aligning compliance to the academic mission · 2016-05-26 · scce higher education compliance...

SCCE Higher Education Compliance Conference June 5‐8, 2016

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TH E OH IO S TAT E UN I V ER S I T Y

O F F I C E OF UN I V ER S I T Y COMPL I ANC E AND I N T EGR I T Y

GAT E S GARR I T Y ‐ROKOUS

Aligning Compliance to the Academic Mission

Leveraging Strengths, Increasing Credibility, and Building Confidence

Higher Education Compliance ConferenceJune 6, 2016

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Picture of Trans am for sale


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Session Objectives

• Why focus on the Academic Mission?

• What common framework underlies the mission of colleges and universities?

• How can we best support that framework?

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IdeaConceived

ResearchStarts

Etc.Animal WelfareHuman Subjects

Office of Sponsored Programs

Trade ControlsLab Safety/

EHS

What University Stakeholders Expect:Efficient resolution of all regulatory requirements

Perception of bureaucracy and inefficiency

Example: Requirements to conduct research


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What Regulators Expect:Full compliance

100% compliance expectedTo establish medical necessity

W22.02XD“Walked into Lamppost; Second Encounter”

V91.07XA“Burn due to water skis on fire; initial encounter”

V95.42XA“Spacecraft crash

injuring occupant; initial encounter”

Example: ICD‐10 Codes for Medical Billing

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“Compliance”Efficiency Regulatory Requirements

Regulators

Students,Faculty and Staff

The Compliance ChallengeReconciling conflicting stakeholder demands

Board of TrusteesUniversity Leadership

The Public

Unfunded mandates; competing expectations of efficiency with “no misses”


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Maintain “Halo Effect” with regulators• Regulators still treat Higher Education

differently because of “desirable trait” of a non‐profit, aspirational purpose

• Defining, and reinforcing, the academic mission reinforces that desirable trait

References: • L.G. Standing, The SAGE Encyclopedia of Social Science Research Methods, Volume 1, 2004• L.M. Goirdon and S. Graham, “Attribution Theory,” The Encyclopedia of Human Development, 142‐44 (2006)

Why align Compliance to the Academic Mission?

Increase stakeholder ownership• Effective decision‐making, if properly structured, moves

individuals to a stronger sense of control• The more compliance decision‐making resembles the

learning enterprise, the more likely stakeholders will attribute compliance decisions as their own

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AcademicMission

Orienting to the Academic Mission

“Compliance”Efficiency Regulatory Requirements

Regulators

Students,Faculty and Staff

Board of TrusteesUniversity Leadership

The Public


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The Foundation of the Academic Mission:A Learning Disposition

Adopted from: Noah Rachlin, Tang Institute, Phillips Andover Academy, Andover MA 2015. Available at: http://tanginstitute.andover.edu/projects/learning‐dispositions/

DeliberatePractice

Habit Formation

GrowthMindset

IntrinsicMotivation

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“Intrinsic motivation drives me to do things just for the fun of it, or because I believe it is a good or right thing to do”

Core elements of intrinsic motivation• Values: drivers for decision‐making• Grit: perseverance and passion to pursue values

Dangers of extrinsic motivation• Extrinsic motivation: external reward or acknowledgement

(e.g., USNWR ratings)• “Intrinsic motivation is far stronger a motivator than

extrinisic motivation, yet external motivation can easily act to displace intrinsic motivation.”

Intrinsic Motivation:Start with values, show grit

References: • R.M. Ryan and E. L. Deci, "Self‐determination Theory and the Facilitation of Intrinsic motivation, Social Development,

and Well‐being," American Psychologist 55 (2000).• Angela Lee Duckworth, Grit: The Power of Passion and Perseverance (2016). See also her TED Talk at

https://www.ted.com/speakers/angela_lee_duckworth


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Fixed Mindset Vs. Growth Mindset

Avoids Challenges Embraces

Gives up easily Obstacles Persists through obstacles

Considers it largely fruitless

EffortConsiders it path to

mastery

Ignores negative feedback

Criticism Learns from criticism

Feels threatened by others’ success

Success of others

Takes lessons from others’ success

Less than full potential RESULTSHigher levels of achievement

Reference: • Carol Dweck, Mindset: The New Psychology of Success (2006). See also her TED Talk at

https://www.ted.com/talks/carol_dweck_the_power_of_believing_that_you_can_improve?language=en

Growth MindsetCompliance failures are opportunities for improvement

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References: • Charles Duhigg, The Power of Habit: Why We Do What We Do in Life and Business (2012). • Paul Jun, “Why Self‐Awareness Is the Secret Weapon for Habit Change,” 99U.com (2015)

Habit FormationEvolve good decisions into automatic behaviors

Habit• A pattern of thought or behavior that becomes automatic• Automaticity is the logical result of learning something well

Breaking a Habit• A habit cannot be “broken” – it must be replaced• Deny it the reinforcement that encourages the behavior• Replace it with a new habit: start small, and repeat

Keystone Habit• “A pattern that has the power to start a chain reaction as it

moves through an organization”• Focus on the habit that, if created, affects the most behavior


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Well‐defined, Specific Goals• Identify the weakness, and develop measurable,

achievable goal to fix it

Focused Practice• Improve what’s weak, not what’s strong

Targeted, Useful Feedback• Be capable of measuring improvement

Not Playing Safe (get out of comfort zone)• If it’s easy, it’s probably not useful

Deliberate PracticeFocus on making the changes that matter

Reference: • Anders Ericsson & Robert Pool, Not All Practice Makes Perfect, Nautilus Magazine April 2016

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Orienting to Support the Academic Mission: Developing a Functional “Learning Disposition

DeliberatePractice

Habit Formation

GrowthMindset

IntrinsicMotivation

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Self and Team (I)Committing to the Academic Mission

Intrinsic MotivationOutlook

• Starts with values• Service orientation: gratitude and curiosity

Roles• Student: listen first, speak second• Teacher:

• Take the “student” as one finds her• Second chances

Modeling • Be the change we want to see

Grit• Strategic plan, annual plan…• Change takes time: track results

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Self and Team (II)Committing to the Academic Mission

Growth MindsetCrisis = opportunity (esp. high risks, investigations)Risk acceptance (informing decision‐making)

Habit FormationRigor (veracity, consistent behavior, tools)Simplify and build processesKey controls

Deliberate PracticeSeeking and giving feedback Orienting to the highest risk

• No scorecard is all green• Regular, dependable• Positive reinforcement works

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LeadershipEngagement

Planning

Regulatory inventory

Risk Assessment

Risk Assessment & Abatement

Testing Monitoring

Evaluation

Policies Training

Communication

Governance Reporting

Testing, Monitoring & Audit Results

Investigations & Regulatory Contacts

Issue Response & Reporting

Laws & Regulations Values

A Standard Compliance Model

Operational controls

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LeadershipEngagement

Planning

Regulatory inventory

Risk Assessment

Risk Assessment & Abatement

Testing Monitoring

4. Evaluation

Policies Training

2. Communication

Governance Reporting

Testing, Monitoring & Audit Results

Investigations & Regulatory Contacts

Issue Response & Reporting

Laws & Regulations Values

GrowthMindset

3. Operational controls

DeliberatePractice

Habit Formation

IntrinsicMotivation

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A Standard Compliance Model: Applied


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• Educational value

• Seized opportunity

• Ongoing extension

• Area of greater challenge

Athletics Example:Leveraging compliance issue

To extend learning

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Original Assessment (2013)

Current State

Complex regulatory scheme

Multiple disclosures for some employees

Inconsistent review

Simplified process saved est. 60,000 hours Implemented in phases to obtain efficiencies first

3 state laws3 federal laws

10 University policies

5 disclosure processes

Virtually all Faculty & Staff impacted

Multiple reviews

Summary

Conflict of Interest Example

• 4 year project

• Simplification and rigor

• Targeted responsiveness

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Lab Inspection Reporting

• All EHS regulatory areas across all laboratories, all colleges

• ~800 Principal Investigators w/over 3,200 lab spaces

• Review safety training, SOPs, hazard assessments, engineering controls, safety related items

Environmental Health and Safety Example

• When deficiencies noted, PI given 15 days to respond

• Report reflects only categories that are not yet resolved and present safety or compliance risk

• Scorecard compares PIs anddepartments for college

Department/College Scorecards

• Regular report drives ongoing improvement

• Focused on PIs of greatest challenge

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Student‐Athlete Academics Example

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Purpose Ensure effectiveness of institutional controls over academic issues related to student‐athletes and athletics

Reviewed 11 issues identified by investigation at UNC

Identified 21 additional risk areas derived from other NCAA cases and OSU environment

Review domains Potential issue Threshold or measurement Operational oversight Control oversight Governance and reporting Further notification if needed

Process Cross‐functional team identified standards, key controls, and data on all 32 issues

Ensured role clarity and definition of key controls

Identified risks (e.g., student‐athlete academic misconduct) that can be mitigated not eliminated

• Self‐initiated, values‐based

• Seized opportunity of UNC

• Formalized process

• Identified focus areas for review/improvement

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HIPAA Hybrid Entity Example

Hybrid Entity(covered and non‐covered activities)

Covered Components

Business Associate‐Like Units (BAUs)

(units performing services for Covered Components)

Research

Business Associates(third party vendors performing services)

• Long‐term project

Framework & process• Defined risk acceptance

on top priorities

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Questions?

aligning compliance to the academic mission · 2016-05-26 · scce higher education compliance...

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