Compliance Network
Supporting Compliance Efforts
In addition to working closely with Audit and Advisory Services and the Office of Risk Services within the university’s Enterprise Risk Management (ERM) framework to identify, reduce and address compliance risks, the Compliance Department works with a network of subject matter experts across the university’s many functions, each of whom has responsibility for compliance efforts within a specific area. The Compliance Department coordinates and collaborates with these compliance partners to provide a cohesive platform for all compliance efforts. This matrix was last reviewed on September 2024.
Our Compliance partners in specific key areas are:
Compliance Network
| Compliance Area | Responsible Office/Official | Office/Official with Daily Oversight | Key laws/ regulations/ policies |
|---|---|---|---|
| Academic Regulatory Compliance | Bryan Lackaye, Vice President – Global Launch Services Regional Campuses | Kristen Smith, Asst VP – Regulatory Affairs Regional Campuses | Regulatory operations for: – California Private Postsecondary Education Act of 2009 Virginia Code Article 3 §23.1 (213-229) -The Virginia Administrative Code 8VAC 40-31 – North Carolina General Statute 116-15 – Section 1005, Florida Statutes – Title 20-A, Chapter 409: DEGREE-GRANTING INSTITUTIONS (mainelegislature.org) – Chapters 149 & 170 Rule Chapters for the Department of Education (maine.gov) – Chapter 28B.85 RCW: DEGREE-GRANTING INSTITUTIONS (wa.gov) – Post-secondary Education Choice and Excellence Act, 2000, S.O. 2000, c. 36, Sched. (ontario.ca) – Regulatory Entity: Ministry of Advanced Education, Skills and Training – Ministry of Post-Secondary Education and Future Skills – Degree Quality Assessment Board – |
| Advancement; Donor gifts | Diane N. MacGillivray, Senior Vice President for University Advancement | Timothy Kenneally, Assistant Vice President for Advancement Operations | Uniform Prudent Management of Institutional Funds Act (UPMIFA); state charitable solicitation and registration laws; Internal Revenue Code (IRC); Higher Education Opportunity Act (HEOA); Philanthropy Protection Act |
| Americans with Disabilities Act | Madeleine Estabrook, Senior Vice Chancellor-Student Affairs Thomas Nedell, Senior Vice President – Finance and Treasurer |
Mary A. Barrows, Senior Director, Learning Strategies and Student Success – Disability Resource Center Kathy Spiegelman, VP & Chief of Campus Planning Campus Planning & Real Estate Michele Grazulis, Vice President and Chief Human Resources Officer |
Americans with Disabilities Act (ADA); Rehab Act |
| Athletics; NCAA; Title IX | Ken Henderson, Chancellor & Sr VP Learning | James Madigan, Athletics Director | National Collegiate Athletic Association (NCAA) rules; Equity in Athletics Data Analysis (EADA); conference rules; Title IX |
| Anti-bribery/Anti-corruption | Thomas Nedell, Senior Vice President- Finance and Treasurer | Kathy Spiegelman, ,VP & Chief of Planning, Real E /Campus Planning & Real Estate | US Foreign Corrupt Practices Act (FCPA), UK Bribery Act (UKBA), Canadian Corruption of Foreign Officials Act (CFPOA) |
| Campus Safety/Crime Statistics Reporting | Mary Strother, Senior Vice President & General Counsel | Michael Davis, Vice President – Safety, Security & Policing | Clery Act; Campus Sex Crimes Prevention Act (CSCPA); Title IX; Campus Sexual Assault Bill of Rights; Emergency Planning and Community Right-To-Know Act (EPCRA); HEOA |
| Conflicts of Interest | Mary Strother, Senior Vice President & General Counsel Robin Cyr, Vice Provost Research Administration |
Lin Qin, Senior Director – Compliance Jeff Seo, Chief Research Compliance Officer |
Internal Revenue Code rules re: private investment; benefits; Public Health Service; National Science Foundation; Food and Drug Administration regs. |
| EEO/Anti-Discrimination | Madeleine Estabrook, Senior Vice Chancellor-Student Affair | Mark Jannoni, Assistant Vice President, University Equity and Compliance | American Disibilities Act; Titles VI/VII/IX; Uniform Services Employment and Reemployment Rights Act (USERRA); Immigration and Nationality Act (INA); Genetic Information Nondiscrimination Act (GINA); Pregnancy Discrimination Act; Equal Pay Act; Older Workers Benefits Protection Act (OWBPA); Age Discrimination Act of 1975; HEOA; Equal Employment of Veterans; Office of Federal Contract Compliance Programs (OFCCP) |
| Environmental Health and Safety |
Marne Smith, Associate Vice Provost – Education & Research Safety Kathy Spiegelman, VP & Chief of Planning, Real E, Campus Planning & Real Estate |
Andrea Voehringer, Director – Office of Academic & Research Safety, Environmental Health and Safety Gina Kerwin, Associate Dir. Environmental Compliance & Occupational Safety |
Occupational Health and Safety Administration (OSHA); VOSH; Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); Resource Conservation and Recovery Act (RCRA); Emergency Planning and Community Right-to-Know Act (EPCRA); Hazardous Materials Transportation Act (HMTA); Federal Insecticide Funficide Rodenticide Act (FIFRA); Nuclear Reglatory Commission (NRC) regs; Board of Pharmacy Specialists (BPS); Higher Education Opportunity Act (HEOA); Asbestos Hazard Emergency Response Act (AHERA); Medical Waste Tracking Act |
| Export Control | Robin Cyr, Vice Provost – Research Administration | Lissette Gilster, Export Control Officer | Dept. of State: Directorate of Defense Trade Controls (DDTC) and International Trafic in Ams Regulation (ITAR); Dept. of Commerce: Bureau of Industry and Security (BIS) and Export Administration Regulations (EAR); Treasury; Office of Foreign Assets Control (OFAC); Trading with the Enemy Act; sanctions and barred entities lists; Anti-boycott Restrictions |
| Facilities, Construction, Building Codes | Anthony Rini, Vice President – Administration & Financial Planning | Kathy Spiegelman, Vice President & Chief of Campus Planning & Real Estate | OSHA; state and local building codes; VOSH; CERCLA; RCRA; EPCRA; HMTA; FIFRA; NRC regs; BPS; HEOA; ADA |
| Financial Aid | Satyajit Dattagupta, Chief Enrollment Officer | Thomas WcWhorter, Dean of Student Financial Service | Title IV; Family Educational Rights Protection Act (FERPA); policies and reqmts of federal Grant and Loan programs; MSSA; Student Load Default Prevention Initiative Act of 1990; Higher Education Opportunity Act (HEOA); federal work/study reqmts; Bankruptcy Abuse Prevention & Consumer Protection Act of 2005; Truth in Lending Act; Student Right to Know Act |
| Government Relations | Michael Armini Senior Vice President for External Affairs |
Jack Cline VP- Federal Relations External Affairs | US Federal Campaign Act (FECA), US Lobbying Disclosure Act (LDA), Canadian Lobbying Act, other applicable state, provincial and local laws such as M.G.L. Chapter 3, Sections 39 – 50 |
| Human Resources | Michele Grazulis, Vice President and Chief Human Resources Officer | Michele Grazulis, Vice President and Chief Human Resources Officer | FLSA; FMLA; Drug-Free Workplace Act; INA; NLRA; USERRA; HEOA; Fair Credit Reporting Act (FCRA); COBRA; ERISA; Employee Polygraph Protection Act; WARN; Deferred Compensation; FICA; OFCCP |
| International Students | Satyajit Dattagupta, Chief Enrollment Officer | Jenn Christ, Senior Director, Primary Designated School Official (PDSO) and Responsible Officer (RO) | US, UK, and CAN immigration laws for international student enrollment and post-graduate work eligibility. US, UK, CAN employment and immigration laws for international student participation in co-op and other experiential learning opportunties. |
| Information Security | Mary Ludden, Sr. VP Global Network & Strategic Initiatives/Regional Campuses | Marcus Robinson, Assoc VP – Engagement & Experience / Deputy CIO Information Technology / Information Technology Services Harry Hoffman, Associate Vice President & Chief Information Security Officer | Gramm-Leach-Bliley; Health Insurance Portability and Accountability Act (HIPAA); Payment Card Industry Data Security Standard (PCIDSS); HEOA; ADA; Federal Information Securities Act (FISMA); Mass. Security Regulations; CMMC; GDPR / Standard Contractual Clauses security requirements. |
| Insurance | Mary Strother, Senior Vice President & General Counsel | Ann Mizner McKay, Director of Risk Services, Asst General Counsel | Massachusetts laws; worker’s compensation, insurance: general liability, directors and officers, employer’s liability, fiduciary and crime, automobile, professional liablity, clinical, cyber and environmental. |
| Intellectual Property | David Luzzi, Sr Vice Provost Research Provost Research | Jennifer Boyle-Lynch, CRI Director Operations and Finance – Research Innovation | Bayh-Doyle Act; Copyright law; Copyright Term Extension Act; Lanham Act; DMCA; VARA; HEOA; TEACH ACT; CREATE Act |
| Investment Management | Thomas Nedell, Senior Vice President – Finance and Treasurer | Kathy Byington, VP Finance | Sarbanes-Oxley; SEC regulations |
| Privacy – Global | Mary Strother, Senior Vice President & General Counsel | Alexis Goltra, Chief Privacy Officer | Family Educational Rights Protection Act (FERPA); Gramm-Leach-Bliley Act (GLBA); Health Insurance Portability and Accountability Act (HIPAA); US State privacy laws; EU & UK General Data Protection Regulation (GDPR) and other applicable global privacy laws |
| Procurement | Kathy Byington, VP Finance and Assistant Controller |
Michael Henderson, Chief Procure Pay Officer Kathy Byington, VP Finance and Assistant Controller |
Anti-Kickback Act of 1988; Federal and state E-signature laws; American College and University Presidents Climate Commitment; Trading with the Enemy Act; Contract Disputes Act; Continued Dumping and Subsidy Offset Act of 2000; Fly America Act; Byrd Amendment |
| Records Management | Rana Glasgal, Vice Provost – Data & Analytics University Decision Support | Mark Chambers, Director – Enterprise Data Governance University Decision Support | ISO 15489; Higher Education Opportunity Act (HEOA); Family Educational Rights Protection Act (FERPA); Freedom of Information Act; Gramm-Leach-Bliley (GLBA); Health Insurance Portability and Accountability Act (HIPAA) |
| Research Compliance | Robin Cyr, Vice Provost – Research Administration | Jeff Seo, Chief Research Compliance Officer | Public Health Service (PHS); National Science Foundation (NSF); National Endowment for the Humanities (NEH); National Education Association (NEA) regs: including policies on Responsible Conduct of Research; Cost sharing; cost transfers; effort reporting |
| Research Compliance: Grants Administration (Pre-Award) | Robin Cyr, Vice Provost – Research Administration | Dana Caroll, Associate Vice Provost – Research Administration | Public Health Service (PHS); National Science Foundation (NFS); National Endowment for the Humanities (NEH); National Education Association (NEA) regs |
| Research Compliance: Grants Administration (Post-Award) | Robin Cyr, Vice Provost – Research Administration | Alex Hui, Executive Director – Office of Research Admin & Finance Jeff Seo, Chief Research Compliance Officer |
OMB Uniform Guidance; Federal Acquisition Regulations (FAR) |
| Research Compliance: Human Subjects Research | Robin Cyr, Vice Provost Research Admin | Anita Balgopal, Executive Director of the Human Research Protection Program Jeff Seo, Chief Research Compliance Officer |
Common Rule; Belmont Report |
| Research Compliance: Animal Research | Robin Cyr, Vice Provost Research Admin |
Sean Sullivan, Director – Division for Lab Animal Medicine Jeff Seo, Chief Research Compliance Officer |
USDA Animal Welfare Act and regs; Guide for the Care and Use of Laboratory Animals; PHS Policy on Humane care/use of laboratory animals |
| Research Compliance: Research Misconduct | Robin Cyr, Vice Provost – Research Administration | Jeff Seo, Chief Research Compliance Officer | Common Rule; NSFA; Public Health Service Act; National Cooperative Research Act; IRB; FDA Amendments Act |
| Tax and Tax-Exempt Issues | Kathy Byington, VP Finance and Assistant Controller | Jignesh Shroff, Tax Director | IRC; SEC regs; state and local tax laws; Fair Credit Reporting Act (FCRA); Federal Unemployment Tax Act (FUTA); Fringe Benefits |
| Title IX and Sexual and Gender-Based Harassment | Madeleine Estabrook, Senior Vice Chancellor-Student Affairs Mary Strother, Senior Vice President & General Counsel |
Mark Jannoni, Assistant Vice President – University Equity & Compliance Michael Davis, Vice President – Safety, Security & Policing |
Title IX; Campus (Sexual Violance Elimination) SaVE Act, VAWA |