The UT Systemwide Compliance Program will support the UT System’s Mission, Vision, Role and Values and help UT System institutions fulfill their responsibilities to the people of Texas in an environment based upon ethical behavior and compliance with applicable laws, rules, and guidelines. In this regard, the Systemwide Compliance Program will provide all UT System institutions with the most accurate, concise, and up-to-date information, assistance and advice to assure that they are aware of their responsibilities with respect to sustaining such an environment. The Systemwide Compliance Program will also continuously assess the effectiveness and quality of the institutional compliance programs to ensure all business is conducted with integrity and in compliance with the law.
Ensuring effective compliance programs throughout the UT System is a collaborative effort between the Systemwide Executive Compliance Committee (Systemwide ECC), the Systemwide Compliance Office, the UT System Executive Offices and the UT System institutions.
Systemwide Executive Compliance Committee
Responsibility for oversight of the Systemwide Compliance Program and the execution of the Compliance Charter rests with the Systemwide ECC. The Systemwide ECC is chaired by the Chancellor. Other members include the Executive Vice Chancellors for Health Affairs, Academic Affairs, and Business Affairs; the Vice Chancellor and General Counsel, and the General Counsel to the Board of Regents. The Systemwide ECC meets quarterly and/or at the request of the Chancellor.
Systemwide Executive Compliance Officer
The Systemwide Compliance Officer reports to the Chancellor of the University of Texas System. The Systemwide Compliance Officer collaborates, coordinates and facilitates his activities as needed with designated staff in the UT System Executive Offices and with institutional compliance officers and/or appropriate institutional personnel. In addition, the Systemwide Compliance Program solicits assistance, as needed, from the Vice Chancellor and General Counsel, the Deputy Ethics Advisor, and the Chief Audit Executive.
The Systemwide Compliance Officer has full and unrestricted access to individuals and information throughout the UT System as necessary to carry out such responsibilities that include:
- Ensuring periodic, effectiveness assessments are performed on each institutional compliance program;
- Developing UT System policies which ensure each institutional compliance program meets the requirements of the Federal Sentencing Guidelines;
- Developing UT System Priorities on high-risk and emerging compliance areas in coordination with UT System Executive Offices;
- Ensuring institutions implement the UT System Compliance Priorities on high-risk and emerging compliance areas;
- Coordinating as needed with the General Counsel of the Board of Regents, the Vice Chancellor and General Counsel, and the Chief Audit Executive to investigate allegations received by the Board of Regents and/or the Chancellor;
- Participating in or designate staff to institutional compliance committee meetings;
- Coordinating and facilitating periodic meetings of the institutional compliance program's effectiveness to the President of each institution;
- Communicating findings from the quality assessments of the institutional compliance officers and their staff as needed;
- Serving as the liaison between each UT System institutional compliance program and the Board of Regents to ensure that the Board has sufficient information to provide effective oversight over each such program;
- Reporting significant compliance matters to the Board of Regents and to the Systemwide ECC on a quarterly or as-needed basis; and
- Providing annual training to the Board of Regents on compliance-related laws and issues.
Institutional Compliance Officers
Each University of Texas System institution has a compliance officer whose key functions include coordination and communication with regard to planning, implementing, and monitoring the compliance program. Responsibilities of the institutional compliance officer include:
- Ensuring the elements of an effective compliance program, consistent with those stipulated in the Federal Sentencing Guidelines, are in place and periodic, quality assessments are performed to validate the overall effectiveness of the compliance program;
- Collaborating with the Systemwide Compliance Officer and other institutional compliance officers to promote compliance best practices;
- Coordinating with the Systemwide Compliance Officer and the UT System Executive Offices to develop UT System Compliance Priorities;
- Working closely with the Systemwide Compliance Officer and staff to ensure UT System Compliance Priorities are acted upon appropriately by management, and implemented within the institutional compliance program; and
- Reporting significant compliance matters to the President and to the Systemwide Compliance Officer.