Compliance Program: Difference between revisions

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Policy No.: '''8000'''<br />
Policy No.: '''8000'''<br />
Effective Date: '''11/01/06'''<br />
Effective Date: '''11/01/06'''<br />
Revised Date: '''03/09/17'''<br />
Revised Date: '''03/09/17 DRAFT'''<br />
Reviewed Date: '''03/09/17'''<br />  
Reviewed Date: '''03/09/17'''<br />  
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<br />
<big>'''Compliance Program Policy'''</big>
<big>'''Compliance Program Policy'''</big>
== Basis for Policy ==
== Basis for Policy ==
The purpose of the Compliance Program and Committee is to identify UNMC’s compliance risks, as well as make recommendations and implement solutions, policies, procedures and standards of conduct to ensure that UNMC complies with all applicable federal, state and local laws and regulations. In support of this purpose, UNMC’s Compliance Program will designate a compliance officer and compliance committee whose responsibilities will include the following: to conduct effective training and education, develop effective lines of communication, and conduct internal monitoring and auditing for adherence to policies and procedures. The University of Nebraska Medical Center (UNMC) Compliance Program consistent with UNMC Policy No. 8006, [[Code of Conduct]] mandates that all UNMC faculty, staff, and students comply with: all applicable federal, state and local laws; all relevant regulations; and University of Nebraska and UNMC Policies and Procedures.
The purpose of the Compliance Program and Committee is to identify UNMC’s compliance risks, as well as make recommendations and implement solutions, policies, procedures and standards of conduct to ensure that UNMC complies with all applicable federal, state and local laws and regulations. In support of this purpose, UNMC’s Compliance Program will designate a compliance officer and compliance committee whose responsibilities will include the following: to conduct effective training and education, develop effective lines of communication, and conduct internal monitoring and auditing for adherence to policies and procedures. The University of Nebraska Medical Center (UNMC) Compliance Program consistent with UNMC Policy No. 8006, [[Code of Conduct]], mandates that all UNMC faculty, staff, and students comply with: all applicable federal, state and local laws; all relevant regulations; and University of Nebraska and UNMC Policies and Procedures.
== Compliance Program Structure ==
== Compliance Program Structure ==
[[File:Compliance-Flowchart3-10-17.jpg]]
[[File:Compliance-Flowchart3-10-17.jpg]]
===Associate Vice Chancellor for Compliance===
===Associate Vice Chancellor for Compliance===
The Associate Vice Chancellor for Compliance reports directly to the Vice Chancellor of 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.
The Associate Vice Chancellor for Compliance reports directly to the 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===
===Compliance Officer===
The Compliance Officer shall report to the Associate Vice Chancellor of 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:
The Compliance Officer shall report to the Associate Vice Chancellor of 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:
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| Research Integrity || UNMC Policy No. 8003, [[Research Integrity]]
| Research Integrity || UNMC Policy No. 8003, [[Research Integrity]]
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| Sponsored Programs Administration and Sponsored Programs Accounting || UNMC Policy No. 3001, [[Sponsored Programs]], UNMC Policy 6100, [[Direct Cost]], UNMC Policy 6101, [https://wiki.unmc.edu/index.php/Facilities_and_Administrative_Cost Facilities and Administrative, F&A) Cost], UNMC Policy 6102, [[Institutional Base Salary]], UNMC Policy 6103, [https://wiki.unmc.edu/index.php/Unallowable_Cost_Policy Unallowable Cost], UNMC Policy 6104, [[Sponsored Project Cost Share]], UNMC Policy 6105, [[Effort Certification]], UNMC Policy 6106, [[Cost Transfer]], UNMC Policy 6107, [[Service Center]] and UNMC Policy 6108, [[Subrecipient]]
| Sponsored Programs Administration and Sponsored Programs Accounting || UNMC Policy No. 3001, [[Sponsored Programs]], UNMC Policy 6100, [[Direct Cost]], UNMC Policy 6101, [https://wiki.unmc.edu/index.php/Facilities_and_Administrative_Cost Facilities and Administrative, F&A) Cost], UNMC Policy 6102, [[Institutional Base Salary]], UNMC Policy 6103, [https://wiki.unmc.edu/index.php/Unallowable_Cost_Policy Unallowable Cost], UNMC Policy 6104, [[Sponsored Project Cost Share]], UNMC Policy 6105, [[Effort Certification]], UNMC Policy 6106, [[Cost Transfer]], UNMC Policy 6107, [[Service Center]], UNMC Policy 6108, [[Subrecipient]]
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| '''Environmental and Safety Compliance'''||  
| '''Environmental and Safety Compliance'''||  
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| Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department] and UNMC Policy No. 2000, [[Safety]]
| Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department], UNMC Policy No. 2000, [[Safety]]
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| Radiation Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department]  
| Radiation Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department]  
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| Bloodborne Pathogens || [http://www.unmc.edu/academicaffairs/compliance/areas/infection.html Infection Control] and UNMC Policy No. 2004, [[Bloodborne Pathogens Exposure]]  
| Bloodborne Pathogens || [http://www.unmc.edu/academicaffairs/compliance/areas/infection.html Infection Control], UNMC Policy No. 2004, [[Bloodborne Pathogens Exposure]]  
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| Biosafety || [http://unmc.edu/ibc/ Institutional Biosafety Committee], UNMC Policy No. 2005, [[Waste Handling]] and [http://info.unmc.edu/safety/safety-office/biohazardous-waste/2005-waste-handling-attachments-2014.pdf Biohazardous Waste Handling]
| Biosafety || [http://unmc.edu/ibc/ Institutional Biosafety Committee], UNMC Policy No. 2005, [[Waste Handling]], [http://info.unmc.edu/safety/safety-office/biohazardous-waste/2005-waste-handling-attachments-2014.pdf Biohazardous Waste Handling]
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| Chemical Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department] and UNMC Policy No. 2002, [https://wiki.unmc.edu/index.php/Shipping_Hazardous_Materials Shipment of Hazardous Materials or Dangerous Goods]
| Chemical Safety || [http://www.unmc.edu/ehs/ UNMC Environmental Health & Safety Department], UNMC Policy No. 2002, [https://wiki.unmc.edu/index.php/Shipping_Hazardous_Materials Shipment of Hazardous Materials or Dangerous Goods]


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| Internal Audit || UNMC Policy No. 8016, [[Internal Audit]]
| Internal Audit || UNMC Policy No. 8016, [[Internal Audit]]
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| Student Services || [http://www.unmc.edu/studentservices/ Student Services], [https://www.unmc.edu/studentservices/_documents/Handbook.pdf Student Handbook] [https://www.unmc.edu/studentservices/_documents/Handbook.pdf Compliance Matrix], [http://www.unmc.edu/studentservices/ FERPA Information]
| Student Services || [http://www.unmc.edu/studentservices/ Student Services], [https://www.unmc.edu/studentservices/_documents/Handbook.pdf Student Handbook] [https://www.unmc.edu/academicaffairs/compliance/matrix.html Compliance Matrix], [http://www.unmc.edu/studentservices/ FERPA Information]
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| Title IX || UNMC Policy No. 1099, [[Non-Discrimination and Harassment]] and UNMC Policy No. 1107, [[Sexual Misconduct]]
| Title IX || UNMC Policy No. 1099, [[Non-Discrimination and Harassment]], UNMC Policy No. 1107, [[Sexual Misconduct]]
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| Family Educational Rights and Privacy Act (FERPA) ||  [http://www.unmc.edu/studentservices/ Student Services], [http://www.unmc.edu/studentservices/ FERPA Information]
| Family Educational Rights and Privacy Act (FERPA) ||  [http://www.unmc.edu/studentservices/ Student Services], [http://www.unmc.edu/studentservices/ FERPA Information]