Compliance Corner – Issue 3.9
It’s in the Numbers
It’s that time again. Time to review all those Annual Reports published by organizations at the end of their fiscal years. In fact, by now, you may have read some of the ones published by the various units across VCU. We, in the Integrity and Compliance Office, recently published our Annual Report and we’d like to share some highlights, by the numbers.
235 – # of reported concerns
Members of the VCU community spoke up to report 235 concerns this year. This was a 10.2% decline from the previous fiscal year. However, within those reports we saw an uptick in the number of reports coming directly to our office via phone, and those coming into the VCU Helpline. Even better, the number of anonymous reports declined to 16%; that means 84% of those reporting a concern shared their name. These last two points are a positive sign: More employees knew how to find their way to the ICO or Helpline, and more felt a higher level of trust in our system than they had in the past.
62% of 15% – Employees who reported misconduct
We learned a lot from the Integrity Survey we sent out last spring, like how likely employees were to report misconduct when they observed it. 15% of employees observed misconduct, and 62% of those people decided to speak up about it. While 62% is 10 points lower than the global benchmark, we applaud the employees who knew that something wasn’t right and decided to do something about it. Having said that, we also want to share a different, related number:
22 – % of employees that were satisfied with the university’s response to their report
It’s true. 78% of respondents felt dissatisfied with the results of their reporting, and we think some of that is our fault. This number made us realize that we need to do a better job of setting expectations about the reporting process, especially when reports lead to investigations. When we investigate a concern, we interview the reporter, the subject of the investigation (who was alleged to have performed the misconduct, etc.), and others who may have witnessed the alleged behavior.
Sometimes, even though behavior is corroborated, it doesn’t violate any university policies or laws. In those instances, the allegations of the investigation may be deemed “unsubstantiated.” At other times, some of the behavior violates university policies or laws, and some of it doesn’t. In those cases, the allegations might be “partially substantiated.” Each case is unique, and the recommended sanctions might require the subject to receive counseling, or a reprimand, or a performance plan, or even termination. While we cannot share the results of investigations, we let each reporter know when their case has been closed and that sanctions were given, if appropriate. While reporters may feel dissatisfied with this ending, it’s an ending we must deliver to protect the confidentiality of employee records. And sometimes, reporters have to wait a while to hear that their case has been resolved; it took an average of 50 days to close investigations last year. The ICO intends to do a better job of explaining all of this to reporters at the beginning of the reporting/investigations process to set expectations and answer questions they might have at that time.
161 – # of VCU policies we manage
That’s a lot of policies! This number reflects the 7 policies we retired, the 26 that received minor revisions and the 14 that we added or revised in a big enough way that they seemed new. And did you know that all employees can view our policies at any time? You can visit the VCU Policy Library on the ICO website and search for the topic or name of the policy you want to read.
2,031 – # of employees in “Positions of Trust”
These employees are required to complete the Conflict of Interest and Commitment questionnaire each year to disclose conflicts like OPAs (Outside Professional Activities). Doing this protects the employees and the university from the appearance of conflicts that could influence the way we make decisions on the job. And here’s another number: At the time of publication of the Annual Report, 83% of employees in positions of trust (1,683) had submitted their disclosures. Well done!
8 – # of videos produced by the ICO
We produced a series of videos based on investigations we’ve conducted over the years. In the original video, “Welcome (With Conditions),” we met a new professor named Dr. Watkins who was being mistreated by his department chair, Dr. Evans. This video appeared as part of the required training assigned through Talent during the fall of 2023. The video was so well-received, we decided to tell more of the story. So, we called all the actors back and created seven more videos to see what each of their characters did in response to the situation. Some spoke up about it, and some didn’t. Some talked to investigators from our office, and some decided not to. In the final two videos, we heard from the victim, Dr. Watkins, and the subject of the investigation, Dr. Evans, to hear how they were doing after the investigation was closed. By showing multiple viewpoints, we hoped employees would see themselves in at least one of the characters, and learn how to get support for whatever it was that they needed. If you didn’t get to watch all of the videos, you can find them in the ICO Resource Library, under CORE Training Videos.
8,821 – # of Employees who completed the annual Ethics and Compliance Training
To be clear: We know what a slog those required trainings can be, and we want to say THANK YOU to the 8,821 of you who completed ours. We heard from many of you what you liked, what you didn’t like, what you found immediately applicable to the work that you do, and what else you’d like to see. We are here for YOU, and we are working to respect your time even more by making our training shorter, more meaningful and more relevant to the work that you do.
We’d like to leave you with two final numbers:
(804) 828-2336 – The number to call when you just want to ask questions or get advice
Sometimes you just want to talk to someone. Maybe you need a sounding-board, to find out if that thing that you thought might be a thing is actually a thing you should report. Or, maybe you’ve decided to speak up, but you’re not sure about the process. For all of those reasons, you can call us in the ICO during normal business hours and say that you need to talk to someone. A note of caution, though: Unless you are ready to report, you should speak in hypotheticals during this conversation. ICO employees, like all VCU employees, are bound by the Duty to Report and Protection from Retaliation policy, so if you give us specifics, we have to report the misconduct.
(888) 242-6022 – The VCU Helpline, and the number to call when you are ready to make a report through our third-party
Some people prefer to call someone who’s not at VCU to report a concern. Using the VCU Helpline allows you to do this. You’ll have the option to remain anonymous and the agent will send us the report so we can look into your concern.
All in all, FY 2024 was a pretty busy year in the ICO, just like in your unit. Often, when we’re in the middle of a task or a project, or a crisis, we lose sight of just how much each of us does to carry out VCU’s mission. Here’s to all of you who do what you do to make that happen, and if you ever need a reminder of the impact your unit has made, just take a look at your last Annual Report; it’s in the numbers.
If you have an idea for the ICO Blog, please contact us at [email protected]. We’d love to hear from you!