PRAIRIE VIEW A&M UNIVERSITY University Compliance Office News DID YOU KNOW? V O L U M E The University Compliance Office is now online! Visit us at www.pvamu.edu/ universitycompliance! The University Compliance webpage now features a list of UAPs and Rules that have been posted and deleted during the fiscal year Did your department/unit participate in the Compliance Champion Challenge? Do you want to know the results of your onsite survey? Contact Alexia Taylor at x2118 or altaylor@pvamu.edu. INSIDE THIS ISSUE: Policy Central 2 Policy Spotlight 2 Compliance Makes a Dif- 2 ference Compliance Contacts 4 Compliance Wordseek 5 I I I , I S S U E I I I A P R I L 2 0 1 4 Health Center Wins First Annual Compliance Challenge A nd the winner is… individual who attended the the Owens-Franklin most trainings. These awards Health Center! went to Ms. Gieseke and Dr. Ms. Thelma Pierre, Terence Finley, respectively. Administrator of Health Services and her staff emerged victorious in PVAMU’s first Compliance Champion Challenge. The winner of the challenge had to demonstrate compliance in monthly account reviews and development of departmental procedures. In addition, all employees in the department had to be current on the five Systemrequired trainings in TrainTraq. To earn additional points for their department, a Health Center staff member attended all nine of the training sessions offered during the week-long event. Second place went to the Office of Disability Services (Dr. Kay Norman) and third place went to Auxiliary Services (Ms. Victoria “Pappy” Gieseke). The University Compliance Office also recognized the first department to sign up to compete in the challenge and the The goal of Compliance Week 2014 was to heighten the University’s awareness of the importance of compliance through a “meet-andgreet” on March 17th and free, on-campus training opportunities, which were offered Tuesday, March 18th through Thursday, March 20th. Training topics included student travel, athletic boosters, ethics, fraud, waste and abuse. The capstone of the week was the Compliance Awards on March 21st, which featured guest speaker Dr. Jairy Hunter, Jr., President of Charleston Southern University located in North Charleston, South Carolina. You may leave your feedback about Compliance Week by completing the feedback survey located on the University Compliance Office’s website. The survey closes April 30, 2014. Pictured (l to r): Dr. George Wright; Ms. Thelma Pierre; Ms. Liz Mitchell; Ms. Lydia Cavanaugh; Dr. Michael McFrazier Photo courtesy of Ms. Christi Landry PAGE 2 Policy Central: Recently Approved PVAMU Policies 11.03.99.P0.01 Shortened Courses 24.01.01.P0.01 University Golf Cart and Service Vehicle Safety 24.01.01.P0.09 Hazard Communication (HazCom) Program 24.01.01.P0.10 Laboratory Decommissioning 29.01.03.P0.03 Information Resources-Email Usage 29.01.03.P0.04 Information Resources-Intrusion Detection 31.05.01.P1 Faculty Consulting and External Professional Employment (Rule) 33.99.08.P1 Student Employment (Rule) Policy Spotlight: PVAMU Rule 33.99.08.P1 Student Employment PVAMU established Rule 33.99.08.P1 Student Employment to oversee the University’s process for student employment. Per the Rule, students may obtain paid employment as work-study employees, student hourly employees or graduate assistants. In order to be in compliance with workstudy requirements, students may not work more than 20 hours per week during a regular semester. Student hourly employees may not work over 20 hours each week, and non-teaching graduate assistants may not work more than 25 hours per week while completing their graduate coursework. Similarly, graduate assistants with F-1 visas may not work more than 20 hours each week while completing their graduate coursework. Questions related to this rule may be directed to the Office of Human Resources at 936.261.1730. Compliance Makes a Difference UNIVERSITY Every organization, its pro- that is considered ac- lished by authority as a grams, and workforce ceptable or desirable; rule for the measure of have standards to meet. something that is very quantity, weight, extent, The definition of a stand- good and is used to make value or quality.” ard according to Web- judgments about the qual- There are also standards ster.com is: “a level of ity of other things; some- for compliance and ethics quality, achievement, etc. thing set up and estab- (continued on pg. 3) COMPLIANCE OFFICE VOLUME III, ISSUE III PAGE Compliance Makes a Difference (continued from page 2) programs. If those standards are met, it can make a tremendous difference. of this discussion, the elements are ness and the expectations for the broken down further to highlight conduct of the workforce. each aspect addressed in the FSG. The standards established for the structure of an effective compliance program are outlined in The 2011 Federal Sentencing Guidelines (FSG) Manual, Chapter Eight for Effective Compliance and Ethics Programs. Each of the elements defined in the FSG has measurements associated with it. The guidelines and measurements help judges to determine how well the compliance and ethics ele- Governance and high-level oversight refers to the board of directors receiving reports about compliance program activities. The directors must demonstrate knowledge and oversight of the program. A high -level person (a compliance officer who has proper authority and reporting responsibilities) is designated to oversee the compliance program. ment/standard was met, or not met, and what the consequence will be. maintaining and publishing policies, Although the elements are often re- procedures, and a code of conduct Establish standards refers to ferred to as the “seven elements of a that address the risks of doing busicompliance program,” for the sake Create a fair and ethical culture refers to establishing incentives tied to performance for the workforce, including leadership, to help create a tone where “doing the right thing” is evaluated and rewarded. Open lines of communications refers to establishing a confidential reporting line/hotline for misconduct and surveying the workforce for feedback. Education and training refers to conducting training programs that cover regulatory (continued on pg. 4) SELF‐MOTIVATION “Start where you are. Use what you have. Do what you can.” —Arthur Ashe 3 VOLUME III, ISSUE III PAGE 4 Compliance Makes a Difference (continued from page 3) requirements, the roles of the work- Auditing & Monitoring refers to compliance officer collaborate to force, and areas of risk. ongoing testing of the controls estab- properly identify and evaluate risks lished to minimize risks and ensure the and lessen or eliminate the risks controls are working. through well-designed internal con- Detection, remediation, and en- forcement refers to screening employees to ensure they have not been involved in criminal activity, establishing sanctions for non-compliance with organizational standards and the law, taking immediate action to address misconduct, and making corrective actions to prevent recurrence. Assessment of effectiveness refers to evaluating the compliance program elements and how well they are being met. Meeting the operational day-to-day responsibilities and standards and meeting the compliance and ethics Risk assessment refers to finding program standards are related. To and evaluating operational and or- implement an effective compliance ganizational risks and taking steps to program, it’s important that the lead- minimize those risk areas. ership, the general workforce, and the trols. An effective and mature compliance program will be established when everyone works together as a TEAM (Together Everyone Accomplishes More). That’s how compliance makes a difference. Deann M. Baker, CCEP, CHC, CHRC Managing Director Compliance Advisor Specialists, LLC University Compliance Office Contacts: Lydia Cavanaugh, CCEP, Director lacavanaugh@pvamu.edu 936.261.2155 Alexia Taylor, CCEP Jacquline Stone, CCEP Craig Nunn Sr. Compliance Officer Compliance Officer Compliance Officer altaylor@pvamu.edu jastone@pvamu.edu clnunn@pvamu.edu 936.261.2118 936.261.2116 936.261.2117 Janet Smalley, System Ethics & Compliance Officer janetsmalley@tamus.edu 979.458.6008 J U G E E Q N A N Y H Y S K T U Y E N X S E R U D E C O R P M U O I P D S R S H I J X C J P T A L O K R M L H A N B H E H J Y T R R I A T B I E X L C I I Z O T J P E C G L S P O H P B M H C Q T Q L O B V M N M A C M L O O P U F F R P Y E B A X J L N V C N H F L P U B D Y L N E T H P W X I E V W J Q J I X O R I O Q A T X R Q B H Y W O K O T C N A Y K R P U V A D X M L M C M X S O C I A L H I C R S E U I I Z P V B E I G L R E V S M F P O M X X X D Compliance Hotline Ethics Procard Export Controls Procedures FERPA SOCIAL HIPAA TAMUS