NACUA Fall 2009 Workshop Creating Effective Compliance Programs at Smaller Institutions or on a Limited Budget: Models and Procedures November 11, 2009

NACUANET queries for one day in September 2009 For schools that use a live domestic mammal as their mascots (as compared to using a person in a costume as the mascot), do you maintain a separate "exhibition" license under the Animal Welfare act in addition to any research institution license you may hold under that act in connection with your other animals?

NACUANET queries for one day in September 2009 How do your universities handle situations where the governing documents of old endowment funds have been lost over time? What are your policies to determine the original donor intent in these circumstances?

NACUANET queries for one day in September 2009 We had a faculty member whose laptop computer was stolen from his home. On the computer he had 7 years worth of grades from courses he taught, along with the student's names. There are over 700 students with grades listed. Any thoughts/suggestions on how to fulfill our notification requirements without sending letters to all 700+ former students? Thanks

Problems for small institutions Lean administrations with many administrators wearing more than one hat Lean administrations with many administrators wearing more than one hat A sense that compliance is taking care of itself – the auditors will catch it A sense that compliance is taking care of itself – the auditors will catch it Absence of complaints and agency inquiries creates a false sense of security Absence of complaints and agency inquiries creates a false sense of security

Non-scientific survey small colleges Private College Private College 1,920 undergraduate students 1,920 undergraduate students 370 graduate students 370 graduate students No comprehensive approach No comprehensive approach Have used external auditor to do a 'scan' of compliance areas Have used external auditor to do a 'scan' of compliance areas

Non-scientific survey small colleges Private College Private College 2,000 undergraduate students 2,000 undergraduate students Distributed model by default more than by policy. Distributed model by default more than by policy. Risk management committee occasionally 'drifts' into compliance issues. Risk management committee occasionally 'drifts' into compliance issues. GC generally believes that the college is materially compliant. GC generally believes that the college is materially compliant.

Non-scientific survey small colleges Private College Private College 2,700 undergraduate students 2,700 undergraduate students No officially organized program other than in athletics No officially organized program other than in athletics Managers with responsibilities take care of compliance issues in their area Managers with responsibilities take care of compliance issues in their area

Non-scientific survey small colleges Private College Private College 2,700 undergraduate students 2,700 undergraduate students 600 graduate students 600 graduate students In some important areas managers know they have compliance obligations and carry them out well. In some important areas managers know they have compliance obligations and carry them out well. In areas where the primary focus is not compliance it is challenging to communicate that compliance is everyone's job. In areas where the primary focus is not compliance it is challenging to communicate that compliance is everyone's job. Using external auditors to help test compliance areas is helpful. Using external auditors to help test compliance areas is helpful.

Non-scientific survey small colleges Private College Private College 800 undergraduate students 800 undergraduate students Don't use the models of the 'big schools' Don't use the models of the 'big schools'

One approach Acknowledge the decentralized nature of compliance issues Acknowledge the decentralized nature of compliance issues Elevate the importance of compliance with attention from trustees and senior leadership Elevate the importance of compliance with attention from trustees and senior leadership Be deliberative and focused Be deliberative and focused Someone has to keep the effort energized Someone has to keep the effort energized

The Compliance Committee Committee with leadership representatives Committee with leadership representatives Subcommittees on specific areas Subcommittees on specific areas Limited number of focused meetings Limited number of focused meetings Two-year cycle Two-year cycle Commitment to working across the institution Commitment to working across the institution

The Compliance Committee Subcommittee structure led by employees with line responsibility for areas of compliance Subcommittee structure led by employees with line responsibility for areas of compliance Create agendas that bring together related compliance areas Create agendas that bring together related compliance areas Compliance Committee supports the efforts of subcommittees and on-going compliance centers Compliance Committee supports the efforts of subcommittees and on-going compliance centers Use the Committee to advertise the work of subcommittees Use the Committee to advertise the work of subcommittees

Lessons Learned Chair of compliance committee brings focus to the work and engages subcommittee leaders individually Chair of compliance committee brings focus to the work and engages subcommittee leaders individually Connect people with different compliance obligations and help with communication to the broader campus audience Connect people with different compliance obligations and help with communication to the broader campus audience Affirm people who have been engaged in compliance efforts for a long time Affirm people who have been engaged in compliance efforts for a long time