Ohio State Restructuring Compliance Office, Creating New Position

The Ohio State Board of Trustees has approved the creation of a new compliance office that will oversee all three phases of compliance---athletic, medical, and research--at the university. The new department will be titled the Office of University Compliance and Integrity, and will be implemented over the next year.

According to The Lantern, the structure behind the new compliance policy was guided by two outside entities, Protiviti, an independent research company, and Dewey and LeBoeuf, a New York-based law firm. Bud Ellis, a partner at Dewey and LeBeouf, advised the Board of Trustees and recommended a hierarchical responsibility system with a single chief officer sitting at the top.

"(The chief officer) would have direct reporting to senior leadership at the university; in particular you have direct reporting to this (audit and compliance) committee, and it would have, on a day-to-day basis, dual reporting to the Office of Business and Finance and Legal Affairs," Ellis said. "The existing compliance personnel and some additional staff would report to the chief compliance and integrity officer. This would ensure direct reporting and clear lines of communication."

The plan will create an authority figure situated above existing compliance staff and below general university leadership like the Athletic Director and President, a new position that the Board believes will eliminate communication errors between departments.

In addition to the new position, the Board is considering "creating an enterprise-wide compliance and risk-assessment methodology," which simply means, jargon-free, that the university wants everyone speaking the same language and addressing the most dangerous compliance risks with adequate resources.

President E. Gordon Gee enumerated the benefits of this latter proposal for non-athletic purposes, noting that the "biggest vulnerability that we have with compliance is in our hospitals. The compliance in athletics is more public perception. If you spend a certain amount of your budget on athletics and it gets 90 percent of the airtime. So it's a perception that you want to get that right. The notion of having a centralized compliance system is that we have a filter that is constantly looking at our overall compliance."

Ohio State certainly needed to rework their compliance structure following the athletic gaffes of the past year, if only for public relations purposes. Without knowing the specific function of the new position, I remain skeptical about how much it can help prevent future violations, but there is undeniable value in homogenizing compliance language and clarifying expectations. In any bureaucracy, language barriers between staff and management can create issues that are resolvable through standardized diction.

If anyone has training in organizational management or compliance management, please speak up. Now's the time to grab some fame.