Compliance and Ethics FAQ

Examples of fraud include, but are not limited to:

• Stealing cash or checks
• Falsifying timesheets or workers comp claims
• Falsifying expense reimbursements
• Personal use of University credit cards or long distance codes
• Stealing property or supplies
• Personal use of University assets (occasional local phone calls are okay)
• Outside employment that conflicts with University employment
• Awarding contracts to friends or relatives
• Awarding scholarships/grants based on personal or financial relationships as opposed to merit
• Seeking or accepting gifts or favors from vendors or contractors in exchange for placing orders or awarding contracts
• Purposefully falsifying financial statements

Examples of issues that should not be reported through Fraud & Non-Compliance Hotline include:

Board of Regents Policy 42.01 established the framework for the UH System's Institutional Compliance Program.  The UHD Institutional Compliance Program was created under this framework to develop standards and procedures that help ensure UHD complies with federal and state laws, as well as UHD Policy Statements (PSs) and UH System Administrative Memorandums (SAMs).  

Examples of external rules and regulations:

• Federal information security laws (FERPA, GLB, HIPPAA, etc.)
• State purchase and payment regulations
• Sponsor requirements on research grants

To support this effort, we take a proactive approach to managing compliance risks.  Because the university operates in a complex environment of laws, regulations, and policies, we face risks every day.  An effective institutional compliance program identifies those risks and implements reasonable measures to reduce the most critical ones. 

The elements of an effective Compliance Program are based upon the requirements of the United States Sentencing Guidelines, revised in November 2018. They include:

1. Existence of written standards
2. Effective oversight
3. Due care in delegation of authority
4. Training
5. Monitoring
6. Discipline
7. Corrective Action
8. Periodic assessment of risks

The consequences of non-compliance can negatively impact UHD as well as the individual(s) involved.

The university could suffer:

• Fines, penalties, and legal fees
• Negative media coverage
• Imposed compliance "settlement" requirements
• Loss of funding sources
• Increased regulatory and audit agency scrutiny
• Increased bureaucracy
• Reduced faculty and staff morale
• Management, faculty, and staff turnover
• The lingering effect of a tarnished reputation in higher education

Involved individuals could suffer:

• Disciplinary action up to and including termination
• Fines
• Tax proceedings
• Imprisonment (depending on the severity of non-compliance)

You have several options for reporting another employee's conduct that you suspect may not be in compliance with applicable laws, rules, regulations, and policies.

1. Notify your Supervisor or UHD Management
2. Notify the Compliance Officer (Mayte Alvarez at 713-221-8639)
3. Notify the UHS Internal Auditing Department (713-743-8000)
4. Use the Fraud & Non-Compliance Hotline (1-800-461-9330)

Yes. Employees who report unlawful activity in good faith are protected by The Texas Whistleblower Act (Texas Government Code, Chapter 554.002. The reporting employee cannot be suspended or terminated from employment in retaliation.

We typically associate risks with financial matters; however, any issue or circumstances that negatively impacts the ability to meet our business objectives represents a risk to UHD.  This includes:

• Strategic Risks: Risks that affect our ability to achieve our goals and mission
• Financial Risks: Risks that may result in a loss of our assets
• Operational Risks: Risks that affect our ongoing management processes, such as the installation of a new administrative system
• Compliance Risks: Risks that affect our adherence to externally imposed laws and regulations as well as internal policies and procedures
• Reputational Risks: Risk that affect our reputation as an institution of higher education

Compliance with applicable laws, rules, regulations, and policies is the personal responsibility of every employee at UHD. Each one of us is a risk manager because we are all presented with risk each day in the workplace. We all have resources at our discretion, such as staff, finances, property, and information. What we do or do not do with those resources can either cause risk or mitigate risk.

The UH System Internal Auditing Department identifies risks in the course of doing audits and brings those concerns to our attention.

The Compliance Officer and members of the Institutional Compliance Committee at UHD coordinate the oversight of the identified high level "A" risks via a Risk Management Program that includes the monitoring of controls, training of policies and procedures, implementing predefined consequences for non-compliance, and taking appropriate action to mitigate the risks.