Stephen F. Austin State University

Compliance Area Responsibility

Committees

Executive Oversight Compliance Committee

This committee is comprised of senior administration. Its primary function is to direct policy and instill the importance of compliance in the university community. This committee monitors progress on key compliance initiatives, reviews updates on compliance developments and best practices, and allocates resources as necessary to achieve the compliance program goals.

Current Members:

Dr. Baker Pattillo, President

Dr. Ric Berry, Vice President for Academic Affairs

Dr. Steve Westbrook, Vice President for Student Affairs

Danny Gallant, Vice President for Finance and Administration

Jill Still, Vice President for University Advancement

Dr. Mary Nelle Brunson, Associate Provost

Gina Oglesbee, Director of Audit Services

Damon Derrick, General Counsel

Compliance Coordinating Committee

This committee is comprised of key representatives from various departments within the university. Its primary function is to oversee the implementation of the compliance program throughout the university. This committee disseminates information about compliance updates and activities to the responsible parties and keeps those individuals updated on any changes in laws or regulations.

Compliance Matrix

The following compliance matrix was created to assist the responsible parties in carrying out their duties as related to the compliance obligations of the university. The matrix is designed to further the coordination and documentation efforts of existing and ongoing compliance initiatives at the state level. The matrix is broken down into different compliance areas followed by the departments responsible for ensuring compliance, representative issues associated with the compliance area and applicable state laws.

For information regarding compliance with federal laws, please refer to the Higher Education Compliance Alliance Compliance Matrix (http://www.higheredcompliance.org/matrix/). The responsible parties for each compliance area in the below matrix are also responsible for the corresponding areas in the HECA matrix.

SFA Compliance Matrix

Compliance Area

Cognizant Policy Officer

Compliance Partner(s)

Representative Issues

Applicable State Laws

Academic Programs Provost & Vice President for Academic Affairs Associate Provost,
Deans, Academic Department Heads
Externships/internships and Placement; Constitution Day; Releases/Waivers; Non-Discrimination; Immigration Issues/Visas; Domestic and Foreign Programs Off-Campus; Faculty Re-Appointments, Promotion and Tenure, Development Education and Texas Success Initiative 19 Tex. Admin. Code §§ 4.10, .51-.60; Tex. Educ. Code § 51.3062; Tex. Educ. Code § 51.942(d).
Accounting VP for Finance & Administration Director of Budget,
Director of Financial Services, Controller
Institutional Conflict of Interest; state accounting; Fiduciary Obligations; Investments
Accreditation Provost & Vice President for Academic Affairs Associate Provost, Deans, Academic Department Heads SACS requirements
Admissions Provost & Vice President for Academic Affairs Executive Director of Enrollment Management, Assistant Directors Automatic Admissions; Bacterial Meningitis Vaccinations Requirements Tex. Educ. Code § 51.803-.804Tex. Educ. Code § 51.9192
Athletics Director of Athletics Athletic Director, Assistant Directors, Associate Director of Athletic Compliance/Student Services Title IX; Liability (incl.consent/release forms); Trainers; Recruiting; NCAA; Student Records; Transportation; Summer Camps
Auxiliary Services VP for University Affairs Director of Student Services,
Director of Divisional Operations,
Director of Athletics
Food vendor relations; Public Health Inspections; service of alcohol; ADA/504 in dining; Student Organizations; Student Travel; Student Code of Conduct; Student Discipline; Risk Management; Summer Camp and Special Events; Releases/ Waivers and Facilities Use Forms; Indemnification; Assumptions of Risk; Parental Consent Forms; Appropriate Supervision; Background Checks; Insurance; Best Practices; Greek Organizations Texas Alcoholic Beverage Code; Tex. Educ. Code §§ 37.151-.157, 51.9361; Tex. Educ. Code § 51.950; Campus Programs for Minors
Campus Safety/Emergency Management VP for UniversityAffairs Executive Director of Public Safety/Chief of Police Clery Act Reporting; Emergency Planning; Incident/Accident Investigations; Law Enforcement Records/Student Records; Missing Student Notification; Applicability of Criminal Laws; Local Agency Relations; Public Health Issues; Transportation; Goods & Supplies; Communications; Documented Plan Tex. Health & Safety Code §§ 502.001-.019; Tex. Health & Safety Code § 361;Tex. Educ. Code § 51.201-.211; The Texas Emergency Management Plan, Governor's Division of Emergency Management; Texas Hazardous Substances Spill Prevention and Control Act, Tex. Water Code §§ 26.261-.267; Texas Disaster Act of 1975, Tex. Gov't Code §§ 418.001-.191; Tex. Gov't Code §§ 433.001-.007; Executive Order by the Governor, Exec. Order RP32 or current version; Tex. Att'y Gen. Op. No. MW-140 (1980);
Contracts & Procurement VP for Finance & Administration General Counsel, Director of Procurement, Director of Research and Sponsored Programs Conflict of Interest; Contract Administration Policy; Compliance Provisions in Contracts (e.g. FERPA, HIPAA, GLB, Intellectual Property); Best Value Procurement; HUB; Payment to Vendors; Property Management; Interagency Cooperation; Membership Dues; Nepotism Prohibitions; Tex. Gov't Code Ch. 771, 791; Tex. Const. art. XVI, § 21; Tex. Gov't Code § 2107.008; Tex. Gov't Code § 2252.903; Tex. Gov't Code § 2113.104; Tex. Gov't Code § 2252.901; Tex. Gov't Code Ch. 2254; Tex. Gov't Code Ch. 573; State Comptroller Fiscal Policies and Procedures; Tex. Educ. Code § 51.9335; Tex. Gov't Code § 669.003; Tex. Gov't Code §§ 2252.001-.004; 2251; Tex. Gov't Code §§ 403.2715, 403.272, 403.273(h), 403.275; Tex. Gov't Code § 2054.003(3)(A). Tex. Gov't Code §§ 2175.304, .905; Tex. Gov't Code § 2203.004; 1 Tex Admin. Code § 202.78 Tex. Gov't Code Ch. 2161; 34 Tex. Admin. Code §§ 20.11-.28;
Copyright & Trademark President General Counsel, Director of Athletics, Executive Director of Marketing & Public Affairs Libel/Slander; Confidentiality; Copyright Public Information Act, Gov't Ch 552;Tex. Bus. & Com. Code §§ 16.01-16.31; Tex. Educ. Code § 51.912;
Disabilities VP for University Affairs Director of Disability Services Employee, Student and Visitor Access/Accommodations under ADA/504; Service and Therapy Animals; Web Accessibility 1 Tex. Admin. Code Chapter 213;Health and Safety Code Title 7; Texas Commission on Human Rights Act, Tex. Lab. Code §§ 21.051-129; Nacogdoches, Tex., Rev. Ordinances ch. 6, art. III, §§ 32-33 (2008);
Diversity/Affirmative Action VP for Finance & Administration Director of Human Resources, General Counsel ADA; ADEA; Title VI and Title VII; Section504; Title IX; Academic and Work Environment; Policies and Complaint Reporting/Investigation Systems; Training of university Officials; Hiring/Promoting Criteria and Process; Affirmative Action Tex. Hum. Res. Code §§ 121.001, .003(f); Tex. Gov't Code §§ 657.002-.007; Tex. Lab. Code Ch. 21; Tex. Const. art I, § 3a; Texas General Appropriations Act
Environmental Health & OccupationalSafety VP for Finance & Administration Director of Environmental Health, Safety, & Risk Management Vehicle, Fire, Building and Facilities Safety/Codes; OSHA / Workplace Safety; Workers' Compensation; Chemicals; Waste Management; HazMat; Lab Safety; DHS & EPA Regulations ; Indoor Air Quality; Safety Trainings; Emergency Plans; Insurance SORM rules; Tex. Gov't Code §§ 2165.301-.305; 28 Tex. Admin. Code Ch. 251-252; Tex. Ins. Code Ch. 1305; 25 Tex. Admin. Code Ch. 289
Ethics President General Counsel Tex. Gov't Code §§ 403.271(a)-.278, 552.352, 556.004-.009, 2203.004, 2254.032, 2262.004, Ch. 553, 572-573, 2256; Tex. Penal Code Ch. 36, § 39.02; Tex. Educ. Code §§ 51.912, .923; Tex. Gov't Code § 572.051
Export Controls Provost & Vice President for Academic Affairs Director of Research and Sponsored ProgramsGeneral Counsel
Financial Aid Provost & Vice President for Academic Affairs Director of Financial Aid Awards/Disbursements; Institutional Eligibility for Title IV Funds; Obligations Under Title IV; Federal Work Study; Code of Conduct Tex. Gov't Code § 572.051
Fiscal Management VP for Finance & Administration Controller, Director of Financial Services, Director of Procurement and Property Services Cash; Credit & Debit Cards; Allowable Expenses; Property Inventory; System Controls; Accounts Payable/Receivable; Purchasing; PCI DSS
Fundraising & Development VP for University Advancement Associate Director of Development Donor Gifts; Gift Restrictions; Confidentiality; Volunteers; CAN-SPAM; Charitable Substantiation Rules; PCIDSS (credit card use) Substantiation and Disclosure Provisions; Charitable Registration Laws (States); Tex. Educ. Code §§ 51.001-.009, 95.34, Ch. 101; Uniform Prudent Management of Institutional Funds Act, Tex. Prop. Code Ch. 163; Uniform Prudent Investor Act, Tex. Prop. Code Ch. 117; Texas Public Funds Investment Act, Tex. Gov't Code Ch. 2256; Tex. Penal Code Ch. 36; Tex. Gov't Code § 2255.001
Governance Board of Regents General Counsel Transparency; Conflicts of Interest; BOR Rules and Regulations; Board of Regents Committees; Regent duties and responsibilities; Ethics Open Meetings Act; Tex. Educ. Code § 51.352, Chapters 95 and 101; SACS requirements; Good Governance practices
Grants Management Provost & Vice President for Academic Affairs Director of Research & Sponsored Programs Pre-Award Requirements; Effort Certifications; Post-Award Requirements; Financial Reporting; Regulatory Review/Approval Texas Uniform Grant Management Standards II (B) (11) (h) (1-5, 7); Tex. Educ. Code § 145.001; Tex. Educ. Code §§ 62.091-.098; 19 Tex. Admin. Code §§ 13.120-.127; Tex. Educ. Code § 141
Health Care & Insurance VP for Finance & Administration Director of Environmental Health, Safety, & Risk Management, General Counsel Required/Recommended Types, Scope & Coverage Limits; Incident Reporting; Required & Best Practices for Covered Compliance Areas; Indemnity; Insurance Certificate Tracking SORM guidelines; Texas Tort Claims Act
Housing VP for University Affairs Director of Residence Life Residential Life; ADA/504/FHA in housing
Human Resources VP for Finance & Administration Director of HR Employment Benefits & Leaves; FMLA; USERRA; Wage/Hour; Personnel Policies; Recruiting/Hiring; Supervisor Training; Termination/Departure/Early Retirement; Immigration; Affirmative Action; Dual Employment; Employment Records Tx Code Sec 411.1405 (Criminal History), Tx Code 672.001 (Preference hiring former foster children), Tx Code 657.003 (Veteran's Preference); Tex. Civ. Prac. & Rem. Code § 106.001; Tex. Hum. Res. Code §§ 121.001, .003(f); Tex. Gov't Code §§ 657.002-.007; Tex. Lab. Code Ch. 21; Tex. Const. art I, § 3a; Texas General Appropriations Act; Tex. Const. art. XVI,; Tex. Gov't Code §§ 667.001-.007; Tx Gov't Code, Sect 656.001, 024, 025, 026; Texas Govt. Code 552.024; Tx Gov't Code, Sect 572.051 (c-d); Tex. Educ. Code § 51.215; Tex. Gov't Code § 411.094; Tex. Gov't Code § 651.005
Immigration Provost & Vice President for Academic Affairs, VP for Finance & Administration Director of International Programs, Director of HR, Controller Study Abroad; Foreign Scholars & Students; Visiting Artists/Lecturers; Immigration (Taxes & SEVP)
Information Technology Provost & Vice President for Academic Affairs Director of IT Services Internet File-Sharing; DMCA Agent; Appropriate Use/Access; Email Privacy; Network Security; PCI DSS; Web Accessibility; Export Controls; Records Retention; Response to Law Enforcement / Agency Inquiries; Access to and production of public information; Response to subpoenas Tex. Gov't Code § 441.180-.205; 13 Tex. Admin. Code Ch. 6; Tex. Educ. Code § 51.912; Tex. Gov't Code Ch. 552; 1 Tex. Admin. Code §§ 202.1-.2, .70-.78; Texas Information Resources Management Act; Tex. Gov't Code § 2054; 1 Tex. Admin. Code §§ 202.70-.78; Tex. Penal Code Ch. 39.01-02
Intellectual Property & Technology Transfer Provost & Vice President for Academic Affairs, VP for University Advancement, Director of Athletics General Counsel, Executive Director of Marketing and Public Affairs, Director of IT Services Copyrights; University Marks; License Agreements; DMCA; PTP; ASCAP/BMI Licenses Tex. Educ. Code § 51.912
International Activities and Programs Provost & Vice President for Academic Affairs Director of International Programs
Privacy and Information Security President Registrar, Director of Health Clinic, Director of Counseling Services, Director of HR, Controller, Director of IT Services Student Records; Employee Medical Records; Personal Financial Information; Employee Protected Health Information; Credit Card information; Information Security Program; ITAR / EAR; Identity Theft Program; Background Checks Records State privacy laws; Tex. Gov't Code §§ 441.180-.205; 13 Tex. Admin. Code Ch. 6
Program Integrity Rules Provost & Vice President for Academic Affairs
Research Provost & Vice President for Academic Affairs Director of Research and Sponsored Programs, Chair of IRB Human Subjects (IRB); Animal Use & Care; Scientific Misconduct; Informed Consent; ITAR / EAR (Export Controls) Ethical Principles and Guidelines for the Protection of Human Subjects in Research: The Belmont Report
Sexual Misconduct VP for University Affairs Director of HR, Chief of Police/Director of Public Safety, Senior Women's Administrator, Dean of Student Affairs
Student Health and Counseling VP for University Affairs Director of Health Clinic, Director of Counseling Services Health Center and Counseling Center; Troubled Students; State & local reporting; medical insurance billing Texas Counseling Association Ethical Code; Texas Family Code, Chapter 107
Tax VP for Finance & Administration Controller, General Counsel, Director of Financial Services 501(c)(3) Issues; 990 Issues; State Taxes; Tax Reporting Obligations; UBIT; Benefit Plans; Fringe Benefits; Income Tax Withholding; Bond/Debt. Mgmt.; Restrictions on Political Campaigns Events, Legislative Liaison Matters, etc.