Risk Management in Intercollegiate Athletics
2006 ACUA Mid-Year Conference
By:
Pete Carlon
Director of Athletics
UT Arlington
Kimberly Hagara
Assistant Director
UT System Audit Office
What is at Stake if Compliance
Systems Fail?
Historical Perspective and
University of Texas System Directive
1998 Action Plan to Ensure
Institutional Compliance
Compliance Initiative at
The University of Texas at Arlington
Institutional Compliance Organizational
Structure and Plan
Compliance Office – Executive Director for
Assurance Services
Institutional Compliance Committee
Quarterly Meetings
Reporting
Ongoing risk assessment by responsible parties
Institutional Compliance Subcommittees
UTA Institutional Compliance Committee
Mission Statement
The University of Texas at Arlington is committed to compliance in all
areas of its operation, including undergraduate, graduate, and
professional education, research activities and operations, and in the
areas of financial, business, academic administration, student services,
campus security, environmental health and safety, intercollegiate
athletics, and other areas of The University. The University will
manage all of its affairs in a manner that will continually reflect a strong
commitment to conducting the business of The University in an ethical,
law-abiding way. This institutional commitment to compliance involves
communication, education and training in the area(s) of ethical
business guidelines for all employees of The University, including
faculty, classified staff, professional and administrative employees, and
others who may be employed by The University on either a part-time or
a full-time basis. The communication of guidelines, education and
training programs will cover federal and state laws, institutional rules
and regulations, policies and procedures covering The University’s
teaching, research, public service, business, and administrative
initiatives, and which will promote an operating environment designed
to encourage all UTA employees to engage in all institutional activities
and business integrity.
Initial Institutional Compliance
Subcommittees
• Research
• Academic Affairs
• Environmental Health and Safety
• Human Resources
• Taxes and Tax Issues
• Financial Accounting, Contracting and Purchasing, HUB
and Associated Reporting
• Student Affairs
• Intercollegiate Athletics
• Campus Security, Crime Control and Reporting Year Y2K
• Development and Fund Raising
Organizing the Intercollegiate Athletics
Compliance Committee
Composition of Initial Intercollegiate
Athletics Compliance Committee
• Chair, Director of Athletics
• Faculty Athletics Representative
• Assistant Dean, College of Education and Chair, Department of
Kinesiology
• Admissions – Transcript Evaluator – Liaison to Athletics
• Associate Athletics Director for Finance and Administration
• Registrar
• Senior Associate Athletics Director/Compliance Coordinator
• Academics and Life Skills Coordinator for Athletics
• Assistant Vice President for Management Services
• Director of Student Governance and Organization
• Assistant Director, Student Health Services
• Financial Aid – Coordinator of Scholarships
Reorganizing – Combining the
Intercollegiate Athletics Compliance
Committee and the Athletics Council
Changes in the
Handbook of Operating Procedures
NCAA Constitution 6.1.2 – Athletics
Board
Intercollegiate Athletics Compliance Committee/Athletics
Council Present Committee Composition and Membership
• Co-Chair – Faculty Athletics Representative – College of Liberal Arts
• Co-Chair – Director of Athletics
• Faculty – College of Business Administration
• Assistant Director, Student Health Services
• Admissions Counselor – International Students
• Student-Athlete – Chair, Student-Athlete Advisory Committee
• Admissions – Transcript Evaluator – Liaison to Athletics
• Student – Student Congress President
• Athletics Academics and Life Skills Coordinator
• Faculty – School of Education
• Registrar
• Student-Athlete – Southland Conference Student-Athlete Advisory Committee
• Faculty – College of Science
• Associate Athletics Director for Finance and Administration
• Associate Provost
• University Financial Reports Manager – Business and Accounting Services
• Faculty – School of Nursing
• Assistant Vice President for Management Services
• Sr. Associate Athletic Director/Compliance Coordinator
• Athletics - Senior Woman Administrator
• Director of Scholarships
• Faculty – School of Urban and Public Affairs
• Faculty – College of Liberal Arts
Performing the
Annual High Risk Assessment
(Fall Semester Each Year)
Risk Assessment Methodology
Steps 1 – 9 will be performed by the members of each subcommittee:
1. Identify and document the goals and objectives of the
subcommittee’s designated high-risk area within the context of
UT Arlington’s Mission Statement. To assistant in identifying
goals and objectives, please consider the following questions:
• What is the nature of the “business” that you (we) are in?
• Who are your (our) “customers?”
• What do those “customers” want and need?
• What does that say about what you (we) are trying to
accomplish?
• How will you (we) know if you (we) have been successful?
Risk Assessment Methodology (con’t)
2. Identify and document risks associated with the accomplishment
of the goals and objectives identified in #1, above. To assist in
identifying these risks, consider the following questions:
• What are some things that could go wrong?
• What are some things that must go right?
• What is the significance of any potential risks?
• What is the likelihood of an occurrence of such an event?
NOTE: Risks associated with accomplishment of goals and objectives
are subject to continual revision due to changing federal and
state laws, management philosophy, personnel, etc.
Risk Assessment Methodology (con’t)
3. Review the most current list of risks (“A” and “B” lists) to determine if the
risks identified in #2, above, are included on that list.
4. Once the inventory of risks has been determined and documented, even
if it is identical to the previous year’s inventory of risks, carefully assess
the probability of occurrence of each risk.
5. Assess the potential impact for each risk and ascertain whether there
has been a previous occurrence of that risk.
6. Each factor (probably of occurrence and potential impact) for each of
the identified risks will then be rated on a scale of 1 to 10; a “10”
indicates the highest level of concern; a “1” indicates lowest of
concerns. (Note newer methodology is using a high, medium, or low
rather than numerical ranking)
Risk Assessment Methodology (con’t)
7. Prioritize the identified risks from the highest to the lowest
based on the multiplied totals determined in #6, above.
8. Based on the prioritization resulting from #7, above, separate
the prioritized risks into two separate lists – “A” and “B”. The
“A” list will reflect those items of highest risk. (Each
subcommittee will be asked to determine the “break point”
between the “A” and “B” lists.)
9. The goals and objectives, and the revised “A” and “B” lists
will be submitted to the Office of Institutional Compliance.
10. The Office of Institutional Compliance will combine the
information received from each subcommittee into a
University-wide “A” and “B” list.
Risk Assessment Methodology (con’t)
11. The Executive Vice President for Academic Affairs and Provost,
the Vice President for Finance, the Vice President for
Administration and Campus Operations and the Executive
Director for Assurance Services will meet to discuss the
University-wide “A” and “B” lists.
12. The University-wide “A” and “B” list will be presented to the
members of the Institutional Compliance Executive Committee.
13. The Institutional Compliance Executive Committee (the
Committee) will meet to validate the University-wide “A” and “B”
lists.
14. Based on this information, and after consultation with the
Institutional Compliance Officer, the annual risk-based plan of
compliance activities will be completed and submitted to UT
System.
Field of Potential High Risk Items
Student-Athlete Health Care Policies and Procedures
Intercollegiate Athletics Travel Policies and Procedures
NCAA Compliance and Rules Education
Student Financial Aid and Academic Regulations and
Procedures
Southland Conference Operating Code
Athletic Department Certification and Annual Audit
Employment Contracts and Conduct of Employees
Department P & P Manual
Crisis Management
Student-Athlete Recruiting Regulations
Student-Athlete Eligibility
Student-Athlete Financial Aid
Field of Potential High Risk Items (con’t)
Student-Athlete Extra Benefits
Gender Equity
Student-Athlete Welfare
Institutional Control
Rules Education
Infractions – Reporting-Corrective Actions
Summer Camps Policies and Procedures
Facilities Safety
Inclement Weather
Travel Advances/Reimbursement Procedures
Drug Testing and Education Program
Employment Contracts per UT System’s Policies and Procedures
Intercollegiate Athletics
Risk Assessment and Implementation
Plan FY 1998-99
(Handout)
Intercollegiate Athletics
Risk Assessment for FY 2003
(Handout)
Developing Monitoring Plans for Each
Identified High Risk Area
(Handouts)
Monitoring Plan Timetable
University of Texas at Austin
(Handout)
Specialized Training Matrix
(Handout)
Specialized Training Report
(Handouts of Examples)
NCAA Division I
Athletics Certification Program
Three Major Components of the NCAA Division I
Athletics Certification Self-Study Instrument
• Governance and Commitment to Rules Compliance
• Academic Integrity
• Equity and Student Athlete Welfare
Subcommittees
I. Executive Committee
II. Governance and Commitment to Rules Compliance
III. Academic Integrity
IV. Equity and Student-Athlete Welfare
Organization and Composition of
Executive Subcommittee
Co-Chair, Director of Athletics
Co-Chair, Faculty Athletics Representative – College of Liberal Arts
Assistant Director, Student Health Services
Admissions, Transcript Evaluator – Liaison to Athletics
Faculty Member – School of Education
Faculty Member – College of Science
Faculty Member – College of Business Administration
Registrar
Assistant Athletic Director for Finance and Administration
Associate Provost
Assistant Vice President for Management Services
Sr. Associate Athletic Director/Compliance Coordinator
Athletics Senior Woman Administrator
Director of Scholarships
Executive Director for Assurance Services (Ex-Officio)
Organization and Composition of
Governance and Commitment to Rules
Compliance Subcommittee
Faculty Member – College of Business Administration
Faculty Member – School of Education
Admissions – Transcript Evaluator – Liaison to Athletics
Registrar
Sr. Associate Athletic Director/Compliance Coordinator
Director of Scholarships
Organization and Composition of
Academic Integrity Subcommittee
Student-Athlete – Chair, Student-Athlete Advisory Committee
Faculty Member – School of Education
Faculty Member – College of Science
Faculty Member – School of Nursing
Faculty Athletics Representative
Associate Provost
Sr. Associate Athletic Director/Compliance Coordinator
Organization and Composition of
Equity and Student-Athlete Welfare
Subcommittee
Director of Athletics
Athletics Senior Woman Administrator
Athletics Academics and CHAMPS/Life Skills Coordinator
Admissions Counselor – International Students
Student – Student Congress President
Student-Athlete – Southland Conference Student-Athlete
Advisory Committee
Assistant Director, Student Health Services
Assistant Vice President for Management Services
Associate Athletics Director for Finance and Administration
Duties and Responsibilities of
Executive Subcommittee
1. Act on department compliance matters between
meetings as necessary
2. Act on sensitive matters which may not be
appropriate for the full committee
Duties of Governance and Commitment to
Rules Compliance Subcommittee
I. Monitor certification of athletes,
II. Monitor coaches recruiting records,
III. Review playing and practice records,
IV. Review rules education of coaches, athletes and
boosters,
V. Receive reports of rules violations and approve plans
for preventing future violations,
VI. Review Operating Principles.
Review Operating Principles
Operating Principle 1.1
Institutional Control, Presidential Authority and
Shared Responsibilities. The Association’s
principle of institutional control vests in the
institution the responsibility for the conduct of its
athletics program, including the actions of its
staff members and representatives of its
athletics interests. In fulfilling this principle, the
institution shall demonstrate that:
Review Operating Principles
Operating Principle 1.1
1) The institution’s governing board provides oversight and
broad policy formulation for intercollegiate athletics in a
manner consistent with other units of the institution
2) The chief executive officer is assigned ultimate
responsibility and authority for the operation and
personnel of the athletics program
3) Appropriate campus constituencies have the
opportunity, under the purview of the chief executive
officer, to provide input into the formulation of policies
relating to the conduct of the athletics program and to
review periodically the implementation of such policies
Review Operating Principles
Operating Principle 1.2
Rules Compliance. Membership in the
Association places the responsibility on each
institution to assure that its staff, student-
athletes, and other individuals and groups
representing the institution’s athletics interests
comply with the applicable Association rules and
regulations. Consistent with this responsibility,
the institution shall demonstrate that:
Review Operating Principles
Operating Principle 1.2
1) It has in place a set of written policies and procedures that assign
specific responsibilities in the areas of rules compliance, including
assignment of direct accountability for rules compliance to the individual
the chief executive officer assigns overall responsibility for the athletics
program
2) In critical and sensitive areas, institutional compliance procedures
provide for the regular participation of persons outside of the athletics
department
3) Rules compliance is the subject of an ongoing educational effort
4) A clear and unambiguous commitment to rules compliance is a central
element in all personnel matters for individuals involved in the
intercollegiate athletics program
5) At least once every four years, its rules-compliance program is the
subject of evaluation by an authority outside of the athletics department
Duties of Academic Integrity Subcommittee
I. Monitor student absences due to team scheduling,
II. Monitor sports scheduling,
III. Recommend institutional and departmental policies regarding
university excused absences,
IV. Monitor athletics graduation rates by sport,
V. Monitor admission of student-athletes,
VI. Monitor grade point averages by sport,
VII. Monitor academic support services,
VIII. Review operating principles.
Review Operating Principles
Operating Principle 2.1
Academic Standards. The Association’s
fundamental principles indicate that an
intercollegiate athletics program shall be
designed and maintained as a vital
component of the institution’s educational
system, and student-athletes shall be
considered an integral part of the student
body. Consistent with this philosophy, the
institution shall demonstrate that:
Review Operating Principles
Operating Principle 2.1
1) The institution admits only student-athletes who have reasonable expectations
of obtaining academic degrees
a) If the academic profile of entering student-athletes, as a whole or for any student-athlete subgroup,
is significantly lower than that of other student-athlete or comparable student-body groups, the
contrast shall be analyzed and explained by appropriate institutional authorities
b) If the graduation rate of student-athletes, as a whole or for any student-athlete subgroup, is
significantly lower than that of other student-athlete or comparable student-body groups, this
disparity shall be analyzed, explained and addressed (through specific plans for improvement) by
appropriate institutional authorities
2) Academic standards and policies applicable to student-athletes are consistent
with those adopted by the institution for the student body in general or the
NCAA’s standards, whichever are higher
3) The responsibility for admission, certification of academic standing and
evaluation of academic performance of student-athletes is vested in the same
agencies that have authority in these matters for students generally and
4) Written policies related to scheduling are established in all sports to minimize
student-athletes’ conflicts with class time and / or final examination periods due
to participation in intercollegiate athletics, consistent with provisions of
Constitution 3.2.4.13.
Review Operating Principles
Operating Principle 2.2
Operating principle 2.2: Academic
Support. Members of the Association
have the responsibility to conduct
intercollegiate athletics programs in a
manner designed to protect and enhance
the educational welfare of student-athletes
and to assure proper emphasis on
educational objectives. Consistent with
this responsibility, the institution shall
demonstrate that:
Review Operating Principles
Operating Principle 2.2
1) Adequate academic support services are available for student-
athletes
2) Student-athletes are encouraged and assisted in reaching
attainable academic goals of their own choosing
3) When it is determined that individual student-athletes have specific
academic needs, these needs are addressed
4) The support services are approved and reviewed periodically by
academic authorities outside the department of intercollegiate
athletics
5) There is a commitment to the fair treatment of student-athletes,
particularly in their academic role as students.
Duties of Equity and Student-Athlete
Welfare Subcommittee
I. Conduct exit interviews
II. Monitor ratio of minorities in each sport
III. Review Student-Athlete Advisory Committee meeting
minutes and concerns and respond as appropriate
IV. Analyze gender and ethnic makeup of staff
V. Monitor sportsmanship and ethical conduct of
students and staff during athletic competition
VI. Review operating principles
Review Operating Principles
Operating Principle 3.1
Gender Issues. Consistent with NCAA
Constitution 2.3, it is the responsibility of
each institution to implement the
Association’s principle of gender equity. In
accordance with this fundamental
principle, the institution shall:
Review Operating Principles
Operating Principle 3.1
1) Have implemented its approved gender-equity plan from the
previous self-study. If modified or not carried out fully, the institution
shall provide an explanation from appropriate institutional authorities
2) Demonstrate that it is committed to, and has progressed toward, fair
and equitable treatment of both male and female student-athletes
and athletics department personnel
3) Formally adopt a written plan for the future for the intercollegiate
athletics program that ensures the institution maintains a program,
or continues progress toward a program, which is equitable for both
genders. The plan shall include measurable goals the institution
intends to achieve, steps the institution will take to achieve those
goals, persons responsible and timetables
Review Operating Principle
Operating Principle 3.2
Minority Issues. It is a principle of the
Association to promote respect for and
sensitivity to the dignity of every person
and to refrain from discrimination
prohibited by federal and state law.
Consistent with this fundamental
philosophy, the institution shall:
Review Operating Principles
Operating Principle 3.2
1) Have implemented its approved minority-opportunities plan from the
previous self-study. If modified or if not carried out fully, the
institution shall provide an explanation from appropriate institutional
authorities
2) Demonstrate that it is committed to, and has progressed toward, fair
and equitable treatment of all minority student-athletes and athletics
department personnel
3) Formally adopt a written plan for the future for the intercollegiate
athletics program that ensures the institution maintains a program,
or continues progress toward a program, which expands
opportunities and support for minority student-athletes and athletics
personnel. The plan shall include measurable goals the institution
intends to achieve, steps the institution will take to achieve those
goals, persons responsible and timetables
Review Operating Principles
Operating Principle 3.3
Student-Athlete Welfare. Conducting the
intercollegiate program in a manner
designed to protect and enhance the
physical and educational welfare of
student-athletes is a basic principle of the
Association. Consistent with this
fundamental principle, the institution shall:
Review Operating Principles
Operating Principle 3.3
Provide evidence that the welfare of student-athletes
and the fairness of their treatment is monitored,
evaluated and addressed on a continuing basis
Have established grievance or appeal procedures
available to student-athletes in appropriate areas
Provide evidence that the institution has in place
programs that protect the health of and provide a safe
environment for each of its student-athletes
Assurance Activities
A. Subcommittee monitoring reports
B. Conference compliance reviews
C. Internal audits and inspections
D. Annual NCAA audits – New agreed upon procedures
for FY 2005 audit process
E. NCAA Division I Athletics Certification Self-Study and
Peer Review
Self-Reporting of Non-Compliance Matters
• Procedure
• Discipline/Corrective Actions
Committee Quarterly Reports for the
Executive Director of Assurance
Services / Institutional Compliance
Officer and the Institutional Compliance
Executive Committee
Quarterly Report Template
(Handout)
Quarterly Specialized
Training Report Form
(Handout)
Intercollegiate Athletics / Athletics
Council
Compliance Committee
Meeting Format
Role of the Institutional Compliance
Officer and Office
Role of the University of Texas System
Intercollegiate Athletics High Risk
Compliance Group
Implementation
Questions and Answers