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Compliance

Fraud Reporting

SUNY Compliance Program Information and Participants

Seven Elements of an Effective Compliance Program

Training

Topics in Compliance

Accessibility and Disability Services

Audit

Athletics Compliance

Conflicts of Interest & Ethics

Education and Student Relations

Environmental Health and Safety Compliance

Employee Relations and Human Resources Compliance

Equity and Diversity

Financial Aid

Financial Management Practices

Fraud Reporting

Healthcare

Information Management

International and Immigation Compliance

Patents, Copyright & Trademark

Research

SUNY Compliance Structures

Safety, Security, and Public Health

Student Rights and Responsibilities

SUNY System-Wide Policies and Procedures Website

SUNY University Audit

SUNY Office of General Counsel

Compliance

***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.  

Structure of Compliance Steering Committee: The Compliance Committee works directly with the Compliance Director, and reports to the Deputy General Counsel, the University Auditor, and the Senior Vice Chancellor.  Those three positions have direct reporting to the Board of Trustees and the Board of Trustees Audit Committee.  The Committee serves the 29 State-Operated Campuses and the efforts at System Administration.

SUNY Compliance Resources

External Compliance Resources

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 commentsCampus 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.was created 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 ey federal laws and regulations governing colleges and universities.

What's New on the Compliance Website 

OFCCP Compliance
The page includes a description of the OFFCP, and new resources, including SUNY Compliance Checklists, FAQ's, and Self-Identifiation 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.

NYS Education Law Article 129-A Certification
The page details the requirements of the law, including information that SUNY campuses must provide certification to the New York State Education Department Office of Higher Education (NYSED) that the college is in compliance with all provisions of the Article on or before July 1st, 2014.  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). 

Mandated Update Domestic Violence and the Workplace Policies - update must be completed and submitted by December 15, 2013
All SUNY campuses must submit their updated Domestic Violence and the Workplace Policies by December 15, 2013 to the OPDV (through the SUNY System-Wide Affirmative Action Officer) to include the language the OPDV outlined in a July 2013 memorandum. SUNY has a Model Domestic Violence and the Workplace Policy template, with the new updated language, for campuses to use.  If your campus simply adopted the original SUNY Model Domestic Violence Policy, then you can use the NEW Model Domestic Violence and the Workplace Policy template and edit the template to include your campus information. If your campus DID NOT follow the Model Domestic Violence in the Workplace Policy, you will have to refer to the OPDV memorandum to see what language you will need to include in your current policy.

Guidance Article on Accommodating Pregnant Students on SUNY Campuses
On June 25, 2013, the United States Department of Education's Office of Civil Rights issues a Dear Colleague Letter (DCL) o offer guidance on accommodating pregnant students. In the wake of the DCL's issuance, Seth Gilbertson, Associate Counsel in SUNY's Office of General Counsel published in the General Counsel Update Number 11 to offer guidance on Accommodating Pregnant Students on SUNY Campuses.

Inspector General Uniform Guidelines Recommendations
The New York State Inspector General's Office issued a training program in February of 2013 titled “Code of Conduct and Uniform Guidelines.” The training included guidance on personnel management, ethics, and the use of State resources.  The recommendations were based upon findings made by the  New York State Inspector General during the course of their own investigations.  The recommendations are detailed on the compliance website, and the power point presentation from the IG's presentation is available as well.

Dear Colleague Letter, Questions and Answers About Fisher v. University of Texas at Austin, issued September 2013 by the U.S. Department of Education Civil Rights Division and U.S. Department of Justice Office for Civil Rights
This most recent Dear Colleague Letter attempts to  provide additional information on the Fischer v. University of Texas at Austin decision and how it will impact colleges and universities.  the DCL is available on the Affirmative Action compliance webpage.

Special Edition of the General Counsel Update in light of Fischer v. Texas Supreme Court Decision, June 25, 2013
This special edition of the General Counsel update is intended to bring you the latest news and advice on the topic of affirmative action in light of the June 24th Fischer v. Texas Supreme Court ruling, which is the court's most recent foray into affirmative action in higher education admissions. The analysis here is only a first step, and the Office of General Counsel will continue to monitor these cases and provide guidance to you, our clients. The General Counsel's Office newsletter details other affirmative action cases from the past, offers helpful guidance regarding what SUNY campuses should do to be compliant with current Affirmative Action court rulings.

Research: New Human Subjects Research and Animal Subjects Research Best Practice Documents
Effective Date: August 2013; released August 20, 2013
SUNY and the RF have jointly developed a Best Practice resource for Human Subject Research titled "Research Involving Human Subjects" and an Animal subjects Best Practice resource titled “Animal Care and Use.”  Both best practice documents are products of the coordinated work of the SUNY Compliance Steering Committee. 

Project Sunlight
A training webinar is available permanently on the SUNY Project Sunlight webpage for campus use for purposes of training on Project Sunlight.

What is Project Sunlight: A New York State statute effective January 1, 2013, establishes the "Project Sunlight" database, and places a compliance mandate on State agencies, including SUNY, to report to OGS appearances by individuals and firms who or that appear before State decision-makers or persons who advise decision-makers, on an OGS form, electronically available in an electronic portal.  SUNY is likely to be most impacted in the area of procurement and to a lesser extent in rule-making activities (including rule-making related to tuition and fees) and some activities of the Charter Schools Institute.

SUNY's Mandatory Child Sexual Abuse Reporting Policy:
This Policy places an affirmative obligation upon all State University of New York employees, students, and volunteers to report child sexual abuse that occurs on campus or off campus at University-sponsored events to the appropriate authority or authorities.  The policy also requires that relevant employees and students be trained on recognizing child sexual abuse crimes and that there is an obligation to report such abuse if it is witnessed.  Updates to this webpage include what the campus needs to do to comply with this new mandated reporting policy, and information on confidentiality issues.   

Dear Colleague Letter on Prohibition Against Retaliation related to Civil Rights Complaints: On April 24th, 2013, the Office for Civil Rights released a Dear Colleague Letter (DCL) to remind school districts, postsecondary institutions, and other Federal funding recipients of the legal prohibition against retaliation with regard to civil rights complaints and to describe OCR’s methods of enforcement. The DCL guidance does not contain any new policy or new interpretations of law and is supported by well-established caselaw. OCR has never before issued any public guidance describing its enforcement of recipients’ non-retaliation obligations, and chose to do so because it is an important area in need of clear concise guidance, as nearly one fifth of all complaints received by OCR raise retaliation allegations.

SUNY Fraud Policy and Revised Fraud Procedure - March 2013
The SUNY Board of Trustees adopted a Fraud Policy at its March 2013 Board Meeting. The impact of this new Fraud Policy and the Fraud Procedure changes are outlined on the Compliance webpage.  SUNY already maintains a System-wide Fraud Hotline to Report Suspected Fraud, but this new policy ensures that those reporting to the Fraud hotline will have whistleblower protection afforded to them.  Also, through the revised procedure, campuses will be required to report all frauds to the Office of University Audit so they may be tracked and monitored by the Fraud Committee using a standard form, and report to the Office of the University Auditor any contact from the New York State Attorney General, the Inspector General, or any other outside agency regarding any investigation. In addition, each campus is required to establish a mechanism (fraud hotline) such as a toll free number, e-mail address, or facsimile number that individuals can use to report suspected and detected fraud and irregularities.  

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.


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Last Update - 4/18/14