Key takeaways from the article
- It is paramount to continuously evaluate your institution’s compliance program
- To accurately measure the compliance program’s effectiveness, consider determining your current “stage of life”
- In March 2023, the U.S. Department of Justice released additional guidance to assist prosecutors in making informed decisions as to whether and to what extent the compliance program was effective at the time of the offense and is effective at the time of a charging decision or resolution
- Whether you decide to conduct a self-assessment or have a third party conduct the assessment, the starting point should involve understanding your institution’s critical risks and reporting mandates as well as trending risks across the higher education industry
- Keep in mind: the goal is not to have a perfect compliance program. The objective is to have an effective compliance program, which means they are malleable and provide room for growth and maturity.
For more information, or to learn more about how Baker Tilly’s higher education risk advisors can help your institution, connect with our team.