Institutional Compliance

Institutional Compliance: Authority and Expectations

The Office of Integrity & Compliance Charter

The Office of Integrity & Compliance (OIC) fosters a culture of accountability and ethical conduct across the University's academic, research, and healthcare missions. Led by the Associate Vice Chancellor for Compliance/Chief Compliance Officer, OIC oversees institutional compliance efforts to ensure adherence to laws, regulations, and university policies.

Under its Charter, the Office of Integrity & Compliance is authorized to initiate compliance related reviews or investigations to address potential risk or non-compliance. The OIC Charter can be found here.

Professional Standards

The AVC for Integrity & Compliance and the OIC staff will act with integrity in accordance with Professional Standards of Compliance and Ethics and will follow the U.S. Federal Sentencing Guidelines for an effective institutional compliance program, which include:

• Leadership and Oversight. Effective leadership and functional committee structures are in place, with regular reporting to the ERC.
• Policies and Procedures. Clear expectations and practical guidance regarding behavior and decision-making are available and accessible.
• Education and Outreach. Reasonable steps are taken to provide appropriate, relevant, and comprehensive education and outreach about compliance requirements.
• Monitoring and Auditing. Program adherence to compliance requirements is monitored. Emerging and changing laws are tracked.
• Receiving Reports and Investigating. Clear avenues exist to seek guidance or report violations of policy and relevant laws/regulations. Investigations follow appropriate processes and emphasize non-retaliation.
• Accountability, Incentives and Corrective Action. Community members are encouraged to behave ethically and responsibly. Appropriate, fair and consistent actions are taken in cases of wrongdoing.
• Response and Prevention. Episodes of misconduct and violations of laws, regulations and policies are responded to appropriately. Systemic issues are identified, root causes determined, and solutions implemented to prevent recurrence.
• Risk Assessment. Regulatory compliance obligations are routinely evaluated and prioritized based on the severity of the potential operational, legal, and financial impact associated with each one.  Control measures put in place are reviewed for effectiveness in mitigating identified risk.