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The Board of Governors Compliance Committee

Derry Harper and Lori ClarkNovember 3-4, 2010, Audit and Compliance Committee Meetingwww.flbog.edu

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Our Philosophy

“…the Board of Governors has reserved overall

fiduciary responsibility for management of the

university system. Part of that responsibility is to be

able to demonstrate accountability. The organization

needs to be able to demonstrate by empirical and

objective evidence that it is achieving that goal.” –Chancellor Frank Brogan, January 28, 2010, Audit and Compliance

Committee meeting

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Board Of Governors Compliance Committee

GENERAL COUNSEL

CORP SECY

INFO RESOURCE MANAGEME

NT

CHIEF FINANCIAL OFFICER

CHIEF of

STAFF

HUMAN RESOURC

ES

FACILITIES

Audit and Compliance Committee

Board Compliance Committee

ACADEMIC & STUDENT

AFFAIRS

Board of Governors

Inspector General, Chair

Chancellor

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Compliance Program Elements

• Risk Assessment

• Responsible Parties and Roles

• Standards and Procedures

• Program Oversight

• Awareness, Education and Training

• Lines of Communication

• Monitoring and Auditing

• Enforcement

• Corrective Action

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Our Philosophy

Step 1: Establish Compliance Program

Identify Project Owner or ChampionEstablish a Steering Committee

Step 2: Identify Key Objectives

List Key ObjectivesPrioritize Key Objectives

Step 3: Identify Key Compliance Risk Areas

Brainstorm and assess high risk areasAssign high risk areas to process owner

Step 4: Establish Systematic Compliance

ProgramDevelop Compliance MatrixTrainingMonitoringIdentify areas of non-complianceCorrective Action Plan Process

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Board Compliance Plan - Phase 1• Review all Board Regulations to identify Board

responsibilities (ref. RCR Project)

• Tool(s): RCR Database

• Projected End Date: November 2010

• OIGC review of staff analyses of Board Regulations

• Tool(s): RCR Database

• Projected End Date: December 2010

• Verify compliance

• Tool(s): RCR Database

• Projected End Date: December 2010

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Analyst Maturity Rating Scale

RED – the regulation has inconsistencies or outdated

information that must be corrected immediately.

Yellow – Clarifications or improvements need to be made

fairly soon.

Green – There are tasks to be done by either university or Board staff,

and procedures are in place and working; no changes are needed.

Blue – The regulation is informational only, and there are

no tasks to be done.

OIGC Review:

• Approved

• Rejected

• For Review

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OIGC Maturity Rating & Analysis

•Generally Adequate - Controls are in place and functioning as designed. Opportunities may exist for improvement or significant improvement applicable to sub-objective controls.

•Needs Improvement – There are designed controls but not always effective and/or other controls are needed.

•Needs Significant Improvement – Some controls may exist, but they are not effective in achieving the primary objective within the scope of the audit.

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Board Compliance Plan - Phase 2

• Review all Board Regulations to identify SUS responsibilities

• Tool(s): RCR Database

• Projected End Date: March 2011

•Validate and verify university compliance

• Tool(s): RCR Database

• Projected End Date: June 2011

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Board Compliance Plan - Phase 3

• Identify statutory requirements (ex. S. 20.055, F.S., and S. 381.79, F.S.) for Board Office

• Tool(s): RCR Database

• Projected End Date: March 2011

• Verify Board compliance

• Tool(s): RCR Database/Data Request System

• Projected End Date: June 2011

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WHAT’S NEXT?

• Establish an SUS Compliance Program

•Adopt a Board Of Governors and SUS Code of Ethics/Conduct ?

• Establish an Enterprise Risk Management System?