Even for someone with experience in compliance or higher education, starting a program at a college or
university can be a daunting task. I have
read that a good first step is to “just do a
compliance risk assessment,” which sounds
like good advice until you stand
in the middle of campus and try
to figure out where to even begin.
College campuses are essentially
small towns, with different
constituencies, gathered for various
purposes, in a highly regulated
industry that is constantly changing.
This article outlines a simple road
map of practical steps that you can accomplish
(or at least begin) in the first six months of
your program. You should tailor this to your
institution, your priorities, and your known
risks—or to put that another way, this is one
practical approach to reviewing all areas of
compliance, but if you see that something’s on
fire, you might want to start there!
I. First things first: Vision and culture
You have to understand the vision, or why
your institution is starting this program in
the first place. Ask yourself, what are you
trying to accomplish? Is the compliance
program part of management or the board?
Is the purpose of the program oversight, or is
it service and support (though these are not
mutually exclusive)? What are the reporting
relationships for Compliance? How does this
office/function relate to other offices such
as internal audit and general counsel? How
and when will Compliance report findings or
issues to the senior leadership or the board?
You have to understand the culture of
your campus. How will leadership support
the development of the program, and how
will they support the program against
pushback? Who has the authority to make
change happen? It is also important to
consider what other functions exist that
support compliance objectives, such as
an enterprise risk function or a training
department, or offices such as internal
audit, insurance, or general counsel. Many
universities have a Compliance Committee,
which is an effective way to include
stakeholders, break down stovepipes,
and communicate about priorities and
A road map for starting a higher
education compliance program1
» Getting started is a challenge, so use your peers and the resources available.
» Take a methodical approach to understanding your culture, compliance structure, and requirements.
» Use the three‑tiered compliance risk assessment to identify and prioritize your early efforts.
» Be prepared to ask probing and well‑informed questions beyond, “What keeps you up at night?”
» Keep leaning forward toward your goals, and stay positive.
by Kenneth J. Liddle, Esq., MBA, CCEP, CFCM