NIE Guide—U.S. Newspapers

For the Audit

For all educational program circulation claimed on ABC documents, a newspaper must maintain documentation to support the following:

• Order
• Payment
• Generation of sponsorship funding (if applicable)
• Delivery

This includes, but is not limited to:

• Orders from school officials, teachers, individual or families (For NIE home delivered), or colleges.
• Financial records for all incoming and outgoing sponsorship funds – specifically for payment of educational program copies.
• Financial records for all school accounts.
• List of fundraising efforts and copies of promotional material utilized for each.
• Affidavits (for NIE classroom copies).
• Copy of any NIE home-delivered curriculum, including minimum completion standards required by the newspaper and documentation supporting the completion of the minimum standards.
• Records of draw and leftovers for all registered college student programs.
• Access to a list of registered college students for all registered college student programs.

During the course of the audit, the auditor will determine the level of review necessary for a newspaper’s educational program. Audit procedures will be employed as deemed appropriate by the auditor and audit management.

As a reminder, copies claimed on Publisher’s Statements that are not supported by cash payment at the time of audit are excluded from paid circulation on the Audit Report.

It is the publishers’ responsibility to ensure their educational programs are executed in compliance with all ABC rules and guidelines. Upon request, ABC’s Publisher Relations department provides a confidential review of members’ programs. To take advantage of this review or if you are developing an initiative that is not addressed in this guide, please contact your Publisher Relations manager.

It is imperative to the efficiency of the audit that the publication responds in a timely manner to all auditor requests for documentation to support circulation claimed as educational programs.