by Skip Anderson

 

Pratt

In response to significantly enhanced enforcement of regulations by government agencies including the IRS, the NIH and the EPA, the Universityrecently authorized the implementation of an umbrella program to help centralize its compliance efforts and to minimize potential risk from external audits.

University officials said highly publicized incidents such as the 1997 audit by the Department of Health and Human Services of Medicare billing at the University of Pennsylvania signal a bellwether change in the government's approach to enforcing federal regulations within the academic community. The result of the Pennsylvania audit culminated in $30 million in fines and penalties.

Menah Pratt, who has been designated the University compliance officer, said compliance is relevant to virtually all of the 13,000 faculty and staff members employed by Vanderbilt.

"All faculty and University representatives are expected to act in accordance with University and department compliance policies and procedures," said Pratt. "This program will assist [faculty and employees] in fulfilling their compliance responsibilities by creating a process to monitor the University's existing decentralized compliance efforts and to document the University's expectations for ethical conduct."

Pratt is responsible for "monitoring and assisting the University in its effort to take reasonable steps to ensure compliance," according to the program's documentation approved by the University's Board of Trust in February. The new program is expected to be functioning by the beginning of the fall 2000 semester.

"The program is designed to work in conjunction with University offices that administer compliance programs, such as the Opportunity Development Center and the Medical Center Compliance Office," said Pratt. "It complements, but does not replace or supersede other programs."

Examples of areas subject to oversight by government regulatory bodies include research on animals and humans; affirmative action; payroll and tax exempt bond compliance; contract and grant accounting; and the use of chemicals, radiation and biohazardous materials in research. Examples of student issues requiring compliance oversight include financial aid, campus crime reporting and the adherence by student athletes to NCAA and SEC regulations.

"We have as many as 20 different departments doing compliance activity," said Pratt. "The objective of this program is to create a program that accomplishes the goals of compliance without duplicating existing decentralized compliance efforts or creating additional burdensome responsibilities."

The program incorporates the elements of an effective program as detailed in the Federal Sentencing Guidelines, as well as the elements of the Office of Inspector General's Model Compliance Program for Hospitals and the National Institutes of Health Guidelines for Effective Compliance, she said.

"The program has been described as being similar to having an insurance policy, in that it helps us to proactively manage risk internally," said Pratt.

The new program also includes a "help line" system that allows faculty and employees to alert campus officials to behavior or situations that may be in violation of federal, state or local regulations, or that breaches University policy as listed in the Faculty Manual and Staff Handbook. The system was installed in a way such that the calls cannot be traced back, she said. Pratt or the compliance liaison of the appropriate department will investigate all reports of alleged misbehavior. Faculty and staff can also use the help line to make confidential inquiries on compliance matters.

Pratt said peer institutions are also in the process of establishing institution-wide compliance programs.

"The NIH has temporarily suspended research at seven institutions, including Duke, due to non-compliance with federal regulations involving research on humans," she said. She explained that institutions found to be without compliance programs could have one forced upon them by the government.

"Vanderbilt recognized very early the risks of not having a university-wide compliance program," she said, especially in light of recent settlement agreements against the University of Minnesota for $32 million, University of Texas for $17 million, the University of Pittsburgh for $12 million and Thomas Jefferson University for $12 million.

Pratt will chair the Committee of Compliance Liaisons, which includes officials from various departments. The committee is scheduled to meet quarterly, and along with the Office of General Counsel, will monitor developments and changes in statutes, court rulings and regulations that affect compliance requirements.

The new program was designed with input from several University offices, including the general officers, the Office of Internal Audit, the Office of General Counsel, the Opportunity Development Center, the Office of Contract and Grant Accounting, the Medical Center Compliance Office, the Environmental Health and Safety Department and the PEAF Committee of the Faculty/Staff Senate.

Pratt, 33, holds three degrees from Vanderbilt: a J.D. from the Law School and an M.A. and Ph.D. in sociology. She also earned an M.A. in literary studies and B.A. in English from the University of Iowa. In addition to her responsibilities as the University compliance officer, which reports directly to the Chancellor and Audit Committee of the Board of Trust, she is also the assistant secretary of the University and an attorney in the office of General Counsel.

For more information, visit call the compliance hot line, 322-1033

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