The University of Texas of the Permian Basin
Institutional Compliance Program
Quarterly Report
For the Quarter Ended November 30, 2007
Section I – Organizational Matters
 A meeting of the Institutional Compliance Committee was held September 18, 2007.
 One change in membership on the Institutional Compliance Committee was completed at
the beginning of the fiscal year in the position held by the President of the Faculty
Senate.
 There were no changes in the Compliance staff.
Section II - Risk Assessment, Monitoring Activities and Specialized Training (Performed by
Responsible Party)
High-Risk Area #1: Research
Responsible Party: J. Tillapaugh, Asst. Vice President for Graduate Studies and
Sponsored Research
Key “A” risk(s) identified:
 Inadequate training about Federal reporting requirements
 Noncompliance with Federal reporting requirements such as Time and Effort
 Inappropriate use of animal and human subjects, research subjects and materials
Key Monitoring Activities:
 The Responsible Party reviewed the Effort Commitment & Certification reports
that were completed by principal investigators of Federal grants during the
period. Questions arising during the review were resolved.
 The Responsible Party and the Provost developed an Action Plan, a Monitoring
Plan, an Effort Commitment & Certification Policy and a Training Plan for
review and approval by the Institutional Compliance Committee.
Specialized Training: Individuals with principal responsibilities on 11 of the 12 UTPB
Federal grants were trained on the Effort Commitment & Certification Policy adopted by
the university.
High-Risk Area #2: Intercollegiate Athletics
Responsible Party: Steve Aicinena, Director of Intercollegiate Athletics
Key “A” risk(s) identified:
 Ineligible students participating in practice and competition
 Lack of comprehensive training program on NCAA rules
 NCAA rules and regulations not disseminated to appropriate individuals
Key Monitoring Activities:
 Maintained and reviewed weekly practice logs for time and signature compliance
requiring follow-up on student-athlete signatures; reviewed, updated and
disseminated (as appropriate) eligibility checklists, team roster deletions, squad
lists and individual student-athlete files to re-verify each student-athlete’s
eligibility for practice and competition as each sport came in season; reviewed
eligibility software (CAi) for accuracy in recording of eligibility data
and found no errors affecting eligibility; held student-athlete compliance
orientation to complete all requisite NCAA and institutional athletically-related
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documentation; and followed-up on student signatures and reminded one studentathlete to complete lab tests for required reporting to Drug Free Sport in January
2008. No NCAA Self-Report Violations involving student-athlete eligibility were
filed during the first quarter.
Revised 4-Year Transfer Eligibility Checklist to better communicate eligibility
issues to Head Coaches
Created a Try-Out guide based on NCAA Bylaws for Coaches regarding the
participation of current student-athletes in try-outs
Created a Try-Out Form for Coaches that tracks NCAA Bylaws to accompany
Official and Un-official Visit forms
Expanded the NCAA Division II Coaches Recruiting Guide to further assist
Coaches in following NCAA Bylaws during the recruiting process
Adapted another institution’s form for Coaches to record recruiting information for
later input to CAi
Collaborated with staff to create scholarship award procedure flowchart for NCAA
Bylaw Article 15 Financial Aid accountability and improve communication with
Coaches and the Financial Aid Office
Disseminated NCAA sport-specific recruiting calendar information to Coaches
Forwarded NCAA and Conference updates to related institutional departments.
Specialized Training:
November 2007: Held Athletic Department meeting led by Athletic Director and
attended by Staff, Compliance Officer, all Head and some Assistant Coaches of
each sport, and the Faculty Athletic Representative. Of 21 eligible for training, 16
were actually trained. Those not attending were 4 Assistant Coaches and the
Athletic Trainer. Training program was on NCAA Bylaw Article 13.02.1
Community Engagement Activity, recruiting and scholarship funds, importance of
timely and accurately recording recruiting information in CAi, and pre-requisites
for a letter of intent or scholarship issuance. Attendees were informed of upcoming
NCAA External Compliance Review (March 5-6, 2008) and each person’s role in
obtaining a successful review.
Coaches were given a December 31 deadline to pass the NCAA Coaches
Certification Exam as required by NCAA Bylaw Article 11.5 Certification to
Recruit Off Campus. As of this date all but one (7 out of 8) have passed the exam.
Section III – Monitoring and Assurance Activities (Performed by Compliance
Office/Designate)
High-Risk Area: Inadequate financial information to establish current position and
close out prior year; Bad financial rating status; Failure to achieve budget assumptions
Assessment of Control Structure: Opportunity for enhancement
 Monitoring/Assurance Activities Conducted: Financial audit of Fiscal Year
2007 Annual Financial Report.
Significant Findings: Opportunities for improvement of controls over financial
reporting were noted during the audit. Some of the recommendations were
repeat recommendations from prior years. None of the findings had a material
effect on the financial statements.
 Monitoring/Assurance Activities Conducted: Compliance Officer and Internal
Auditor/Asst. Compliance Officer meet weekly with the President, Provost and
Director of the Office of Accounting to review current financial position and
potential actions that could impact year end results and financial rating status.
High-Risk Area: Research
Assessment of Control Structure: Opportunity for enhancement
 Monitoring/Assurance Activities Conducted: The Institutional Compliance
Committee reviewed and approved the Action Plan, Monitoring Plan, Effort
Commitment and Certification Policy and Training Plan developed to move
toward compliance with the requirements of UTS 163 and to satisfy audit
recommendations received in an August 2007 audit report related to compliance
with UTS 163.
High-Risk Area: All “Top 20” risks
Assessment of Control Structure: Opportunity for enhancement
 Monitoring/Assurance Activities Conducted: A review of the monitoring plan
for each of the “Top 20” risks was started in order to identify areas of potential
improvement.
Section IV – General Compliance Training Activities
Six modules of General Compliance training administered through Training Post were assigned to
all continuing employees. New employees were assigned twelve General Compliance modules.
December 31, 2007 is the date set by the Institutional Compliance Committee for the assigned
training to be completed. As of the end of the first quarter of fiscal year 2008, 1,088 of the 1,956
modules assigned or 55.6% were completed. Follow-up reminders from the appropriate
executive staff will be used to remind staff to comply with the deadline.
Section V – Action Plan Activities
The following Action Plan items were implemented during the quarter just ended:
 Surveys were completed by the Committee to assess the compliance program and the
compliance officers.
 A self-assessment survey of the program was completed by the Compliance Officer. The
Compliance program, Compliance Committee, and Compliance function were assessed to
ensure continual improvement.
 The Committee requested individual certification letters from all budget heads and
responsible parties that provide assurance and/or note exceptions to compliance activities
and programs within each area.
 The Assistant Compliance Officer participated in UT System Institutional Compliance
Advisory Council (“ICAC”) and the Peer Review and Assurance Activities Committee.
 Provided monthly reports during the first quarter and the annual report for FY 2007 to the
U.T. System office.
 Held a meeting of the Institutional Compliance Committee during the quarter.
Completion of the following Action Plan items scheduled for the first quarter of FY 2008 were
delayed until subsequent quarters due to other projects that demanded the attention of the
Assistant Compliance Officer:
 The Committee will obtain final approval and distribute the revised Compliance Manual
to appropriate staff.
 Monitoring plans for the top risks will be reviewed by the compliance officers and
completed plans will be presented to the Compliance Committee for review.