Authored by Cassandra Walsh and Meghan St. George
As part of the Society of Corporate Compliance and Ethics’ (SCCE) Higher Education Compliance Conference, which convenes college and university compliance professionals from across the country, Baker Tilly and compliance leadership from a large public state system shared perspectives and tips for conducting institution-wide compliance assessments.
The discussion focused on the following topics:
- Sharing key elements and benefits of compliance program assessments
- Defining the role of the compliance function and other stakeholders in executing an assessment
- Leveraging compliance program assessment results to improve risk management
What is an institution-wide compliance assessment?
It is an evaluation of the effectiveness and alignment of an institution’s compliance structure and processes relative to industry leading practices and federal expectations for compliance programs.
Why should your college or university perform an institution-wide compliance assessment?
There are several reasons to conduct such an assessment, including:
- Expand compliance oversight and enhance your institution’s culture of compliance
- Improve collaboration across various compliance functions and achieve stakeholder buy-in
- Align resources with strategic priorities
- Evolve compliance monitoring and improve responsiveness to institutional needs
- Inform roles and responsibilities for compliance process owners
- Assess how compliance roles are understood by the broader community
- Provide a road map for the future state of the compliance function
Who is involved?
There is no “one-size-fits-all” approach to building an assessment team.
- An assessment team can include internal and/or external compliance leaders or subject matter experts (e.g., professional services, associations)
- An internal team could perform a self-assessment for a recently established compliance program
- A hybrid approach of internal and external team members could work well for an institution that has the resources to complete the assessment internally, but wants to benefit from an objective, outside perspective
- A fully external team of compliance experts provides maximum objectivity
Invest time upfront identifying key stakeholders to involve in the process.
- Members of the compliance team should participate in the interview and information-gathering process
- The assessment should include participation from leaders who oversee key compliance areas (e.g., research, enrollment, campus safety, athletics) and members of compliance-related committees
- Key members of senior leadership, such as presidents, vice presidents or chancellors, should also participate to provide perspective on aligning the compliance function with the institution’s strategic priorities
- If your institution has multiple campuses or is part of a system, consider including compliance leadership from these areas
- Gathering feedback from board members (e.g., audit committee or audit and compliance committee) can also provide a broader perspective of risk priorities
What tools are available to enable a systematic and objective assessment?
Although the process for evaluating a compliance function is subjective, there are several tools that can help an institution perform a technical assessment:
- Surveys and questionnaires to gather feedback from participants
- Matrices to synthesize information and identify key themes
- Frameworks to evaluate practices against the Federal Sentencing Guidelines
- Maturity models to assess the current state and desired future state of key program aspects
What are leading practices for performing a successful institution-wide compliance assessment?
- Engage stakeholders at the beginning of the assessment to help ensure buy-in for the resulting recommendations.
- Spend time upfront ensuring that the right participants, including both the assessment team and interviewees, are involved.
- Identify the tools and frameworks that will be used for evaluation at the beginning, and confirm that they assess alignment with leading practices.
- Structure interviews strategically and efficiently, considering the order of interviews, the structure and focus of each interview and how to group together interviewees to foster discussion while enabling individuals to speak candidly.
- Monitor implementation of the recommendations, including considering the priority of suggested enhancement and how metrics can be employed to track implementation progress.
With thoughtful planning and execution, an institution-wide compliance assessment can help compliance functions evaluate whether they have effective compliance management practices in place, understand their alignment with institutional strategic objectives and provide a road map for the future of the program.
For more information, or to learn how Baker Tilly higher education specialists can help, contact our team.