<\/a>Boston University is committed to the highest ethical<\/strong><\/a> and professional standards of conduct. Members of the University community should conduct their activities as required by law and University policies<\/a><\/strong>. Each department is responsible for monitoring applicable laws, developing and maintaining appropriate procedures, and communicating those policies and procedures to the community.<\/p>\n The Compliance Services Office coordinates the University\u2019s efforts to meet compliance obligations efficiently and effectively and fosters ethical behavior and a culture of integrity through reinforcement of Boston University\u2019s Code of Ethical Conduct and Conflict of Interest Policy.<\/p>\n We fulfill this mission by:<\/p>\n In furtherance of our mission and activities, the Compliance Services Office endeavors to be knowledgeable, responsive, and ethical.<\/p>\n Boston University is committed to meeting the legal obligations that govern its many activities.\u202f Those obligations often are complex and require coordination among several departments across the University.\u202f The Six-part Compliance Framework<\/strong> below identifies the critical components of any effort to achieve compliance. The BU community will be able to meet its compliance obligations more efficiently and effectively if we share a common framework for communicating about and tackling compliance.<\/p>\n Understanding what is required \u2014 and what isn\u2019t \u2014 is the necessary first step in meeting our legal obligations.<\/span><\/p>\n The first step in meeting our legal obligations is to clarify what is \u2014 and what isn\u2019t \u2014 required.<\/p>\n The most common sources of compliance obligations are:<\/p>\n Generally speaking legal obligations require us to do something or prohibit us from doing something.\u202f For example, Title IX and related regulations and guidance prohibit us from discriminating on the basis of sex or gender.\u202f But in the modern era many laws go well beyond \u201cdo\u2019s\u201d and \u201cdon\u2019ts\u201d and require us to engage in specific types of compliance activities, including:<\/p>\n The best way to ensure that you and your departments are meeting these obligations is to identify the requirements clearly.\u202f The\u00a0Higher Education Compliance Alliance<\/a>\u00a0details most of the federal requirements in higher education by subject area.\u00a0 We would be happy to work with you to clarify related state, local or other obligations.<\/p>\n An important part of clarifying your obligations is identifying the areas that require individuals or departments outside of your own to meet obligations.\u202f For example, many grants or other government documents require the University to certify that it complies with a whole host of laws and regulations, some of which will be outside your area.\u202f Many reports required by federal, state or local agencies require information that comes from departments outside of your own.\u202f Who do you rely on to meet obligations you are responsible for?\u202f Compliance Services can help you identify those circumstances and help clarify responsibilities.<\/p>\n <\/div>\n<\/div>\n Assessing and monitoring the consequences of any compliance shortcomings (including how laws are enforced in higher education)\u202fcan help ensure that you spend limited time and resources most effectively.<\/span><\/p>\n Given the limited time and resources available for compliance efforts, it\u2019s important to establish priorities and make a plan to meet your obligations.\u202f As you establish priorities you should consider the possible consequences of any failure to meet legal obligations.\u202f For example:<\/p>\n Compliance Services can help you with this risk assessment.\u202f We can monitor enforcement activities and notify you when other colleges and universities are sued or pay fines or penalties in connection with compliance issues.<\/p>\n We suggest that you look back at the list of your departments\u2019 obligations, either the federal list we provided to you or an expanded list with requirements state, local or other organizations.\u202f Which two or three do you worry about most?<\/p>\n As we\u2019ll discuss next time, developing and publicizing clear policies and procedures will make it easier \u2013 and therefore more likely \u2013 that individuals will do what\u2019s necessary to meet these obligations.<\/p>\n <\/div>\n<\/div>\n Developing and publicizing clear policies and procedures makes it easier \u2013 and therefore more likely \u2013 for members of our community to do the right thing.<\/span><\/p>\n Clear policies and procedures makes it easier \u2013 and therefore more likely \u2013 that individuals will do what\u2019s necessary to meet legal obligations.\u202f Although we\u2019re fortunate to have many long-time employees who may understand what\u2019s necessary to meet some obligations, that knowledge often is lost as employees retire or take on new or different responsibilities. For significant legal obligations, the best approach is to write and share clear instructions that specify what we will do and who will do it. That\u2019s particularly true for the many significant legal obligations that require action by individuals in different departments throughout the University.<\/p>\n Writing procedures does not have to be complicated or time-consuming.\u202f Keep in mind the following guidelines:<\/p>\n Usually these written instructions will be internal to a department or shared among a few departments and need not take the form of a\u00a0University Policy<\/a>.\u202f However, if a law requires a policy or the nature of the obligation requires University-wide action, consider whether a University Policy is necessary.<\/p>\n Compliance Services can help you draft policies or procedures for meeting legal obligations.\u202f Consider the two or three obligations that are of most concern to you.\u202f Would new or improved procedures help your departments and the other departments you work with meet those legal obligations?<\/p>\n As we\u2019ll discuss next time, procedures may be sufficient if a few individuals are primarily responsible for meeting straightforward legal obligations.\u202f However, if legal obligations require a larger group or segments of our entire community to understand what\u2019s necessary, we should consider developing concise, practical training materials.<\/p>\n <\/div>\n<\/div>\n Offering concise, practical training materials helps members of our community understand what they\u2019re required to do and how to do it.<\/span><\/p>\n Policies and procedures will help ensure compliance if a few individuals are primarily responsible for meeting straightforward legal obligations.\u202f However, if legal obligations require a larger group or segments of our entire community to understand what\u2019s necessary, we should consider developing concise, practical training materials.\u202f Training helps members of our community understand what they\u2019re required to do and how to do it.<\/p>\n Training can take a variety of forms, including:<\/p>\n There are several options for developing and delivering training.\u202f For example, online training may be available at little or no cost through higher ed organizations such as the\u00a0Collaborative Institutional Training Initiative<\/a>.\u202f If you would like to develop your own training materials, peer institutions often make their training materials available online, which can provide an excellent starting point.<\/p>\n Compliance Services can help you identify, develop and deliver training.\u202f Consider the two or three obligations that are of most concern to you.\u202f Would new or improved training help your departments and the other departments you work with meet those legal obligations?<\/p>\n As members of our community understand obligations more clearly, it\u2019s fair to expect that individuals will raise questions or concerns.\u00a0 Although it may seem counterintuitive, it is important to welcome reports of concerns or complaints about alleged wrongdoing and to investigate any complaints promptly and responsibly.<\/p>\n <\/div>\n<\/div>\n Encouraging members of our community to report violations of laws or policies and diligently investigating reports made in good faith fosters our ethical culture, one of our most critical core values.<\/span><\/p>\nCompliance Services Mission Statement<\/h2>\n
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The CSO Program Framework<\/h2>\n
![\"Compliance](\"\/compliance\/files\/2020\/06\/six-part-framework.jpg\")
<\/p>\nStep 1: Clarify Obligations<\/h2>
![\"Circle](\"\/compliance\/files\/2020\/06\/clarify-obligations.jpg\")
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\nStep 2. Establish Priorities<\/h2>
![\"Circle](\"\/compliance\/files\/2020\/06\/establish-priorities.jpg\")
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\nStep 3: Develop Procedures<\/h2>
![\"Circle](\"\/compliance\/files\/2020\/06\/develop-procedures.jpg\")
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\nStep 4: Provide Training<\/h2>
![\"Circle](\"\/compliance\/files\/2020\/06\/six-part-framework-training.jpg\")
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\nStep 5: Report and Investigate Concerns<\/h2>
![\"Circle](\"\/compliance\/files\/2020\/06\/report-and-investigate-concerns.jpg\")
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