Eunice-

This is a really interesting question! Like OSU, IU has affirmative duty to 
report non-compliance in a few policies like Fiscal 
Misconduct<http://policies.iu.edu/policies/categories/financial/accounting-administration/FIN-ACC-I-30-fiscal-misconduct.shtml>
 or in Programs Involving 
Children<http://policies.iu.edu/policies/categories/administration-operations/public-safety-institutional-assurance/PS-01.shtml>.
 However, overall I think we are working to improve our compliance culture with 
a fairly new university compliance 
program<http://www.iu.edu/~vpgc/compliance/compliance-program/index.shtml> and 
Principles of Ethical Conduct<http://principles.iu.edu/>, which were approved 
last year. The Principles speak to reporting non-compliance in one section:

ยง 5 - Promote a Culture of Compliance with Applicable Laws, Regulations, and 
Policies.
Indiana University is committed to meeting legal requirements and to fostering 
a culture of ethics and compliance.
A. Expectations - Community Members are expected to:

  1.  Learn and follow applicable laws, regulations, contracts, environmental 
health and safety policies, and all Indiana University policies and procedures 
applicable to their University duties and responsibilities;
  2.  Be proactive to prevent and detect any compliance violations or 
noncompliant activities;
  3.  Report violations or noncompliance to supervisors or other University 
officials with the assurance that Indiana University policy prohibits 
retaliation against anyone who does so in good faith; and
  4.  Ensure that reports of violations within their area of responsibility are 
properly resolved, including disclosure to sponsors or other state or federal 
authorities as appropriate.
B. Prohibition - Community Members are prohibited from:

  1.  Willfully violating applicable laws, regulations, and policies; and
  2.  Retaliating against another Community Member for reporting a suspected 
compliance violation.
Hope this helps!
Jenny


Jennifer U. Kincaid
Chief Policy Officer
Office of the Executive Vice President for University Academic Affairs
Indiana University
Bryan Hall 210
Bloomington, IN 47405
(812)856-1291
[email protected]<mailto:[email protected]>



From: [email protected] 
[mailto:[email protected]] On Behalf Of Hornsby, Eunice
Sent: Wednesday, July 16, 2014 3:29 PM
To: ACUPA
Subject: [acupa-l] Affirmative Duty to Report Noncompliance with Policy

All:

I was just in a meeting during which it was asked if we require all faculty, 
staff, and students to report noncompliance with policies.  At this point, we 
do with some policies but not with all.

I'd appreciate your advice:

-        How does your institution address duty/requirement to report 
noncompliance with policy.

-        Do you add such a requirement to all or some your policies?  If just 
some, what criteria do you consider when making this decision?

-        If you do require such reporting, is the report made to the employing 
unit, to the office that issues the policy, or somewhere else?

-        And, do you have standard wording regarding reporting noncompliance 
that you could share with me in the few days, whether or not you use it in all 
or just some of your policies?

I look forward to hearing from you.  -Eunice
Eunice Hornsby, Ph.D.
Policy and Training Director
The Ohio State University
Office of University Compliance and Integrity
1543 N. High St., Columbus, OH 43201-2190
614-292-8728 Office
[email protected]<mailto:[email protected]> 
compliance.osu.edu<http://compliance.osu.edu> 
osu.edu/policies/<http://www.osu.edu/policies/>



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