Greetings. I was curious if during an audit when the auditor requested training history records the auditor remarked how close in time various items were completed. Our users will tend to read the documents that have been revised, which in some cases may not have material changes based on the version control information, and move on to the next document. Having reviewed the revised documents, they will electronically sign for all of the documents at one time or may sign for them individually but the time between will be quite short. Recently during an audit an auditor questioned the completions because the times were so close. It was requested (internally) that we develop a report that excludes the time stamp of the completion. To my knowledge we have not had any other auditor make these remarks.
If you have experienced questions regarding the completion dates/times, was there a system (LMS) based response?
I appreciate your response as my background has been in a non-validated environment.
We had a similar conversation with our internal audit team, and we even asked Sany to join us on a phone call to explain things from an LMS perspective. We explained that the Completion Date and time as shown in the user's record and in reports such as Item Status and Learning History reflect the actual date of completion, regardless of when the electronic signature was entered. In places where the e-signature completion date is displayed, it is clearly identified as E-Signature Date, not Completion Date. Our internal auditor was not happy that the system allowed a user to delay entry of e-signature. We explained that, if a user clicked the Return to Content Structure button (in the legacy content structure page, not in the new Course Home interface), that a user who completed the item would be taken directly to the e-signature page. However, if the user "accidentally" clicked the menu option for Learning Home, he would have access to a link on the Learning Home page that would take him back to the e-signature page at his earliest convenience. We explained that the software provided a variety of navigation options to get from item completion to e-signature entry but that the software did not force the user into any one path. Our auditor was concerned that there might be the question later of whether or not the user could be accused of performing a procedure for which he had not been trained if he did not record e-signature immediately. We answered that the learning event completion date would show the true date of completion once the e-signature was entered. To allay his concerns, we created a custom report that displayed unverified learning events and their dates of completion so that we could follow up with negligent users if the need were to arise. So far so good.
Mary Katherine Johnson