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The University of Texas System Institutional Compliance Program. The Compliance Officer. The Compliance Officer. Responsibilities and activities Who to Appoint. Compliance Office Responsibilities. Make compliance a part of everyday activities of the institution

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Presentation Transcript
the compliance officer
The Compliance Officer
  • Responsibilities and activities
  • Who to Appoint
compliance office responsibilities
Compliance Office Responsibilities
  • Make compliance a part of everyday activities of the institution
  • Monitor the various compliance program activities
  • Communicate with the chief executive officer and others regarding compliance program activities
  • Establish a compliance function
making compliance a part of everyday activities
Making Compliance a Part of Everyday Activities
  • Awareness communication avenues
  • Risk-based plan and compliance manual
  • Training tools and delivery mechanisms
  • Monitoring plans and assurance processes
  • Confidential reporting mechanism
  • Reporting procedures
monitor compliance program activities
Monitor Compliance Program Activities
  • Training
  • “A” list risk monitoring plans
  • Non-compliance
  • Program
communicate with executive management
Communicate with Executive Management
  • Instances of non-compliance that require executive action
  • Risk-based plan
  • Monitoring activities
  • Compliance Committee meeting minutes
  • Compliance program self-assessment
establish the compliance function
Establish the Compliance Function
  • Robust compliance function
  • Coordinator compliance function
  • Informal compliance function
  • No compliance function
robust compliance function
Robust Compliance Function
  • Complex compliance environment
  • Full-time compliance officer
  • Full-time support staff
  • Separate budget and organizational chart
  • Absorbs previously independent compliance activities such as medical billing or environmental health & safety
  • Usually found in health-related and major research-oriented institutions
coordinator compliance function
Coordinator Compliance Function
  • Complex compliance environment
  • Compliance Officer has other pre-existing responsibilities and devotes little time
  • Delegates daily operation of the compliance program to a “coordinator”
  • Full-time support staff, usually with separate budget
  • Usually found in academic institutions with some research, intercollegiate athletics, on-campus housing, etc.
informal compliance function
Informal Compliance Function
  • Limited compliance environment
  • Full-time compliance officer
  • Support staff comes from existing institutional operating units such as EH&S, internal auditing, human resources, etc
  • Budget limited and may be buried
  • Usually found in institutions that expect opposition to the program or that want to emphasize the importance of the program
no compliance function
No Compliance Function
  • Limited compliance environment
  • Compliance officer has other pre-existing functional responsibilities
  • Support provided by compliance committee, other institutional units, and outsiders
  • Budget usually for external help only
  • Usually found in small institutions engaged mostly in undergraduate instruction
who to appoint
Who to Appoint?
  • Current Executive Staff member
  • Create new executive level position
current executive staff member
Current Executive Staff Member
  • Pro
    • Knows the culture
    • Immediate start
    • Network already established
    • No reallocation of resources required
  • Con
    • Not the main job
    • Compliance perceived as part of functional area
    • Possibly conflicts with regular duties
create a new executive staff position
Create a New Executive Staff Position
  • Pros
    • Main job
    • Not attached to an existing functional area
  • Cons
    • Hiring process takes time
    • Must learn institutional culture
    • Must develop personal network
    • Delays program implementation
    • Reallocation of institutional resources required
summary
Summary
  • Big job
  • Compliance officer must be a communicator
  • Compliance coordinator and staff need consultant, assurance provider mentality
  • Start-up decisions and long-term decisions may not be the same