The University Compliance Office is a function which helps to verify that compliance is occurring in select activities governed by federal law and regulation, and by university policy.
The University Compliance Office consists of a Director and two full-time compliance auditors. The team performs proactive and investigational (as needed) compliance audits that are based on select university compliance activities. The results of the compliance audits are often used to incorporate compliance training programs that are either being developed or refined.
Verification
The University Compliance Office performs verification of select activities that occur at the university. Verification does not mean performing the actual work of compliance. Rather, it means making sure that the relevant activities have effective compliance organizations, and that the organizations have the following elements:
- Effective policies and procedures
- Effective training programs
- Effective techniques for monitoring compliance
Compliance Audits
The University Compliance Office conducts compliance audits of select activities across the university. Compliance audits are not the same as monitoring. Both are a means of checking to see if compliance has occurred; however, there are differences as noted below:
| Monitoring | Auditing |
| – Monitoring is done within the activity or department. – Monitoring activities occurs much more frequently than auditing. – Monitoring is less formal. Monitoring checks mechanically for compliance. | – Audits are done by an outside entity. – Audits are more occasional and may occur with or without advance notice. – Audits are governed by formal protocols that involve checking the process itself. – Audits include discussions and communications with department heads and/or other outside entities such as Deans and General Counsel. – Audits involve systematic follow-up for the purpose of curing the noted deficiencies. |
It is important to note from above that auditing is an arm’s length activity of monitoring.
- Monitoring is typically done by an office or individual who is perceived to have an interest in protecting the activity. Thus, their perception may potentially diminish the credibility of the checking activities.
- Auditing does not typically have a connection to the activity that being checked which may result in greater objectivity. This is a primary reason why audits are usually conducted by an office which does not report to a dean or an administrator that is responsible for the overall success of the given activity or department. Instead, the auditor typically reports independently up to the Chancellor and/or Board of Trustees.
It is also important that monitoring and auditing work together.
- Monitoring may uncover deficiencies that suggest the need for audits.
- Audits may uncover deficiencies that suggest the need for enhanced monitoring. Monitoring and auditing should be complements of each other.
University Code of Conduct
The University Compliance Office is responsible for developing, revising, and maintaining a university code of conduct.
University Hotline
Washington University has established a hotline as a means to confidentially and anonymously report on select concerns or suspected violations of university polices. The Office of Human Resources and the University Compliance Office currently oversee the company which has been contracted by the university for administering the hotline.
Communication with University Leadership
The University Compliance Office maintains effective and ongoing communication with senior management and the audit committee of the Board of Trustees members regarding the state of select university compliance activities. This communication includes regular reports of compliance activities such as audits, hotline activities, as well as plans for future compliance activities.
Benefits of University Compliance Program
Below are some key benefits for the university compliance program:
- Furthering a university culture that does not tolerate illegal or actionable behavior and prompts faculty and staff to consider the potentially adverse legal consequences of certain conduct.
- Increasing the likelihood of early detection if potentially illegal or actionable conduct does occur, thus creating the opportunity to correct or self-report.
- Serving as a basis to persuade governmental authorities to decline prosecution or the initiation of a civil or regulatory action.
- Reducing significantly the penalties or fines assessed and avoiding the imposition of a governmentally-mandated Corporate Integrity Agreement, a set of expensive and burdensome compliance procedures, if noncompliance does occur.