Vendor Management: Audit Sampling and Intuitive Judgment 

For years, when assessing third-party collection vendor performance, I have tried to come up with a better word than “audit”.  Much of the time, the audit word conjures up a negative impression, and I think of the audit as a tool for communication and effectiveness between the vendor, in this case, the collection agency, and the client.  By verifying that performance aligns with contract expectations, and work effort meets expectations, we can foster trust and build long-term connections with our vendors. 

I’ve tried calling it a performance review and/or assessment.  I’ve avoided calling it an examination or investigation.  I think of it as a compliance check or monitoring.  Whatever it’s called – these evaluations are a vital communication tool, helping to align expectations and promote transparency between vendors and clients. Ensuring that performance meets agreed-upon standards is key to building lasting, productive relationships. We’ll just have to call it audit for ease of use here in this blog. 

Audits can take on many different forms and focus areas. In some situations, it’s more effective to target specific issues rather than trying to conduct a comprehensive, mind-blogging annual audit that covers everything.  Rather than an all-encompassing analysis, when possible, I like to break down the audit/evaluation into more manageable bites.  For example, rather than an annual review of all the areas, I might break it into every other month reviews, concentrating on specific areas each period.  Here’s some broad areas you might want to consider. 

  • Financial and Payments/Invoicing 
  • Compliance 
  • Operational 
  • IT & Security 
  • Quality, Performance and Effectiveness

Audit Sampling  

At first blush, it seems that pulling an objective and statistically valid sample is the key to success.  However, from experience, I’ve learned that there are many factors that affect the success of the audit. Developing a solid audit plan is the first step. Understand the goals for the audit, and then develop a work plan to reach those goals.  Part of the sampling question depends on your audit focus.   

Many years ago, a boss was vague when asking the vendor manager to conduct an audit of their agency.  After reviewing accounts for work performance, and checking for compliance with regulations, the vendor manager reported findings that included how well the vendor worked the accounts, timeliness of activation and current activity on the active accounts at the agency. Although the report was comprehensive and covered many areas – the boss then asked how many attempts were made prior to payments, settlement (if applicable) or closure.  So, the boss had some specific questions in mind – but didn’t share with the vendor manager conducting the review.  His concern was whether they had exhausted all efforts prior to closure, and the vendor manager was concentrating on understanding how quickly they initiated collection efforts.  Few accounts in his sample were even closed. 

The sampling methodology can greatly affect the results.  Once you understand the population you want to sample, there are a few next steps.  For example, if you wanted to better understand the accounts with settlements, you’d want to be sure to include a random sample of accounts that were identified as settled, and some accounts that were not identified as settlement accounts, but that have paid something on the account.   If you were to just do a complete random sample of accounts at the agency, you might not have enough accounts in the settlement sample to validate your findings. 

Don’t let “random” selection criteria deter you from using your judgment.  I remember one auditor that saw an unusual proportion of accounts with $10 payments.  This auditor delved deeper into that discovery, with a judgment selection sampling, rather than continuing only with the “random” accounts.  As it turned out, the accounts with the $10 payments were all within 10 days of a six-month required closure (with a contract that said accounts must be returned at 6 months if no payment.)  You can imagine the challenges this might have created. 

So, use random and statistics when you can, but trust your gut instincts to review other things or activities.  Rather than a pure statistical look at random sampling, the auditor needs to be sure there is an adequate amount of the high-risk areas in the sample, and that the sample provides the breadth and depth of coverage that they need to make the informed decisions about the overall compliance and effectiveness of the vendor.  Accounts in the sample can be rated for their overall compliance and work effort, or certain accounts can be sampled and rated for their activity around key areas.  For example, random selection is great for compliance tests, and a stratified sample, or a specific sample of paying accounts, would be good for a remittance check.  A simple random selection might be achieved with a computer program, or random number tables. Or some use systematic, or interval sampling, like choosing every tenth account.  Although both simple random and systematic sampling are generally free from bias, there is a potential hidden pattern in the systematic sample, for example if every tenth account also had been picked for additional work effort or a special campaign.     

Stratified sampling provides for a selection of sample items by breaking the population down into strata, or subgroups. A specific review of paying accounts or skip accounts might be good examples of strata to be included in a review.  

Block sampling is often used when evaluating remittance activity for example.  One might review all the remittances for a certain block of time, or month in this case.  Block selection should be used with caution, as valid references cannot be made beyond the period examined.  With block sampling, many blocks should be selected to minimize sampling risk.  

Personally, I like a combination of audit sampling techniques within the scope of an audit.  And, I think a judgment selection can be an important part of any audit process.  With judgment selection sampling, as illustrated above, there is a reliance on the expert judgment of the auditor. This method can be quicker and more cost effective than other sampling methods because it targets specific strata.  It also allows the auditor to adapt the sampling strategy as they learn more about the accounts.  It can also lead to in-depth insights that might not be captured through random sampling methods.  Of course, the downside to a judgmental audit sampling would be potential unconscious bias, so it’s important to to understand when the expert insight is more important than the random sampling.  It seems that by mixing random with judgmental when appropriate, we can have the best of both worlds. 

Objective vs. Subjective  

After developing the audit plan and determining the audit focus, it is essential to strive for objectivity in evaluation. Objectivity ensures that findings are based on clear, measurable criteria rather than personal opinions or biases. When evaluating something that can be inherently subjective, like assessing work effort or quality, many auditors resort to using rating systems, such as a scale of 1-5 or labels like “Exceeds Expectations” and “Does Not Meet Expectations.” These systems attempt to quantify subjective observations, providing a semblance of structure and standardization. However, while these rating systems can offer some level of consistency, they often leave too much room for interpretation, resulting in variability and potential bias. 

Subjectivity in evaluations can lead to significant discrepancies. For instance, what one auditor considers to be “exceeding expectations” might just be seen as “meeting expectations” by another. This variance can lead to confusion and inconsistency in performance feedback, which may be counterproductive. After all, we’ve all encountered situations where someone’s personal standards influence their assessments—like a teacher who rarely gives top grades because their expectations are so high, or one who never fails anyone because they believe everyone is trying their best. These kinds of subjective judgments can skew results and impact the perceived effectiveness of the audit. 

I prefer a system grounded in factual assessments—one that relies on clear, objective criteria that leave little room for personal interpretation. Instead of using ambiguous ratings, I prefer yes/no answers or quantifiable metrics that provide concrete data. For example, consider a scenario where an auditor is assessing whether accounts were activated within the contracted time period. A straightforward yes/no question eliminates ambiguity and focuses on factual compliance with agreed-upon standards. Similarly, using numerical data like “the collector met 9 out of 10 requirements” gives a more accurate picture of performance than subjective labels of “passing” or “exceeding expectations.” 

This approach not only makes the audit process more transparent and reliable but also provides clearer feedback to vendors. They can see exactly where they meet expectations and where they fall short, based on concrete evidence rather than subjective opinions. This transparency fosters a more constructive dialogue between the auditor and the vendor, paving the way for meaningful improvements and ensuring that both parties have a mutual understanding of performance standards. Ultimately, focusing on objective data helps build trust, maintain consistency, and drives effective vendor management practices. 

The Audit Plan 

Developing an audit plan for your organization is an important step.  It does not have to mirror any other company’s audit plan – just develop what works for you and your company, understanding your own products and risk levels.   You don’t have to do this alone. There are resources and people who can assist.  Our company has been teaching auditing of collection agencies and providing auditing of agencies for more than 30 years.   

With that experience, we could easily identify more areas to review and validate in audits than there is time in the day/week/month/year.  So, a focused approach of the key items, and use of appropriate sampling techniques and exception reporting will be crucial.  Rather than defining all the questions or areas you might include in a variety of audits, here are a few basic categories and descriptions of things you might want to address as you develop your audit plans: 

  • Compliance with Contractual Obligations 
    • Adherence to terms and conditions specified in the contract 
    • Performance against service level agreements (SLAs) 
  • Financial and Payment Records 
    • Accuracy of invoicing and payment processing 
    • Reconciliation of payments received, and fees charged 
  • Regulatory Compliance 
    • Adherence to industry regulations and standards 
    • Compliance with specific state legal requirements for debt collection  
  • Account Management 
    • Timeliness of account activation and updates 
    • Accuracy of account information and records 
  • Collection Practices 
    • Adherence to legal and regulatory requirements 
    • Compliance with Reg F and state regulations 
  • Operational Efficiency 
    • Effectiveness of collection strategies and methodologies 
    • Efficiency of workflows and processes 
  • IT & Security 
    • Data security measures and compliance with data protection regulations 
    • Integrity of IT systems used for account management and collections 
  • Quality of Service 
    • Accuracy and professionalism in communication with consumers 
    • Resolution of disputes and handling of complaints 
  • Performance Metrics 
    • Success rates in collecting debts 
    • Average time to resolve accounts 
  • Risk Management 
    • Identification and management of potential risks 
    • Policy and Procedure management 
  • Reporting 
    • Accuracy and timeliness of reports  
    • Transparency in reporting practices 
  • Staff Training and Development 
    • Training programs for staff on compliance and best practices 
    • Evaluation of staff performance and adherence to procedures 
  • Audit Trails 
    • Documentation of all collection activities and decisions 
    • Availability and completeness of records for audit purposes 
  • Exception Reporting 
    • Identification and review of exceptions or anomalies in account handling 
    • Procedures for addressing and resolving exceptions 

For the newcomer, this might seem overwhelming.  So, you can start by breaking it down into manageable pieces.  Try sampling and auditing to answer specific questions rather than the comprehensive overall review.   For example, start by identifying your biggest risk area, and look there first.   If you had a consumer complaint about the agency’s performance, that would be a good place to start.  Maybe you want to start with consumer treatment – so build an objective scorecard and start with some call monitoring to hear/see how the agency treats your customers.  Next, look at compliance, and the agency’s practices for staying up to date on regulations.  Then, maybe payments. 

But for the more seasoned industry veteran, it is probably not as overwhelming.  One thing that I have learned, however, is that there is always more to know, there is always change and there is always new things – so the good news is… you can always keep learning, and exploring new ways of auditing, reviewing, evaluating, assessing – or whatever you want to call it! 

Conclusion

In summary, vendor management audits are not just about ticking boxes or finding faults; they’re about fostering better communication, building trust, and enhancing the overall effectiveness of business partnerships. By carefully selecting audit types and focusing on specific areas, we can create a more manageable and insightful process that aligns with the strategic goals of both the vendor and the client. Balancing objective sampling methods with informed judgment allows for a comprehensive understanding of performance, compliance, and quality.  

The key is not just in the data but in how it is interpreted and applied to improve processes and outcomes. By being thorough yet practical, objective yet intuitive, these audits can serve as a valuable tool for continuous improvement and long-term success in vendor relationships.  

As we move forward, it is essential to remember that the goal of an audit is not just to scrutinize but to support and strengthen the collaboration between vendors and their clients, ensuring both parties thrive together. 

Judy Hammond

judy.hammond@resourcemanagement.com

President and Founder of Resource Management Services, Inc.

Publisher: CollectionComplianceNews.com

Judy Hammond is founder and President of Resource Management Services, Inc. The corporation was founded in 1986 and specializes in auditing and consulting, serving the collection and recovery industry.  As President of Resource Management Services, Inc., she has more than 35 years of experience with an emphasis on operational reviews for compliance and operational effectiveness of collection operations, both for creditors’ internal collection and recovery operations as well as collection agencies and attorneys.  She has worked with top banks and financial institutions, utilities, credit unions and telcoms, (and their vendors) and has conducted many Best Practices projects.  She is author of various industry publications: “Comprehensive Agency/Attorney Usage Study,” “Comprehensive Agency/ Attorney Usage Study II” and “Collect More From Collection Agencies”. Her work with creditors who were looking to sell debt for the first time, and subsequent Buyer/Seller research was the foundation for the second corporation, The Debt Marketplace, Inc.   She worked with Dennis Hammond as co-founders of the Debt Buyers’ Association, (now RMAi), building the foundations for industry standards, as well as the original code of ethics. She developed and produced two industry conferences, Collection and Recovery Solutions and Debt Connection Symposium & Expo, from their inception in 2002 and 2006, respectively, to 2022.  Prior to starting her own company, she worked with two large collection agencies.

Sign Up for the  Twice Monthly Newsletter

Just enter your email address at the top orange bar at:

Collection Compliance Experts – “The Power of Expertise: Oversight Perfected”

It’s that easy!  Twice a month – we provide blog updates and Resources for the Collection and Industry Professional. 

Your email is just for this newsletter.  We never sell your information.  No fee.  Opt-out at any time.