Old Dominion University
1003 University Responsibility for Compliance
|Responsible Oversight Executive:||Vice President for Administration and Finance|
|Date of Current Revision or Creation:||November 21, 2019|
The purpose of this policy is to establish the University's framework for compliance with applicable laws, rules and regulations, and institutional policies and to define the responsibilities of the Compliance Advisory Committee, Vice Presidents, and individuals in meeting and maintaining compliance requirements.
Code of Virginia Section 23.1-1301, as amended, grants authority to the Board of Visitors to make rules and policies concerning the institution. Section 6.01(a)(6) of the Board of Visitors Bylaws grants authority to the President to implement the policies and procedures of the Board relating to University operations.
University Policy #1002 - Code of Ethics, Goal # 1 - "We will maintain the highest level of ethical standards, and comply with all applicable laws and regulations and University policies."
Compliance Advisory Committee - A University-wide group made up of key individuals knowledgeable of compliance issues, whose chair is the Vice President for Administration and Finance.
Compliance Registry - A database of compliance requirements that includes a description of the activity, reporting requirements, regulation or other citable reference, responsible vice presidential area, responsible office, responsible position number and title, and status of compliance.
Compliance Requirements - Federal and State laws, rules, regulations, standards and institutional policies and procedures that University employees, students, volunteers and vendors are expected to be aware of and in compliance with.
This policy applies to all employees, students, volunteers, employees of affiliated organizations who are paid through the University, and vendors. Employees include all staff, administrators, faculty, full- or part-time, and classified or non-classified persons who are paid by the University. Students include all persons admitted to the University who have not completed a program of study for which they were enrolled; student status continues whether or not the University's programs are in session. Volunteers include individuals who perform services in support of the University's mission without promise, expectation, or receipt of compensation for services rendered. Affiliated organizations are separate entities that exist for the benefit of the University through an operating agreement and include the Foundations, the Community Development Corporation, and the Alumni Association. Vendors are those individuals who have a relationship with the University by virtue of a contract.
Compliance with laws, rules, and regulations that govern the University is an ever growing responsibility of the University and is mandated by a number of oversight agencies and organizations that impose requirements on the University. The risks of non-compliance can be significant, and may include, but are not limited to, loss of accreditation, reputation, and/or funding, financial and non-financial penalties, and potential criminal prosecution.
This policy outlines the University's compliance structure and responsibilities in its commitment to fostering an institutional culture of ethical conduct and adherence with compliance requirements. University compliance is a shared responsibility among all employees, students, volunteers, vendors and the Compliance Advisory Committee, whose responsibilities are described below.
Vice Presidents are responsible for promoting compliance awareness and responsibilities within their respective organizations; maintaining an inventory of all compliance requirements for units within their organizations; and developing programs, processes, and internal controls to ensure compliance requirements are being met.
All University employees, students, volunteers and vendors are expected to be aware of and comply with any compliance requirements that are applicable to their respective status and responsibilities within the University. They are also responsible for being cognizant of any changes in the compliance environment that may impact these responsibilities and, where applicable, cooperating with other affected units of the University in order to ensure compliance requirements are met for the University as a whole.
The role of the Compliance Advisory Committee is to promote compliance awareness among the University's academic and administrative units. These duties include:
- Promoting effective communication and collaboration among those responsible for compliance;
- Monitoring emerging compliance trends and disseminating information as needed;
- Serving as a resource in developing or improving compliance related processes;
- Working with the University's Policy Review Committee to ensure development of policies and procedures required for current or future compliance requirements; and
- Making recommendations to senior management as to any resources or actions required for University compliance.
The Vice President for Administration and Finance (or designee) will chair the Compliance Advisory Committee and will consult with the other Vice Presidents to appoint members of the Committee. The chair determines the scope and frequency of meetings of the Committee in the fulfillment of its duties as outlined in this policy.
The Vice Presidents will maintain an inventory of all compliance requirements for the units within their organizations. The inventory should include the position number and title of the employee(s) responsible for each compliance requirement and any associated reporting requirements. The inventories will be submitted to the Compliance Advisory Committee at the request of the chair, or as changes are made throughout the year. The lists submitted by the Vice Presidents will be used to update the Compliance Registry maintained by the Committee. Vice Presidents should ensure that position descriptions for those employees who have been identified as responsible for meeting compliance requirements include compliance as a core responsibility that is evaluated during the annual evaluation process. On an annual basis as determined by the Compliance Advisory Committee, Vice Presidents will be required to submit a current status report on each compliance requirement within their organizations.
The Vice President for Administration and Finance will report on the activities of the Compliance Advisory Committee to the Board of Visitors Audit and Compliance Committee on a periodic basis.
Applicable records must be retained and then destroyed in accordance with the Commonwealth's Records Retention Schedules.
Director of Special Projects, Office of Administration and Finance
Policy Formulation Committee (PFC) & Responsible Officer Approval to Proceed:
Policy Review Committee (PRC) Approval to Proceed:
Chair, Policy Review Committee (PRC)
Executive Policy Review Committee (EPRC) Approval to Proceed:
Responsible Oversight Executive
University Counsel Approval to Proceed:
May 16, 2013; November 21, 2019
Scheduled Review Date
November 20, 2024