Institutional Compliance

Comparison of Federal Sentencing Guidelines, OIG Guidelines, and UToledo "Action Plan to Ensure Institutional Compliance"






Written policies and procedures

Step 14:  Develop a compliance manual which provides documentation of management’s considerations of compliance, sets forth expectations and standards of conduct and outlines methodologies to be employed to annually assess the effectiveness of the plan and the compliance officer


Compliance standards and procedures

Written policies and procedures, including a standard of conduct

Designated high-level manager as responsible for compliance program

Step 2:  University-Wide compliance officer


Step 3:  Component compliance officers


Specific individual within high-level personnel of the organization must have been assigned overall responsibility to oversee compliance with the standards and procedures


Designation of a compliance officer responsible for operating and monitoring the compliance program


Step 10:  Ensure that appropriate general compliance training for all employees and specialized training for appropriate employees is provided on a regular basis


Communicate effectively its standards and procedures to all employees and other agents by requiring participation in training and by disseminating publications explaining the program


Regular employee education and training programs

Auditing and Monitoring

Step 9:  Establish…  and develop a support structure to ensure accomplishment of the plan for each activity that is deemed high-risk


Step 15:  Annually audit the design and effectiveness of the UToledo compliance function and the component units











Auditing and monitoring










Periodic audits to monitor compliance

Anonymous reporting mechanism

Step 13:  Establish a confidential reporting mechanism


A method of reporting noncompliance without fear of retribution


A reporting mechanism to receive complaints anonymously

Consistent discipline for noncompliance

Step 12:  Follow-Up to determine that appropriate corrective, restorative, and/or disciplinary action has been taken in the event of noncompliance


Standards must be consistently enforced through appropriate disciplines of responsible individuals

Corrective action policies and procedures, including disciplinary policies, to respond to allegations of noncompliance

Responsible steps to correct any identified problems with compliance

Step 12 (see above)

After noncompliance is reported the organization must take reasonable steps to respond and prevent

Investigation and correction of identified systemic problems, including policies addressing the non-employment of sanctioned individuals

Last Updated: 1/3/23