1. Compliance Program Model
Academic and Student Affairs
August 2015

2. Research Models and Resources Higher Education Compliance Organization
SUNY
Federal Sentencing Guidelines (FSG)
Compliance Officers (GCC, GWCC, Rio)
No “one size fits all” model

3. Maricopa Considerations
Current Compliance Assets
Sources of Compliance
Large, complex system
Shifting Organizational culture
Independently accredited
ONE Maricopa

4. Regulatory Compliance
Training or Communication
Policy, Procedure and Business Process
Reporting, Disclosures and Monitoring
Federal Laws and Regulations
State Laws and Regulations
Case Law
Accreditation Standards
Institutional Policies and Procedure

5. Areas of Focus Program Integrity Rules
Higher Education Opportunity Act (HEOA)
Title IV - Financial Aid
FERPA/Admissions/Student Records
Title IX/VAWA
ADA/504
Veterans Affairs
HLC – DOE compliance Packet

6. Maricopa Model Committee/Matrix Structure
Central leadership, oversight and communication
Leverage Subject Matter Expertise
Collaborative
Representatives from all colleges
Many councils
Ad-hoc team members

7. Strategy and Compliance
Vice President Strategy and Compliance
Leads Academic and Student Affairs in monitoring on- going and new institutional compliance issues within defined regulatory areas.
Fosters a culture of shared responsibility and collaboration to develop and document a common interpretation of regulatory requirements.
Collaborates with key stakeholders (College/District) to facilitate the consistent implementation of regulatory mandates.
Assist with the documentation, monitoring, and reporting of compliance related activities.

8. ASA Compliance Core Team
Provide oversight and guidance for work-teams
Recommend approval for strategic items
Approval for operational items
Communication
Monitoring
Meets every 4-6 weeks initially
12-16 member team (College and District)
Each team member will lead a “Compliance Work-Team”
Ad-Hoc members added as needed

9. ASA Core Team Members Kishia Brock – DO -Chair Donna Silber – DO/IR
Andrea Banks – DO/Veterans
Donna Young – SCC/Deans/Title IX
Bill Clites – MCC/Veterans
Lanna Deuck – Rio/Program Integrity
Alka Arora Singh - GCC/HLC DOE
Ken Clarke – DO FA
Mary Blackwell – GCC/HEOA
Brenda Starck – PC/DARS
Char Hunting – GWCC/Program Integrity
Gene Heppard – PC/ADA & 504
Damita Kaloostian –SMCC/IR
Rosanna Short – EMCC/FA
Veronica Garcia – PV/VPSA
Bill Guerro – CGCC/VPAA
Salind Bednarek – DO/Faculty Leadership
Miguel Hernandez – DO/Technology Security
Chief Longman – Public Safety
Patti Cardenas-Adame – EMCC/VPSA
Amy Chueng – DO/Training
Robert Bienkowski – Do Administrative Support

10. Focus Area Work-Teams Monitoring regulatory compliance
Research/Recommend a ONE Maricopa Interpretation of regulatory requirements
Assessment of Requirements and Resource Implications
Risk Assurance Activities
Recommend Consistent Implementation Strategy
College Responsibilities
District Responsibilities
4-6 member team
Chaired or co-chaired by members of the ASA Compliance Steering Team
Subject Matter Experts (SMES) at District or the Colleges
Meet as frequently as required (could be weekly)
Communicate to core team

11. Compliance II Decision Documents
Interpretation and Implementation Decision Documents
Team name and members (to include Ad-Hoc members consulted on particular topic)
Regulation
Research and Resources related to the topic
Implications of non-compliance
Timeline for compliance
Proposed/Approved ONE Maricopa interpretation
Proposed/Approved college affirmation tasks
Proposed/Approved District Office affirmation tasks
Impact (cost/resource requirements – estimate)
Scope (large – minimal)

12. Communication Core team VP Compliance College compliance teams Council
Work Teams
VP Compliance
Executive Vice Chancellor and CEC
Maricopa Community – Maricopan
Councils

13. Detractors/Benefits Demand on Human Capital
Shift in approach to compliance
Differentiation between business, operational, strategic mandates
Shift from reactive to proactive
Improved collaboration
Improved communication
Leveraging internal talent
Elevate cost of compliance
Structure and documentation

14. Compliance Accomplishments
ASA Compliance Program Structure
Title IX/VAWA – Student Training module - 9/4
Title IX/VAWA Employee Training
Title IX/VAWA Investigators Training
Title IV/VAWA Policy
Student Discrimination Procedure Updated – OCR Resolution
Technology Accessibility Policy Updated – NFB Settlement Agreement
Opinion – Closed Caption requirements – Proactive
Opinion – Job Placement Rates/Reporting
Gainful Employment Reporting – first 5 years
EMCC Program Review
PC Program Review
Program Review Finding – Exit Counseling - Corrective Action
Title IX website 9/4

15. Current Compliance Projects
Gainful Employment Reporting
Most current year reporting – October 1, and beyond
Response to Single Audit
ECAR tutorial
NSLDS Reporting Improvements
Title IX/VAWA – Awareness Campaigns
Bystander
Domestic Violence Prevention
Title IX/VAWA – Campus Security Administrator (CSA) training
Title IX/VAWA – Ongoing Training Module
NFB

16. Initial Work-Team Projects
FERPA/Admissions/Records
FERPA Training – new regulations
Directory Information
Record Retention Policy
NSLDS
Business Process - GE
Date graduation before program stack date
Stack added/graduated same day

17. Next Steps Compliance Core Team 9/14: Kick-off
Continue communication to stakeholder groups
Core Team
begin to identify/form work teams
Identify initial scope of work
Projects - assigned
Finalize SharePoint Site
Finalize II Decision Documents
Updates – Maricopan

18. Questions?