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COMPLIANCE AND ETHICS TRAINING IN HIGHER
EDUCATION
Kimberly Fearney, CCEPVirginia Pack, APRN, CCEP, CCP
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Objectives
• Discuss the unique culture of an academic environment and its impact upon training.
• Share our history and experiences. • Review examples of program elements that
have been successful and those that have not.• Provide practical tips in developing or refining
a compliance education program.• Hear your stories and ideas.
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Training in Higher Education – Why is it Different?
• Unique culture in academia• Tenured Faculty
– Independent– Academic Freedom– College/University Profit Center
• Making faculty understand that compliance is important to them and can impact their teaching/research/service.– Connect them into the fabric of the organization.
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University of Connecticut
• 14 schools and colleges, five regional campuses and Health Center.
• Research awards in 2008 exceeded $194 million.
• $2.8 billion, 20-year infrastructure investment from the state.
• Approx. 21,000 undergraduate students; 8,000 graduate students.
• Approx. 10,000 union and non-union employees.
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THE STORRS STORY
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2005
• The University settled allegations with the EPA Office of Inspector General (OIG) by signing a five year CIA.
• $2.5 million fine.• By July 1, 2006, certify “adequate and
appropriate compliance program.”• BOT hired first Chief Audit and Compliance
Officer– Reorganized Internal Audit department into Office of
Audit, Compliance & Ethics– Oversight of ALL campuses
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Ethics• June 2004 – CT Governor John Rowland resigns
– allegations of accepting expensive gifts from employees and contractors.
• July 2004 – Lt. Governor Jodi Rell takes office– Executive Order No. 1 – “committed to restoring
public trust”.– Established Special Counsel for Ethics Compliance
• 2005 – dismantled former State Ethics Commission– Internal fighting among staff and firing of Director– Established new Office of State Ethics and Citizen’s
Ethics Advisory Board
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THE HEALTH CENTER CHRONICLE
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University of Connecticut Health Center (UCHC)
• John Dempsey Hospital (JDH) –224 beds.• Schools of Medicine/Dental Medicine and
postgraduate residency programs.• University Medical Group.• UConn Health Partners.• University Dentists.• Correctional Managed Healthcare.• Clinical and translational research.
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UCHC Compliance History
• Mid-1990’s-Existing Internal Auditor assigned additional role of Compliance Officer.
• 2000-EVP of Health Affairs recognized importance of individual Audit and Compliance functions.– Compliance Officer named.– Training initiated with focus upon academic medical centers and
clinical compliance.
• 2005-Program expanded and “domains” were born.• 2007-Certification of Compliance Agreement (CCA) signed
between JDH and Department of Health and Human Services OIG.– Existing Compliance Program reduced penalty.
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THE COMPLIANCE TRAINING
EXPERIENCE
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….In the Beginning
• 2006 - Code of Conduct, University Guide to the State Code of Ethics and Federal False Claims Act (UCHC)
• One module for both faculty and staff• “Roll out” plan
– Dean’s Council/Faculty Councils/Senior Management– Executive Compliance Committees– Presented training to the unions
• Online and Classroom Sessions • General and Individual Department sessions
– Anytime, anywhere, any place– Spanish translation & Sign Language Interpreter sessions
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What We Learned the First Year…• Support from senior management essential.
– Invite President/Provost/Deans/VPs to make opening remarks.
• Differences between faculty/staff and campuses. – Tailor sessions for specific audience
• Individual department sessions not efficient use of resources.– Refined classroom sessions
• Make the training relevant.• Critical to reinforce the role of Compliance.
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Online Training
• Key component, but should not be your only method.
• “Home-grown” system vs. outside system.– Benefits vs. weaknesses
• Include a post test in your online system.• Consider your environment.
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Regional Campuses and Programs
• Feel like the “step-children” of the University.• Classroom sessions are important to create a
connection.– Video conferencing
• Individual culture – including specific examples that are relative to their environment.
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The Art of Nagging
• Accurate attendance tracking system is key.• Frequent attendance reports to Deans,
Directors and Department Heads.– unions
• Reminder emails and mailings.• Phone calls.• Embarrassment/Fear Factor.
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Sanctions
• Storrs developed formal Compliance Training Policy in 2008.– Input from senior managers and unions.– Approved by Executive Compliance Committee– Requires annual compliance training.– Attestation.– Sanctions.
• Due to CIA, any mandatory employees who do not complete specific grant management training will have their grant monies withheld until compliant.
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PRACTICAL TIPS
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Bodies in the Seats vs. Making an Impact
• “Converts”– How you build a “culture of a compliance”
• Employees in the trenches want to comply with the rules.– Know how the system works and when there may be
a problem.• Using “hot topics” and frequently asked
questions from previous year to create next year’s training.
• Support from your Joint Audit & Compliance Committee.
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It’s all in the Approach
• Legal/regulatory with Faculty.• Include the “Who” and the “Why”.• Real life examples of consequences of
non-compliance.• Subject matter expertise is a plus!• “We’re here to help”.• Set standards of behavior upfront in classroom
setting.
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Knowing the Culture
• Ongoing support from your Joint Audit & Compliance Committee.
• Using your allies.• Knowing the organizational structure.• Recognize your audience.• Picking your battles.
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Collaboration
• Other departments may also require mandatory training.– Creates confusion/frustration for faculty and staff
• Work with these departments to ensure clarification.– Online system– Master Calendar– Use your training to assist with overall compliance.
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What They Don’t Tell You
• Never EVER show fear!• If you don’t know the answer, admit it up front.• “Messenger” approach.• Develop a thick skin.• Patience & Humility.• Be ready to respond to questions about every
public figure in your school and state.
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Building Trust
• “Face” of the Compliance Program.– New Employee Orientation
• Employees will not report to the Compliance Program if they don’t trust YOU.– What people tell you during/after sessions.– Coming from the ranks helpful.
• We ALL want our university to succeed.
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Think Outside the Lecture Hall….
• Newsletters• Websites• Broadcast messages• Posters• Committee membership• “Lunch and Learn”• Collaborating with professional development
programs
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The Numbers• 2006-2007
– Storrs – 95% Completion (67% live, 33% online)» 85 Live Sessions
– UCHC – 95% Completion» 49 Live Sessions
– JDH – 100% Completion
• 2007-2008– Storrs – 98% Completion (58% live, 42% online)
» 67 Live Sessions
– UCHC –» 44 Live Sessions
– JDH -
• 2008-2009
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Takeaways
• One-size-fits-all does not work in an academic environment.
• Buy-in from Faculty important.• Support from BOT & senior management.• Use the experts available to you to help create
your training.• Don’t be afraid to make mistakes.• Persistence.
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QUESTIONS?