Purpose
Higher education is one of the most regulated industries in the nation. With regulations continuously increasing and being revised, the University faces challenges in meeting both academic objectives and compliance requirements.
These challenges necessitate a University wide ethics and compliance program that promotes a responsible, efficient, and effective risk based approach to managing the myriad of regulations allowing the University community to focus on achieving its University Strategic Plan. Despite the challenges, Western is committed to compliance while upholding it’s value of integrity, ethics, and accountability among its’ workforce and students.
University Ethics and Compliance Program (UECP)
The UECP is under the purview of the Vice President for Business and Financial Affairs. The University’s Compliance Program framework document outlines the:
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- Program Goals
- Key Elements of an Effective Ethics and Compliance Program
- Roles and Responsibilities
The University Ethics and Compliance Committee (UECC) is established by the President with members selected by each Vice President to represent key compliance areas. The UECC will facilitate the objectives of the University Ethics and Compliance Program ("Program") and make recommendations in response to regulatory oversight, regulatory changes, and assessed risks that will be communicated to executive leadership and the Board of Trustees.
The Program, while being an enterprise program, works individually with the Provost and Vice Presidents, their college and department level leadership, and compliance owners and partners.
The matrix provides a high-level overview of the University's key areas of compliance obligations, assigned executive leadership oversight, and delegated compliance owners and partners. It is a tool designed to not only assist in managing regulatory requirements but to communicate a sense of shared accountability for compliance and internal controls, and to promote an institutional culture of integrity.
Compliance Accountability Matrix
An internal control system provides reasonable assurance regarding the achievement of the University's objectives related to operations, reporting, and compliance. Internal controls should:
- Be designed to eliminate or reduce inherent risks,
- Be incorporated within business operations not around them, and
- Provide assurance that controls are working effectively.
The University's Internal Controls Program is based on:
- Washington State's required internal control program framework as sited in SAAM Chapter 20. Western integrates the framework components and principles for an effective internal control system into the elements of the University's Ethics and Compliance Program.
- The Higher Education Act [34 C.F.R. Section 668.16(c)(1)] which requires Western to have adequate checks and balances in a system of internal control in order to participate in the Title IV programs (federal student financial aid).
- OMB A-133, Part 6 – Internal Controls which requires that non-federal entities receiving federal awards (i.e. faculty research grants) establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements.
University Contacts:
Brian Sullivan, Associated Vice President for Business and Financial Services, Internal Control Officer
David Patrick, Vice Provost for Research
Nicole Goodman, University Compliance Officer
To supplement the University's Enterprise Risk Management Program, Compliance Services conducts a Compliance and Internal Control Risk Assessment which includes a high-level assessment conducted on an annual basis and an in-depth assessment no longer than every three years.
Compliance/Internal Control Risk Assessment Framework and Methodology
University Ethics Guide
The University has developed an Ethics Guide on common University related topics. If you do not find your answers in this guide, please feel free to contact the University Ethics Advisor.
University Ethics Advisor
Darin Rasmussen, Assistant Vice President for Risk, Ethics, Safety and Resiliency
Darin.Rasmussen@wwu.edu
Ethics Training
Employees and students can click here to complete the University's on-line Ethics Training. To receive credit, the quizzes must be completed. The course content was developed by the State Ethics Board.
Additional Resources
Ethics Related University Policies
State Ethics Laws and Rules
Washington State Ethics Board
Whistleblower Information
Compliance Services supports the various University compliance owners in developing compliance training. Below are links to newly updated compliance trainings.
Protecting Payment Card Information (PCI) Training
Opioid Overdose Response Training
Success of the Program Requires the Engagement of all Employees
Every University employee has some level of responsibility for compliance and internal controls. The Compliance Resources page provides information and internal control tools for employees, compliance owners, and partners to assist with maintaining an effective University Compliance Program.
