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The University of Texas System Institutional Compliance Program

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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The University of Texas System Institutional Compliance Program

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  1. The University of Texas System Institutional Compliance Program The Compliance Officer

  2. The Compliance Officer • Responsibilities and activities • Who to Appoint

  3. 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

  4. 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

  5. Monitor Compliance Program Activities • Training • “A” list risk monitoring plans • Non-compliance • Program

  6. 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

  7. Establish the Compliance Function • Robust compliance function • Coordinator compliance function • Informal compliance function • No compliance function

  8. 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

  9. 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.

  10. 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

  11. 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

  12. Who to Appoint? • Current Executive Staff member • Create new executive level position

  13. 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

  14. 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

  15. 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

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