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University’s Statement of Ethical Principles

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Regulatory Compliance Help and Referral Line

Centralized University Policies

Compliance Program Frequently Asked Questions

Reporting issues of Non-compliance

Regulatory Compliance Help and Referral Line Brochure

Compliance Awareness Guide

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Compliance Program Frequently Asked Questions

 

What is a Compliance Program?

A Compliance Program is an enterprise-wide program to coordinate, manage and monitor internal and external risks associated with regulatory compliance. It builds on the existing university structures and improves the coordination, dissemination and communication of compliance information and identifies gaps in compliance. The program empowers employees to report instances of noncompliance using the Regulatory Compliance Help and Referral Line.

The program changes our compliance paradigm from detect/correct to anticipate/ prevent.

Why is a Compliance Program Needed?

The foremost goal of the University’s Compliance Program is to maintain our reputation for integrity and high standards in the educational and business community. In today’s world of increasing government rules and regulations involving research, tax, information security, human resources, safety, and environmental issues, it would be easy to violate a law or regulation and tarnish our reputation. The compliance program helps protect the university from regulatory errors, omissions and failures by improving communication and information. Noncompliance, at other major universities, has resulted in millions of dollars in settlements of government lawsuits and tarnished reputations.

If an inadvertent violation does occur, the Compliance Program is also needed to protect the university from severe criminal and civil penalties. Courts and prosecutors must make their choice of prosecution, settlement and the size of fines based on the Federal Sentencing Guidelines. While we expect and hope never to face a government civil or criminal suit, the existence of a formal voluntary Compliance Program shows the government that the university has taken its compliance responsibility seriously and has communicated this to the campus. The existence of a formal Compliance Program allows the courts to reduce the fines and penalties under the Federal Sentencing Guidelines.

What are the benefits of a Compliance Program?

The benefits of a compliance program are improved information and communications as well as better monitoring of compliance risks. The program provides the campus with better communications of regulatory compliance issues as well as improved monitoring of regulatory issues. The centralization of all university policies improves the access, reliability and communications of those policies. The Regulatory Compliance Help and Referral Line provides employees with an opportunity to communicate their concerns while staying anonymous. In addition, the existence of a program reduces the monetary risk associated with noncompliance.

What are compliance issues?

Compliance issues relate to situations, activities and transactions that could potentially violate federal, state, or District laws and regulations, or violate GW’s policies and procedures. Examples include violations of regulations associated with research, taxation, fraudulent financial activities, political activity, conflict of interest, sexual harassment, discrimination, information security, health/safety, environmental, fraud, NCAA, financial reporting and controls, etc. This is not meant to be a complete list but rather examples of compliance issues.

How do I know if there is a Compliance issue?

It would be impossible to publish a listing of every possible compliance item, but ask yourself the following questions. If the answer is NO, then there is probably a compliance issue:

Are the actions legal?
Do these actions seem fair and honest?
Is an approved university policy being followed?

If I think there is a compliance issue, what should I do first?

Your first step should be to review your concerns with your supervisor. If you believe that your supervisor is involved, or your previous concerns have gone unanswered, then report your concerns to their supervisor.

If you believe that your management has been unresponsive, or is involved in the issues, then you can contact one of the established university offices that are responsible for complying with various policies and regulations. These offices can also answer your questions concerning the university’s polices and government regulations. The university’s polices can be found at gweb.gwu.edu after logging in with your GWMail Password. Under "Quick Links," click on "Policies, University." You can also find university policies at http://policy.gwu.edu.

The following list of compliance issues is not meant to be a complete list but rather a list of general compliance issues and the responsible departments:

Type of Issue Responsible Department Phone
Discrimination (staff related)

Equal Employment Opportunity & Affirmative Action

994-9656
Discrimination (faculty related) Faculty Recruitment & Personnel Relations 994-6783
Discrimination (student related) Division of Student Affairs 994-6710
Violations of EPA regulations and Hazardous material releases Office of Health & Safety 994-4347
Falsification of Documents Comptroller’s Office 726-4079
Fraud Comptroller’s Office 726-4079
loss of company assets Comptroller’s Office 726-4079
Problems with Student Billings Student Accounts Services 994-7350
Violation of OSHA, HFPA, BOCA, NRC, and FDA regulations Risk Management 994-3265
Sexual Harassment Office of the Senior Vice President & General Counsel 994-6503
Workplace Conduct-staff Human Resources 994-9610
Workplace Conduct-faculty Faculty Recruitment & Personnel Relations 994-6783
Confidential GW Information Being Disclosed Division of IT- Information Security & Compliance Services 726-4262
Violation of System Security Division of IT- Information Security & Compliance Services 726-4262
Critical information system being hacked or compromised (Oracle, Banner, e-mail) Division of IT- Information Security & Compliance Services 726-4262
Not Following NCAA Rules Athletics Department 994-6282
Animal Research Violations of NIH, USDA, AAALAC Regulations Office of the Vice President for Research 994-6255
Sponsored Project Billing and Reporting Grants & Contract Accounting Services 994-4242
Conflict of Interest violation of DHHS, FDA, NSF or other Federal Agency Regulations Office of the Vice President for Research 994-6255
Human Subject Research Violations of DHHS/OHRP, FDA and other Federal Regulations pertaining to human subject research Office of the Vice President for Research 994-6255
Improper accounting and costing on sponsored projects Grants & Contract Accounting Services 994-6255
Laboratory Safety Violations Office of the Vice President for Research 994-6255
Misconduct in Research Violation of DHHS, FDA, NSF or other Federal Agency regulations Office of the Vice President for Research 994-6255
Radiation Safety Violation of NRC or DCRA Regulations Office of the Vice President for Research 994-2995
Alcohol and Drug Use University Police 994-6111
Threats of Immediate Violence and Physical Violence University Police 994-6111
Not Following Federal (DOE/DHHS) Rules Student Financial Assistance 994-6620
Not Following IRS rules Tax Department 726-8382
Violation of Worker's Compensation Laws Risk Management 994-3265

*Phone numbers starting in 994 have a 202 area code; phone numbers starting in 726 have a 703 area code.

If you are afraid of retaliation, or if you want to remain anonymous, you can always use the Regulatory Compliance Help and Referral Line at 1-888-508-5275.

What is the Regulatory Compliance Help and Referral Line?

The Regulatory Compliance Help and Referral Line is a toll-free, 24-hours, 7 days-a-week telephone service, that provides the university community an opportunity to anonymously report workplace regulatory compliance concerns. These concerns can include, but are not limited to, suspected illegal or unethical behavior associated with non-compliance with laws, regulations and policies. The service can also answer general compliance questions and direct you to the proper GW department.

Why is the Regulatory Compliance Help and Referral Line important?

The university is committed to conducting business ethically, and in compliance with applicable federal, state, and District laws. The Regulatory Compliance Help and Referral Line, with the support of the university community, is an effective way to help the university address potential violations of laws, regulations and university policies.


For questions or comments about The George Washington Compliance Office, e-mail us at comply@gwu.edu or call (202) 994-3386.

© 2001 The George Washington University Compliance Office. All rights reserved.

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