Developing an Institutional Compliance Program: A Case Study Assessing the Organizational Structure of Two Universities

Compliance programs have grown since the early 1990s and evolved more formally into corporate institutional or enterprise-wide programs with the passage of the Sarbanes-Oxley Act of 2002. Formal institutional compliance programs are emerging in colleges and universities to assist in the management of the myriad of regulations and requirements placed on them by accrediting bodies, creditors, boards, donors, grantors, and federal and state regulators. An effective compliance program provides the structure for the institution and its employees to conduct operations ethically, with integrity, and in compliance with legal and regulatory requirements. The goals of this study were to identify organizational structures that assist large, public universities in effectively managing institutional compliance, the elements that shape these structures, and the benefits and limitations of those structures.