Welcome to the World of Compliance Frank Arredondo and Brandy Hataway

Overview General information. Governance structure. Institutional control. Compliance committee. Key elements of a compliance program. Resources.

General Information

The NCAA is: A voluntary Association of about 1,300 colleges, universities and athletics conferences devoted to the sound administration of intercollegiate athletics.

The NCAA is: The “membership” or “members” – the colleges, universities and athletics conferences that make up the NCAA. Appoint volunteer representatives that serve on committees. Introduce and vote on legislation. Establish programs to govern, promote and further the purposes and goals of intercollegiate athletics.

The NCAA is: Division III Division II Division I Divided into three main divisions (Divisions I, II and III). Each NCAA division has a separate governing structure.

The NCAA is: The national office – 400 staff members. Draft, interpret, teach and implement the rules and programs established by the membership. Administer 89 championships in 23 sports. More than 45,000 student-athletes annually compete for national titles. Headquarters – Indianapolis, Indiana.

The NCAA is: The Association. The entire organization comprised of members and staff. Many believe the national office staff makes the rules. Actually it is the membership that proposes and adopts the rules.

Governance Structure

Eight FBS members from NCAA Division I Board of Directors Executive Committee Eight FBS members from NCAA Division I Board of Directors Two IFCS members from Division I Board of Directors Two Division I members from Division I Board of Directors Two members from NCAA Division II Presidents Council Two members from Division III Presidents Council Ex officio non-voting members: NCAA President, Chair of NCAA Division I Leadership Council, and the Chairs of NCAA Division II and Division III Management Council. Association-Wide Committees NCAA Division I Board of Directors (Chancellors and Presidents) NCAA Division II Presidents Council (Chancellors and Presidents) NCAA Division III Presidents Council (Chancellors and Presidents) NCAA Division I Leadership Council (Athletics Administrators and Faculty Athletics Representatives) NCAA Division I Legislative Council (Athletics Administrators and Faculty Athletics Representatives) NCAA Division II Management Council (Athletics Administrators and Faculty Athletics Representatives) NCAA Division III Management Council (Chancellors/Presidents, Athletics Administrators, Faculty Athletics Representatives, Student-Athletes) Division I Committees and Cabinets Division II Committees Division III Committees Sport and Rules Committees

DIVISION I GOVERNANCE STRUCTURE

Institutional Control

Institutional Control It is the responsibility of each member institution, through the chancellor or president, to “control its intercollegiate athletics program in compliance with the rules and regulations of the Association.” – NCAA Constitution 2.1.1. NCAA legislation. Constitution 2.1. Principle of institutional control and responsibility. Constitution 2.8.1. Principle of rules compliance – responsibility of the institution (monitoring). Constitution 6.01.1. Institutional control.

Institutional Control Analysis Analysis attempts to: Measure commitment to rules compliance. Explain why violation(s) occurred. Evaluate the atmosphere of compliance.

Institutional Control Analysis Determination of whether an institution is exercising proper institutional control involves an extremely fact-sensitive analysis. No mathematical formula or checklist. Situations evaluated on a case-by-case basis.

Institutional Control. Four Pillars of Institutional Control. Commitment to Compliance Monitoring and Enforcement Rules Education Institutional Control Analysis

This list is not intended to be exhaustive. Compliance Systems Implement systems in areas of key NCAA legislation. Financial aid. Eligibility certification. Recruiting. Amateurism. Sports wagering. Investigating and self-reporting. Student-athlete employment. Awards and benefits. Playing seasons. Booster activities. Camps and clinics. This list is not intended to be exhaustive.

Monitoring and Enforcement Regularly check the operation of compliance systems. Compliance personnel should be visible, proactive and accessible. Ensure that compliance forms are being used and used properly.

Monitoring and Enforcement Communicate with athletics administrators, coaches, student- athletes and personnel outside of the athletics department. Establish a formal procedure for reporting and investigating violations. Conduct independent, external audits of the athletics department periodically. Should include audits of compliance systems.

Rules Education Comprehensive and ongoing for those engaged in activities promoting athletics interests of the institution. Know your audience. Use outside resources and personnel for training on topics requiring specific expertise.

Commitment to Compliance Document specific responsibilities for each individual with compliance responsibilities. Designate an individual with authority as having primary responsibility for rules compliance. Establish outside oversight of the athletics department through senior-level institutional administration. Make clear that rules violations will result in disciplinary action.

Commitment to Compliance Communicate the duty to report any perceived violations of NCAA rules without fear of reprisals or retaliation. Thoroughly and promptly investigate suspected rules violations. If substantiated, report any violations to the conference and NCAA. Duty to report and abstain from unethical conduct defined in NCAA Bylaw 10.1

Institutional Control Analysis Continuum of relevant facts: No system. Detailed system. No monitoring . Strict monitoring. No education. Extensive education. No commitment. High commitment.

Compliance Committee

Establishing a Compliance Committee Documents and evaluates compliance policies and procedures. Assists in rules education. Communicates importance of rules compliance to the campus community. Assists in rules-violations investigations. Serves as an advisory group. Provides checks and balances.

Compliance Committee Members Director of athletics. Senior woman administrator. Compliance coordinator. Faculty athletics representative. Registrar's office. Financial aid office. Academic advisor. Sports medicine. Admissions office. Dean of students office representative. Faculty representative. Student-athlete. Athletics board representative. Coaches. This list is not intended to be exhaustive.

Defining My Role COMPLIANCE OFFICE FAR Admissions Financial Aid Academic Support Internal Auditor Student Affairs Coaches Athletics Dept. Registrar

Key Elements in a Compliance Program

Key Elements in a Compliance Program KNOW THE C.O.D.E Communication Organization Documentation Evaluation

Communication Open lines of communication with various campus entities. Use different styles of communication to reach all campus entities. Keep all campus entities informed.

Communication – Rules Education Know your audience. Written materials. Meetings. Website content.

Communication – Rules Education Know your audience. Who are you trying to teach? Student-athletes. Coaches. Athletics administrators. Marketing staff. Development staff. Tickets staff. Academic advisors. Registrar’s office. Financial aid office. Deans. Boosters. Prospective student-athletes.

Communication – Rules Education Written materials. Why do you have this document? Make it relevant to the audience. Do not overwhelm the audience with “paper.” Use different types of written materials. Develop and/or continually update a compliance manual.

Communication – Rules Education Written materials. Compliance manual. Memos. Reminders. Newsletters. Scoreboards. Mailer fill-ins. Brochures. Emails. Text messages.

Communication – Meetings Develop an annual rules-education calendar. Make the information specific to the group. Vary presentation techniques. Keep the sessions and information simple. Involve the institutional community.

Communication – Website Content Be thorough – include as much as possible. Address all audiences. Add things as you can. Be creative.

Organization Senior-level institutional administrators assume leadership roles in the institution's commitment to compliance initiatives. Institutional staff assume responsibility for rules knowledge and compliance. Clearly define compliance procedures including key individuals, tasks and responsibilities. .

Organization – Compliance Tasks Recruiting. Eligibility. Financial aid. Playing and practice seasons. Miscellaneous.

Organization – Compliance Tasks Recruiting. Communication with prospective student-athletes. Contact/evaluation logs. Transfer recruitment. Official and unofficial visits. National Letter of Intent program.

Organization – Compliance Tasks Eligibility. Initial eligibility. Institutional Request List (IRL). NCAA initial-eligibility reports. Amateurism certification. Final certification reports. Waivers.

Organization – Compliance Tasks Eligibility. Continuing eligibility. Full-time enrollment. Drop/add procedures. Summer school. Progress toward degree. Exceptions and waivers.

Organization – Compliance Tasks Eligibility. Transfers. Transfer requirements. Transfer exceptions. Waivers. Eligibility reports. Hardship waivers. Outside competition.

Organization – Compliance Tasks Financial aid. Grants-in-aid. Institutional and outside aid. Noncounter certification. Renewals, reductions and cancellations.

Organization – Compliance Tasks Playing and practice seasons. Playing and practice season declarations. Contest limitations. Countable athletically related activities logs. Participation records. Membership requirements (Bylaw 20).

Organization – Compliance Tasks Miscellaneous. Personnel (Bylaw 11). Amateurism (Bylaw 12). Camps and clinics (Bylaw 13.12). Awards and benefits (Bylaw 16). Required NCAA, conference and institutional forms.

Policies and Procedures Documentation Written policies and procedures show a commitment to rules compliance. Document everything! Policies and Procedures Document

Documentation – Interpretations How do coaches/administrators ask questions? Form. Written requests. Verbally. Maintain documentation of all interpretations. Historical perspective – precedent. Protection.

Documentation – Interpretations Documentation should include: Name of individual requesting the information. Date requested and date answered. Issue or question with any relevant facts. Name of individual providing the answer. Answer and source of the answer provided. Anything else you feel is important/relevant.

Documentation – Investigations Establish defined procedures: Investigating alleged violations. Self-reporting discovered violations. Start with a list of those personnel to be notified. Visit ncaa.org for helpful information.

Documentation – Investigations Have policies in writing. On file in the office of all athletics personnel. Ensure careful adherence to the policy. Update as necessary to ensure proper procedures. Use the written policy to keep everyone informed. Investigations must be done in a timely manner.

Evaluation Ensure continuing and regular administrative oversight in key compliance areas. Are the systems in place working? Periodic review of the rules compliance program by entities outside the athletics department. This is required once every four years. Institutional authorities. Conference office. Outside consultants. Bylaw 22.2.1.2-(e)

Compliance Resources

Compliance Resources Compliance Asst. (CA) LSDBi AMA Online Case Management System ncaa.org NCAA Eligibility Center Website

Compliance Assistant (CA) Tool designed to help administrators ensure compliance with NCAA legislation. Generate NCAA-required forms. Program, documentation and technical support. Areas: Financial aid, eligibility, recruiting, athletics personnel and playing and practice seasons.

LSDBi Legislative Services Database for the Internet. Search legislative proposals. Search for NCAA bylaws. Search legislative interpretations in conjunction with bylaws. Locate helpful questions & answers and education columns.

LSDBi Search for waiver precedent. Search infractions cases. Initial-eligibility waivers (IEW). Progress-toward-degree waivers (PTD). Legislative relief waivers (SLR). Formerly ARS. Search infractions cases. Search for student-athlete reinstatement cases.

AMA Online Case Management System Standardizes the waiver and student-athlete reinstatement request processes. Tools to help determine the correct waiver to file and required documentation checklists. Automatically populates member institutions' core information. Online status updates, access to previously submitted cases and relevant case information.

NCAA Website (www.ncaa.org) AMA Education on Demand videos. NCAA News (Online). NCAA Publications. NCAA manuals. NCAA Guide for the College-Bound Student-Athletes. Transfer Guide. NCAA Guide to International Academic Standards for Athletics Eligibility.

Compliance Resources Conference office. Conference websites. Collegiate websites. NCAA academic and membership affairs (AMA) staff. Conference contact program. Mentor/professional contacts. NCAA Regional Rules Seminars.

Contacting the NCAA Phone line dedicated to member institutions. 317/917-6003. Interpretive phone line. Chancellor/president, director of athletics, senior women’s administrator, faculty athletics representative or compliance office.

Contacting the NCAA Hours of operation. Monday, Tuesday, Thursday and Friday: 9 a.m. to 5 p.m. Eastern time. Wednesday: 11 a.m. to 5 p.m. Eastern time. Best times to call: 9 a.m. to Noon Eastern time. 4 to 5 p.m. Eastern time.

Contacting the NCAA Best Practices. Prior to calling the interpretation line. Do your research. Have all facts ready. During the call. Take notes. Get the staff member’s name and case number.

Conference Contact Program AMA staff serve as resources for conference office. General purpose. Assist with rules interpretations. Compliance assistance/rules presentations at conference meetings. NCAA national office visits.

Conference Contact Program Interpretative Request Process. Institution contacts conference office with question. Conference office researches question. If needed, conference office contacts AMA staff. Do’s and Don’ts. Follow conference office policy. Generally, institutions should not call/emails the AMA conference contact directly.

Conference Meetings AMA staff contact is available as a resource. Rules presentations. New legislation review. Round table/interpretation sessions. Use of technology. Videoconferences. Teleconferences.

Review General information. Governance structure. Institutional control. Compliance committee. Key elements of a compliance program. Resources. Review

Questions