About the Compliance Services Office

 

The Compliance Services Office coordinates the University’s efforts to meet compliance obligations efficiently and effectively and fosters ethical behavior and a culture of integrity through reinforcement of Boston University’s Code of Ethical Conduct and Conflict of Interest Policy.

We fulfill this mission by:

• Supporting departments with a primary responsibility for compliance, and assisting the University’s Compliance Area and Operational owners with monitoring, identifying, and understanding new and existing compliance obligations.
• Providing safe, confidential, and effective mechanisms for asking questions and reporting about compliance and ethics issues.
• Collaborating with offices across the university to ensure that  compliance matters are resolved in a manner that uphold community standards of integrity and ethical behavior.
• Promoting and facilitating the University’s confidential Ethics and Compliance Hotline, and assisting the Compliance Committee with oversight of case investigations and outcomes.
• Enabling access to the University’s Policies and Procedures through management of a central Policies webpage.
• Providing advice to the Boston University community on compliance and ethics issues.
• Assisting with the development and implementation of the University’s compliance training and education efforts.

In furtherance of our mission and activities, the Compliance Services Office endeavors to be knowledgeable, responsive, and ethical.

Compliance Services is a resource for the entire Boston University community. The Compliance Services Office supports the departments with primary responsibility for compliance and coordinates the University’s efforts to meet these obligations efficiently and effectively. Compliance Services is available to assist all members of the University community in clarifying obligations, assessing risk and prioritizing compliance projects, developing and providing training, maintaining lines of communication that allow anyone to report a concern, monitoring and assessing compliance efforts, and taking corrective action as necessary to address concerns.

 

Compliance Services Office Core Responsibilities
Compliance Program	Maintain a University-wide Compliance Program committed to meeting the legal obligations more efficiently and effectively through a compliance framework for communicating about and tackling compliance. The Framework includes six components: (1) clarifying obligations; (2) establishing priorities; (3) develop procedures; (4) provide training; (5) report and investigate concerns; and (6) monitor and correct course.
Policy Website	Maintain the University’s central policy website www.bu.edu/policies Identify policy gaps, facilitate updates to existing policies with Policy owners as needed, monitor policy changes, provide information about the Policy and Procedure governance process, and communicate with the University community about policies.
Conflict of Interest Process and Oversight	Facilitate and oversee the University’s annual conflict of interest disclosure process pursuant to the Conflict of Interest Policy governing financial, family, and organizational conflicts, and implement management plans as necessary.
Compliance Accountability Matrix	Maintain a Compliance Matrix and inventory of compliance obligations which includes identifying responsible individuals and units charged with meeting compliance obligations. The matrix establishes campus ownership of compliance obligations in a transparent way.
Ethics and Compliance Hotline Oversight and Facilitation	Oversees the University’s Ethics and Compliance Hotline and assist with other non-Hotline complaints and reports made to the Compliance Office through email, phone, and referrals. Consults on all investigations, prepares investigation reports, conducts some investigations, prepares response provided to reporter at case closure.

Compliance Services Office Ongoing Activities and Projects The Office contributes to these campus compliance obligations and initiatives by coordinating with other offices and stakeholders.
Enterprise Risk Management (ERM)	Contributes to the University-wide Enterprise Risk Management effort that identifies compliance (and other) risks across the University, and works to evaluate and mitigate risks.
Training	Oversees and manages the University-wide training on Sexual Misconduct Prevention and Harassment and Discrimination prevention taken by all employees, and assists with the implementation of the student training managed by the Health Promotion and Prevention Office. Promotes training and professional development of individuals on campus who have compliance responsibilities, and assists in assessing training gaps, and making recommendations for future trainings. Manages relationship with the University’s primary training content vendor.
Ongoing Monitoring	Work closely with Internal Audit and Advisory Services, the Office of the General Counsel, Research Compliance, and other offices to monitor ongoing compliance efforts and determine resources needed to manage existing, changing, and new compliance obligations. Implements procedures for identifying areas of compliance vulnerability and assists in managing and mitigating risks, and documenting processes.
Contribute to specific compliance obligations and projects	Clery Act Compliance: Facilitate Clery compliance tasks with OGC, BUPD, and others throughout campus, including CSA designation. Protection of Minors: Contributes to working group that manages the Protection of Minors Program, delivers trainings, answers questions, and provides programs with information and resources to facilitate compliance with the Protection of Minors Policy. Title IX: Supports and contributes to ongoing Title IX efforts as needed, including monitoring changes to the federal and state regulatory landscape, and assisting with Climate Survey efforts. Privacy: Coordinate Privacy efforts by co-leading a Privacy Coordinating Committee. Drug Free Schools and Communities Act: Prepare the Biennial Drug and Alcohol Review Report.

We work with compliance partners across the University to clarify obligations; coordinate compliance activities; support training and other educational efforts; investigate compliance concerns and identify, assess and mitigate risks. To that end, we offer a number of services to help assess and address compliance issues, including:

–  Table top exercises:  Guided discussion of simulated hypothetical scenarios to clarify roles and responsibilities for responding to incidents.
–  Risk assessments:  Discussion with key stakeholders to identify potential compliance gaps of concern and assess the risks presented by those gaps.
–  After action reviews:  Structured review or de-brief process to assess a recent incident, focusing on identifying what went well and what could be improved in responding to a similar
incident in the future.

The Compliance Services Office partners include the Office of the General Counsel, Internal Audit and Advisory Services,  the Director of Health Privacy and Compliance, Research Compliance, Information Security within IS&T, and the Associate Director of Enterprise Risk Management and Planning. We encourage you to reach out to report any compliance concerns or to discuss any questions related to compliance obligations.

Nedra Abbruzzese-Werling, Associate Vice President for Compliance Services

Nedra has overseen Boston University’s Compliance Services Office since 2016. The Compliance Services Office (CSO) is a resource for the entire Boston University community that works with compliance partners across the institution to clarify obligations, coordinate compliance activities, support training and other educational efforts, investigate compliance concerns and identify, assess and mitigate risks.  In her role, Nedra provides leadership and guidance in support of the University’s compliance efforts. As AVP for Compliance Services, Nedra is responsible for carrying out all of the office’s responsibilities as described above on this webpage, including CSO’s core functions of Hotline facilitation, conflict of interest oversight, and management of the Policies website. CSO reports up to the General Counsel and the Board of Trustees Audit Committee.

Prior to BU, Nedra facilitated compliance efforts for the State University of New York (SUNY) System Administration, where she served as the Director of Compliance and Ethics. Nedra’s duties at SUNY were to establish, coordinate, and maintain a University-wide Compliance function to serve the SUNY system of campuses, act as a central resource for individual campus compliance efforts, maintain the system-wide policy website, and help with training efforts. Nedra also served as the System-wide Ethics Officer and System-wide Records Management Officer. Prior to SUNY, Nedra worked for over seven years in higher education administration at the University of Connecticut School of Law. Nedra graduated from the University of Connecticut, cum laude, and received her J.D. from the University of Connecticut School of Law. 

Send Nedra an email

Samantha Khosla, Compliance Director

Samantha facilitates the daily operations of the Compliance Services Office (CSO) and supports the office’s mission to coordinate the University’s efforts to meet compliance obligations efficiently and effectively, and to foster ethical behavior and a culture of integrity through reinforcement of Boston University’s Code of Ethical Conduct and Conflict of Interest Policy. Samantha supports the Associate Vice President for Compliance Services with furthering the University’s Compliance Program and administering CSO’s core functions, projects, and initiatives in furtherance of its mission. Examples include assisting with investigations, monitoring for new laws and regulations and facilitating University efforts to comply with new obligations, and coordinating with offices around the university to follow up on reports received through CSO.

Samantha has worked for Boston University since 2009. Prior to joining the Compliance Services Office, she was Senior Director of the Office of University Faculty Governance. Samantha is a graduate of Boston University and the University of Toronto. She received her J.D. from Suffolk University Law School and is admitted to the bar of the Commonwealth of Massachusetts.

Send Samantha an email

Shanika Coney, Compliance Coordinator

Send Shanika an email

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Compliance Services Office
125 Bay State Road, Boston MA 02215
(617) 358-8090
Comply@bu.edu; Policy@bu.edu