University Compliance Program
WesternU’s Compliance Program is designed to proactively identify, assess, and mitigate compliance risk across all colleges, departments, and administrative units. Anchored in a commitment to ethical conduct, institutional accountability, and continuous improvement, the Program aligns with federal and state regulatory guidance, including the U.S. Department of Justice’s elements of an effective compliance program, as well as accreditation standards and applicable policies. It evolves in response to lessons learned from compliance reviews, audit findings, and external guidance to ensure relevance and effectiveness across the institution.
The Program is structured around the 7 core elements:
- Compliance Oversight & Leadership
- Standards, Policies, & Procedures
- Communication & Training
- Monitoring & Auditing
- Reporting & Investigation
- Enforcement & Accountability
- Response & Prevention
University Compliance Committee
The University Compliance Committee is a cross-functional body that brings Compliance Partners together to share information, coordinate on compliance matters, and support the effectiveness of WesternU’s University Compliance Program. The Committee serves as a forum where members partner with University Compliance to assess compliance within their own areas and help define the university’s compliance universe.
The Committee shall:
- Promote awareness of regulatory compliance requirements.
- Provide input into the development, implementation, and evaluation of the institutional compliance program.
- Support the creation and maintenance of effective policies and procedures.
- Oversee compliance-related education, training, monitoring, and reporting efforts.
- Recommend strategies for addressing compliance gaps and risks.
- Foster cross-functional communication and alignment across university departments.
Responsibilities
The Committee is responsible for:
- Reviewing compliance risks and mitigation strategies identified through audits, assessments, and incident reports.
- Advising on the implementation of the Seven Elements of an Effective Compliance Program:
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- Compliance Oversight & Leadership
- Standards, Policies, & Procedures
- Communication & Training
- Monitoring & Auditing
- Reporting & Investigation
- Enforcement & Accountability
- Response & Prevention
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- Supporting the evaluation and continuous improvement of compliance activities, using the DOJ’s “Evaluation of Corporate Compliance Programs” framework.
- Reviewing and endorsing the university-wide Compliance Plan and Compliance Matrix.
- Participating in policy review cycles and promoting department-specific compliance accountability.
- Reviewing compliance training metrics and completion rates.
- Recommending priority areas for internal audits or external reviews.
University Compliance Committee membership consists of the Compliance Partners
RACI Model
The University Compliance Program has built the RACI model — Responsible, Accountable, Consulted, Informed — into its governance structure and its policy architecture.
Operational Owner who performs the task. The person or office that does the actual work.
Owns the outcome. One name only — the person who signs off and answers for the result.
Subject matter experts who provide input before a decision is finalized. Two-way conversation, not a formality.
Kept up to date after the fact. One-way notice, no input required.