The University of Texas of the Permian Basin
Institutional Compliance Program
Quarterly Report
For the Quarter Ended May 31, 2009
Section I – Organizational Matters
 A meeting of the Institutional Compliance Committee was held May 21, 2009.
 There was one change in membership on the Institutional Compliance Committee during
the quarter with Dr. Karen Smith, Interim Assistant Vice President for Graduate Studies
and Research replacing Dr. J. Tillapaugh.
 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: Karen Smith, Interim Asst. Vice President for Graduate Studies and
Sponsored Research
Key “A” risk(s) identified:
 Noncompliance with Time and Effort reporting
 Failure to follow laws, policies and procedures regarding use of animal and
human subjects.
Key Monitoring Activities:
 A new part-time staff member that was hired to serve as ECRT functional leader
received training, then trained PI/Directors on use of the new ECRT software.
 Ten programs were certified through the new ECRT certification software.
Program query feature was used to ensure required PI/Director review of
monthly data with follow up if necessary. Period covered by the certification
was 9/1/2008 through 2/28/09.
 The Responsible Party reviewed 2 IACUC and 29 ACHE protocols, approved 24
without revisions and 7 were not approved. The requested materials for the 7 not
approved were not received by the end of the reporting period.
Specialized Training:
On-going specialized training continued regarding Time and Effort reporting for
PIs and staff on all externally funded projects. Completion rate at the end of the
quarter was 69%. Training on ECRT/Huron software for Time and Effort
tracking was completed during the quarter for 10 (100%) of PI/Directors
identified for the training.
High-Risk Area #2: Institutional Advancement
Responsible Party: Kay Bivens, Director of Institutional Advancement
Key “A” risk(s) identified:
 Failure to comply with Federal regulations and donor requirements
Key Monitoring Activities:
 Checked 197 (100%) of gifts received as of 5/26/09 by reviewing the gift register
before deposit was made and initialed Gift Entry Validation before the
donor’s folder was filed. No errors were detected.
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High-Risk Area #3: Information Resources
Responsible Party: Roy Mendoza, Information Security Specialist
Key “A” risk(s) identified:
Inadequate information security program impacting confidentiality, availability and / or
integrity of data
Key Monitoring Activities:
 Ongoing monitoring of email for confidential content. All inbound and outbound
email messages are examined. Emails containing social security numbers have
averaged 17 per month to date in FY 2009. Emails containing credit card numbers
have averaged one per month.
Specialized Training:
Annual Information Security Awareness training is required of all UTPB
information resource users. An updated Information Security Awareness Training
module was made available to faculty and staff during November 2008. As of the
end of May, training has been completed by 398 of 707 users (56%). A weekly
reminder is now being sent to all who have not completed the requirement. A
report of training remaining to be completed will be provided quarterly to the
Institutional Compliance Committee.
High-Risk Area #4: Weapons and Drug and Alcohol Use
Responsible Party: Susan Lara, Vice President for Student Services
Key “A” risk(s) identified:
Failure of students to follow federal, state and local laws and / or university policies
related to weapons, health and drug and alcohol use
Key Monitoring Activities:
 Monitored student referrals from housing and the campus police department.
Twelve alcohol offenses, three drug offenses and no weapons offenses occurred
during the reporting period. Committeee for student engagement met numerous
times as did a committee for alcohol and drug prevention on campus. The decision
was made to have more student engagement activities and two more
awareness/prevention programs.
Specialized Training:
Alcohol and drug training was provided for RAs and orientation leaders. Six full
time staff and 38 student RAs and orientation leaders were trained.
Section III – Monitoring and Assurance Activities (Performed by Compliance
Office/Designate)
High-Risk Area: Failure to follow financial reporting standards and UT System
guidelines for budgeting and financial reporting
Assessment of Control Structure: Opportunity for enhancement
 Monitoring/Assurance Activities Conducted: Tracking of findings from AFR
Financial audit for Fiscal Year 2008. Three of the findings were considered
significant deficiencies and other recommendations were made for improvement.
The VPBA and Director of Accounting have a regularly scheduled meeting every
other week with the Asst. Compliance Officer / Internal Auditor to discuss
progress on implementation of the audit recommendations. A schedule of
findings and progress on the implementation is used as a tool for tracking. In
addition, an action plan for each of the significant findings was prepared for the
President by the Director of Accounting.
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Monitoring/Assurance Activities Conducted: Compliance Officer and Asst.
Compliance Officer / Internal Auditor 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.
Training Provided: Training for budget heads and support staff regarding
proper reconciliation of statements of account was completed during the second
quarter. The Internal Auditor attended each session to stress the importance of
proper reconciliation procedures and to answer questions about expectations for
proper documentation. 100% of 93 budget heads and administrative staff
identified to receive the training achieved completion by May 20, 2009.
High-Risk Area: Financial Aid
Assessment of Control Structure: Opportunity for enhancement
 Monitoring/Assurance Activities Conducted: The audit report for the State
Auditor’s Office A-133 limited scope audit of financial aid was issued during the
quarter with material weaknesses in the disbursement section. Progress on
implementation of the changes to correct the findings is being monitored by the
audit department and reported to the Audit Committee.
Section IV – General Compliance Training Activities
Seven modules of General Compliance training administered through Training Post were
assigned to all continuing employees. New employees were assigned twelve General Compliance
modules. December 15, 2008 is the date set by the Institutional Compliance Committee for the
assigned training to be completed. As of May 20, 2009, 2,318 of the 2,668 modules assigned or
86.9% were completed. Follow-up reminders from the appropriate executive staff will be used to
remind staff to complete the assigned modules. A conversion from Training Post to Adobe
Connect for delivery of general compliance training is in process, with new assignments made in
the new software beginning February 2009.
Section V – Action Plan Activities
The following Action Plan items were implemented during the quarter just ended:
 Surveys completed by the Committee and the Compliance Officer to assess the
compliance program and officers were received and summarized for review of the
Committee.
 The annual Compliance Awareness survey was completed and survey results were
provided to the Committee, with comparison to prior year results.
 The Committee approved a training plan for the 2009-2010 fiscal year, assigning general
compliance modules to new and continuing staff.
 The Compliance Officer continued the process of collecting 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 revised Compliance Manual received final approval from Executive Staff on May
27, 2009. It is ready for distribution and update on the Compliance website.
 Provided the 2nd Quarter compliance reports for high risk areas to the Compliance
Committee for review.
 Provided the second quarter report for FY 2009 to the U.T. System Compliance Office.
 Held a meeting of the Institutional Compliance Committee during the quarter.
 Provided articles for inclusion in the employee newsletter that highlight various
compliance topics and educate the UTPB community regarding the Compliance Program.
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The Assistant Compliance Officer provided resource information during training
provided to Budget Heads and Administrative staff in sessions provided by the university
trainer on the statement of accounts reconciliation process. As of May 21, 2009, 100% of
the budget heads and administrative staff required to take the training had achieved
completion.
Training on the Time and Effort certification process was monitored by the Office of
Human Resources during the quarter. As of May 20, 2009 the completion rate of
identified indivuals required to complete the training was 69%.
Conversion of Training Post modules to Adobe Connect continued during the quarter by
the trainer in the Office of Human Resources.
Received and investigated or forwarded to appropriate administrators compliance
inquiries received through various means including the “888” hotline, internal phone,
email and in person. Provided an update on the inquiries to the Compliance Committee
in May 2009 at their regularly scheduled meeting.
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