid in this process are offered. A more in depth look at the technology issues facing the office will be reviewed later in this report. 17

Office of the Registrar: Structure and Staffing Recommendations (continued) Empirical data is needed to assess the volume of transactions in the Registrar's Office, current process performance, and the adequacy of the current staffing levels to handle the work. The balance between responsibilities, skills, and compensation should also be part of the analysis. ASU should mount a project to undertake this work, since it will help to address staffing concerns (whether real or imagined), provide a baseline for monitoring future activity, assist the establishing of specific objectives, and provide a basis for creating new job descriptions. 18

Office of the Registrar: Structure and Staffing Recommendations (continued) Essentially, what is needed in order to begin assessing the staffing needs for the Registrar’s Office is a “clean sheet”. This approach affords the opportunity to lay out the tasks that must be accomplished and then at a later time, create new job descriptions and match people to the new positions. The steps to follow are these: Identify the basic needs of the office. Have each area develop a list of what they believe are the mandatory tasks that must be performed to support the mission of the office and meet all statutory and regulatory requirements. Evaluate all perceived “mandatory” tasks to determine which of these activities have limited value or benefit. Prioritize the list of tasks to be performed and rate the current performance level of the office in accomplishing these tasks. 19

Office of the Registrar: Structure and Staffing Recommendations (continued) Determine the level of manning needed for each functional area/task. After the initial evaluation and rating of the office tasks, the next step is to determine if the level of activity in each area is being met by the present staffing levels. Determine which, if any, tasks/functions of the office can be transferred to other areas of the office to gain the benefit of synergy and reduce the dedicated manpower required for the task. Identify functions/tasks that would benefit from “off-loading”. This can encompass such things as off-loading via technological solutions. 20

Office of the Registrar: Structure and Staffing Recommendations (continued) Finally, new job descriptions need to be written and the appropriate staff assigned to positions. It is recommended that options be explored for providing more privacy for the staff. Students need to be able to talk to staff in a private, non-public place. Computer screens need to be fitted with obscuring shields to prevent students and other constituents from seeing sensitive information. 21

Records ManagementObservations A large walk-through vault in the center of the office is filled to near capacity. The vault is filled with grade books, grade entry sheets, drop/add forms, change of major forms, old academic records, and various other student records dating back many years. Some movable file shelves are not working properly and cannot be accessed without considerable physical intervention. The staff must use a large board to wedge against one of the files in order to try to move it. 22

Records ManagementObservations (continued) Many boxes in the vault are piled high and are not safely accessible. Student records from 1896 to 1969 are on microfiche and in the vault. The Registrar’s Office is unable to use the microfiche because of the lack of a microfiche reader and printer. These records are also in hard copy in the vault. 23

Records ManagementObservations (continued) Student Records from 1970 to 1976 are in the vault, it is not clear if these are also in an electronic format. Student Records from 1977 to 1981 are in a legacy system as well as in the vault. Student Records from 1982 to 1999 are in the vault, and in a legacy system. Student Records from 2000 to present are in IA+ as well as in the vault. Some paper records stored in the vault are in danger of being lost because of age and degrading of the paper. 24

Records ManagementRecommendations A project to preserve the degrading paper transcripts must be undertaken. The most efficient way to accomplish this is to start preservation and repair on documents as they are requested by alumni. Possible technological solutions need to be considered in light of expediency and cost, with the most pressing issue being the preservation of vital paper records. A simple and straight-forward solution would be to have the vital records copied/scanned to CD or DVD. Software to read the disks would need to be purchased and the staff trained in its use. Ideally, the disks would be downloaded onto a server: this makes finding information easier, and it addresses the problem of the perishable nature of the disks. 25

Records ManagementRecommendations (continued) Before a project to scan paper documents is undertaken, a comprehensive and systematic approach is recommended for determining the need for and value of all items stored in the vault. This will require a records management program be created. Below are recommendations to help with undertaking such a project. Some of the recommendations below are taken from AACRAO publication, Retention of Records; A Guide for Retention And Disposal of Student Records (ROR). 26

Records ManagementRecommendations (continued) A number of issues need to be explored and decisions to be made in regards to the student files in the vault in the ASU Registrar’s Office. A plan needs to be put in place to identify the records ASU must preserve, and then determine the appropriate medium for preservation. As an example, paper records that need to be preserved permanently in most cases can be transferred to an electronic medium and the paper copy disposed of properly. Any plan to preserve records must meet the legal, fiscal, historical, and administrative needs of the institution. The records that will not be preserved then need to be culled and destroyed in a manner that will not compromise student confidentiality. 27

Records ManagementRecommendations (continued) Once a plan is in place and the files are culled and the identified records preserved, it is vital that the remaining records be housed in a safe and orderly manner. It is important that the records area is secure and deters potential security breaches. The area also needs to provide enough access for audit and control on a continuing basis. It is recommended that an administrator be given responsibility for overseeing the job of retention and disposal of student records. If a current administrator is given this task, training will be required in records management. 28

Records ManagementRecommendations (continued) In order for the student records plan to be effective, the goals of the plan need to be considered. The plan should make provisions to accomplish the following: Save valuable resources – money, time, space, and staff. Ensure that legal requirements are met prior to record disposal. Ensure that information of administrative, fiscal, legal, and historical/research value is available. Ensure that all vital records are secure. Ensure that records to be destroyed are incinerated or shredded under controlled conditions to preserve confidentiality. Ensure that record information is readily available when students request access. Ensure that machine-readable records remain accessible when computers and other technological devices are changed. 29

The implementation of the plan can be accomplished in five steps: Identification of need. Inventory of records. Appraisal and categorization of records. Creation and implementation of a retention and disposal schedule. Ongoing review and modification of the program. Appendix C to this report is a time table for the retention and disposal of student records. Records ManagementRecommendations (continued)

Use of Social Security NumbersObservations Social Security Numbers are being used as the student’s ID in the IA+ system and by the University in general. Social Security Numbers are being used as the faculty log-in ID to the self-serve system to enter grades etc. The PIN for the faculty to log-in to the self-serve system is the last four digits of their Social Security Number. Students’ Social Security Numbers are printed on transcripts. Students’ Social Security Numbers are included as part of the enclosure receipt mailed with each transcript. MIS is building a new security system to replace the use of Social Security Numbers as IDs. 31

Use of Social Security NumbersRecommendations It is recommended that ASU continue with its plan to convert from the use of the Social Security Number (SSN) as a student and faculty identifier to a non-SSN based ID system. This change will be in keeping with best practices in Higher Education and will address issues related to security, privacy, and possible public relations issues. Until the conversion to the use of a student ID is completed, it is recommended that displaying the SSN on transcript receipts to third parties, and other unnecessary uses of the SSN, be discontinued immediately. It is further recommended that the use of the SSN, in whole and part, for faculty log-in to the self-service client, be discontinued as soon as possible. 32

Certifying Eligibility for AthletesObservations An Athletic Compliance Committee is being formed. Members of the committee will be from the Registrar’s Office, Admissions, Housing, Financial Aid, Fiscal Affairs, Cafeteria, telecommunications, President’s Office, and others. CAI software is to be implemented. It was reported that in order for this compliance software to work properly, it will be necessary to have the electronic degree audit system, On Course, also working. Eligibility audits are being done by Athletic Compliance Officer and the Registrar is signing-off on the academic data. There is some difference of opinion as to where responsibility for the various components of the athletic compliance audit should reside. Questions were raised as to whether the Compliance Office should be doing the academic audit. 33

Certifying Eligibility for AthletesObservations (continued) Deborah Katz, J.D., PhD. in The Registrar’s Guide, Evolving Best Practices in Records and Registration (2006), describes the key elements of a compliance program as follows: The NCAA asks its members to follow the “C.O.D.E.” in order to implement an effective compliance program and to uphold the basic principles of institutional control, presidential authority and shared responsibility. The key elements in a compliance program are “Communication, Organization, Documentation, and Evaluation,” and are defined as follows: Communication: The institution’s commitment to rules compliance is demonstrated through oral and written communication with various campus entities. Organization: Senior level administrators assume leadership roles in establishing institutional commitment to compliance initiatives. Compliance procedures are clearly defined and assigned to institutional staff members. The staff assumes responsibility for knowledge of the rules and compliance with them. 34

Certifying Eligibility for AthletesObservations (continued) Documentation: Compliance policies and procedures are documented and distributed to appropriate campus and external constituencies. Evaluation: Mechanisms are in place to ensure continuing and regular administrative oversight in areas of compliance. The rules compliance program is subject to periodic review by some institutional authority outside the athletics department. 35

Certifying Eligibility for AthletesRecommendations The compliance strategies must be incorporated into each aspect of an athletic program, and in the case at hand, certification of student academic/athletic eligibility. As the enrollment manager ultimately responsible for certifying student athletes’ academic eligibility, the Registrar is advised to take the following steps to help demonstrate institutional commitment to compliance: Establish a communication system and comprehensive education program to convey eligibility objectives, policies, and procedures to the athletic and university community. Provide written job assignments and an organizational chart to identify participants in the eligibility certification process, and to clarify their roles and responsibilities. 36

Certifying Eligibility for AthletesRecommendations (continued) Devise an information management system to collect, track, process and report eligibility and other related academic data, and to facilitate the making of compliance decisions. Document policies and procedures. Create an evaluation program that features continuing and regular administrative oversight, as well as period review of eligibility certification by an institutional authority outside of the athletic department. The above recommendations are further strengthened by NCAA 23.2.2.1 which reads, “The responsibility for admission, certification of academic standing, and evaluation of academic performance of student athletes is vested in the same agencies that have authority in these matters for students in general.” 37

TechnologyObservations ASU is currently using the IA+ SunGard system. IA+ will no longer be supported by SunGard as of 2011. ASU is contemplating a move to the SunGard Banner system. Every module in IA+ has an MIS Analyst assigned to it. All Registrar Office reports are written and run by the Analyst assigned to the Registrar’s module in MIS. The reports are written in Focus. No one in the Registrar’s Office has the training to write or run reports in Focus. No one in the Registrar’s Office has technical expertise. All technical matters are handled by the Analyst in MIS. 38

TechnologyObservations (continued) Classroom and faculty scheduling is being done by hand in the Registrar’s Office. The Registrar does all the scheduling and deals with all changes to the schedule. The computers and other office equipment in the Registrar’s Office are outdated and inadequate for their needs. Some of the computers are at least eight years old. There is no high-volume printer/copier. There is no scanner. There is no microfiche reader/printer All Registrar Office forms are paper-based. There is now an on-line transcript request form in addition to the paper form. 39

TechnologyObservations (continued) The National Student Clearinghouse is being used for reporting student enrollment to lenders. Clearinghouse reports are prepared and run by Analyst in MIS. Staff expressed a desire for there to be a phone system to deal with the frequently asked questions from students and alumni. Phone calls are a constant interruption for the staff. The calls take staff away from one-on-one meetings with students as well as increase the possibility for error when they are performing very detail-oriented tasks. 40

TechnologyObservations (continued) Nancy Krogh, in The Registrar’s Guide, Evolving Best Practices in Records and Registration (2006), said “The goal to supply through a software system all the knowledge an institution may need is ambitious indeed. Furthermore, the ability to meet this goal may have more to do with the implementation process and the people involved than with the software itself.” She goes on to say, “Certainly, the software system is important, but it is the people who use it and how they use it that matter most.” 41

TechnologyRecommendations ASU has a number of technological resources that are being utilized by the Registrar’s Office with varying degrees of success and expertise. The intent of the following recommendations is to distinguish between the issues involving software and the issues involving people. Fully utilizing the SIS and writing reports against the data in the SIS are two of the biggest technology challenges facing the Registrar’s Office. It is not easy to write reports against the system, and the responsibility for doing so has been given over to MIS. It is recommended that the appropriate members of the Registrar’s staff be given training in the use of Focus. 42

TechnologyRecommendations (continued) There is an acute need for a higher level of technical training and support within the Registrar’s Office. In essence there are two different types of tech support needed. The first is in-office tech support to deal with using software and applying technology to office processes. The second is tech support for communicating with MIS about programming, technology initiatives in the Registrar’s Office, and other MIS related matters. 43

TechnologyRecommendations (continued) The Registrar’s Office needs to consider adding a full-time technical support position to the office. In addition to addressing the immediate technical needs of the office, this person could do the following: Act as the liaison with MIS. Coordinate staff technical training. Oversee the On Course degree audit implementation as well as other technical initiatives. Find and recommend technical solutions for classroom scheduling, phone tree implementation, and the mounting of a project to automate the Registrar’s Office forms. Keep up-to-date with the latest technical developments. 44

TechnologyRecommendations (continued) In addition, if it is decided that ASU will move to Banner or another integrated database, the expertise of an in-office technical expert will be vital to the success of the conversion for the Registrar’s Office. In order to keep abreast of evolving best practices in the profession, it is recommended that at the very least the Registrar, and if possible, other members of the Registrar’s staff, attend professional conferences. These organizations offer training in both technological and professional development areas. The dedication and use of resources for these endeavors is crucial to enhancing the effectiveness of the office. 45

TechnologyRecommendations (continued) It is recommended that an inventory of equipment in the Registrar’s Office be undertaken. This should include computers, printers, and any other office equipment used by the staff. The age and condition of each piece of equipment needs to be noted, as well as an assessment of the equipment’s ability to efficiently perform the task(s) for which it is intended. After the inventory is completed, recommendations for replacement and/or upgrading need to be developed, as well as recommendations for purchases of new equipment. -Contract, p. 8 46

It is strongly recommended that ASU explore the full spectrum of services available through the National Student Clearinghouse (NSC). Listed below are services offered to schools by NSC: Degree Verify – NSC acts as your agent to verify degrees for graduates to employers, background search firms, and recruiters. Electronic Transcript Exchange – Allows for the electronic exchange of transcripts with other schools via the Clearinghouse secure network. Enrollment Verify – Allows for fully outsourcing requests for enrollment verifications using data that you already provided to the Clearinghouse. Student Self-Service – Allows your students to print enrollment certificates and view their enrollment histories and verifications via the web for free. Transcript Ordering - Allows you to improve the level of service you provide your students and alumni by enabling 24/7 online transcript ordering. TechnologyRecommendations (continued)

Suggested Next Steps Agree on a date for a conference call to review the draft report. As part of the review, clarify the conclusions and findings as necessary, and reach agreement on the recommendations. Discuss ways ASU can address the recommendations in the report. Agree on a date for issuing a final report.

AppendicesA. Documents and Publications Provided Notice of Allegations Degree Audit Worksheets Link to University Catalog Organizational Chart Grade Submission Instruction to Faculty, Summer 2008

B. Individuals and Groups Involved in the Consulting Visit Dr. Bernadette Chapple Mr. Larry Cobb, Director, MIS Ms. Harrietta Colvin, Degree Systems Auditor Mr. Ron Dickerson, Athletic Director Ms. Mary Dumas, Registration Data Analyst Dr. William Harris, Interim President Ms. Monique Holland, Associate Athletic Director, Compliance Dr. John Knight, Acting President Mr. Ronald Lindsey, Systems Analyst/Documentalist Dr. Derryn Moten, Chair, Faculty Senate Ms. Felisa Owens, Academic Records Analyst Ms. Betty Pollard, Transcript Clerk/Special Records Asst. Dr. Alfred Smith, AVP Academic Affairs Ms. Ruby Wooding, Registrar Ms. Betty Zachary, Records Analyst/Veterans Service Officer

Alabama State University Grading System Audit Report