What is Institutional Compliance?Administrators, faculty, staff and students who work on behalf of the institution assume responsibility for conducting their assignments within the law and in maintaining the highest ethical standards. “Compliance” refers to adherence to, or the following of, laws, rules, policies, and any other requirements that apply to a set of job duties. While employees are not responsible for knowing all the laws and policies that pertain to the institution, they are responsible for those that relate to their immediate job duties.
BackgroundIn response to continuing scrutiny from government regulators and an increasingly complex statutory and regulatory environment, in 2006 the president established an Office of Institutional Compliance Assistance and Policy Administration with the directive to build an effective institutional compliance program. Compliance Assistance is a central office intended to foster and support the institution’s commitment to comply with all applicable laws and regulations, to assist in detecting and correcting compliance violations promptly and to aid in eliminating misconduct and other wrongdoing, whether intentional or unintentional.
The institution is committed to conducting business consistent with applicable laws and regulations and to promoting high standards for ethical conduct. To achieve this objective, the Office of Institutional Compliance Assistance and Policy Administration follows the guidelines established by the United States Sentencing Commission that clearly outline seven (7) components for establishing an effective compliance program. The key components are as follows:
- Establish compliance standards and procedures that are reasonably capable of reducing the prospect of noncompliance by employees and faculty.
- Assign high-level personnel in the organization the responsibility of overseeing compliance with such standards and procedures.
- Exercise “due care” not to delegate substantial discretionary authority to individuals who the organization knew, or should have known through exercise of due diligence, had a propensity to engage in illegal activity.
- Effectively communicate compliance standards and procedures to all employees by requiring participation in compliance education and training programs.
- Take reasonable steps to achieve compliance through the use of monitoring and auditing systems that are designed to detect noncompliance and by having in place a mechanism for reporting possible misconduct, fraud, abuse and noncompliance.
- Establish and enforce standards through appropriate disciplinary mechanisms.
- Take reasonable steps to respond appropriately to detected offenses and to prevent further similar offenses.
- Identifying compliance risks and effective methods to mitigate those risks;
- Improving delivery of compliance resources;
- Educating and promoting awareness of ethical and legal standards of conduct through effective programs; and
- Partnering with responsible institutional representative to monitor compliance to ensure that appropriate and effective corrective actions are taken where non-compliance is detected.