Personal Health Information Privacy

There are numerous locations at Western that collect and retain personal health information and are required to protect those records in a manner required by both state and federal laws. The main healthcare related areas are:

Other areas that maintain personal health information include, but are not limited to:

  • Human Resources
  • Athletics
  • Education Abroad

Regardless of the location of personal health information, department heads are to ensure the protection of this
information. If there is a concern regarding privacy of personal health information:

  • Contact Western’s HIPAA Officer at 360.650.2477 or nicole.goodman@wwu.edu, or
  • Report a potential breach of personal health information by selecting a reporting option below.

For employees or student trainees of a WWU health care clinic, click here to report a privacy breach.
For patients/clients or general public, click here to report a privacy breach.

Raffles/Bingo/Gambling

Raffles

Western does not have University policy on conducting raffles. Raffles held by a WWU department, program, or
student activity or club must comply with state and federal requirements.

Legal Authority

State:        RCW 9.46  Gambling
Federal:   IRS Publication 3079  Tax-Exempt Organizations and Gaming

Required Compliance

What is considered a raffle under state law?

The state definition of a raffle is “a game in which tickets bearing an individual number are sold for not more than one hundred dollars each and in which a prize or prizes are awarded on the basis of a drawing from the tickets by the person or persons conducting the game, when the game is conducted by a bona fide charitable or nonprofit organization, no person other than a bona fide member of the organization takes any part in the management or operation of the game, and no part of the proceeds thereof inure to the benefit of any person other than the organization conducting the game.”

If raffle tickets are not sold, but rather a random drawing will be held in which event attendees do not pay to participate in the drawing, the state requirements do not apply.

Who can offer raffles?

Raffles are a form of gambling only allowable by certain entities:

  • Individuals and commercial businesses cannot offer raffles, even if the money is given to charity.
  • Only certain charitable or nonprofit organizations that have been operating for at least 12 months can offer raffles.
  • Credit unions, cities, counties, towns and executive-branch state employees can offer raffles.
  • Lobby groups don’t typically qualify.

What are the legal requirements for holding a raffle?

University Procedures

  1. Review rules with the department/unit head and ensure compliance with state raffle rules.
    Department/unit heads are responsible for ensuring compliance. Click here for printable handout of the rules.
  2. Submit a Request to Provide an Award, Prize, Incentive, Gift Form. The prize must be approved.
    Please review the required Standards for Providing Awards, Prizes, Incentives, or Gifts.
  3. Determine if the value of the prize must be reported to the IRS.
    Contact Accounting Services prior to conducting a raffle. Ph: 360.650.3675 or email Western’s Associate Controller michael.ulrich@wwu.edu
  4. If the WWU Foundation is auctioning off alcohol, a raffle permit must be obtained from the state.
  5. Register your raffle with the University.
    Click here to register your raffle if you plan on move ahead with holding a raffle. This is not to grant approval, but to track and monitor raffle activity at the University.

 

Contracts

 

Primary Compliance Requirements

  • No employee may bind the University to an agreement (either in writing or verbally) without determining whether the agreement must first be reviewed and approved in accordance with policy. See Agreement Types below to determine if an agreement requires a formal University contract.
  • A Contract Owner must review an agreement against the Contract Compliance Checklist (in CMM system) to ensure all appropriate compliance reviews are conducted prior to submitting a contract for approval.
  • Only employees who have been delegated as a Signature Authority may sign an agreement/contract. A Contract Owner in most cases does not have signature authority. See “Contract Signature Authority” under Compliance and Internal Control Tools below.

Governing Documents

Document No. Document Name
POL-U5348.05 Authorizing Agreements and Contracts Policy
STN-U5348.05A Standards for Ratifying an Agreement as a Formal Contract
STN-U5348.05B Standards for Managing a Contract
STN-U5348.01A Standards for Ethical Purchasing
STN-U5348.01C Standards for Purchasing Goods and Services

Compliance and Internal Control Tools

Contact for Assistance

Andrea Rodger, Associate Director, Business Services
Phone: 360.650.4478

Janette Rosebrook, Contracts Specialist 2
Phone: 360.650.6641

Compliance Owner and Partners

Compliance Owner:

Pete Heilgeist, Director of Business Services/Chief Procurement Officer
Phone: 360.650.6340

Compliance Partners:

Michael Ulrich, Controller/Director of Financial Services
Phone: 360.650.3675
Michael.Ulrich@wwu.edu

Liz Parkes, Associate Vice President for Human Resources
Phone: 360.650.6456
Liz.Parkes@wwu.edu

Regulatory Authorities

State Law:

RCW 43.19, Department of Enterprise Service

State Rules:

DES-140-00, Sole Source Contract
DES-210-01, Agency Contract Reporting

Authorized Departments

Below is a list of departments currently authorized to directly charge and/or receive payments for goods and services. The Financial Managers must ensure employees within their department must complete the Cash Handling and Safeguarding Non-Public Financial Information Training before being authorized to accept any form of payment.
Department Financial Manager
Admissions Director of Admissions
Alumni Association AVP for Alumni Relations
A.S. Bookstore Manager, General Bookstore
ATUS Director of ATUS
Box Office Director of Financial Services
Campus Recreation Services Director of Campus Recreation
Extended Education Vice Provost of Extended Education
Huxley College Dean of Huxley College
Outdoor Center
Print & Copy Services Director of Business Services
Registrar’s Office Registrar
Testing Center Vice Provost of Extended Education
University Residences Director of University Residences
Viking Outdoor Recreation/OC  Associate Dean Student Engagement/ Director of VU
Viking Union  Associate Dean Student Engagement/ Director of VU
Viking Union Lakewood  Associate Dean Student Engagement/ Director of VU
WWU Libraries Circulation Dean of Libraries

 

Billing and Receiving Payments

 

The following information is essential for employees, or supervisors of employees, that are directly or indirectly involved in the process of making or receiving payments or refunds in the form of cash, check, or bank cards.

Risks of Handling Cash, Checks and Credit Cards

  • Loss of funds due to mishandling, errors in processing, and fraud.
  • Loss of donor confidence resulting in reduced donations.
  • Reputational loss which may jeopardize future state funding and admission rates.

Primary Compliance Requirements

  • No employee may accept cash, check, or credit card payments without prior authorization from Treasury Services.
  • No department may charge a fee for any service not approved by the University Budget Office.
  • No department may directly charge/bill or receive payment (cash, check, or bank card), even when an fee has been approved, unless prior authorization has been given by Treasury Services.
  • Refunds of any kind must be made in accordance with University policy and procedures.
  • Financial Managers of authorized departments must ensure compliance with the policies and procedures listed below.

LLLLList of departments authorized to directly charge and/or receive payments for goods and services

Compliance Resources

Policies:
POL-U5351.01            Billing and Receiving Payment for Tuition, Fees, Goods and Services
POL-U5320.03           Authorizing and Defining Financial Responsibilities
POL-U1400.05           Establishing and Changing Service Fees
POL-U5352.03           Adjusting Student and General Receivable Accounts and Refunding Credit Balances
POL-U5315.25           Reporting Loss of University Funds or Property

Procedures:
PRO-U5351.01A         Authorizing a Decentralized Billing and/or Payment Receipt Location
PRO-U5351.01B         Authorizing a Short-Term Payment Receipt Location

  1. Billing and Receiving Internal Control On-Line Assessment
    Required for departments authorized by Treasury Services before they may directly bill and/or receive payments
  2. Cash Handling/Safeguarding Non-Public Information On-Line Training
    Required before any employee may handle cash, checks, or bank cards (see "Basic Compliance Requirements" above)
  3. Know Your Money
    A tip sheet in identifying counterfeit money.

Becky Kellow, Manager of Treasury Services
Becky.Kellow@wwu.edu
360.650.7320

Bob Putich, Assistant Director of Student Business Office
Bob.Putich@wwu.edu
360.650.2866

Additional Contacts:
Discuss a Compliance Concern
Submit a Fraud/Ethics Report

Compliance Owner:
Teresa Hart, Director of Financial Services 
Teresa.Hart@wwu.edu
Phone: 360.650.2508

Compliance Partners:

Becky Kellow, Assistant Director Treasury Services
Phone: 360.650.3720
becky.kellow@wwu.edu

Bob Putich, Assistant Director Student Business Office
Phone: 360.650.2866
Bob.Putich@wwu.edu

Taya Winter, Assistant Registrar
Phone: 360.650.7912
Taya.Winter@wwu.edu

Federal Law:
P.L. 108-159            Fair and Accurate Credit Transactions Act of 2003

State Law:
RCW 28B.63           Commercial Activities by Institutions of Higher Education
RCW 28B.15           College and University Fees
RCW 43.01.050     Daily Remittance of Moneys to Treasury – Undistributed Receipts Account

State Rules:
SAAM Chp 20          Internal Control
SAAM Chp 85          Accounting Procedures

 

Accessibility/Disabilities

The following information is essential knowledge for all employees when providing services and assistance to students, other employees, and the general public. It is important to understand that not all disabilities are visible.

Purpose of Regulatory Requirements

To build awareness of how Western’s business practices and individual actions can result in unfair treatment and/or unequal opportunities for those with disabilities when participating in University academics, activities and employment benefits and opportunities. Compliant practices support Western’s goals for an inclusive educational and work environment and can help avoid reputational or financial harm that can impact Western’s ability to fulfill its strategic mission. See Western’s Commitment to Accessibility.

  • Electronic information, such as websites and electronic documents, must be accessible.
  • No employee may deny any person who requests an accommodation due to disability (apparent or not) except for authorized employees in Human Resources, the Civil Rights and Title IX Compliance Office, Disability Access Center for students, or University Residences.

Compliance Resources

Send questions or comments about this webpage to compliance.matters@wwu.edu