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Administration

Compliance and Ethics FAQs

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​​Fraud FAQs​

Q: What is fraud?

Fraud is the use of your occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization's resources or assets. Fraud is normally considered to be a criminal act, and employees who commit fraud may be terminated, fined, and/or imprisoned depending on the severity of the fraudulent act.

​For additional information, see:

System Administrative Memorandum
01.C.04 - Reporting/Investigating Fraudulent Acts

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Q: What are some examples of fraud?

Examples of fraud include:

      • ​​​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
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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.

Examples of issues that should not be reported through MySafeCampus include:​

​Issue in the Workplace​Contact​
  • Employee/supervisor disputes
  • Affirmative Action/EEO issues​​
  • Harassment or misconduct
Campus Relations/Affirmative Action Officer
Phone: 713 -222-5818
  • ​​Violent crimes, breaking and entering, or burglary
  • Medical emergencies
  • Fire
UHD Police Department
Phone: 713 -221-8065 or 713 -221-8911
  • Hazardous waste spill
  • Problem with the building
Environmental Health and Safety Manager
Phone: 713 -221-8040
  • Problem with the building
Facilities Management
Phone: 713 -221-8026​

 

The Institutional Compliance Program was established to develop standards and procedures to help ensure UH Systems' compliance with federal and state laws and regulations. Many of the policies and procedures of UH System and UHD are based upon these legal requirements.

Development of the University of Houston System Institutional Compliance Program began in 2002 with an Institutional Compliance Action Plan. Under this plan, each component university in the UH System was required to:

      • Designate both an Institutional Compliance Officer
      • Appoint an Institutional Compliance Committee that meets at least quarterly
      • Identify and assess the risk to the University
      • Develop a High-Risk Management Program that meets the criteria for the U.S. Sentencing Guidelines
      • Establish a Confidential Hotline to allow individuals to report suspected fraud outside of the normal chain of command
      • Ensure specialized compliance training for employees in high risk areas and general compliance training for all employees
      • Submit a quarterly component University reports on compliance activities to the UH System Compliance Officer for quarterly Board of Regent reports
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Q: What are the elements of a good Compliance Program?

The elements of an effective Compliance Program are based upon the requirements of the United States Sentencing Guidelines​, revised in November 2007. 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 Compliance Program at UHD is structured upon the following components:​
Item Comments
Action Plan​Developed for UH System and currently in place
Executive Officer David Bradley
Compliance Officer Mary Cook
Compliance Committee Membership varies periodically to accommodate identified high level risk
Infrastructure Training (for Committee Members)David Crawford(Co-Author of "Effective Compliance Systems: A Practical Guide for Educational Institutions")
Risk AssessmentInitial/Periodic Risk Assessment and Identification of Institutional Level Risk
Assurance StrategiesConfidential Reporting Mechanism in Place (MySafeCampus)
Risk ManagementRisk Management Program for identified Institutional level risks are developed by Responsible Party and Subject Matter Expert in conjunction with Compliance Officer
Predefined Consequence of NoncomplianceIncludes training, reprimand, loss of authority, suspension and/or termination
Employee Compliance and Ethics GuideIncluded in this Web-site
Assurance StrategiesIncludes reports, monitoring and audits
General Compliance Training Employee training specifically applied to work responsibilities, Employee Compliance and Ethics Guide and Compliance and MySafeCampus video
Assessment of the Compliance ProgramIncludes self-assessment and internal audit to assess the ongoing effectiveness of the compliance program

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.

Internally, you can:

      • Notify your Supervisor
      • Notify UHD Management
      • Notify the Compliance Officer (Mary Cook at (713) 222-5340, room 621 S)
      • Notify the Director of Internal Audit (Don Guyton at (713) 743-8000)

​​Externally and anonymously via phone call or the web you can contact:

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Q: With all of the concerns about risk, who is responsible for resolving the risks?​

 

Compliance with applicable laws, rules, regulations, and policies is the personal responsibility of every employee at UHD. Each one of us is a risks 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.

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Compliance and Ethics
Last updated 9/17/2015 3:10 AM