The University of Texas System-wide Compliance Program began in 1998
with The UT System's Action
Plan to Ensure Institutional Compliance.
Under this plan, each institution is required to report quarterly to
the University of Texas System-wide Compliance Program
Officer and is required to have a:
- Compliance Officer
- Compliance Committee
- General Compliance Training Program
- Risk Inventory
- High-Risk Monitoring Plan
- Confidential "Hotline"
What if I see something that is wrong? What should I
do?
If you are concerned that another employee's conduct may
not be in compliance with applicable laws, rules, regulations,
and policies, please report your concern to your institution's
Compliance Office, the affected department or other appropriate
official, or your institution's toll-free
compliance hotline. When you call the hotline at your institution,
you remain anonymous. A trained professional will ask
you questions and provide a confidential report to the
Compliance Officer within one business day of your call.
The telephone number for the hotline
is posted and readily available at your institution,
or you can address your concern to the compliance mailbox:
compliance@utsystem.edu.
What are the elements of a good compliance
program?
For an organization to have an effective
compliance program, the following elements are required:
- Existence
of written standards
- Effective oversight
- Due care in delegation
of authority
- Training
- Monitoring
- Discipline
- Corrective Action
These
elements have come about as a result of the United
States Sentencing Guidelines, updated in 2004.
What type of
risk is the University of Texas System concerned about?
While we often associate risk with financial matters,
there are many types of risk. The UT System broadly defines
risk as any issue that could impact the University's
ability to meet its business objectives. In other words,
risk applies to many aspects of our work.
Specifically, risks include:
- Strategic risks - risks
that affect an organization's ability to achieve
its goals
- Financial risks - risks that may result in a loss
of assets
- Operational risks - risks that affect ongoing
management processes, such as when new administrative
systems are installed
- Compliance risks - risks that
affect compliance with externally imposed laws
and regulations and internal policies and procedures
- Reputational
risks - risks that affect the University's reputation
With all of the concerns about risk, who is responsible
for resolving the risks?
First, we are all risk
managers. We are all presented with risk in the workplace.
For example, 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. In
an environment where many functions are decentralized, it is generally
effective to utilize a risk-based approach to handling risks.
Here at
UT System, each individual department is responsible
for the risk. However, there are other departments that
assist in identifying and overseeing risks. The Internal
Audit Department identifies risks in the course of doing
audits and brings those concerns to our attention. The
Compliance Officer at the institution manages risks by
customizing risks to the institution. The Compliance
Officer gives attention to the highest risks or "A" risks,
as we call them at UT System. The Compliance Officer
also coordinates the oversight of risks. You should share
your concern for risks with your supervisor and the Compliance
Officer at your institution.
Who is my compliance officer?
A complete listing
of Institutional Compliance Officers is maintained
by the University of Texas System-wide Compliance
Program.
How and to whom does the System-wide
Compliance Officer report?
The System-wide
Compliance Officer reports to the Chancellor
of the University of Texas System. Additionally, the System-wide
Compliance Officer is a member of the Executive Compliance
Committee and chairs the System-wide Compliance Committee
and several other committees relating to compliance.
The System-wide Compliance Officer has many avenues
to report and resolve your concerns and bring
about constructive change at the University of Texas System.
How and to whom does the institution's compliance
officer report?
Each Compliance Officer
reports to the President at their institution.
In the course of their duties as the institution's
Compliance Officer, Compliance Officers report compliance
matters to the System-wide Compliance Officer through
quarterly reports and also serve on the Institutional
Compliance Officers Committee. See the Quarterly
Report Guidelines for information concerning what is reported in the reports.
