Scope implementation of an effective institutional compliance ethics program
Download
1 / 23

Scope & Implementation of an Effective Institutional Compliance & Ethics Program - PowerPoint PPT Presentation


  • 368 Views
  • Uploaded on

Scope & Implementation of an Effective Institutional Compliance & Ethics Program. Presented by: Charles G. Chaffin, CPA, CIA Director of Audits and System-wide Compliance Officer The University of Texas System AND Todd Guttman of the Ohio State University. KEY POINTS.

loader
I am the owner, or an agent authorized to act on behalf of the owner, of the copyrighted work described.
capcha
Download Presentation

PowerPoint Slideshow about 'Scope & Implementation of an Effective Institutional Compliance & Ethics Program' - floria


An Image/Link below is provided (as is) to download presentation

Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author.While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server.


- - - - - - - - - - - - - - - - - - - - - - - - - - E N D - - - - - - - - - - - - - - - - - - - - - - - - - -
Presentation Transcript
Scope implementation of an effective institutional compliance ethics program l.jpg

Scope & Implementationof an Effective Institutional Compliance & Ethics Program

Presented by: Charles G. Chaffin, CPA, CIA

Director of Audits and System-wide Compliance Officer

The University of Texas System

AND

Todd Guttman of the Ohio State University


Key points l.jpg
KEY POINTS

  • The University of Texas Challenge

  • How Do I Get Started?

  • Implementation of an Institutional Compliance Program

  • Building the Infrastructure

  • Creating Compliance Awareness

  • Managing Critical Risks

  • Appraisal and Renewal

  • Benefits

  • Sharing the Best Practice Initiative

  • Resources


The university of texas challenge l.jpg
The University of Texas Challenge

  • Design, implement, and operate:

    a program that will provide an on-going, real-time assessment of the compliance profile of the system and each of its entities for executive management and the Board of Regents.

    • Board of Regents Issued Challenge

    • Challenge assigned by Executive Management to Director of Audits

      • 9 Academic Institutions

      • 6 Health Institutions

      • 1 Central Headquarters


How do i get started l.jpg
How Do I Get Started?

  • Appoint an ad hoc committee representing all stakeholders in the collegial community

    • Including:

      • Business Affairs

      • Academic Affairs

      • Student Affairs

      • Athletics

      • Development

      • Safety

      • Human Resources

      • Research

      • Faculty


How do i get started continued l.jpg
How Do I Get Started? (continued)

  • Obtain a MENTOR for outside expert advice.

    • For Example: Charles G. Chaffin or Todd Guttman

  • Adopt an operating philosophy and goals and objectives for the program.

  • Produce an Action Plan (a written blueprint) to guide the program.


Implementation of an effective institutional compliance program l.jpg
Implementation of an Effective Institutional Compliance Program

  • Definition: An Institutional Compliance Program is one that encompasses your entire university.

    • Must have one within Athletics

    • And within the Safety Program

  • The Institutional Compliance Program joins it all together, creating a situation in which one individual is held accountable by the president.


  • Implementation of an effective institutional compliance program cont d l.jpg
    Implementation of an Effective Institutional Compliance Program (cont’d)

    • Building the Infrastructure

    • Creating Compliance Awareness

    • Managing Critical Risks

    • Appraisal and Renewal


    Building the infrastructure l.jpg
    Building the Infrastructure Program (cont’d)

    • TIME and RESOURCES Required

      • Driven by the Size and Overall Complexity of your Institution

      • Convincing your Institution to Fund and/or staff the Program

    • Specific Tasks

      • Appoint a COMPLIANCE OFFICER

        • Current executive or a new position

        • Attorney, Auditor, Business Officer

        • Full-time or part- time


    Building the infrastructure continued l.jpg
    Building the Infrastructure (continued) Program (cont’d)

    • Appoint a COMPLIANCE COMMITTEE

      • Executive – President’s Cabinet

      • Working Committee – High Risk Area Department Heads (H.R. Director, Safety Officer, etc.)

    • Establish a COMPLIANCE FUNCTION/OFFICE

      • Full-time staff or slice of current staff time.

      • Can be housed in the legal, audit, business affairs office, or it can stand alone.


    The infrastructure l.jpg
    The Infrastructure Program (cont’d)

    • Compliance Officer

    • Compliance Committee

    • Compliance Function/Office

    • Institutional Community Imbued with Ethical Culture


    Creating compliance awareness at your institution l.jpg
    Creating Compliance Awareness Program (cont’d)at Your Institution

    • Compliance Awareness = An Institution Imbued with Ethical Culture

      • From the bottom up, include everyone

  • Develop a Standards of Conduct Guide (Code of Conduct)

  • Develop a General Compliance Training Program

    • Face – to – face

    • Web-based

    • Articles and emails.


  • Creating compliance awareness at your institution continued l.jpg
    Creating Compliance Awareness Program (cont’d)at Your Institution (continued)

    • Establish a confidential reporting mechanism (Compliance Hotline)

      • Third Party Vendor

      • In-house Legal or Audit

      • Email


    Managing critical risks l.jpg
    Managing Critical Risks Program (cont’d)

    • Risk ASSESSMENT Process

      • Identify Risks:

        • Probability of Occurrence

        • Potential Impact Related to Occurrence

          • Identify the SHOW-STOPPERS


    Managing critical risks continued l.jpg
    Managing Critical Risks (continued) Program (cont’d)

    • Determine Risks that are Organization Critical:

      • Medicare Billing Rules (fines)

      • Research Time and Effort Reporting (fines)

      • Research Human Subjects (suspension)

      • Research Medical Billing (fines)

      • Lab Safety (injury)

      • Fire (injury and death)

      • Athletic Recruiting (loss of scholarships)

      • Athletic Boosters (loss of scholarships)

      • Sexual Harassment (very bad)

      • Endowment Spending (repay endowment)


    Managing critical risks continued15 l.jpg
    Managing Critical Risks (continued) Program (cont’d)

    • Risk MANAGEMENT Process

      • Single High-Level Responsible Party

        • Medical School Dean

        • Vice President of Research

        • Dean or Provost

        • Vice President for Business

        • Athletic Director

        • Human Resources Director

        • Provost

      • Specialized Training Plan

        • (Risk Specific)


    Managing critical risks continued16 l.jpg
    Managing Critical Risks (continued) Program (cont’d)

    • Monitoring Plan

      • How do you know if you are following the rules?

    • Reporting Plan

      • Report Cards to Compliance Officer and President


    Appraisal and renewal l.jpg
    Appraisal and Renewal Program (cont’d)

    • Addressing instances of non-compliance

    • On-going assurance regarding the management of mission critical risks

      • Certifications

      • Inspections

      • Agreed-upon Procedures

      • Audits (design and/or information validation)

      • Peer Reviews


    Appraisal and renewal continued l.jpg
    Appraisal and Renewal (continued) Program (cont’d)

    • Periodic assessment of the Compliance Program

      • Self-assessment

      • External Peer Review

    • Renewal

      • (Action Plan based on periodic assessment)


    Benefits l.jpg
    Benefits Program (cont’d)

    • Reduction in NEGATIVE PUBLICITY

    • Reduction in FINES and EXTERNAL AUDITS

    • Reduction in WORKERS’ COMP. CLAIMS

    • Safety Program Awards

    • Change in Organizational Culture

    • Established Basis for Enterprise-wide Risk Management and Accountability Program


    Sharing the best practice initiative l.jpg
    Sharing the Best Practice Initiative Program (cont’d)

    • How-to book: Effective Compliance Systems: A Practical Guide for Educational Institutions(available from The Institute of Internal Auditors, Inc.)

    • Hosted: 1st and 2nd National Conferences on Effective Compliance Systems in Higher Education

    • Sharing: Major Research Institutions Compliance Group

      (formed after the 2nd Compliance Conference)


    Resources l.jpg
    Resources Program (cont’d)

    • www.utsystem.edu/compliance

    • www.theiia.org

    • www.utsystem.edu/AUD

    • Chapter 8 -- 2004 Federal Sentencing Guidelines Manual Index (for the Sentencing of Organizations). http://www.ussc.gov/2004guid/tabconchapt8.htm  (effective November 1, 2004)


    Resources continued l.jpg
    Resources (continued) Program (cont’d)

    • http://www.ussc.gov/2004guid/8b2_1.htm

    • CHAPTER EIGHT SENTENCING OF ORGANIZATIONS http://www.ussc.gov/2004guid/CHAP8.htm

    • http://www.pcms-team.com/federal-sentencing-guidelines/

    • http://www.ethics.org/ethicsindex/fsgo.html

    • http://finance.pro2net.com/x46801.xml


    Resources continued23 l.jpg
    Resources (continued) Program (cont’d)

    Other, important related sites and articles:

    • http://www.midicorp.com/articles.php?section=articles&id=77

    • http://www.ussc.gov/PRESS/rel0504.htm  (Gov-ernment Press Release)


    ad