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 newly implemented 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 Activity |
994-9656 |
| Discrimination (faculty related) |
Faculty Recruitment & Personnel Relations
|
994-6783 |
| Discrimination (student related) |
Dean of Students |
994-6710 |
| Violations of EPA regulations and Hazardous
material releases |
Risk Management and Safety |
994-3265 |
| Falsification of Documents |
Comptroller’s Office |
994-7777 |
| Fraud |
Comptroller’s Office |
994-7777 |
| loss of company assets |
Comptroller’s Office |
994-7777 |
| Problems with Student Billings |
Student Accounts Services |
994-7350 |
| Violation of OSHA, HFPA, BOCA, NRC, and
FDA regulations |
Risk Management and Safety |
994-3265 |
| Sexual Harassment |
Office of the VP & General Counsel
|
994-6503 |
| Workplace Conduct-staff |
Human Resources-Employee Relations |
994-9611 |
| Workplace Conduct-faculty |
Faculty Recruitment & Personnel Relations
|
994-6783 |
| Confidential GW Information Being Disclosed
|
Information Security Office
|
994-7803 |
| Violation of System Security |
Information Security Office
|
994-7803 |
| Critical information system being hacked
or compromised (Oracle, Banner, e-mail) |
Information Security Office
|
994-7803 |
| Not Following NCAA Rules |
Athletics Department |
994-6650 |
| Animal Research Violations of NIH, USDA,
AAALAC Regulations |
Office of Health Research, Compliance & Technology Transfer |
994-2995 |
| Sponsored Project Billing and Reporting
|
Grants & Contract Accounting Services |
994-7700 |
| Conflict of Interest violation of DHHS,
FDA, NSF or other Federal Agency Regulations |
Office of Health Research, Compliance & Technology Transfer |
994-2995 |
| Human Subject Research Violations of DHHS/OHRP,
FDA and other Federal Regulations pertaining to human
subject research |
Office of Health Research, Compliance & Technology Transfer |
994-2995 |
| Improper accounting and costing on sponsored
projects |
Grants & Contract Accounting Services
|
994-7700 |
| Laboratory Safety Violations |
Office of Health Research, Compliance & Technology Transfer |
994-2995 |
| Misconduct in Research Violation of DHHS,
FDA, NSF or other Federal Agency regulations |
Office of Health Research, Compliance & Technology Transfer |
994-2995 |
| Radiation Safety Violation of NRC or DCRA
Regulations |
Office of Health Research, Compliance & Technology Transfer |
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 |
Comptrollers-Tax Department |
994-2556 |
| Violation of Worker's Compensation Laws
|
Risk Management & Safety |
994-3265 |
|
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.
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