***The SUNY Compliance webpage is continually developing and will expand as the program evolves. Check back for additional resources and compliance topic pages***
Mission of the SUNY Compliance Program
The State University of New York is committed to operating with integrity and in compliance with all applicable laws, regulations and policies. The State University of New York has established the Compliance Steering Committee to coordinate SUNY's numerous existing compliance efforts and to provide senior leadership with a comprehensive view of SUNY's compliance activities. The Committee will assist the Board in overseeing SUNY’s compliance program with respect to (1) compliance with legal, regulatory, and ethical responsibilities and (2) minimizing SUNY’s risk. The Committee will not assume the duties of the various substantive compliance areas and all ongoing compliance activities will continue in their existing reporting structure. Rather the Committee’s role will be to coordinate and monitor these efforts and assess University-wide performance, making recommendations for change and enhancement where necessary. It is expected that the SUNY Compliance Program will be an evolving process and additional resources will be needed to enhance our efforts over time.
SUNY Compliance Resources
SUNY Audit Hotline to Report Fraud
The State University of New York is committed to ensuring its funds and other University resources are used in an effective and efficient matter. The hotline is intended for faculty, staff, students, and others to report suspected fraud, waste, abuse or irregular activities. These activities include improper transactions, such as suspected thefts, losses, misuse or inappropriate action involving State funds, equipment, supplies or other assets. Complaints about other matters, such as personnel issues or academic misconduct, should be brought to the attention of the appropriate office at the campus involved. The hotline is monitored by University Audit, and each complaint is reviewed by the Fraud Committee in accordance with the SUNY System-Wide Fraud and Irregularities Policy and Procedure.
The hotline is intended for faculty, staff, students, and others to report suspected fraud, waste, abuse or irregular activities. These activities include improper transactions, such as suspected thefts, losses, misuse or inappropriate action involving State funds, equipment, supplies or other assets. Complaints about other matters, such as personnel issues or academic misconduct, should be brought to the attention of the appropriate office at the campus involved. The hotline is monitored by University Audit, and each complaint is reviewed by the Fraud Committee. Click here to find more information about how to report fraud.
Campuses also maintain fraud hotlines locally, in addition to the System-Wide Fraud hotline.
SUNY Policies and Procedures
The Policies and Procedures webpage contains a listing of the System-Wide Policies and Procedures. Click here to access the SUNY System-Wide Policies and Procedures webpage. Note that each campus also maintains their own local Policies and Procedures.
SUNY Office of the University Auditor
The mission of the Office of the University Auditor is to assist the State University of New York Board of Trustees and University management in the discharge of their responsibilities by providing the independent and objective appraisals of SUNY's financial, operational, and control activities. Included on the University Audit website is a list of Audit Guidance and Best Practices resources for the campuses on topics of Agency Account Administration, Auxiliary Service Corp.Management Letter comments, Campus Procurement, Campus Foundations, Cash Receipt Controls, Elevator Maintenance Contracts, EOP Audit Guidance, OSC Audit Guidance, OSC Payroll Audit Summary, Procurement Card Program Audit Guidance, Student Government Associations Audit Guidance, Student Textbooks Audit Guidance, and Vehicles, Fuel Inventory, Usage, Gas Credit Credit Guidance.
SUNY Internal Control Program
Internal controls are about helping organizations achieve their goals and objectives in an efficient and accountable fashion. For more than fifteen years the State University has conducted its internal control program in accordance with New York State's Internal Control Act.
SUNY Compliance Topics
The Compliance Topics page contains a listing of all the topics related to higher education Compliance. Click here to access the Compliance topic page. The topic menu on the left hand side of the screen also contains all of the available topic pages.
SUNY General Counsel's Office Updates
Find up-to-date information on the activities of the SUNY Office of General Counsel. These newsletters also contain guidance on various compliance issues.
SUNY Compliance Listserv and other SUNY listservs on specific compliance topics and functions
To join the Compliance listserv, send an e-mail to the Director of Compliance.
In addition, several other Compliance listserv's are maintained in conjunction with particular compliance topics. To join one of these listservs, e-mail the Director of Compliance, who will pass the request along to the appropriate SUNY contact.
There are SUNY internal listservs for the following compliance topics/ functions:
- Clery Act Compliance
- Title IX Compliance
- Affirmative Action Officers
- Records Management Officers
- FOIL/ Records Access Officers
- Ethics Officers
External Compliance Resources
Higher Education Compliance Alliance
The Higher Education Compliance Alliance was a site created by the National Association of College and University Attorneys (NACUA), in partnership with thirty other higher education associations, to provide the higher education community with a centralized repository of information and resources for compliance with federal laws and regulations. The site features a Federal Compliance Matrix, a comprehensive list of the key federal laws and regulations governing colleges and universities.
What's New on the Compliance Website
New SUNY Procedure, Emergency Notification Protocol Requirements, Document No. 5608
This new procedure establishes a communication protocol from the campuses to System Administration during emergency situations. Consistent with current practice, campus officials are required to promptly inform the Chancellor of the State University of New York when a major unplanned event occurs on or near a campus that could have a significant adverse impact on the campus community, campus property, or other component of the State University of New York.
Title IX Compliance webpage includes some new recent developments:
- On April 29, 2014, The White House Task Force To Protect Students From Sexual Assault issued its a report titled “The First Report of the White House Task Force to Protect Students From Sexual Assault”.
On April 29, simultaneous to the White House Report, The United States Department of Education Office for Civil Rights (OCR) issued a 52-point guidance document to further clarify the obligations imposed by the April 2011 Dear Colleague Letter and OCR’s 2001 guidance. SUNY Associate Counsel Andrea Stagg developed a summary of the guidance, titled Distilling the April 29, 2014 OCR Questions & Answers on Title IX and Sexual Violence, that highlights the key points of each question and answer.
- SUNY UPCOMING COMPLIANCE TRAINING ON TITLEIX, VAWA, and Clery: The Violence Against Women Act: Updating SUNY Codes and Handbooks - Compliance with New Guidance at SUNY
SAVE THE DATE: June 26, 2014 and July 9, 2014 in Albany
The Office of General Counsel, Office of University Life and Office of University Police invite SUNY campuses to a one-day comprehensive conference where we will cover all required changes and provide up-to-date solutions. We will also cover ADA Title II.
NYS Education Law Article 129-A Certification
The page details the requirements of the law, including the July 1, 2014 Compliance filings that each SUNY State-operated and Community College must submit to the New York State Education Department Office of Higher Education (NYSED). In addition to the certification, in 2014, institutions are required to submit actual copies of their policies to demonstrate their compliance rather than signing a form attesting that policies exist (this policy submission is required by all institutions every ten years). SUNY 2014 Compliance with Article 129-A Checklist: The SUNY Compliance Office and the SUNY Office of General Counsel worked together to create a checklist of the applicable policies that campuses must submit. Please send an email to the Director of Compliance, or your Campus Counsel for a copy of the checklist.
The Nonprofit Revitalization Act of 2013
The page details the law passed by the New York State Legislature in June of 2013, which will become effective July 1, 2014. More guidance on this law as it applies to SUNY will be forthcoming.
E-Discovery (including SUNY's recently issued E-discovery procedure)
The page explains the basis of e-discovery, and also shares the new SUNY Legal Proceeding Preparation (E-Discovery) Procedure, which established a set process for campuses and campus counsel to follow when faced with e-discovery.
The page includes a description of the OFCCP, and new resources, including SUNY Compliance Checklists, FAQ's, and Self-Identification forms created to help campuses comply with the new OFCCP requirements that became effective on March 24, 2014.
SUNY Email Retention Guidance
This SUNY guidance document describes in detail how emails should be retained. The guidance documents release coincided with the release of SUNY's new Legal Proceeding Preparation (E-Discovery) Procedure.
Start-Up New York, with SUNY START-UP NY Program Participation Policy and SUNY Procedures for START-UP NY Program Participation
This page shares the law and regulations surrounding Start-Up New York, as well as the SUNY Start-Up Policy and Procedure, including the up-to-date forms that campuses need to fill out to comply with Start-Up.
The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements. The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses. Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete. For complete compliance information, consult your campus compliance officials or the SUNY Director of Compliance. For legal advice, consult your lawyer.