Integrity and Compliance Office

2022: The (ICO) Year That Was

Compliance Corner: Issue 1.9

Here in the Integrity and Compliance Office (ICO) we are looking back at the year that was and, like a lot of you, taking stock of what we accomplished and what lies ahead. So, in this final installment of Compliance Corner for 2022, we thought it would be fun to peek in on each of our team members to ask what they’ve been up to. 

Suzanne worked closely with compliance partners across VCU, leading sessions on creating a speak-up culture, consulting on compliance matters and running investigations. Suzanne acted as liaison between the ICO and the Board of Visitors, Compliance Advisory Committee and Compliance Steering Committee. She also inspired her small but mighty ICO team.

As December marks one year since Suzanne stepped into her role, we spoke to her about what that first year was like. You can read our interview with Suzanne below.

Jason spent much of 2022 migrating VCU policies from the old policy library to the newer, user-friendly version using a platform called DocTract. He also consulted on policy matters, assisted with more complex investigations, and wrote the quarterly Policy Points Newsletter. When we asked Jason what some of the most significant policy changes were this year, he said: “The new comprehensive Hazing Policy was a significant accomplishment in that it involved feedback from numerous constituencies at VCU and really brought us in line with best practices. The revised Visa Sponsorship policy was also a significant accomplishment because the old version was extremely dated and did not reflect current practice. We also worked with HR to make minor tweaks to many of their policies. This was an accomplishment simply by the sheer number of policies we worked on. Finally I think our new Interim Conflicts of Interest policy is a major accomplishment. This pilot policy sets us on a path to have a unified approach to non-research related COIs and COCs– something we’ve needed for some time.”   

Sara Jones , Program Manager, Analytics and Investigations – Trend Tracker

Sara spent a lot of 2022 coordinating investigations based on reports that came into the VCU Helpline (23%) or through our partners in offices like Employee Relations, Equity and Access Services, and Human Resources (77%). To date, we’ve received and tracked 244 reported concerns. Of those, 188 have been closed and 56 remain open with ongoing investigations or reviews.

Sara also managed the project to launch a new Conflict of Interest and Commitment (COI&C) policy and digital reporting tool. According to Sara, “This new tool will help VCU better track compliance with laws and regulations around conflicts of interest, while making it easier for employees to report and track their outside interests and activities. Look out for communication from the ICO about this new policy and reporting tool in 2023.”

Kim McQuillen, Compliance Training and Communications Specialist – Code Crusader

Since the ICO maintains the Code of Conduct Kim spent much of 2022 creating materials and messaging about that. She launched the annual training courses and worked with partners across VCU to help them create compliance messaging tailored for their employees. She also launched the ICO blog and email blasts to keep the VCU community updated on current trends and topics.

According to Kim, employees responded well to learning about compliance issues through stories. “We got positive feedback from people who liked reading the case studies we feature in the blog each month; these are based on actual investigations we conducted in the ICO, with takeaways highlighting what we learned from them. People also enjoyed the videos we produced for the last annual training, because they featured real, live VCU employees telling their stories about what they experienced when faced with compliance challenges.”

A Compliance Corner Chat with CECO Suzanne Milton

We sat down with Suzanne to talk about her first year as CECO at VCU.

Q1: Suzanne, you’re a Chief Ethics and Compliance Officer, or CECO. What exactly does a CECO do?

A1: My role is to engage everyone in the university community in building and sustaining a culture of integrity in every transaction.  Our team does this in many ways, but the most critical are engaging with all employees – including leaders, faculty and staff – and “connecting the dots” each day to demonstrate how integrity can contribute to our success.

Q2: Prior to coming to VCU in December of 2021, you worked in labor law and corporate compliance. What are some of the things that you find unique about running a compliance department in an academic setting? Any surprises?

A2: The focus on the “mission” of higher education has been inspiring.  The commitment to student success and academic freedom are powerful forces, and seem to unify the campus.  That is a powerful base to build on.  I have also been surprised at the remarkable complexity of VCU’s enterprise – I think many members of the public don’t appreciate what an operation a university is.

Q3: After a year in your role, what are some of the accomplishments of which you are most proud, and what challenges lie ahead?

A3: I am very proud of our team’s significant collaboration with partners on investigations, data sharing, policy development and risk assessment.  And I am very proud of our refreshed engagement with the community through the blog, case summaries and this year’s video-rich annual training.

Q4: People who know you know that you’re reluctant to toot your own horn. But, you are a rower and you recently rowed in a four-person crew in the Head of the Charles Regatta, the world’s largest 3-day rowing competition. Can you draw any analogies between rowing and leading your compliance team?

A4: I love rowing because it is the ultimate in teamwork – to make the boat “swing,” you have to be entirely in sync with your crewmates.  It is a magical feeling but requires lots of perseverance and focus.  Ethics and compliance is the same – we are all in this together!