1. 1 Welcome to UTPA’s Institutional Compliance Program

2. 2 Today we will talk about… What compliance means Why compliance programs exist Points that President made And most important Answer any questions that come up as we go along

3. 3 What does Compliance Mean? Dictionary defines compliance as: an act or process of complying with a demand or recommendation observance of official requirements What does it mean for all of us? “Doing the Right Thing” Reference: compliance. (n.d.). Merriam-Webster's Medical Dictionary. Retrieved August 27, 2007, from Dictionary.com website: http://dictionary.reference.com/browse/compliance

4. 4 Why Compliance Programs Exist State and Federal Statutes 1. United States Sentencing Guidelines 2. Whistleblower Act 3. Sarbanes Oxley UT System – Various experiences at other campuses UTPA – ELI money taken, NCAA probation approx 10 – 15 years ago

5. 5 Points President Made Story of misuse of agency funds Key points in the story: – Assume responsibility – Explore and verify facts before acting – Be persistent Ultimately succeeded with help of boss and investigative resources at his disposal Ultimately succeeded with help of boss and investigative resources at his disposal The agency was never sidetracked from its mission

6. 6 Points President Made UTPA is a precious asset to this region We have the responsibility to recognize and address compliance questions - These questions will always come up for the simple reason that we all make mistakes Bottom line – If we fix mistakes quickly and effectively, UTPA will never be sidetracked from its mission because of them

7. 7 President’s Request Learn about the spirit of our compliance program It is designed to be used as a problem solving tool, not a policing mechanism. It becomes a policing mechanism if we fail to use it correctly.

8. 8 Mission of Program To fulfill our responsibilities to the people of Texas in an environment based on ethical behavior and compliance to laws and rules. (HOP 2.4.1A) The gist of it sounds simple, but it’s a culture change

9. 9 How Our Program is Different Mr. Langabeer’s reaction- its everyone’s job – Rejected idea that “you work, we make sure you comply” What UTPA employees taught us – We raise compliance questions (don’t “report suspected non-compliance”) The Spirit of the Compliance Function – To explore and evaluate questions raised with the aim of improving the overall level of compliance at the University

10. 10 Difficult compliance questions are not common, but are important to understand – Happen when management is inattentive to compliance questions raised – or override the efforts of those trying to address them These are the issues that do the most harm to University The result - UTPA has a clear statement of policy for employees to persist in raising questions until resolved

11. 11 Options to raise compliance Questions Supervisor or higher level manager in chain of command Supervisor or higher level manager in chain of command Institutional Compliance Officer Institutional Compliance Officer Anonymous Compliance Hotline Anonymous Compliance Hotline Compliance Program Compliance Program Wilson Ballard, Compliance Director, 381-2652 Wilson Ballard, Compliance Director, 381-2652 Katrina Luna, Compliance Specialist, 381-2653 Katrina Luna, Compliance Specialist, 381-2653 If 1st option fails, pursue one of the other options Employees can choose method they feel comfortable with

12. 12 Hotline - how it works Third party company Third party company Available 24/7 Available 24/7 Trained interviewers – English or Spanish Trained interviewers – English or Spanish Callers remain anonymous at their choice Callers remain anonymous at their choice Company emails report of call to the Compliance Program Company emails report of call to the Compliance Program Anonymous caller calls the company back to receive answers Anonymous caller calls the company back to receive answers

13. 13 Responsibilities of Employees Learn compliance requirements of our jobs Learn compliance requirements of our jobs Obey the requirements Obey the requirements Raise compliance questions we become aware of Raise compliance questions we become aware of Cooperate in evaluation of questions raised Cooperate in evaluation of questions raised The program asks employees to trust the process to the extent that it overcomes any desire to avoid making waves.

14. 14 Supervisor Responsibilities Create a positive atmosphere – – Encourage employees to raise questions – – Address compliance issues raised – – Manage compliance risks Any form of retaliation against employees who raise questions is prohibited The program asks supervisors to desire compliance more than they desire personal control over situations that come up.

15. 15 Statistics for FY08 103 questions were raised 81 had compliance issues 27 were anonymous Questions are being resolved informally in departments More questions are raised earlier

16. 16 Examples of Questions Alcohol served at art exhibit Alcohol served at art exhibit Timely employee evaluation Timely employee evaluation Solicitation - political, commercial, etc. Solicitation - political, commercial, etc. Use of University equipment Use of University equipment Time worked vs. time reported Time worked vs. time reported Copyrights Copyrights Appropriateness of expenditures Appropriateness of expenditures

17. 17 Exploring Compliance Questions (HOP 2.4.1 G) Some questions are referred to more appropriate offices Some questions are referred to more appropriate offices – Dean of Students – EO/AA/ADA Coordinator – University Police – A faculty governance process

18. 18 Additional Compliance Training Online training module Online training module – Provides an overview of the compliance program with detailed information on the Standards of Conduct Guide Employee will receive notice via email Employee will receive notice via email Employees must complete within 30 days from date of notice is received Employees must complete within 30 days from date of notice is received Review every two years Review every two years

19. 19 Proper Use of the Program Program is here to promote compliance Program is here to promote compliance State laws protect us from retaliation when we use the program in good faith State laws protect us from retaliation when we use the program in good faith We assume good faith We assume good faith Employees have shown good faith Employees have shown good faith All of this is essential to the program’s success All of this is essential to the program’s success

20. 20 Where we’re located… Our program is located on the corner of 5 th and Van Week-NE corner of campus by railroad tracks Our program is located on the corner of 5 th and Van Week-NE corner of campus by railroad tracks Wilson Ballard - 956-381-2652 Wilson Ballard - 956-381-2652 Katrina Luna - 956-381-2653 Katrina Luna - 956-381-2653 Our website is: Our website is: UTPA Institutional Compliance Office UTPA Institutional Compliance Office

21. 21 In closing….. Welcome to UTPA Welcome to UTPA We hope you never need to call us….but if you do, we hope you will remember us We hope you never need to call us….but if you do, we hope you will remember us We don’t want you stuck in a situation We don’t want you stuck in a situation We don’t want the University stuck in it either We don’t want the University stuck in it either We’ll do our best in exploring your question We’ll do our best in exploring your question

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