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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.

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Establishing A Compliance Program: It Makes Sense Derry Harper

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  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

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