Compliance

MSU is committed to integrity, a culture of compliance and the promotion of the highest ethical standards for the MSU Community.

Institutional Compliance provides independent oversight of MSU’s compliance programs to assure that the University is compliant with federal, state, and local laws and regulations as well as University policies. The department was established in November 2018 to continue the University’s commitment to meeting the highest standards of ethics, integrity, and responsibility.

The Compliance program is the collective efforts of all the various schools and business units exercising due diligence in order to prevent and detect misconduct. The program is designed to promote an organizational culture that encourages ethical conduct and compliance with the law, regulations, university policies and our core values without disrupting the successful operations of individual areas.

Institutional Compliance will serve as an additional point of contact for ethics and compliance inquiries and concerns, especially issues of university-wide significance or impact, by supplementing and complementing the subject-based compliance expertise each school or business unit possesses. Specifically, this office will provide guidance and support to university members with managing compliance requirements and self-monitoring.

Responsibilities

Institutional Compliance is responsible for designing, implementing, and monitoring the compliance program. The office’s primary responsibilities include the following:

  • Perform compliance monitoring to assess the design and effectiveness of the compliance activities including high risk areas. 
    • Recommend improved controls and/or provide independent services such as communicating the need for new procedures, resources, or stronger enforcement or working as a liaison between multiple parties.
  • Assist the university compliance liaisons in their various duties as operational owners of laws, regulations, and policies.
  • Monitor university compliance liaisons:  risk identification processes (impact and likelihood); monitoring efforts to mitigate risk; occurrences of noncompliance and reporting mechanisms (internal and external); remediation efforts for noncompliance (to enhance controls and prevent future noncompliance); and, compliance training.
  • Review compliance committees’ functions and charters.
  • Report regularly to the Board of Trustees Audit, Risk and Compliance Committee relating to annually summarizing the institutional compliance risks; monitoring activities and significant instances of noncompliance.
  • Construct, improve and maintain the Policy Library framework.
  • Construct and maintain a compliance matrix.
  • Promote the University’s Code of Ethics and Business Conduct (under construction) and Misconduct Hotline.

The most significant benefits of a compliance program are the following:

  • Promoting a culture that will not permit or promote illegal or actionable behavior and prompts the university community to consider the potentially adverse legal consequences of certain misconduct.
  • Increasing the likelihood of early detection if potentially illegal or actionable conduct does occur, thus creating the opportunity to correct or self-report as required.
  • Serving as a basis to influence governmental authorities to decline prosecution or the initiation of a civil or regulatory action.
  • Potentially reducing penalties or fines assessed and avoiding the imposition of a government-mandated Corporate Integrity Agreement if misconduct does occur.

As applicable, the Seven Elements of an Ethics and Compliance Program will be implemented:

1. Organizational Leadership, Culture and Governance

Demonstrate a compelling “tone from the top” by instituting effective organizational vision, structure, oversight, communication and governance.

2. Standards and Procedures

Establish standards and procedures, policies and guidelines to promote operational excellence through ethical behavior.  Encourage commitment to the University’s Code of Conduct and other University standards and unit guidelines for performance and conduct.

3. Right People, Right Roles

Hire and empower exceptional personnel.  Grant and monitor appropriate authority to enable effective support of the University’s mission.  Promote recognition for exceptional work and ensure decision-making authorities are informed and knowledgeable about operations.

4. Education and Awareness

Communicate expectations of high ethical standards and adherence to policies, procedures and other aspects of ethics and compliance.  Providing training and education consistently, effectively and in a practical manner as appropriate to an individual’s role and responsibilities.

5. Program Evaluation and Guidance

Monitor and audit periodically to detect unusual results or noncompliant conduct. Establish and promote mechanisms for individuals to seek guidance or report potential noncompliant conduct without fear of retaliation.

6. Consistent Enforcement of Standards and Discipline

Promote and consistently enforce standards and discipline throughout the organization. Establish a response to detected offenses and implement corrective action plans. Uniformly enforce standards through appropriate discipline to prevent similar conduct.

7. Response and Prevention

Respond appropriately to noncompliant acts to prevent further instances. Make any necessary improvements to reduce the risk of future noncompliance and perform outreach to re-align organizational culture.