ICO: A Year in Review
The Integrity and Compliance Office’s FY 2026 Annual Report provides a data-driven look at how VCU’s compliance program is evolving, where measurable progress has occurred and where the university has opportunities to continue strengthening its approach.
Across our offices in reporting, policy management, conflicts, disclosures, training and communications, the FY 2026 data will be used to identify trends and guide future priorities.
A Closer Look at Compliance Cases
During FY 2026, VCU reported 1.69 compliance cases per 100 employees, a significant decrease from the rate of 2.41 cases per 100 employees in FY 2025.
External benchmarking provides additional context. NAVEX, a software used to manage governance, risk and compliance, reported a benchmark of 1.65 reports per 100 employees, placing VCU very close to the broader benchmark.
The more important story, however, is not whether VCU sits slightly above or below an external number. The year-over-year change gives ICO an opportunity to examine what may be contributing to shifts in reporting behavior and whether reporting channels, awareness efforts or the types of concerns being raised are changing over time.
How individuals choose to report also provides useful information about VCU’s speak-up environment.
VCU’s anonymous reporting rate was 38%, compared with a NAVEX benchmark of 55%, meaning approximately six out of every ten individuals who raised concerns with VCU chose to identify themselves.
While anonymity remains an important option, identified reporting can provide investigators with greater opportunities to ask questions, gather additional information and maintain communication throughout the review process. Tracking this measure over time can help ICO better understand how employees are engaging with reporting systems and where additional education may be useful.
Beyond the Numbers
Case volume alone does not provide a complete picture of an ethics and compliance program. The Annual Report also examines what happens after concerns are received.
VCU’s adjusted substantiation rate (cases confirmed) was 30% in FY 2026, compared with a three-year internal benchmark of 22%. NAVEX reported an external benchmark of 44%.
The difference illustrates why compliance data requires context. Some concerns received by ICO could not move through a full investigative process because they did not contain an allegation of a policy violation, lacked sufficient information or did not receive the additional participation necessary to complete a review.
Rather than viewing substantiation as a simple measure of success or failure, the data can help identify opportunities to improve reporting guidance, encourage individuals to provide actionable information and better communicate what types of matters fall within ICO’s investigative responsibilities.
Retaliation data provides another area for continued attention. Concerns involving retaliation represented 5.8% of VCU reports, compared with a NAVEX benchmark of 3.3%.
One retaliation matter was substantiated during FY 2026, and the university took action to address the concern. The broader trend reinforces the importance of continued education around retaliation, Psychological Safety and the responsibilities of leaders when employees raise concerns.
Measurable Progress Through Policy Management
The Annual Report also demonstrates significant movement in VCU’s policy-management program.
At the end of FY 2026, 85% of university policies were current, and every remaining lapsed policy was under active review. The number of current policies increased by approximately 10% during the year.
That improvement represents more than an administrative milestone. Keeping policies current helps ensure that employees have access to reliable guidance, responsibilities remain clearly defined and university requirements reflect current operations.
The data also establishes a clear baseline for future years. ICO can now continue measuring not only the percentage of current policies, but also the pace of policy review, areas where delays occur and opportunities to make policy administration more efficient.
Conflict Disclosures: Higher Participation and a Smaller Backlog
FY 2026 also marked VCU’s transition of its Conflict of Interest and Commitment disclosure process to Lextegrity.
The university achieved a 91% disclosure completion rate, increasing from 88.61% the previous year.
Perhaps more significantly, VCU made substantial progress in reviewing those disclosures.
By the end of FY 2026, 82.6% of disclosures had been fully reviewed and cleared or otherwise resolved, compared with 54% the previous year.
That represents a 28.6 percentage-point increase in the proportion of disclosures reaching resolution.
The combination of higher participation and faster review provides a stronger foundation for identifying potential conflicts, resolving questions earlier and reducing administrative backlogs.
Expansion of ICO’s Training and Communications
The Annual Report also documents continued growth in ICO’s education and outreach efforts.
During FY 2026, ICO:
- Created seven trainings
- Integrated seven videos into trainings and communications efforts
- Published nine Compliance Corner blogs
- Developed additional job aids and practical resources for employees
- Achieved a 99.1% completion rate for Annual Ethics and Compliance Training
These measures provide a useful starting point for evaluating not only how much compliance education is being delivered, but eventually how employees engage with that information and whether training and communications are reaching the audiences that need them most.
Using Annual Report Data for Future Decisions
The value of an annual report documents what happened during the previous year and creates a baseline for years to come.
FY 2026 gives VCU measurable data across reporting activity, case outcomes, policy management, conflicts disclosures, training and communications. External benchmarks such as NAVEX can help provide context, but VCU’s own year-over-year trends are especially valuable for understanding where processes are improving and where additional attention may be needed.
Over time, these measures can help ICO identify emerging risks, evaluate whether initiatives are producing meaningful change and make increasingly data-informed decisions about where to focus resources next.
The FY 2026 Annual Report therefore represents more than a collection of numbers. It provides a clearer picture of how VCU’s integrity and compliance program is developing—and a stronger foundation for measuring where we go next.