16.5.4 Implementation

(Last Modified on January 16, 2025)

An institution-wide approach to compliance shall be adopted by all USG institutions. Compliance processes must be embedded into the institution’s management systems and processes. Each institution President or designee shall develop a campus compliance framework and associated procedures to:

1. Identify and document key regulatory and compliance areas;
2. Assess compliance risks to determine appropriate management action(s);
3. Identify management infrastructure and/or oversight committees within the institution that have responsibility for ensuring compliance with identified regulatory and compliance areas, as applicable, (examples may include athletics, research (including human subject research), finance and administration, and programs serving non-student minors);
4. Develop risk and mitigation strategies and steps to implement them;
5. Provide initial and ongoing compliance and education training. Institutions must coordinate with CHRO to ensure compliance with BOR policy 8.2.5 Employee Orientation and Training.;
6. Provide for systematic assessments to evaluate and audit compliance and report on progress;
7. Communicate compliance ownership and significant or revised regulations to oversight committees, management and stakeholders.