1 / 13

Establishing A Compliance Program: It Makes Sense Derry Harper

Establishing A Compliance Program: It Makes Sense Derry Harper Inspector General & Director of Compliance January 28, 2010. Institutional Compliance Program Broadly Defined.

glenna
Download Presentation

Establishing A Compliance Program: It Makes Sense Derry Harper

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. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Establishing A Compliance Program: It Makes Sense Derry Harper Inspector General & Director of Compliance January 28, 2010

  2. Institutional Compliance Program Broadly Defined • A program that has been reasonably designed, implemented, and enforced so that it will generally be effective in preventing and detecting violations of law. • Program must evidence the organization’s “due diligence” in seeking to prevent and detect violations of law.

  3. Compliance Program Design Proactive • Identify key risk areas and perform a risk assessment on compliance readiness. • Prioritize implementation of compliance program in the areas of higher regulatory risk because of impact on health or safety, academic or fiscal integrity. • Provide recommendations, education and training in connection with regulatory compliance gaps that have been identified.

  4. Compliance Program Design (Cont.) Integrated • Work collaboratively and as a liaison to other compliance offices/functions throughout the organization • To identify risk areas and conduct assessment • To monitor new developments or requirements in regulatory compliance

  5. Compliance Program Design (Cont.) Transparent • Promote Mission/Vision of the organization • Promote an organizational culture that encourages a commitment to compliance with law

  6. Internal Control A process affected by an entity, board of directors, management and other personnel designed to provide reasonable assurance regarding achievement of objectives related to: • Reliability of financial reporting • Effectiveness and efficiency of operations • Compliance with applicable laws and regulations

  7. Compliance Program Elements • Risk Assessment • Responsible Parties and Roles • Standards and Procedures • Program Oversight • Awareness, Education and Training • Lines of Communication • Monitoring and Auditing • Enforcement • Corrective Action

  8. Audit & Compliance Committee Charter • Regarding the SUS, the Audit & Compliance Committee will: • Receive and review university audit reports; • Identify trends in such reports and confirm that adverse trends are being addressed by the universities; • Initiate inquiries if Committee has reasonable cause to believe a university is not providing appropriate response to audit findings; • Direct the IG to conduct an inquiry or investigation if the Committee has reasonable cause to believe that a university board of trustees is unwilling or unable to provide for investigation of allegations of fraud. 8

  9. The Brogan Doctrine • Step 1: Establish Compliance Program • Identify Project Owner or Champion • Establish a Steering Committee • Step 4: Establish Systematic Compliance Program • Develop Compliance Matrix • Training • Monitoring • Identify areas of non-compliance • Corrective Action Plan Process • Step 2: Identify Key Objectives • List Key Objectives • Prioritize Key Objectives • Step 3: Identify Key • Compliance Risk Areas • Brainstorm and assess high risk areas • Assign high risk areas to process owner

  10. Florida Constitution U.S. Constitution BOG/Chancellor State Statutes Federal Statutes BOG Policy Regulations, Policies & Procedures Charters BOG Internal Operating Policies & Procedures BOG Regulations External Policies & Procedures External Policies & Procedures???? Compliance Matrix – Schema

  11. Compliance Matrix Steps Compliance Matrix > Constitution > State Admin Regs & Rules > State Statutes (20.055) > Federal Statutes > BOG Regulations > Charter Research Analysis Implementation: Development of Policies & Procedures

  12. Compliance Assistants • SUS Compliance Work Group: • FAMU Vice President for Compliance & Audit • FIU Assoc Vice President & University Compliance Officer • UCF Vice President & General Counsel • USF Executive Director for University Audit & Compliance • USF Chief Compliance Officer • BOG Compliance Steering Committee: • Senior Associate Vice Chancellor, Associate Vice Chancellor, Chief of Staff, IRM Assistance Vice Chancellor, Director of University Budgets, Director of Academic & Student Affairs, General Counsel, IRM Assistant Director, Assistant Director of Personnel, Budget Analyst, Campus Development Coordinator, and Research Associate

  13. BOG Regulation Compliance Review Tools

More Related