General Compliance Information

 

Institutional Compliance Program

All component institutions of the University of Houston System are required to have an Institutional Compliance Program that follows the guidelines set forth in the University of Houston System Action Plan to Ensure Institutional Compliance. Some key elements of the Action Plan are:

The appointment of a Compliance Officer at System Administration and each component institution.   The mandate for a continuous and proactive compliance function which reports to the Institutional Compliance Officer . The allocation of sufficient resources at each component institution and at System Administration to fund compliance activities (including information resources, training, and monitoring activities) that reduce compliance risk to an acceptably low level.   The requirement that the Institutional Compliance Officers and Committees at the component institutions and System Administration report their activities to the UH System-wide Compliance Officer at least quarterly.

 

Purpose of the Institutional Compliance Program

The purpose of the Institutional Compliance Program (the Program) at UHS is to promote and support a culture, which builds compliance consciousness into the daily activities of the University. This is accomplished by establishing an infrastructure that provides ongoing assurance to management that risks, particularly compliance risks, are being mitigated to acceptable levels. Continuous management of high risks by those involved in each process is an essential element of the Program and is necessary in order to minimize threats to the achievement of UHS's goals and objectives.

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Mission of the Institutional Compliance Program

To promote and support a culture at the University of Houston - Downtown which builds compliance consciousness into the daily activities of the University and encourages all employees to conduct University business with honesty and integrity.

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Goals of the Institutional Compliance Committee

Goals of the Institutional Compliance Program

 To develop an institutional compliance program that:

Identifies and evaluates risks that are critical to the institution.   Ensures that critical institutional risks are properly managed by the appropriate individuals.   Provides all employees with the training and or information necessary to do their jobs and understand the relevant compliance issues.   Provides ongoing positive assurance to managers, executive officers, and the Board of Regents regarding the status of critical institutional risks.   Provides all employees with an opportunity to report issues of potential non-compliance in a manner that preserves confidentiality.

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Types of Risks

We typically associate risks with financial matters; however, any issue or circumstance that negatively impacts the ability to meet our business objectives represents a risk to UHD.  This includes:

	Strategic Risks	-	Risks that affect our ability to achieve our goals and mission
	Financial Risks	-	Risks that may result in a loss of our assets
	Operational Risks	-	Risks that affect our ongoing management processes, such as the installation of a new administrative system
	Compliance Risks	-	Risks that affect our adherence to externally imposed laws and regulations as well as internal policies and procedures
	Reputational Risks	-	Risk that affect our reputation as an institution of higher education

 

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Roles and Responsibilities

Employees (Faculty and Staff)

Each employee is responsible for the following:

Maintaining high ethical standards,   Compliance with laws, regulations, policies, and procedures applicable to the performance of their job, and   Reporting instances of non-compliance in an appropriate manner.

Managers

Every manager, regardless of their level in the organization, is accountable for compliance in their operational unit.

Responsible Persons

These individuals are responsible and accountable for management of the institutional risks identified in risk assessments. Each risk must have one Responsible Person who meets the following criteria:

Exclusive responsibility for managing the risk,   Knowledge to manage the risk, and   Authority to manage the risk.

 

The Responsible Persons work with the Compliance Officer and members of the Compliance Committee to develop the necessary monitoring, training, and reporting plans to manage institutional compliance risks and may be asked to present information to the Compliance Committee or internal audit regarding their risk areas.

Compliance Committee Members

Administers the day-to-day operations of the Compliance Program. Some specific responsibilities include:

Conducting risk assessments for the Committee Member’s assigned Compliance Area. Where others complete the assessments, the Committee members are responsible for the accuracy of the information within their compliance area.   Working with responsible persons to create monitoring, training, and reporting plans.   Developing and administering general compliance training for their Compliance Area and ensuring that specialized training is adequate.   Providing input and recommendations on Training issues that relate to the Institutional Compliance Program.   Ensuring oversight in areas with risk that are critical for the institution.   Providing input on policy and operational issues relevant to a successful compliance effort.   Working with the Compliance Officer to prepare reports which provide UHD and UH System administrators information concerning the status of the control of compliance risks.

 

The Compliance Committee Members are advocates for compliance. They are a communication avenue between the Compliance Committee and first line management and staff. They work within the University community to raise and maintain the compliance consciousness in daily departmental activities.

Compliance Officer

Oversees the Compliance Program to ensure that the infrastructure of the program is adequate and that it is operating effectively. Some specific responsibilities include:

Establishing and maintaining a system that builds compliance consciousness into daily activities.   Monitoring the various compliance program activities to ensure that they are being performed as designed.   Communicating with the appropriate University of Houston - Downtown administrators regarding compliance program activities and issues of non-compliance.   Coordinating the Confidential Reporting Mechanism to ensure that concerns regarding non-compliance are reported and are handled appropriately

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Institutional Compliance Committee Members (Currently 17 Members)

Administration

ESO

Academic Affairs

Student Affairs

Administration

Name / Title	Compliance Area / Phone
David Bradley Vice President, Administration & Finance	Executive Officer (713) 221-8610
Mary Cook Director, Risk Management & Compliance	Compliance Officer (713) 222-5340
Karen Alfaro Director, Advancement Services and Operations	Public Affairs (713) 221-8402
George Anderson Assistant Vice President, Business Affairs	Finance (713) 221-8449
Richard Boyle Chief, Police Department	Law Enforcement (713) 221-8129
Erin Mayer Director, Technology Planning & Project Management	Information Technology (713) 221-8543
Theresa Meneley Director, Budget & Procurement	Purchasing (713) 221-8612
Lorena Sanchez Coordinator Trainee, Purchasing HUB	Purchasing (713) 221-8561

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Employee Services and Operations

Name / Title	Compliance Area / Phone
Minh Lam Employment and Campus Relations Administrator	Employment (713) 221-8060
Betty Powell Assistant Vice President, Employee Services and Records Management	Annuities and Compensation (713) 221-8072
Douglas TeDuits Assistant Vice President, Employment, Training, Campus Relations Affirmative Action Officer	Law - OOA and EEO (713) 221-5366

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Academic Affairs

Name / Title	Compliance Area / Phone
Austin Allen Faculty Senate President and Associate Professor, Social Sciences	Academic Representative (713) 221-5217
Gail Evans Professor, Business	Academic Representative (713) 221-2735
Carolyn Ivey Director, Office of Sponsored Programs	Sponsored Research (713) 221-8681
Lisa Morano Chair and Associate Professor, Natural Sciences	Science Research (713) 221-8167
Elaine Pearson Division Business Administrator III, Office of Academic Affairs & Provost	Standard of Conducts Guide (713) 221-8273

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Student Affairs

Name / Title	Compliance Area / Phone
LaTasha Goudeau Director, Scholarships & Financial Aid	Financial Aid (713) 221-8162

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Compliance FAQ's

What is the Institutional Compliance Program?

What are the elements of a good Compliance Program?

What are the consequences of non-compliance?

What if I see something that is wrong? What should I do?

With all of the concerns about risk, who is responsible for resolving the risks?

 

What is the Institutional Compliance Program?

The Institutional Compliance Program was established to develop standards and procedures to help ensure UH Systems' compliance with federal and state laws and regulations. Many of the policies and procedures of UH System and UHD are based upon these legal requirements.

Development of the University of Houston System Institutional Compliance Program began in 2002 with an Institutional Compliance Action Plan. Under this plan, each component university in the UH System was required to:

Designate both a UH System-wide Compliance Officer and an Institutional Compliance Officer   Appoint an Institutional Compliance Committee that meets at least quarterly   Identify and assess the risk to the University   Develop a High-Risk Management Program that meets the criteria fo the U.S. Sentencing Guidelines   Establish a Confidential Hotline to allow individuals to report suspected fraud outside of the normal chani of command   Ensure specialized compliance training for employees in high risk areas and general compliance training for all employees   Submit a quarterly component University reports on compliance activities to the UH System Compliance Officer for quarterly Board of Regent reports

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What are the elements of a good Compliance Program?

The elements of an effective Compliance Program are based upon the requirements of the United States Sentencing Guidelines, revised in November 2007. They include

Existence of written standards Effective oversight Due care in delegation of authority Training	Monitoring Discipline Corrective Action Periodic assessment of risks

 

The Compliance Program at UHD is structured structured upon the following components:

Item	Comments
Action Plan	Developed for UH System and currently in place
Executive Officer	David Bradley
Compliance Officer	Mary Cook
Compliance Committee	Membership varies periodically to accommodate identified high level risk
Infrastructure Training    (for Committee Members)	David Crawford  (Co-Author of "Effective Compliance Systems: A Practical Guide for Educational Institutions")
Risk Assessment	Initial/Ongoing Risk Assessment and Identification of Institutional Level Risk
Assurance Strategies	Confidential Reporting Mechanism in Place (MySafeCampus)
Risk Management	Risk Management Program for identified Institutional level risks are developed by Responsible Party and Subject Matter Expert in conjunction with Compliance Officer
Predefined Consequence of Noncompliance	Integrated into Monitoring Plan Includes training, reprimand, loss of authority, suspension and/or termination

Employee Compliance and Ethics Guide	Included in this Web-site
Assurance Strategies	Includes certification, inspection, audits and peer reviews
General Compliance Training	Employee training specifically applied to work responsibilities, Employee Compliance and Ethics Guide and Compliance and MySafeCampus video
Assessment of the Compliance Program	Includes self assessment, internal audit and peer reviews to assess the ongoing effectiveness of the compliance program

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What are the consequences of non-compliance?

The consequences of non-compliance can negatively impact UHD as well as the individual(s) involved. 

 

The University could suffer:

Fines, penalties and legal fees   Negative media coverage   Imposed compliance “settlement” requirements   Loss of funding sources   Increased regulatory and audit agency scrutiny   Increased bureaucracy   Reduced faculty and staff morale   Management, faculty and staff turnover   The lingering effect of a tarnished reputation in higher education

 

Involved individuals could suffer:

Disciplinary action up to and including termination   Fines   Tax proceedings   Imprisonment (depending on the severity of non-compliance)

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What if I see something that is wrong? What should I do?

You have several options for reporting another employee's conduct that you suspect may not be in compliance with applicable laws, rules, regulations, and policies.

 

Internally, you can:

Notify your Supervisor   Notify UHD Management   Notify the Compliance Officer (Mary Cook at (713) 222-5340, room 621 S)   Notify the Director of Internal Audit (Don Guyton at (713) 743-8000)

 

Externally and anonymously via phone call or the web you can contact:

The MySafeCampus Hotline at www.mysafecampus.com or 1-800-716-9007, or   The State Auditor’s Office at www.sao.state.tx.us or 1-800-892-384

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With all of the concerns about risk, who is responsible for resolving the risks?

Compliance with applicable laws, rules, regulations, and policies is the personal responsibility of every employee at UHD. Each one of us is a risks manager because we are all presented with risk each day in the workplace. We all have resources at our discretion, such as staff, finances, property, and information. What we do or do not do with those resources can either cause risk or mitigate risk.

 

The UH System Internal Auditing Department identifies risks in the course of doing audits and brings those concerns to our attention.

 

The Compliance Officer and members of the Institutional Compliance Committee at UHD coordinate the oversight of the identified high level "A" risks via a Risk Management Program that includes the monitoring of controls, training of policies and procedures, implementing predefined consequences for non-compliance and taking appropriate action to mitigate thr risks.

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Page maintained by cookm@uhd.edu

Last updated or reviewed on 9/7/12