7.16 Compliance Policy
It is the policy of the University System of Georgia (USG) to comply with applicable Federal and State laws, rules, and regulations and to encourage ethical conduct as detailed in the USG Ethics Policy (see Board Policy 8.2.20 University System of Georgia Ethics Policy). The USG Compliance and Ethics Program (Program) refers to the USG policies and procedures designed to ensure ethical conduct and compliance with legal requirements and ethical conduct.
Adherence to Federal guidelines for an effective compliance and ethics program is also a key Program purpose. Effectively implementing the Program will ensure that USG institutions are equipped with the information needed to effectively follow applicable laws and regulations while also reducing potential fines and penalties should a USG institution inadvertently not adhere to a legal or regulatory requirement.
Effectively implementing the Program will also ensure that USG institutions are equipped with the information needed to effectively comply with applicable laws, rules and regulations. A system wide compliance program can help identify subject matter experts in various fields and assist in making their expertise known across the University System. Program implementation will focus on leveraging current resources and Board Policy 7.15 Risk Management in support of Program implementation.
Program objectives are to:
- Identify applicable laws, regulations, policies, and contractual requirements which pertain to each institution and to the USG;
- Ensure that responsibility for ensuring compliance has been properly assigned to responsible personnel;
- Monitor compliance with applicable requirements; and,
- Provide training and expertise to assist institutions and the USG in meeting its compliance requirements.
An effective Program is designed to meet the following elements and ensure that:
- Standards have been adopted that require compliance with applicable law;
- High-level personnel have been assigned the authority and responsibility to implement the Program and that the Board of Regents is periodically updated on Program status;
- Individuals with substantial discretionary authority and/or charged with implementing the Program have not engaged in illegal activities or other conduct inconsistent with an effective compliance program;
- Program requirements and ethical standards are periodically communicated to all employees through effective training and regular communication;
- Effective monitoring is implemented to detect misconduct, evaluate Program effectiveness, and provide a reporting system whereby employees can report misconduct without fear of retribution;
- Program standards are enforced through appropriate incentives and sanctions; and,
- Responses to misconduct are appropriate and that reasonable steps are taken to prevent further offenses to include modifying the Program to prevent and detect violations of the law.
The Compliance Policy applies to all USG institutions and the University System Office.
An institution-wide approach to compliance shall be adopted by all USG institutions. It is expected that compliance processes will be embedded into the institution’s management systems and processes. All compliance efforts will be focused on supporting the institution’s objectives. Therefore, each institution president or designee shall develop a campus compliance framework and associated procedures to:
- Identify and document applicable policies, procedures, laws and regulations;
- Establish job positions and/or oversight committees within the institution that have responsibility for ensuring compliance with each identified policy, procedure, law or regulation as applicable;
- Appoint one or more Compliance Officers where there are a substantial number of high risk policies, procedures, laws and regulations in a single area and in a manner as deemed appropriate for the specific institution (examples may include athletics, research, and human subject research);
- Communicate the policies, procedures, laws and regulations and their associated Compliance Officers or owners to institution staff as applicable and to the USG Office of Internal Audit and Compliance; and,
- Develop procedures where Compliance Officers and other individuals with responsibility for ensuring compliance: a. Conduct assessments of compliance requirements; b. Identify steps to implement these requirements; and, c. Report on the progress thereof.
There are multiple offices within the USG that have responsibility for compliance activities. The Chancellor shall designate a position responsible for coordinating the Program system wide.