Earlier this month, a large proportion of the university community received emails regarding online compliance training in such subjects as ethics, diversity and fraud. Some wondered whether the emails were spam. Some feared they represented a thinly disguised attempt to spread a computer virus. Still others accepted the message as real, but questioned the rationale: Why now? Why these subjects? What’s the goal?
The university’s chief compliance officer, Boyd Kumher, authored the emails and coordinates the university’s training efforts in this area. These modules in particular cover all staff and all individuals in supervisory roles, including faculty members who supervise others. Those who fell into one of those categories, and who were listed as part of the organization as of Dec. 31, 2013, should have received the emails. Since that time, Kumher has handled many queries individually, but in a special version of The Daily’s “five questions” feature, we give him a chance to address some of the most common issues in a campuswide setting.
Kumher, whose independent function reports to the senior vice president and general counsel, works within the Office of General Counsel and joined the university in 2010 as part of the university’s efforts to improve awareness of the practices that Case Western Reserve employees must follow as dictated by government laws and regulations or other relevant policies and codes. As our chief compliance officer, Kumher is responsible for providing regulatory updates, informing the community about the availability and use of the Integrity Hotline, and identification of key issues on which additional education or presentations are merited.
A committee of senior university leaders oversees the University Compliance Program. Chaired by Provost and Executive Vice President W.A. “Bud” Baeslack III, the group also includes the university’s general counsel, senior vice presidents for administration and finance, and the vice president for human resources.
Those who have additional questions or comments after reading this feature can contact Kumher at firstname.lastname@example.org or 216.368.0833.
1. So, the emails from you regarding online modules are legitimate, and the training is required. The next question is, why? We are an institution with more than 6,000 employees and more than 10,000 students. We receive hundreds of millions of dollars from government agencies, philanthropic organizations and individuals, as well as the thousands who pay tuition. We all have an obligation to act in the most professional and ethical manner possible, and the overwhelming majority of the members of our community do exactly that.
Even so, in an era full of ever-changing regulations and expectations, the university has a responsibility to provide clear guidance about both the rules and the reasoning behind them. We realize that everyone on campus faces immense demands on time, so we favored an approach that allows participants to complete training on their own schedules, rather than set arbitrary meeting times and then demand attendance.
2. What do you expect people to gain from these online sessions that they don’t already know through training that you and others have done? We see significant value in live presentations where attendees can ask questions and receive immediate answers. In addition, we can tailor those sessions to specific needs, providing information that is relevant to select staff, but not necessarily useful to all employees. By the same token, these online training sessions have their own distinct advantages:
Participants can control the way they learn from the programs to some extent by choosing to listen, read and listen, or just read much of the content.
They can proceed at their own pace.
Three of the modules take about 30 minutes each to complete. A fourth module, intended for supervisory employees only, takes about an hour to complete.
Unlike live presentations, they can be completed at any time of the day or night, and even completed over several days if an individual has to stop the training in the middle of a module.
The sessions include multiple scenario questions to allow participants to apply the information right away.
The training can be made available in a format that works with screen readers for the visually impaired. If you would like to use that format, contact me at email@example.com or 216.368.0833.
3. What is the goal of the modules? Our hope is that members of our community will have a deeper understanding of these key issues and also appreciate their responsibilities. The university does expect people to be aware of activities or trends that might indicate problems, but puts investigation and enforcement in the hands of those with expertise and responsibility for those activities. This training provides not only information, but also guidance about steps to take when people have concerns or questions.
That said, we also have a fourth, separate module for those who are in supervisory roles, people who are charged with greater responsibilities regarding reporting and enforcement. The emails we issued are customized by recipient and detail precisely which modules that person must complete.
4. Why is all of this compliance activity happening now? It’s really been an evolution within the organization that began several years before I arrived. Our Board of Trustees carries a fiduciary responsibility for the institution, and members have been proactive about ensuring that Case Western Reserve meets its legal and societal obligations as an institution of higher education.
Two of the first charges members gave President Snyder when she arrived involved a long-overdue update of the conflict of interest policy, as well as development of a coherent set of business policies, which previously had been spread across multiple settings and offices of the university. We all owe a great debt of gratitude to the faculty and staff involved in those two efforts, as well as the multiple organizations that reviewed the final documents before implementation.
Those processes highlighted additional areas where the university had opportunities to improve—including the creation of my position and expansion of training programs. My work with the university compliance committee has identified additional ways to improve existing programs and include new offerings, including this online training.
5. What’s next after the modules? The deadline to complete the modules for the majority of participants is Friday, March 28. I sent a second round of emails about two weeks after the first messages to ensure that all of those who should have received the notifications had been included. Those in the latter group have a deadline of Friday, April 11. The appropriate deadline is noted in the messages individuals received.
As you know, we already have received a great deal of feedback about our communication and the training itself. We’re going to continue to listen to people’s responses, and consider ways to improve what we have offered to date. We also will look to the compliance committee to provide direction about additional steps we can take to support the community in being part of an ethical, accountable and inclusive community.
Thank you for this opportunity to share some of the background about this initiative. Again, if anyone has questions, please contact me at firstname.lastname@example.org or 216.368.0833.