2013 Annual Compliance Training

Office of Audit, Compliance and Ethics 2013 Annual Compliance Training Place logo or logotype here, otherwise delete this. Individual Responsibility, Institutional Success

OVERVIEW • Compliance Updates • Americans with Disabilities Act (ADA) • Family Educational Rights and Privacy Act (FERPA) • Records Management • Exit Interviews • Policy Updates • Travel & Entertainment • Faculty Consulting • Everyday at UConn • Freedom of Information Requests • Guide to the State Code of Ethics • Staying Safe in the Workplace • Ombuds Officer Annual Compliance Training FAQs Q: Who needs to complete the training? A: All faculty and staff need to complete the 2013 Annual Compliance Training. Individual departments may require special payroll employeesor graduate assistants. Q: What is the deadline for completion? A: This year’s deadline is May 17, 2013. Q: Do I have to attend a live session? A: No. Training is also available online. Office of Audit, Compliance and Ethics

Before We Begin… “It may make a difference to all eternity whether we do right or wrong today.” --James Freeman Clarke • The complete presentation is available on the OACE website under “Training”: • www.audit.uconn.edu • Approximate length: one hour • Questions can be emailed to OACE at ethics@uconn.edu • For live sessions – please silence your cell phones • For on-line sessions – please remember to complete the test after viewing the entire session Office of Audit, Compliance and Ethics

Americans with Disabilities Act (ADA) Compliance & Accommodations University Policy Statement: People with Disabilities Available online: http://policy.uconn.edu/?p=419 Office of Audit, Compliance and Ethics

Key Definitions and Concepts • Disability: • Federal law: (1) an impairment that substantially limits one or more major life activities; (2) a record of such an impairment; or (3) being regarded as having such an impairment • Connecticut law: (1) chronic physical handicap, infirmity, or impairment; or (2) a mental disability as defined in the most recent version of the Diagnostic & Statistical Manual of Mental Disorders • University Policy: persons satisfying either the Federal or Connecticut definitions • Reasonable Accommodation: • Any change to the work environment that will enable a qualified employee with a disability to perform the essential functions of their position, unless granting the accommodation would result in undue hardship to the University. Accommodations are explored through an interactive process facilitated by ODE • Request for an Accommodation: • Notification that an individual is having difficulty performing a job function because of a medical condition Requests need not include the phrase “reasonable accommodation.” ODE’s website (www.ode.uconn.edu) has a Reasonable Accommodation Request Form that persons needing an accommodation are encouraged to complete Office of Audit, Compliance and Ethics

The Reasonable Accommodation Process • STEP 1: Employee seeking accommodation completes an accommodation request form • STEP 2: ODE meets with the employee to discuss their limitations, job duties, and the desired accommodation(s) • STEP 3: ODE communicates with the employee’s health care provider (with the requestor’s permission and if the disability is not self-evident) to gather information regarding the medical condition, limitations, the necessity of the requested accommodation, and to explore alternative accommodations. Medical information is not shared outside of ODE • STEP 4: If the request is medically supported, ODE meets with the supervisor to discuss the request, the feasibility of implementing the requested accommodation, the availability of alternative accommodations, and any other issues • NOTE::Each employee’s individual situation may be unique and, as a result, the process utilized may vary from case to case Office of Audit, Compliance and Ethics

When to Call the Office of Diversity & Equity (ODE) ODE is the University-wide resource for ADA-related workplace accommodation issues including: • Questions or other inquiries concerning the process generally or specific accommodations; • Training for staff in your department; • Referrals for employees who have notified you of their need for an accommodation; or • Any other questions you may have about workplace accommodations NOTE: for student accommodations, please contact the Center for Students with Disabilities (CSD) Wood Hall – Unit 4175 241 Glenbrook Road Storrs, CT 06269 www.ode.uconn.edu E-mail: ode@uconn.edu Phone: (860) 486-2943 Fax: (860) 486-2437 Office of Audit, Compliance and Ethics

FERPA Records and Information Management Office of Audit, Compliance and Ethics

Family Educational Rights & Privacy Act (FERPA) • New version of FERPA policy-Winter 2013 • Changes to Directory Information • Contract needed if sharing student data for vendors, audits, evaluations, research • Greater focus on data security Office of Audit, Compliance and Ethics

FERPA - Reminders • “School Officials” with “Legitimate Educational Interest” • Health & Safety Emergencies • Log of disclosures required Office of Audit, Compliance and Ethics

FERPA contacts FERPA Records Requests: (if you have written release from student) Jennifer Gattilia Registrar’s Office • 486-6228 jennifer.gattilia@uconn.edu Questions? Rachel Krinsky Rudnick OACE (860) 496-5256 rachel.krinsky@uconn.edu Office of Audit, Compliance and Ethics

Records & Information Management (RIM) Lifecycle of a record Creation Proper Storage Maintenance Destruction Office of Audit, Compliance and Ethics

RIM Steps • Inventory • Records Review • Clean up and clear out! • Privacy & security review (paper & electronic) • Rinse & Repeat Office of Audit, Compliance and Ethics

Records Retention Reminder • Record Retention Schedules • Record Disposition • Official Record Copy vs. Unofficial Records • Resources Available Office of Audit, Compliance and Ethics

RIM Resources & Contacts Office of Audit, Compliance and Ethics

Exit Interviews Office of Audit, Compliance and Ethics

Exit Interviews • OACE has begun offering exit interviews to departing employees • Compliance based • In-person meeting and online survey available • Anonymous to the extent possible by law • Example of types of questions: • Are you leaving the University now because of any compliance concerns that you had about your job or work environment? Office of Audit, Compliance and Ethics

Policy Updates Office of Audit, Compliance and Ethics

Travel and Entertainment Policies and Procedures • Respect and safeguard our travel privileges and funds • Practice fiscal, ethical, and public responsibility • Sets forth rules and procedures that balance the University’s legitimate travel and entertainment needs with sound stewardship of public resources Office of Audit, Compliance and Ethics

Travel and Entertainment Policies and Procedures • Business Meal Limits: Maximum of 2X the GSA meal rate • Conference Agenda Required: When meals are provided by conference - no per diem or other reimbursement for that meal • Mileage reimbursement: Deduct normal commuting mileage in calculating mileage reimbursements • Cap on Hotel Rate: Maximum allowable hotel reimbursement is 125% of GSA Lodging Rate Office of Audit, Compliance and Ethics

Faculty Consulting • Consulting is an activity performed by a faculty member for compensation as a result of his/her expertise or prominence in his/her field while not acting in his/her official capacity as a State employee (i.e. in his/her own time.) The University's Laws and Bylaws prohibit faculty from consulting on "time due to the University" Office of Audit, Compliance and Ethics

Faculty Consulting • Conflict of Commitment • Time Due to the University: “Any time necessary for successfully carrying out the duties assigned to and for which a faculty member was hired. This includes both sufficient time to perform assigned duties as well as sufficient opportunity to meet with other faculty, staff and students.” • Conflict of Interest • Can the contracting entity benefit from the faculty member’s role as a State employee? Is the compensation appropriate for the service provided? Does the faculty member own a portion of the contracting entity? Does the faculty member have a grant from the contracting entity in their State position? Office of Audit, Compliance and Ethics

Faculty Consulting • Compensation • “Compensation” includes direct monetary payment, “honoraria", or non-cash considerations (luxury travel, gifts, equity in a product and/or company), but not necessary travel expenses and not compensation from another CT State agency • Teaching Elsewhere • As of November 14, 2012, faculty members may request permission to teach elsewhere under the conditions of the Faculty Consulting Policy and as long as the assignment is determined to be beneficial to the interest of the University of Connecticut (i.e., recruitment, course development) Office of Audit, Compliance and Ethics

Faculty Consulting • Summer Consulting while 100% on Federal Grant • Due to time and effort reporting, consulting while employed 100% on a federal grant during the summer is not allowed on time owed to the University. Consulting work must be completed on time not owed to the University (i.e., evenings, weekends, etc.) • Storrs and Regional Campuses • Faculty Consulting OfficeSally Reis, Ph.D.Vice Provost, Academic Affairs sally.reis@uconn.eduUnit-1086Phone: (860) 486-4037 Office of Audit, Compliance and Ethics

Everyday at UConn Office of Audit, Compliance and Ethics

Freedom of Information Act (FOI) • Assume anything you create, use, review is public • Assume anything on your University device is public (including anything personal) • Assume anything University or work-related on your personal device is public  Send all FOI requests to the Compliance Office immediately. (If you are not sure if it is an FOI request, send it anyway) Office of Audit, Compliance and Ethics

State Code of Ethics Office of Audit, Compliance and Ethics

State Code of Ethics for Public Officials • Applies to all of us as state employees • Part of the Connecticut General Statutes • Intended to prevent individuals from using their public position for personal financial benefit • Violations can lead to Fines and Penalties Office of Audit, Compliance and Ethics

State Code of Ethics for Public Officials • Gifts • Outside Employment • Financial Benefit for Oneself or Family • Appearance Fees/Honorarium • Political Activities • Post-State Employment Office of Audit, Compliance and Ethics

State Code of Ethics for Public Officials Just because there isn’t a law or University policy that prohibits an activity doesn’t mean it is the right thing to do…… Office of Audit, Compliance and Ethics

State Code of Ethics for Public Officials • Office of Audit, Compliance & Ethics • 1-860-486-2530 • REPORTLINE – anonymous • 1-888-685-2637 Office of Audit, Compliance and Ethics

Staying Safe in the Workplace Office of Audit, Compliance and Ethics

Staying Safe in the Workplace • The term “violence” refers to a range of inappropriate behaviors that include but are not limited to the following: • Physical or verbal abuse • Vandalism, Arson, Sabotage • Carrying or possessing weapons of any kind on property owned/leased or otherwise controlled or occupied by the state, unless properly authorized • Using such weapons • Any other act(s) which a reasonable person would consider as inappropriate and/or posing a danger or threat of danger/violence in the workplace • Offensive comments regarding violent events and/or behaviors Office of Audit, Compliance and Ethics

Staying Safe in the Workplace The following is a list of examples of indicators of increased risk of violent behavior. While human behavior cannot be accurately predicted, the behaviors below should be viewed with concern. • Direct or veiled threats of harm • Bringing a weapon to work, brandishing a weapon in the workplace, making inappropriate reference to guns or fascination with weapons • Fascination with incidents of workplace violence, statements indicating approval of the use of violence to resolve a problem, or statements indicating identification with perpetrators of workplace homicides Office of Audit, Compliance and Ethics

Staying Safe in the Workplace • Statements indicating an increased tone of desperation from the person, feeling that normal interventions to solve the problem will not work, feeling hopeless about a situation at work, with family, financial, and other personal problems • Signs of abuse of drugs/alcohol on or off the job • Extreme or uncharacteristic changes in behavior or displays of emotion • All members of the University community are encouraged to report any employee who has engaged in threatening or violent behaviors to the University of Connecticut Police Department by dialing 911 or by contacting any of the following offices: Office of Audit, Compliance and Ethics

Staying Safe in the Workplace •UConn Police Department •Office of Faculty and Staff Labor Relations •Office of Audit, Compliance and Ethics •Office of Diversity and Equity •UConn Employee Assistance Program In addition, anonymous reports may be made to the UCONN REPORTLINE by telephone (1-888-685-2637) or by e-mail (reportline@uconn.edu) All members of the University community are also encouraged to register for the Alert Notification System. The Alert Notification System provides a number of ways in which the University may contact the community in the event of an emergency. Office of Audit, Compliance and Ethics

University of Connecticut Police Department • The UConn Community Police Unit works with university faculty, staff and students to provide educational programs for the university community. The Community Police Unit can provide a wide variety of educational programs that are directed towards your specific needs and audience. • Active Threat Training • Orientation for new students, faculty and staff • First Year Experience (FYE) seminar • University Safety Awareness • Emergency 9-1-1 information • Crime Prevention • Introduction to the UConn Police Department (hosted at Public Safety complex) The Community Police Unit can be contacted by calling the UConn Police Department at (860) 486-4800. Office of Audit, Compliance and Ethics

Ombuds Officer Office of Audit, Compliance and Ethics

What does an Ombuds do? • Actively listens to your questions and concerns • Offer informationre: policies, procedures, and programs • Discuss your concerns and clarify issues • Help identify and evaluate a range of options • Gather information and offer referral Office of Audit, Compliance and Ethics

What doesn’t an Ombuds do? • Make decisions, findings of fact, or determine the “guilt” or “innocence” of those accused of wrongdoing • Establish, change, or set aside policies or administrative decisions • Offer legal advice • Offer psychological counseling • Participate in grievances or other formal processes • Serve as an agent of notice • Serve as an advocate for any individual Office of Audit, Compliance and Ethics

QUESTIONS? “Integrity without Knowledge is weak and useless, and Knowledge without Integrity is dangerous and dreadful.” --Samuel Johnson . Office of Audit, Compliance and Ethics Phone: 860-486-2530 Email: compliance.training@uconn.edu Office of Audit, Compliance and Ethics

2013 Annual Compliance Training