Compliance Updates

Important news and developments

Compliance Messages

Compliance Memos to Management.  This series of memoranda to supervisors and managers helps create awareness of the compliance & ethics program and their role in building a fair, ethical workplace. 

Memo on Research Compliance from the Vice Provost for Research & Graduate/Professional Studies (pdf)

President's Message on Sexual Assault and Harassment

Clery Act/Campus Safety:

  • Campus Security Authorities Memorandum.  This message from the Chief Compliance Officer notifies Campus Security Authorities of their reporting obligations under the Clery Act.
  • Annual Security Report. This report is required by the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, commonly known as the Clery Act.  The report contains policy statements and crime statistics for the school. 

Essential Matters Memorandum - for Faculty and Staff.  The Provost sends this notification to faculty and staff at the beginning of each academic year, reminding them of some of the most important compliance matters.

Welcome Back and Important Announcements - for Students.  This message from the Vice President for Student Affairs gives students information about important policies, rights, emergency procedures, and other compliance-related information.  

Notification of Drug Free Schools Act. William & Mary is required to provide this notice each year to employees and students.  In addition to providing information about the legal and health risks of drugs and alcohol, this notice also provides links to resources such as the Employee Assistance Program and other non-university affiliated support groups.  If you or someone that you know is in need of assistance, the Office of Human Resources is  available to help connect employees with the appropriate resource. Student issues or concerns may be shared with the Office of the Dean of Students.

Memo Regarding Parental Leave

Human Resources Memo re Form I-9 Hiring Requirements (pdf). The Form I-9 is a legally mandated form used for verifying the identity and employment authorization of individuals hired for employment in the United States. Both employees and employers (or authorized representatives of the employer) must complete the I-9 form within certain strict timeframes. A student employee also cannot begin work until the appropriate supervisor receives the completed Student Authorization to Work form.

Commonwealth of Virginia Notice: Whistle Blower Protection Act (pdf). A whistle blower who makes a good faith report of wrongdoing, fraud or abuse is protected under § 2.2-3011 of the Whistle Blower Protection Act.. A good faith report is a statement or testimony made truthfully and in good conscience, without ill intent or malice and with supporting evidence that a wrongdoing, fraud or abuse has occurred. 

Commonwealth of Virginia Notice: Fraud, Waste and Abuse Hotline (pdf). In order to encourage effective and efficient government practices and wise stewardship of taxpayer dollars in Virginia’s executive branch agencies, state employees and citizens have the opportunity to anonymously report suspected instances of fraud, waste or abuse of state resources through the hotline.

Memo re Application of University Procurement and Expenditure Policies (pdf). Effective for FY 2018, the university implemented new expenditure guidelines that provide greater flexibility for university employees using non-state funds to support William & Mary business

 
Rescission of Policy Protecting Transgender Employees


On October 4, 2017, the U.S. Department of Justice issued a memorandum rescinding a previous policy that prohibited employment discrimination on the basis of gender identity.  This policy change indicates a change in DOJ's approach in terms of whether and how transgender employees will be protected from discrimination or harassment under Title VII of the Civil Rights Act of 1964.  

W&M policy remains unchanged: it prohibits discrimination on the basis of gender identity or gender expression as well as any other "irrelevant personal factor."  To learn more, visit W&M's LGBTQ website.

 



Title IX Guidance Change

In September, 2017, the Office of Civil Rights of the U.S. Department of Education (OCR), which enforces Title IX, rescinded prior regulatory guidance (the 2011 Dear Colleague Letter) and issued new, interim guidance.  These actions relate to university's obligations to prevent and respond to sexual violence affecting students.  The change reflects a shift in focus from the civil rights of students reported to have experienced sexual violence; the new guidance is focused also on the due process rights of students reported to have engaged in sexual violence.  

The university has reviewed the new, interim guidance and is not making significant changes to its policies and procedures at this time. 

OCR has not indicated when the proposal for permanent (non-interim) guidance will be made, but has indicated that they will seek public comment. 

To learn more, several law firms and media outlets have published summaries and articles:
http://www.franczek.com/frontcenter-OCR_Title_IX_Withdraws_Obama.html 

https://www.insidehighered.com/news/2017/09/25/education-department-releases-interim-directions-title-ix-compliance  


Compliance Curriculum - for new hires
 
 

New faculty and staff are now receiving an introduction to W&M's Compliance and Ethics program through Cornerstone (the new HR system also used for performance management).  The introduction is in the form of a "Compliance Curriculum" and includes information on key policies and procedures.  New hires are also assigned the training course that covers sexual harassment, sexual assault, relationship violence, and stalking.  For more information, visit the Haven training website.  

This site last updated October 2017