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The Research Foundation Compliance Office

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Jeneeta O'Connor

on 16 August 2018

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Transcript of The Research Foundation Compliance Office

Vision
Compliance Services
MISCELLANEOUS FUNCTIONS
Elements of an Effective Compliance Program
History
To provide best-in-class compliance and ethics programming, training, and guidance in support of the Research Foundation’s mission to support the State University of New York.
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
FOIL Appeals
Information Security and Privacy
Audit Support
Legal Support
Board Support & Corporate Governance

Sentencing Reform Act of 1984 created the field of corporate compliance
The Act’s purpose was to achieve sentencing uniformity
A byproduct was a series of “compliance” elements that could be used to mitigate a penalty resulting from a finding of liability or guilt
In 2003, Sarbanes-Oxley (“SOX”) focused attention on white collar crimes and strengthened the sentencing guidelines and mandated that those subject to SOX created an “effective compliance and ethics program.”
The guidelines list the elements that make up an “effective compliance and ethics program”.
Today, there are accrediting bodies and standards of professional conduct for compliance and ethics officers.
Mission
To enhance the RF's tone at the top, provide executive level ethics and governance leadership, and to create a focused and compliant business environment resulting in:
Enhanced Productivity through Integrity
Better Communications through Transparency
Improved Employee Engagement through Commitment
The Research Foundation for SUNY's
Office of Compliance Services

Serving a Culture of Compliance
Employee Orientation

Joshua B. Toas, Chief Compliance Officer

Enhanced Productivity
through Integrity
Better Communications through Transparency
Improved Employee Engagement
through Commitment
Mission
To enhance the RF's tone at the top, provide executive level ethics and governance leadership, and to create a focused and compliant business environment resulting in:
5. Standards enforced through well-publicized disciplinary guidelines
6. Auditing and monitoring
7. Response to detected offenses and corrective action plans and
8. Ongoing risk assessment
Hierarchy of Compliance and Ethics
Compliance Oversight
•Board of Directors
•Audit Committee
Delegation and Responsibility
Chief Compliance Officer
Resources and Authority
RF President
Hierarchy of Compliance and Ethics
The RF’s Board of Directors through the Audit Committee oversees the implementation and effectiveness of the RF’s Compliance and Ethics program
The RF President ensures that the appropriate staff and resources are dedicated towards an effective compliance program
The RF Chief Operating Officer provides administrative oversight of the RF’s Chief Compliance Officer (CCO)
The RF’s General Counsel, the VP of Internal Audit, and the CCO work together to maintain the RF’s control environment
The CCO is responsible for assessing risk, monitoring controls, providing guidance on ethics and conflicts management, reviewing training and education, administering written policies and procedures, and investigating allegations of fraud or misconduct, and providing assistance in the enforcement of policy.
You should be aware of the 7 Warning Signs that can lead to Ethical Collapse
1- Pressure to maintain numbers in a performance based system
2- Lack of communication and failure to openly discus lapses
3-Young guns and larger than life CEO
4- Weak Board
5-Conflicts
6- Innovation like no other feeds ego and narcissism associated with success
7- Moral rationing
The Board and Compliance
The Board must ensure that management puts an effective compliance program in place and must understand who is responsible for what
Proper Board level understanding and communication can protect against corporate and INDIVIDUAL civil and criminal liability
It is essential for material compliance, audit, and legal concerns to be reported to the Board
A compliance program protects insurance coverage
Corporate Ethics and Values- what you need to know
NYS Public Officer’s Law
Code of Conduct
Conflicts of Interest Policies
Ethics Hotline
Fraud and Misconduct

Risk Management
You should asses the risk associated with:
Your work
New projects
Changing situations

Tools are available to help you evaluate and manage risk
Internal Controls
Internal Control Methodology
Internal Control Evaluation – stakeholders must review controls to mitigate current risks
Internal Control Testing and Monitoring – Self Assessment
Policies Administration and Enforcement
Establishing Policies and Procedures Policy
General definitions and process
Administration
Policy review
Mandatory Review
Violations

Essential Policies and Concepts
Compliance Program
Code of Conduct
Conflicts of Interest Policy and Interest Disclosures
Establishing Policies and Procedures Policy (Policy Administration)
Fraud and Whistleblower Policy and Non-Retaliation Policy/Procedure for Investigating Fraud and Misconduct
Audit Standards Manual
Internal Control Methodology and Internal Controls
Progressive Discipline Policy
Record Retention and Destruction and E-Discovery
Travel and Entertainment Policies
Gift Policy (Section 73)
Public Officer’s Law
Ethics Hotline
Duty to report potential fraud, misconduct, and violations of RF or SUNY policy
Procedure for Investigating Fraud and Misconduct
Non-retaliation and Confidentiality
Helps protect against fraud, waste, and abuse
Develop an investigators handbook (needed)
Ethics Hotline:
www.compliance-helpline.com/
rfsuny.jsp or 800-670-7225
Training, Education, & Communication
Works with the functional training unit to ensure

relevant C & E training is available
Two types of training:
General C & E for all employees and
Content Specific for appropriate employees
Key Training Components:
The RF’s Compliance and Ethics philosophy, Code of Conduct and COI
Communications
How to report concerns – Ethics Hotline
Vendors and RF Ethics
Discipline
Properly fill out documents, i.e. billing, claims, invoices, financial statements
Record Retention and User Security
Government and private payor reimbursement principles
Prohibitions on paying or receiving renumerations to induce a referral
Duty report
 Training plan by Department/Function
Questions?
Contact:
Joshua B. Toas, JD, CCEP
Chief Compliance Officer
518.434.7145


Jeneeta Howe, JD, MBA
Compliance Associate
518.434.7019
Nadia M. Sidarous, CCEP
Senior Administrative Assistant
518.434.7202
Research Foundation
1. Written policies and procedures
2. A designated compliance officer and a compliance committee
3. Effective training and education
4. Effective lines of communication
Compliance Team

Joshua B. Toas
, JD, CCEP, CCEP-I, CFE
Chief Compliance Officer
Carol Berdar
Senior Research Compliance Manager
Liz Piga
Research Compliance Administrator
Jeneeta Howe
, JD, MBA
Compliance Associate
Nadia Sidarous
, CCEP
Senior Administrative Assistant

Campus Relationships
Campus Operations Managers
Enterprise Compliance Team
Campus compliance, risk, and audit professionals
Various functional stakeholder teams, i.e. SPFG
Why Compliance?
“We like to believe that, as adults, we make decisions independently and are far beyond succumbing to peer pressure. But social science research tells us that is simply not the case. Study after study confirms it: the vast majority of people act based on the circumstances in their environment and the standards set by their leaders and peers, even if it means compromising their personal moral ideals.
‘Good’ people do bad things if they are put in an environment that doesn’t value values, if pressured to believe that they don’t have any choice but to get the job done – whatever it takes.”
The Importance of Ethical Culture: Increasing Trust and Driving Down Risks, The Ethics Resource Center
Corporate Ethics and Values

Hotline Management – Internal Investigations

Risk Management and Internal Controls

Corporate Records Management

Policy and Procedure Administration

Research and Sponsored Programs Compliance Support

What we do at Central Office
Compliance and You
Implement the Compliance Program
Code of Conduct
Conflicts Management
Gift guidance
High impact/investigation case management
Risk Management and Evaluation
Policy administration, guidance, development
Research compliance support
Delegations of Authority Office of Record
Chair, Enterprise Compliance Team
As an RF employee you should be:
Familiar with the Code of Conduct
Aware of what can go wrong
Follow the law and policies
Avoid conflicts
Understand the rules that govern your work
Discuss concerns as appropriate
The RF Ethics Program Part1 : Tone at the Top and the RF Code of Conduct 1-15-13
The RF Ethics Program (Part 2): Gifts to Employees from Non-RF Sources, Nepotism, Fraud and Whistleblower policies 1-29-13
Ethics Compliance 5-20-14
Remember to Watch:
Carol Berdar
Senior Research Compliance Manager
518.434.7143
Liz Piga
Research Compliance Administrator
518.434.7038
Full transcript