Trueba: Office of Compliance is a value-added campus resource

With new staff in key positions, a new website launched, and approaching a year under its belt, UW–Madison’s new Office of Compliance is now focused on building a campuswide network of compliance partners, director Cathy Trueba says.

Trueba served as an assistant dean of students and director of the McBurney Disability Resource Center before being hired to head OC last year. She says the office’s mission is more than adherence to laws and regulations.

“We have compliance because it keeps people safe, and it minimizes our risk. Promoting a compliance culture of trying to do right, to meet these obligations, will move us forward in a positive way,” she says.

The office filled a key role in October with the hiring of Letissa C. Reid as the equal opportunity complaint investigator. Also joining the office this fall is program assistant Cheng Brandau. A search is underway for a new HIPAA privacy officer, who should be in place this spring. Additional OC staff include Title IX Coordinator Dave Blom and Public Records Custodian Lisa Hull.

Trueba talked with University Communications about how her experience on campus has helped her in the new position, how the office interacts with campus, and how the effort to create a campuswide network is going so far.

Q: You’ve served in different roles on campus. How did that experience help you here?

A: I have worked in higher education disability services, primarily at the McBurney Disability Resource Center, my entire career. In that capacity, I went from working individually with students with disabilities in the classroom setting to working more broadly on campus access issues. That gave me an opportunity to interact with, at the time what I felt was, most programs, services and activities here.

Accessibility intersects with facilities, teaching, learning, housing, extracurricular activities, study abroad, and so on, so I had an opportunity to understand and develop relationships with a pretty broad swath of campus. In addition to being the director of the Office of Compliance, I am also the campus ADA coordinator, so that background will serve me well.

What I learned at McBurney is that there are two aspects to ensuring accessibility: There are the needs of the individual in the moment, and then there’s stepping back and looking more broadly at how we can create structures so a person doesn’t have to ask that the program or service be made more accessible. I was able to work at both the micro and macro level to improve campus access for all members of the disability community.

Compliance is a similar mindset. We have to meet our obligations on any particular regulation, statute or policy. But it is critical to look more broadly at how we can position the campus to have a “compliance mindset.”

I will say that I underestimated the size of the university in thinking that accessibility touched all parts of campus. In this new role, campus has more than quadrupled in scope for me, particularly the research side of the institution, which is an enormous part of our campus and where a great deal of compliance lives. I have an opportunity to meet new colleagues and understand what they are working on, what their challenges are. I hope to use some of the same approaches I used in disability services, recognizing these are concerns or obligations we have (and) yet they add value — they add value to the institution when we do them well.

Q: What are the primary duties of the Office of Compliance?

A: The main elements of compliance are to enhance safety and minimize risk. An important way to accomplish this is to provide adequate training to our community. When training is tied to a position, for example, if you need to have a certain license to do your job, that’s operational at the field level and may be happening quite well. If we have an obligation to deliver compliance training across the university on a macro level, do we have an infrastructure to do that? Do we have effective and efficient systems to track training and ensure that it is being delivered in a coordinated manner? If not, how can the Office of Compliance assist in developing such a system? I see that as one of the duties.

Another duty is to evaluate risks associated with our compliance obligations and elevate them to executive leadership, making sure we identify the highest risks that campus has, and then working to mitigate those risks.

One of the goals of this office is to facilitate those conversations and bring these issues forward in a more centralized way. Then it’s not one voice saying we need to do this, but a collective voice saying it.

Q: How do you break down any barriers to that sort of organization and collaboration?

A: To start, I’ve been getting out to meet and greet compliance colleagues, to introduce myself and the concept of this new office and find out more about what they are hoping this office can do for them. I have been asking what’s working well in their areas and what are their concerns.

From those conversations, some themes have emerged — training being one of them, communication being another. This has led to one of my first initiatives, which is to develop a campus compliance network. I am working with Jeff Karcher, director of risk management, to bring the leads in major compliance areas together to discuss shared concerns and perhaps identify resources or best practices that can be leveraged. I am really looking forward to hearing what comes forward from these conversations.

My office is also a very logical partner with Human Resources in the training area. It’s hard to hold somebody accountable for something if they don’t know that’s part of their work obligation. Improving our training practices through our new HR onboarding processes, as well as providing coordinated training opportunities for employees, is another way to improve communication and promote “right doing” as a part of our campus culture.

Q: Under what circumstances would a member of the campus community contact you?

A:  The compliance functions within the OC include the Americans with Disabilities Act, HIPAA privacy, Title IX, public records, and equal opportunity discrimination investigations. If a member of the campus has a question about any of those compliance areas, this is the office to call.

Additionally, the goal of the OC is to be a resource to campus on the broader compliance obligations we have. One of the ways I plan to do that is to provide a compliance matrix on our website that identifies institutional leads and primary compliance managers for the other 120+ compliance areas.  So a member of the campus community should be able to find who to contact in another compliance area on the OC website.

Q: What has been the reception to introducing people to the idea of this network for compliance?

A: There has been a range of responses from curiosity to excitement. There has also been some uncertainty about what having an office of compliance or a compliance network means. I’ve worked to communicate that this office is not here to step in and manage or take over compliance obligations, other than those that are specifically within the OC purview. We are here to support compliance efforts that are already established at the field level.

On a campus of our size, it generally holds that the people closest to the work are best able to ensure that it happens, and I want to support that practice. Overall, people seem glad to have someone paying attention at the macro level and that campus leadership has identified compliance as a priority by establishing this office.

Q: How has the office grown in the first year?

A: By the end of the first year, we will have filled three staff vacancies in our office of six. That will allow us to move from spending time on recruitment to getting busy with program development. I know staff is excited about that. Our new website just launched in November and we’re pretty excited about that. It gives people a place to go to see what this office is all about and serves as a hub of information and resources about compliance for the campus community.

In addition to links to resources like the Title IX and ADA coordinators, the compliance matrix will identify the compliance obligations of the institution, where they live, who the institutional lead is, and who to contact. That should be a very useful tool for campus when it goes on the webpage later this spring.

Making sure that people know this new program exists and what we do is really a huge step and one we will continue to work on in the coming year.

Q: What do you see as the greatest opportunities for the office moving forward?

A: One opportunity is to have the concept of compliance be more visible, and to emphasize that it’s a value-added element to campus because we keep people and our community safe while reducing reputational and financial harm. And another is certainly building an efficient and effective training infrastructure that allows people to know what they need to be trained on, where to go for the training, and to hold people accountable for training. That includes supervisors, whose responsibility it is to make sure that their employees receive the requisite training and then act on what they have learned.

An institution like ours will always be highly regulated and that regulatory burden is not going to diminish anytime soon. Having buy-in on the importance of compliance, however, and ensuring we have the systems and the commitment of people to engage in the systems makes our campus stronger. It is how we do our best work and I am looking forward to promoting that, wherever I can.