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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.
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.
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.
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.
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|
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.
Every manager, regardless of their level in the organization, is accountable for compliance in their operational unit.
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.
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
Name / Title Compliance Area / Phone
Vice President, Administration & Finance
Director, Risk Management & Compliance
Director, Advancement Services and Operations
Assistant Vice President, Business Affairs
Chief, Police Department
Director, Technology Planning & Project Management
Director, Budget & Procurement
Coordinator Trainee, Purchasing HUB
Name / Title Compliance Area / Phone
Employment and Campus Relations Administrator
Assistant Vice President, Employee Services and Records Management
Annuities and Compensation
Assistant Vice President, Employment, Training, Campus Relations Affirmative Action Officer
Law - OOA and EEO
Name / Title Compliance Area / Phone
Faculty Senate President and Associate Professor, Social Sciences
Director, Office of Sponsored Programs
Chair and Associate Professor, Natural Sciences
Division Business Administrator III, Office of Academic Affairs & Provost
Standard of Conducts Guide
Name / Title Compliance Area / Phone
Director, Scholarships & Financial Aid
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
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
- Corrective Action
- Periodic assessment of risks
The Compliance Program at UHD is structured structured upon the following components:
Developed for UH System and currently in place
Membership varies periodically to accommodate identified high level risk
Infrastructure Training (for Committee Members)
(Co-Author of "Effective Compliance Systems: A Practical Guide for Educational Institutions")
Initial/Ongoing Risk Assessment and Identification of Institutional Level Risk
Confidential Reporting Mechanism in Place (MySafeCampus)
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
Included in this Web-site
Includes certification, inspection, audits and peer reviews
General Compliance Training
Assessment of the Compliance Program
Includes self assessment, internal audit and peer reviews to assess the ongoing effectiveness of the compliance program
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
- Tax proceedings
- Imprisonment (depending on the severity of non-compliance)
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
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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Last updated or reviewed on 9/7/12