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Questions and Answers
1.
What is institutional
compliance?
2.
Why is there an emphasis on "compliance" within the UH System?
3.
When did the Institutional Compliance Program begin at UHV?
4.
Why does UHV need a Compliance Program?
5. Who is the UHV
Institutional Compliance Officer?
6.
How does the campus Institutional Compliance reporting structure work?
7.
As an employee, what is my role in
institutional compliance?
8.
If I have questions about
compliance, who can answer them?
9.
What should I do if I suspect something is wrong, but I don't know for
sure?
10. Is there a way to make confidential reports?
11. What type of information should be reported?
12. Will I need to take compliance
training?
1. Q: What is institutional
compliance?
A: For every employee
at UHV, compliance is simply doing the right thing.
At the institutional level,
the management of compliance risks is good ethical business practice.
Within the university, we operate in an increasingly complex environment
of laws, regulations, policies, standards and procedures. We encounter
risks on a daily basis. An effective compliance program is knowing what
our particular risks are and then putting into place reasonable measures to
help insure that the most critical risks are lessened to reasonable levels.
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2.
Q:
Why is there an emphasis on "compliance" within the UH System?
A: In the wake of
instances of major non-compliance at various University systems across the
United States that resulted in very negative publicity, large fines and/or
loss of funding, the UH Board of Regents requested that the System
administration develop an Institutional Compliance Program. The Action
Plan that was developed includes the following elements:
- Approval of a compliance
program following the UT System model;
- Designation of the Director of Internal Auditing
as the System-wide Compliance Officer;
- Designation of an Institutional Compliance
Officer at each component institution;
- Appointment of an Institutional Compliance
Committee at each component institution;
- Requirement for the Institutional Compliance
Committee to meet quarterly;
- Adoption of a formal Board policy on
institutional compliance;
- Organize, fund and provide oversight for an
ongoing and proactive compliance function meeting the criteria of the
U.S. Sentencing Guidelines;
- Submission of an annual risk-based plan of
compliance activities;
- Establishment of functional liaisons and a
support structure to ensure accomplishment of those activities deemed
to be high risk;
- Development of a compliance manual that sets
forth expectations and standards of conduct for employees;
- Establishment of a confidential reporting
mechanism with summary information presented at Compliance Committee
meetings;
- Budgeting of sufficient resources to fund
compliance activities that reduce compliance risk to acceptably low
levels;
- Ensuring that appropriate general and
specialized compliance training is provided for employees and that
attendance is acceptable;
- Submission of quarterly reports on compliance
activities to the System Compliance Officer;
- Follow-up to determine that appropriate
corrective actions have been taken in the event of non-compliance;
- Annual auditing of the
compliance functions at component institutions by the Director of
Internal Auditing
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3.
Q: When
did the Institutional Compliance Program begin at UHV?
A: The development of UHV’s Compliance Program began in
2002 as a directive from the UH Board of Regents. It is an ongoing
process. At UHV there is/are:
-
Compliance Officer
-
Compliance Committee
-
Employee Standards of Conduct
-
Compliance Training Program (in development)
-
Risk
Assessment of Known External Compliance Issues
-
Mitigation focused on the Highest Rated Risks
-
Quarterly Reporting of Compliance Related Activities
-
Confidential Reporting Line
-
Scheduled auditing of the campus program by the UHS Internal Auditing
Department (to be scheduled beginning FY05)
-
A
campus Institutional Compliance Website
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4.
Q: Why does UHV need a Compliance Program?
A: To reduce our
highest known risks to acceptable levels. The campus Compliance
Program goals are to achieve the following objectives:
1.
Comply with the UH Board of Regents and System mandates;
2.
Reduce the risk of non-compliance that could result in significant
harm to the institution's operations, finances or reputation;
3.
Provide evidence to external entities, e.g., Texas Legislature,
Federal oversight authorities, and UH System that UHV has a system in place
to identify and actively manage its highest risks;
4.
Develop and then maintain a campus compliance program that has the
following elements:
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5.
Q: Who is the UHV Institutional Compliance Officer?
A: The campus
Institutional Compliance Officer is Gregory Fanelli, Director of Business
Services. E-mail:
fanellig@uhv.edu or telephone
361.570.4820.
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6.
Q: How
does the campus Institutional Compliance reporting structure work?
A:
The
UHV Compliance Officer is appointed by and reports to the President and is
the campus liaison to the System Compliance Officer. The Compliance
Officer serves as the chair of the campus Institutional Compliance Committee
and is a member of the UHS Institutional Compliance Officers Committee. The
campus compliance officer monitors the various compliance program activities
to try to help ensure that compliance activities and the program in general
is operating the way it should. The campus Compliance Officer also prepares
formal quarterly campus compliance activity reports to the System Compliance
Officer and campus Administration. Report information is also available to
all employees on the campus Institutional Compliance website which is also
maintained by the campus compliance officer.
The System Compliance
Officer, in turn, is responsible to the Chancellor and the Board of
Regents. The System Compliance Officer, who is also the UHS Director of
Internal Auditing, chairs the System-wide Institutional Compliance
Committee and is responsible for auditing the component compliance programs.
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7.
Q: As an employee, what is my role in
institutional compliance?
A: Your role, basically, is “to do the right thing.” Each of
us are faced with various risks and compliance issues in the workplace and
in our particular positions of responsibility. Many of us have resources at
our discretion, such as staff, finances, property, and information. Each of
us is entrusted with responsibilities associated with our positions at the
University. It is how we handle our responsibilities and what we do with
and how we use the resources available to us that either increases risk or
lessens it.
As a faculty or staff employee, your role is to understand
the various types of risks you may encounter as part of your job and the
proper and correct way to respond. As part of your involvement in campus
compliance, you have an obligation to take any required general or
specialized training required for your position or for employees in
general. You need to keep abreast of the laws and regulations that may
affect your area of operations. You need to be knowledgeable of the Board,
System and Campus policies and procedures that affect your position and
responsibilities.
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8.
Q: If I have questions about
compliance, who can answer them?
A: The answers to many common compliance
questions can be found in the
Employee Standards of
Conduct Guide. Every employee has access to the guide on the
Institutional Compliance website.
-
If the Guide does not answer your question, you are encouraged to go
to your supervisor with questions.
-
If your supervisor cannot answer your question or you feel
uncomfortable asking your supervisor, you have a variety of offices you can
go to depending on the issue you are trying to resolve. These offices and
their phone numbers are also listed in the Employee Standards of Conduct
Guide.
-
The Office of Institutional Compliance may be able to
answer your questions or put you in contact with someone who can.
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9.
Q:
What should I do if I suspect something is wrong, but I don't know for
sure?
A:
Discuss it with your supervisor. If you feel uncomfortable asking your
supervisor, there are other offices you can go to. These offices and their
phone numbers are also listed in the Employee Standards of Conduct policy.
Federal and state laws and university policy
prohibit retaliation against employees who report violations of possible
illegal activities in good faith. The University encourages employees to
make good faith reports of alleged illegal activity and is committed to
maintaining the confidentiality and anonymity of all individuals who make
such reports to the extent allowed by law.
Your assistance may also help the University to comply with
the law, thereby possibly preventing or lessening fines, regulatory
penalties, negative publicity and embarrassment to the University.
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10.
Q: Is there a way to make confidential reports?
A: Yes. The University uses a personal incident
reporting system called MySafeCampus. You may report allegations of fraud,
waste or other regulatory compliance issues anonymously and confidentially
from any phone or from any computer with internet access. To make a report
online, go to www.MySafeCampus.com
. To make a confidential report by phone, you may call toll-free
1-800-716-9007. MySafeCampus services are available 24/7 and are not
affiliated in any way with the University of Houston System. To learn more
about MySafeCampus,
click
here.
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11.
Q: What type of information should be reported?
A: The information should be limited to potential
violations of laws, regulations or rules such as fraud, embezzlement, time
and expense abuse, conflicts of interest, kickbacks, or other illegal
activities rather than employee dissatisfaction issues or complaints.
Personal concerns about individual employee matters, e.g., complaints
concerning wages, hours of work, performance evaluations, merit raises,
etc., should be handled in accordance with other University policy in place.
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12. Q: Will I need to take compliance
training?
A: It is
very important that as an employee, you are aware of the compliance issues
that impact you or your position on a daily basis. Awareness of the
Employee Standards of Conduct
is the first place you should start. General compliance training will be used to broaden
awareness. More specialized training for higher risk operations identified
through the risk assessment process, e.g. life safety, financial aid, may
also be required. All employees may be
expected to participate in any General and/or Specialized Compliance
Training developed.
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