UNCW Institutional Risk Management Update Board of Trustees Audit Committee November 20, 2014 IRM Best Practice Action Steps 1. 2. 3. 4. 5. 6. 7. 8. 9. Develop a disciplined process to consider risk in strategic discussions. Designate an owner of the risk identification process. Require all top administrators to prioritize risk. Sift through the prioritized risks to decide which ones warrant attention at the highest level. Require annual written reports on each high-priority risk being monitored. Re-assess priority risks at the board level at least once a year. Look for blind spots. Move risk identification deeper into the institution each year. Keep repeating the process. C 2009 Association of Governing Boards of Universities and Colleges, United Educators 2 IRM Organization IRM Steering Committee IRM Committee, Chaired by IRM Officer Provost and Vice Chancellor for Academic Affairs Academic Affairs (4) Vice Chancellor for Business Affairs Business Affairs (9) Vice Chancellor for Student Affairs Student Affairs (2) General Counsel Chancellor (2) Director – Internal Audit University Advancement (1) Two processes: Tier 1 Profile: Engages leadership Tier 2 and Emerging Risk Assessment Process: Engages employees across the institution; provides a screening of changing processes; helps the organization to manage interconnected risks. 3 Goals of the Tier 1 Profile (Strategic Risk Profile) To understand institution-level risks* Correlate those risks to their potential impact on institutional strategy Measure, monitor and report on those risks to the board *Institution-level risks are not owned by any one department. 4 Tier 1 Evaluation – Interim Update IRM Best Practice Action Steps 1. Require annual written reports on each high-priority risk being monitored. (Annual report is in April. November is an interim update.) 2. Keep repeating the process. C 2009 Association of Governing Boards of Universities and Colleges, United Educators 5 Interim Tier 1 Update – New Mitigations Essential Resources • Monitoring and watching state revenues for any downside impact • Monitoring average student debt and student cohort default rate Regulatory Intervention • Title IX responsibilities re-organized • Federal Grant for $300,000 to provide enhancements to victim advocacy services, prevention and intervention teams, as well as bystander intervention programming • Financial Aid Compliance checklist completed during DOE Program Review of Financial Aid • Incorporated in the 2014 Annual Security Report (ASR) the requirements of new SaVE Act legislation (Clery Act amendment) Talent Management • AVC HR search nearing completion • Key positions filled for Assoc. Provost-Research/Dean, Vice Chancellor for Business Affairs, Dean – College of Arts & Sciences, Controller • Informal succession planning (by division) 6 Interim Tier 1 Update – New Mitigations (cont’d) Campus Health & Safety • $300,000 federal grant to enhance prevention and intervention teams as well as bystander intervention programming • Active shooter exercise after action report • Study and proposal to design replacement of fire alarm notification system • Increased frequency of lab inspections and training • New and improved touch points between EH&S and new research faculty plus earlier warning of research lab closures • Updated Communicable disease plan, partnering with area health providers • Added express shuttle route on Randall Drive to accommodate new apartments off campus Continuity of Operations • Design proposal received for new code-compliant fire alarm notification system for main campus. • Design facilities plan for alarm receiving center in progress. (Also a safety item) • Infrastructure improvements: Performance Contract 2; Stormwater Plan; Randall Library structural improvements; Renovation of S&BS. 7 Identification Cycle for Emerging/Tier 2 Risks IRM Best Practice Action Steps 1. Sift through the prioritized risks to decide which ones warrant attention at the highest level. 2. Move risk identification deeper into the institution each year. C 2009 Association of Governing Boards of Universities and Colleges, United Educators 8 Determining which risks warrant attention requires a periodic identification and analysis of emerging and/or tier 2 risks, and evaluation to include completed or planned mitigations International Travel Ebola Mental and Physical Health Issues in Remote Programs Determine and codify the alternatives for managing the risk analysis and decision-making around non-credit bearing international travel Protocols and partnerships are being established between EH&S, Student Health, EMT’s and local hospitals. An educational and awareness campaign for our students and employees is ongoing. Procurement and usage of PPE. Coupled with the review of international travel policies is the degree of partnership with Student Health, evaluating where this expertise could be leveraged to reduce risks Executive Sponsors: Provost Battles/VCSA Leonard Executive Sponsor: VCSA Leonard Executive Sponsors: Provost Battles/VCSA Leonard Facilitator: Dr. Martin Posey Facilitator: Stan Harts Facilitator: Katrin Wesner Determining which risks warrant attention requires a periodic identification and analysis of emerging and/or tier 2 risks, and evaluation to include completed or planned mitigations (continued) Research Programming and Business Continuity Fire Prevention and Preparedness Pedestrian, Bicycle and Skateboard Safety Transportation Review process for new programming. Assess support and requirements for buildings, laboratories, and equipment as well as adequacy of compliance. Fire system upgrades and replacement. Monitoring and reporting systems effective 24/7. Exit drills for academic spaces. Draft policy for on campus. Changes to physical infrastructure, additional shuttle services, and traffic counts at major intersections. Inadequate coverage at department level. Coordination with NCDOI affirms controls in place are appropriate. White paper forthcoming from DOI to define affiliates. Executive Sponsors: Provost Battles/ VCBA Whitfield Executive Sponsors: VCBA Whitfield/VCSA Leonard Executive Sponsors: VCSA Leonard/VCBA Whitfield Executive Sponsor: VCBA Whitfield Facilitator: Dr. Ron Vetter Facilitator: Stan Harts Facilitator: Stan Harts Facilitator: Pam Elliott Determining which risks warrant attention requires a periodic identification and analysis of emerging and/or tier 2 risks, and evaluation to include completed or planned mitigations (continued) IT Security Breach Response Plan Network and Physical Plant Infrastructure Growth Capacity National incidents (Target, Home Depot) and average incurred cost increasing (one source: $200/record). Controller commissioning study. Updating registers and contract language. Expand our all hazards response planning to include data breaches. Assess our response to the incident occurring in 2014. Our network is in need of significant upgrades, requiring increased funding. Performance contracts are enabling upgrade of HVAC and energy monitoring systems. Analyze the capacity of instruction, facilities and services. Consider teaching and specialized spaces, infrastructure and human capital. Executive Sponsor: VCBA Whitfield Executive Sponsors: GC Hoon/VCBA Whitfield Executive Sponsor: VCBA Whitfield Executive Sponsors: Provost Battles, VCBA Whitfield, VCSA Leonard Facilitator: Sara Thorndike Facilitator: Zach Mitcham Facilitators: Steve Perry and Bob Fraser Facilitators: Bob Fraser and Dr. Terry Curran PCI Compliance Determining which risks warrant attention requires a periodic identification and analysis of emerging or Tier 2 risks, and evaluation to include completed or planned mitigations (continued) Applied Learning ADA – eLearning Financial Aid and Student Debt Cohort Default Rate Retention Analytics Applied learning opportunities (e.g., study abroad, service learning, field research practicum) introduce a variety of safety and programming risks. How we comply with the Americans with Disabilities Act changes as we increase our eLearning programming. The financial demographics of our student population is changing reflective of larger societal concerns. Significant efforts and planning are required to ensure the success of our student body. Analysis to probe who, what and why around student retention. Executive Sponsors: GC Hoon/Provost Battles Executive Sponsors: GC Hoon Executive Sponsors: VCBA Whitfield/Provost Battles Executive Sponsors: VCBA Whitfield/Provost Battles Facilitator: Pam Elliott Facilitators: Dr. Martin Posey/Dr. Cecil Willis/Dr. Peggy Turner Facilitators: Sara Thorndike/Dr. Ixchel Baker Tate Facilitators: Dr. Martin Posey/Dr. Terry Curran Determining which risks warrant attention requires a periodic identification and analysis of sufficiently narrow focus in Tier 1 areas. These two items are compliance based and continue to emerge as significant risks. Clery Act Compliance Response Protocols for Incidences of gender-based/sexual misconduct New reporting and education requirements in the Violence Against Women Reauthorization Act / and Campus Sexual Violence Elimination Act (SaVE) Provision (Clery Act amendment). How we comply with Title IX is constantly evolving since the Dear Colleague letter of April 2011 and continuing legislation and enforcement. Executive Sponsors: GC Hoon/VCBA Whitfield Executive Sponsors: GC Hoon/VCSA Leonard Facilitator: Chief Donaldson Facilitator: Dr. Brian Victor UNCW Institutional Risk Management Update Questions? Board of Trustees Audit Committee Tier 1 Risks Evaluations – Interim Update Volatile Essential Resources – Rated High Risk Strategic Objective Risk Name Key Drivers Key Risk Indicators Current Mitigations Minimize the impact of changing resources supporting University mission and goals Shortfalls in funding with limited time to manage accordingly Other state policy funding priorities No significant change in the revenue mix State withdrawal from continuing and one time needs Positive enrollment (higher than expected) for Fall 2014. Housing contracts higher than expected as well. Risk Issue Tuition limits, state support, research funding, and outcomesbased policies have the potential to reduce the availability of essential resources Heightened competitiveness for research awards Potential Impact Financial Strategic Operational Continuing decrease in indirect cost receipts Heightened competitiveness for out of Budget cut more in FY14 state students than FY13, but less than FY12. 2015-17 Limits on available Pell Biennium, 2% funding Average student debt Pressure to increase expenses to meet regulatory mandates Updating, retrofitting and replacing critical infrastructure Supporting strategic initiatives • Focused management of research and graduate programs • New revenue sources • Improved Moody’s credit rating outlook • Monitoring and watching out of state enrollment for any downside impact • Monitoring and watching state revenues for any downside impact Caps on tuition, 5% Caps on financial aid paid with tuition, 15% (UNCW • Monitoring average student debt and at 12.7%) student cohort default Shortfall in state rate revenues first 2 quarters Student default rate maintaining after several years rising 15 Tier 1 Risks Evaluations – Interim Update Regulatory Intervention – Rated High Risk Strategic Objective Risk Name Key Drivers Key Risk Indicators Current Mitigations Mitigate regulatory compliance risk in an inherently decentralized environment Inability to comply with all laws and regulations DOE: Title IX/Clery Act Nationally, 85 OCR investigations, key Resolution Agreements, federal inquiries, federal “It’s On Us” program, and legislation in several states • Internal Audits with Compliance Components Nationally Increase in federal and state regulations Increased political scrutiny Instances of culture caught unaware of compliance failure Risk Issue Potential Impact Increased regulatory oversight and intervention: coordination and Financial Accountability for safety support Reputational Pressure to increase Operational affordability and efficiency Governance Deficient DOE program review at UNCW, uptick in Title IX reports (risk of federal complaint) New reporting and education requirements in the Violence Against Women Reauthorization Nationally, many states have Act / and Campus Sexual legislation affecting tuition – Violence Elimination Act (SaVE) Provision (Clery Act freezes, caps and amendment). apportionment UNCW Compliance position turnover Added responsibilities Pending rulemaking on federal financial aid PCI Compliance • UNC System Coordination • ITS Assessments • Increased use of trained fact finders for Title IX investigations • Title IX responsibilities reorganized • Federal Grant for $300,000 to provide education and programming • Financial Aid Compliance checklist completed during DOE Program Review of Financial Aid • Incorporated in the 2014 Annual Security Report (ASR) the requirements of new SaVE legislation (Clery Amendment) 16 Tier 1 Risks Evaluations – Interim Update Campus Health & Safety – Rated High Risk Strategic Objective Risk Name Key Drivers Mitigate vulnerability of students, faculty and staff in an open environment Inability to achieve the safest possible environment in which to learn Risk Issue Potential Impact Expectations and accountability for safety and health is increasing, and existing resources must meet stronger requirements Shift in national expectations from shared responsibility to the safest possible environment in which to learn Title IX, White House “It’s On Us” Key Risk Indicators Current Mitigations 2012 to 2013 (calendar year), • $300,000 federal grant to violent crimes increased from 5 enhance victim advocacy to 10; weapons violations services, enhance decreased; many KRIs constant prevention and intervention teams as well as bystander Workers’ comp costs up 3.5% intervention programming FY14, Student health as self • Active shooter exercise after reported by students improved; action report Alcohol prevention strategies health center visits increased • Funding for Dept. of 11% Reputational Title IX training of mandatory Insurance Hazard reporters. Title IX training of FY15 (current year), uptick in recommendations; study Operational investigators. Title IX campus reports and and proposal to design Financial investigations replacement of fire alarm Compliance Active shooter threat – notification system FY12: 0 reportable fires increased frequency FY13: 1 reportable fire nationwide • Increased frequency of lab FY14: 2 reportable fire inspections and training. UCLA Lab Incident resulting in personal accountability for • New and improved touch 2014, smoke from faculty member and $4.5 points between EH&S and malfunctioning lab equipment million institutional expense new research faculty plus Fall 2014, Growth in new off for legal and consulting. earlier warning of research campus housing impacting lab closures safety on College Road (150 left Ebola (low likelihood, high • Updated Communicable impact), meningitis, seasonal turns, 60 bicycles/hour) disease plan, partnering flu with area health providers Ebola death in US and travel to Growth in off campus student affected countries • Added express shuttle route housing on Randall Drive 17 Tier 1 Risks Evaluations – Interim Update Talent Management – Rated High Risk Strategic Objective Risk Name Key Drivers Key Risk Indicators Mitigate talent management recruitment and retention risk Inability to achieve a rightsized, innovative, highly effective workforce Very limited institutional control over compensation • AVC HR search FY12 to FY13, Turnover rose nearing completion from 9% to 10.8%. The highest numbers were in • Informal succession employees with 0-10 years of planning (by division) service; retirements represented 3.0% of workforce • Leadership development (LEAD turnover. Potential Impact Noncompetitive salary/benefits/startup packages Risk Issue High quality Stagnant wages, colliding with greater economic mobility faculty and Strategic dedicated Operational Counterpoints staff are Institution Quality and essential to Location delivering the programs and services that best serve 21st century students Turnover was highest among professionals and paraprofessionals (these two classes represent 52.5% of all turnover and increased from 10.8% to 14.7%) Current Mitigations Program • Climate surveys • SPA compensation philosophy • Key positions filled for Assoc. ProvostFaculty turnover is <6% Research/Dean, Vice Chancellor for Leadership turnover is resulting in Business Affairs, Dean transitions – several key positions – College of Arts & filled, new vacancies Sciences, Controller 18 Tier 1 Risks Evaluations – Interim Update Continuity of Operations – Rated High Risk Strategic Objective Risk Name Key Drivers Key Risk Indicators Current Mitigations Mitigate impact to students, faculty and staff, facilities and operations on a campus vulnerable to natural disasters Inability to complete our teaching, research, and service mission following a disaster Critical restoration abilities rely heavily on redundancy and hardening of critical services, such as power and data Campus withstood Hurricane Arthur very well with little issues with stormwater • MARBIONC building with generators – gives campus hardened research centers Risk Issue Potential Impact Dependency upon provision of supplies and services Monitoring alarms is a 24/7 responsibility Continuity of operations plans are essential to minimizing the severity of impact and related business interruption caused by natural or manmade disasters Strategic Operational Financial Hazard Reputational Scientific and computer-based research heavily dependent upon specialized equipment and facilities Mutual aid is key when there is a larger scale event affecting the region Effectiveness requires developed knowledge, relationships and training of essential personnel Core mission delivery alternatives aid in recovery Several temporary failures of fire alarm notification system – (system has since been upgraded to more current technology) • Infrastructure improvements: Performance contract 2 and stormwater plan; renovation of S&BS. • Eliminated single point of failure for data connection with the addition of MCNC site • Design proposal received for new code-compliant fire alarm notification system for main campus, and facilities plan for alarm receiving center in progress. (Also a safety item) • Having a FEMA-approved Pre Hazard Mitigation Plan establishes critical restoration priorities and allows federal reimbursement in a declared disaster • Relationships with county and 19 UNC system