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Compliance Services works closely with the University community to promote an institutional culture of compliance and thus prevent and effectively address violations of law, regulations and University policy and protocols.

Services

 

   ✔ Consultations                                     ✔ Training                        ✔ Table-Top Exercises/Mock Inspections
   ✔ Post-Incident Follow-Up                    ✔ Process Review           ✔ Policy Development, Review, Consultation
   ✔ Help Line Monitoring

What is a Compliance Program?

A Compliance Program is a framework of elements that allows an organization to reduce its risk of regulatory violations that could result in fines and other penalties.  The federal government has defined the criteria that make a compliance program effective; that is, a program that can meet its goals of preventing and addressing non-compliance. Among other things, the federal guidelines encourage organizations to “(1) exercise due diligence to prevent and detect criminal conduct; and (2) otherwise promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.” The federal guidelines go on to describe the “7 elements” that constitute an effective compliance and ethics program.  These elements include (click on the element to see how the University addresses it):

Standards & Procedures

The Office of Compliance Services administers and maintains UVM's Institutional Policies website and assists the VP for Executive Operations in the management and maintenance of the University’s policy program.

Oversight

The Audit Committee of the Board of Trustees has authority and responsibility for the Compliance Program and its effectiveness. The Director of Compliance Services serves as the individual assigned with day-to-day responsibility for the Compliance Program. The Chief Internal Auditor, to whom the Director reports, reports directly to the Chair of the Audit Committee of the Board of Trustees. This reporting structure provides independence from operations that is needed for the Compliance Program.

Avoid Delegation of Authority to Unethical Individuals

The University performs background checks as required by law and for many new hires depending on the nature of the position. These background checks include a review of publicly available government sanction lists to determine whether an individual has been suspended or excluded from any federal programs.

Education & Training

The Office of Compliance Services provides Code of Conduct and Compliance Program training at new hire orientation. The office provides training for various groups and departments throughout the year as identified or on an as-needed basis. In addition, the office is always available to provide consulting services and assistance to departments developing their own department-specific compliance training.

Reporting, Monitoring & Auditing

The Office of Compliance Services administers the Ethics and Compliance Reporting and Help Line (“HelpLine”). The HelpLine accepts anonymous reports. In addition, the Office of Compliance Services provides several other mechanisms for reporting suspected wrongdoing including email, direct call, in-person meeting and regular mail. For more information on the reporting system, click here.

The Office of Compliance Services continually monitors and performs a risk assessment of all the regulatory compliance assurance activities existing throughout the University and also monitors emerging compliance issues.

The Office of Compliance Services works closely with the Office of Audit Services; however, our missions and functions are different. The Office of Compliance Services refers HelpLine reports to the Office of Audit Services when that office can provide information on compliance assurance and risks. Similarly, the Office of Audit Services will refer areas to the Office of Compliance Services that have compliance implications or risks.

Enforcement & Discipline

Many University policies and operating procedures contain language addressing disciplinary action for violations. The Office of Compliance Services, in consultation with the Office of General Counsel, Human Resources and individual department leadership, review violations identified through HelpLine reports to determine appropriate enforcement actions and equitable disciplinary action for same or similar violations.

Response & Prevention

The Office of Compliance Services provides consultations for a diverse mix of compliance issues both on a proactive and a reactive basis. Most consultations are provided to University operating departments upon request. Other consultations are provided either as a result of audit findings, through identification of a new compliance risk or when new regulation is proposed or promulgated. Risks are identified through a variety of sources and are reviewed to determine the most appropriate response and/or prevention plan based on the individual characteristics of the risk. The Office monitors government reviews of the University to identify trends, assist in correcting issues and to prevent reoccurrence.

The Office is also charged with responding to allegations of wrongdoing that are reported through any of the compliance reporting mechanisms. Reports that are reported under the Compliance Program are thoroughly investigated. Instances of substantiated noncompliance are addressed and corrected.

 

What does my Compliance Program do?

Your Compliance Program identifies, monitors, and assesses risk as it relates to the large number of regulatory requirements that exist within higher education.  It provides a system for you to report suspected wrongdoing as well as a framework for you to inquire about various situations (for example, processes, situations or behaviors) that could impact the University’s compliance efforts.  Your Compliance Program encourages open and transparent communication.  It provides you with a single contact when you need assistance, guidance or more information on existing or emerging compliance issues.

Why do we have a Compliance Program?

The number of regulations and regulatory oversight continues to increase while budgets and funding continues to be a challenge.  We have to do more with less.  An effective Compliance Program is designed to help all members of UVM’s workforce comply with the multitude of laws, acts, regulations and statutes that govern higher education.  The University of Vermont is strongly committed to ethical conduct and fostering a "culture of compliance".  In 2009, the Board of Trustees approved the creation of a Compliance Program in part to (i) reduce the risk of violations, (ii) mitigate identified violations, (iii) maintain public trust, and (iv) provide a framework for all members of the UVM community to encourage and support ethical behavior in all University-related activities.

What is a “Culture of Compliance”?

At the most basic level, a "culture of compliance" is an environment that supports adherence to both the law and to institutional policies and procedures.  A “culture of compliance” provides mechanisms for employees to report suspected wrongdoing and to seek guidance when faced with a difficult ethical decision.  But, it’s more than that.  A “culture of compliance” recognizes that the ethical decision is not always obvious.  It recognizes that people make mistakes.  It encourages us to speak up when we’re not sure what the right course of action is.  It gives us the confidence in ourselves and the trust in the process to be able to self-report when we’ve made a mistake and to encourage others to self-report.  A “culture of compliance” understands that speaking up can be difficult but it also knows that the University needs individuals to speak up.  It gives us all, regardless of our position or title, a voice and it holds us all accountable for our actions.  A “culture of compliance” does all of this while providing protection from retaliation or retribution for good faith reports or inquiries.  In other words, it encourages all of us to be active and engaged participants in the environment that we work in.

What are the benefits of the Compliance Program?

Your Compliance Program reduces the risk of regulatory violations occurring in the first place.  If a violation does occur, your Compliance Program reduces the impact that violation could have on the University.  Put another way, your Compliance Program:

  • Encourages communication and teamwork which, ultimately, allows the University to self-correct mistakes before it becomes a finding in a regulatory review or governmental audit.
  • Allows us to use our financial resources on activities designed to achieve the University’s mission, vision and goals rather than on fines or other penalties. Regulatory violations can be costly in terms of finances, time and reputation. Having the ability to use these precious resources as they were intended rather than on fines, legal fees, other costs will, in the end, benefit those that we are here to serve: students.
  • Gives us an ability to focus on our mission with confidence. When the rules are unclear, arbitrary or otherwise confusing, you’ll spend much of your own time navigating the complex regulatory and policy requirements. You’ll hesitate. You’ll take additional steps or do something that you normally wouldn’t do because you’re not sure what the right course of action is. We all have a responsibility to comply with regulations. The Compliance Program provides resources to help you take that right course of action, it clarifies the rules and attempts to take the “guess” out of the “work”.

 

Infographics

 

What does Compliance Services do? Culture of Compliance Reporting Options

What the Compliance Office does infographic

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Culture of Compliance Inforgraphic

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Reporting Options Infographic

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