Essential Elements of an Effective Compliance Program

Oversight

• Designate compliance professionals to oversee the development and management of the USA Campus Compliance Program;
• Operate objectively, with an arms-length separation from business operations (to a reasonable extent), and with necessary support from leadership.

Policies and Procedures

• Develop, review, modify, and publish guiding principles, including the Community Values and Code of Conduct, applicable portions of the Staff Employee Handbook and Faculty Handbook, and compliance-related University Policies;
• Subject matter experts should stay abreast of new state and federal laws, regulations and statutes that impact higher education and the University of South Alabama in particular, and assure University policies and procedures are updated accordingly.

Education and Training

• Develop, implement and maintain an effective training program which ensures employees are aware of applicable policies and procedures;
• Recommend focused, role-based training on identified high-risk topics for applicable employees.

Open Lines of Communication

• Assure the availability of a means by which employees may report potential compliance violations, free of retaliation, and anonymously if desired;
• Assess efficacy of compliance issue reporting processes;
• Foster a culture of ethical conduct and transparency so that employees feel comfortable reporting concerns directly to their supervisors.

Auditing and Monitoring

• Compliance audits and surveys should be scheduled routinely to assure University processes and procedures are compliant with our standards and policies (e.g., the biennial Compliance Risk Assessment);
• Auditing and monitoring findings should be communicated to department or division leadership, with remediation steps and follow-up requirements clearly communicated.

Response and Prevention

• Monitor long-term trends of compliance violations and make recommendations for necessary mitigation;
• Recommend areas of concern for targeted risk assessments to the University’s compliance professionals and Internal Audit;
• Corrective actions in the wake of confirmed violations should be addressed to all involved, and leadership should consider sharing lessons learned with others;
• Assure employee criminal background checks are consistent, effective, and appropriately scaled to the level and type of responsibility of the employee.

Enforcement and Discipline

• Assure that enforcement measures and disciplinary options are reasonably consistent across departments and divisions;
• Develop positive incentives to promote ethical and compliant conduct.

Compliance Program Evaluation

• Evaluate periodically the effectiveness of the University's ethics and compliance program.