Enclosure (1) to COMDTINST 16721.1
(2) Covert audits must be well planned and the auditor must be briefed on his/her conduct
while attending the course. The person selected to attend the course should have an
in-depth knowledge of the area(s) covered in the course. The auditor should not
attempt to entrap the training institution or instructor(s). The auditor should pose as
someone having difficulty in passing an assessment or comprehending the course
material and determine the responses to such behavior by the supervising instructor.
(3) If discrepancies are noted, the auditor should complete an in-depth report indicating
the nature of the discrepancies, his/her actions during the course, and the responses by
the instructors or training institution to those actions. The report may be used in court
proceedings or administrative hearings.
(4) Covert audits are expensive because the Coast Guard must pay course registration
fees. The NMC has limited funds available to pay registration fees, but travel and per
diem, if any, are the responsibility of the unit performing the oversight.
(5) The NMC must be contacted before a covert audit is conducted.
7.
POST AUDIT ACTION.
a.
Post audit action may consist of:
Action Type
Authority for Action
Letter report of audit
OCMI
Suspension
OCMI/NMC
Withdrawal
NMC
b.
As soon as possible after an administrative or informal audit, the REC should send a letter
to the organization stating the results of the oversight. Preferably the letter should be sent
within two weeks of the audit. If discrepancies were noted, a date for corrective action
should be specified. If no discrepancies were noted, the letter should include appropriate
congratulatory language.
c.
Should an audit of an approved course reveal discrepancies of a serious nature, such as,
but not limited to a failure to teach a course in accordance with approved procedures,
allowing absence from class, making unauthorized changes to the course, failure to
maintain records, or use of non-approved instructors the training institution may be subject
to suspension or withdrawal. Such discrepancies must be well documented. Serious
discrepancies that would warrant suspension or withdrawal of a course's approval should
be reported to the NMC immediately upon completion of an audit.
d.
An annual report, due 31 January and covering the oversight activities of the past calendar
year, shall be submitted to the NMC via the District Commander. A report's format is
shown in enclosure (2).
e.
The RECs shall maintain records of all oversight activities, and copies of letter reports
shall be forwarded to the NMC. If desired, RECs may batch letters and forward a batch at
the end of a calendar month.
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