The University of Texas System Institutional Compliance Program

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