1. Legal and Regulatory Compliance: 3 Primary Areas Higher Education Regulations (Federal, State, & Private Agencies) Corporate Laws & Regulations (Federal, State & Local) Healthcare Provider Laws & Regulations (Federal, State & Local) Examples Title IV: Federal Financial Aid Title IX: Student Equality Clery Act: Campus Crime/Safety Homeland Security: Int’l Students FERPA HLC & CCE Accreditation Governance, Mission, Institutional Planning, Financial Health, Student Learning Assessment, etc State Licensing: IA, FL & CA Publication Integrity, Academic & Enrollment Policies, etc Examples ADA COBRA OSHA Red Flag Equal Opportunity Affirmative Action Smoke-free environment Drug-free environment Record Retention & Disposal Whistleblower Communicable Disease Reporting Financial Audits Examples Medicare/Medicaid HIPAA Child Abuse Reporting Requirements Anti-kickback

2. External Compliance Reviews Who/how is compliance checked? Higher Education Regulations (Federal, State, Local & Private Agencies) Corporate Laws & Regulations (Federal State & Local) Healthcare Provider Laws & Regulations (Federal State & Local) U.S. Dept of Education (DOE) Accreditation & Licensure Agencies External Audits: Financial, Safety, Facilities, Clinical, etc

3. Palmer’s Compliance Program Seeks to reduce institutional risk through: Global oversight of compliance requirements and activities Increasing lateral and horizontal communication about compliance efforts and requirements Establishing or clarifying division/department compliance processes

4. Palmer College Compliance Program Structure Acad- emics Admin Serv Clinic Affairs Enroll- ment Inst. Advance Research /PP Student Success Strat Dev Supp. Servic es Market- ing/ PR Chief Compliance Officer Glenda Weise Alexis Vander Horn Shayan Shebani Karen Eden Maegen Gorham Karen Grimm Mindy Leahy Jeann. Danner Kathy Sebille Kim Kent Dana Lawre nce Michelle Walker Shelley Hammill J. Ren- dazzo Earlye Julien Kathy Lange Mike Benedict OSD OSD utilized as needed for policy and process development, gap analysis accreditation, audits and data support. External Expert Auditors /Reviewers

5. Roles in Palmer Compliance Program 1. Compliance Officer Oversee compliance program; chairs the compliance committee Audits division documented processes for maintaining compliance Report concerns to Exec Admin team and the Audit Committee of the Board as necessary 2. Exec Admin Team Designate key staff to participate on compliance committee Support staff in obtaining and maintaining currency in compliance regulations for their respective areas i.e. Attend conferences and training for compliance Support staff in establishing processes to facilitate division/department compliance i.e. Establish dept/division manuals that include procedures to maintain compliance Hire external experts for audit and compliance review as needed

6. Roles in Palmer Compliance Program 3. Compliance Committee Members Function as Compliance Coordinators for their areas Obtain and maintain knowledge of compliance regs for their areas Share compliance info with VCs/ExecDirs and committee members Work with others to create processes to ensure compliance within their respective areas (i.e. dept manual includes compliance procedures and schedule) 4. OSD Assist Dept/Division Compliance Coordinators with: Developing processes/procedures & policies to maintain and track compliance within their division (Earlye Julien & Liz Rodriguez) b. Align dept/division compliance processes and/or data with Accreditation and Licensure regulations/standards (Jeannette Danner & Kim Heatherly) c. Data Analysis and effective presentation of data (Dustin Derby/IPR)