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Compliance Program

82 bytes added, 18:17, February 2, 2018
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Policy No.: '''8000'''<br />
Effective Date: '''11/01/06'''<br />
Revised Date: '''0302/3102/1718 DRAFT'''<br />Reviewed Date: '''03/31/17'''<br />
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<big>'''Compliance Program Policy'''</big>
== Compliance Program Structure ==
===Associate Senior Vice Chancellor for ComplianceAcademic Affairs===The Associate Vice Chancellor for Compliance reports directly to the Senior Vice Chancellor for Academic Affairs and is responsible for overseeing the development and implementation of policies, procedures and practices necessary to effect compliance with federal, state, and local laws and regulations.
===Compliance Officer===
The Compliance Officer shall report to the Associate Senior Vice Chancellor of for Academic Affairs for Compliance, but has the authority to communicate directly with the Chancellor or Vice Chancellors for Academic Affairs, Business and Finance, Research, Deans or others on compliance matters , which include, but are not limited to:
*coordinate with subject matter experts to analyze laws and regulations applicable to UNMC to ensure compliance;
*monitor day-to-day compliance activities;
*oversee visits by regulatory agencies and responses to inquiries and investigations;
*report compliance matters directly to the UNMC Chancellor’s Council;
*coordinate with the Associate General Counsel for Health Care on legal issues;
*coordinate with the Director of Internal Audit;
*coordinate with the Information Security Officer;
The Compliance Committee shall meet no less than quarterly. The Compliance Committee shall be composed of at least the following representatives who shall be responsible for the overseeing compliance and assist the Compliance Officer with managing the Compliance Program:
*Compliance Officer
*Associate General Counsel for Health Care
*Export Control Compliance Officer
*Human Resources Director
The Compliance Office shall complete meeting minutes and maintain them on file for no less than seven years. The draft meeting minutes shall be distributed to committee members, vice chancellors, college deans and executive directors to inform UNMC leadership about compliance activities.
==Compliance Hotline==
A UNMC compliance hotline (1-844-384-9584 or www.nebraska.ethicspoint.com) has been established to provide individuals with an additional communication channel to report compliance concerns. The Compliance Officer shall investigate concerns and take corrective action in response to identified issues. For additional information, see UNMC Policy No. 8001, [[Compliance Hotline]].
==Compliance Training==
All University of Nebraska Medical Center employees, students (including visiting students), and faculty (including but not limited to courtesy, adjunct, volunteers) must be knowledgeable of and comply with laws and regulations related to their duties or field of study as determined by the Compliance Officer and Compliance Committee.
Mandatory compliance training is required of UNMC staff and students. All UNMC invited visitors on campus for seven (7) or greater days must complete all mandatory compliance training required of UNMC staff and students. It is the individual's responsibility to complete the compliance training requirements at http://www.unmc.edu/academicaffairs/compliance/training-requirements/index.html. Failure to complete the training requirements will be grounds for corrective action up to and including dismissal or termination of employment. Delinquency notices will be sent according to the guidelines below:
{| class="wikitable" style ="text-align:center"
| 30 Days || E-mail/verbal notice from unit management || E-mail/verbal notice from Dean’s office
| 60 Days || Communication from Human Resources || Letter from Senior Vice Chancellor for Academic Affairs; records placed on hold
| 90 Days || Notification to Dean, access removed from all UNMC resources except Blackboard until training has been completed ||

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