I was just reviewing Section 1231.30 of the Administrative Code to look at the record keeping requirements for instructors when I ran across this:
c) The Department may, without providing prior notice, audit an Instructor's scheduled training for purposes of investigating allegations that an Instructor and/or curriculum is not in compliance with the Act and this Part.
1) To facilitate an adequate audit trail, instructors shall maintain all records to support any training certification as required by Section 75(f) of the Act, which shall include...
The way I read this is that ISP is authorized to conduct an audit to investigate allegations of noncompliance by the instructor. What, if anything, empowers them to conduct random audits without an allegation against the instructor?
Also, in regards to the curriculum, the Administrative Code says:
g) The Department may request a complete course outline and instructional notes or any additional course related information from the applicant. If the applicant refuses the request, the application will be deemed incomplete and returned to the applicant.
h) Upon receiving substantiated information that a curriculum is not consistent with Section 75 of the Act, the Department may remove that curriculum from the list of approved curriculums maintained on the Department's website.
If my curriculum has been submitted and approved, I am no longer an "applicant" and not subject to submit a copy of my curriculum. The only way to remove my curriculum from the approved list is to after a substantiated allegation that it doesn't meet the requirements of the law.
These "audits" appear to be illegal fishing expedition on the part of the ISP.
Edited by stm, 13 October 2017 - 02:31 PM.