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The University of Texas System Institutional Compliance Program: A Best Practices Initiative

The University of Texas System Institutional Compliance Program: A Best Practices Initiative. Presented by: Charles G. Chaffin, CPA, CIA Director of Audits and System-wide Compliance Officer The University of Texas System. Outline. Introduction to UT System The Problem and the Challenge

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The University of Texas System Institutional Compliance Program: A Best Practices Initiative

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  1. The University of Texas System Institutional Compliance Program: A Best Practices Initiative Presented by: Charles G. Chaffin, CPA, CIA Director of Audits and System-wide Compliance Officer The University of Texas System

  2. Outline • Introduction to UT System • The Problem and the Challenge • Design of the Best Practice Initiative • Implementation of the Best Practice Initiative • Benefits • Sharing the Best Practices Initiative

  3. The University of Texas System • Sixteen entities (9 academic; 6 health-related; 1 central administration) • 160,000+ Students (5K to 50K per campus) • 86,000 Employees/4,000 managers • 7 billion dollar annual operating budget • 13 billion dollars in endowments • 3.7 billion dollar construction program • 1 billion dollars in annual research funds

  4. The Problem • Repeated high profile internal control failures in areas that were believed to have adequate systems to ensure compliance with all external laws, rules and regulations and all internal policies and procedures. • $800,000 theft • Making “Speed” • $150,000 theft • Imposter on bowl-bound football team • $20,000,000 repayment to Medicare

  5. The Challenge • Design, implement, and operate a program that would provide an on-going, real-time assessment of the compliance profile of the system and each of its component entities for executive management and the Board of Regents. • Board of Regents Issued Challenge • Challenge assigned by Executive Management to Director of Audits

  6. The Design of the Best Practice Initiative • Appointed an ad hoc committee representing all stakeholders in the collegial community • Obtained outside expert advice • Adopted an operating philosophy and goals and objectives for the program • Produced an Action Plan (written blueprint) to guide the program

  7. Implementation of the Best Practice Initiative • Building the Infrastructure • Creating Compliance Awareness • Managing Critical Risks • Appraisal and Renewal • Summary

  8. Building the Infrastructure • Time and resources required • Specific tasks • Appoint a compliance officer • Current executive or new position • Appoint a compliance committee • Executive or working committee • Establish a compliance function/office • Full time staff or slice of current staff time

  9. Creating Compliance Awareness • Develop a Standards of Conduct Guide (Code of Conduct) • Develop a General Compliance Training Program • Establish a confidential reporting mechanism

  10. Managing Critical Risks • Risk Assessment Process • Identify risks • Determine those that are organization-critical • Risk Management Process • Single Responsible Party • Monitoring Plan • Specialized Training Plan • Reporting Plan

  11. Appraisal and Renewal • Addressing instances of non-compliance • On-going assurance regarding the management of mission critical risks • Certifications • Inspections • Agreed-upon procedures • Audits (design and/or information validation) • peer reviews (cont.)

  12. Appraisal and Renewal (cont.) • Periodic assessment of the compliance program • Self-assessment • External peer review • Renewal (Action Plan based on periodic assessment)

  13. Implementation Summary • UT System program is applicable to any type and size institution • Implementation process has no end; it is continuous

  14. Benefits • Reduction in negative publicity • Reduction in fines and external audits • Reduction in workers’ compensation claims • Safety program awards • Change in organizational culture • Established basis for enterprise-wide risk management and accountability program

  15. Sharing the Best Practice Initiative • How-to-do-it book: Effective Compliance Systems: A Practical Guide for Educational Institutions available from The Institute of Internal Auditors, Inc • Hosted: 1st and 2nd National Conferences on Effective Compliance Systems in Higher Education March 2001 and October 2002 in Austin, Texas • Sharing: Major Research Institutions Compliance Group formed after 2nd Compliance Conference

  16. Resources • www.utsystem.edu/compliance • www.theiia.org • www.utsystem.edu/AUD

  17. Questions?

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