I. Scope
This policy applies to all George Mason University employees, contractors, employees of contractors, and agents.
II. Policy Statement
George Mason University cooperates with regulatory and other external entities performing External Reviews within their authority to supervise, oversee, or evaluate the University and its programs and operations. All Persons contacted by regulatory or other external entities regarding External Review activities must report in accordance with this policy.
III. Definitions
Coordinator means the Person(s) designated by senior leadership (e.g. the President, Provost, Chief of Staff, Senior Vice President, or their designee) as the primary point(s) of contact for the regulatory or other external entity performing an External Review. A Coordinator has responsibility for organizing and administering the University’s interactions with the regulatory or other external entity.
External Review, for the purposes of this policy, means the procedures employed by a regulatory or other authorized external entity to examine, evaluate, or inspect the University. External Reviews may be referred to by a variety of terms, such as: regulatory audit, examination, compliance review, risk review, desk review, financial statement audit, assessment, accreditation review for the University or for a specific unit, inspection, investigation, and others. External Reviews under this policy do not refer to reviews where the University affirmatively seeks an external entity, such as a consultant or subject matter expert, to assist with a routine internal review process.
Issue means findings, comments, observations, recommendations, or other communications from regulatory or other external entities requiring management remediation actions. Generally, Issues are communicated to Mason in a formal External Review report.
Person means a George Mason University employee, contractor, employee of contractor, or agent.
IV. Compliance
All Persons must immediately report to the Institutional Compliance Leader within the Office of Audit, Risk, and Compliance any initial notices from any regulatory or other external entity initiating External Review activity. The Institutional Compliance Leader will acknowledge receipt of the report.
Persons who are unsure whether a notice or communication from an external entity should be reported under this policy should discuss the communication with the Institutional Compliance Leader.
The Institutional Compliance Leader will notify senior leadership and the Office of University Counsel of reported External Reviews, and provide information regarding the External Review to assess potential legal, regulatory, or other risks related to the subject of the External Review.
Senior leadership is responsible for ensuring the University cooperates with regulatory and other external entities performing External Reviews.
Upon receipt of a report of External Review activity, senior leadership will designate a Coordinator(s) for the External Review. The Coordinator serves as the primary point of contact for the regulatory or other external entity performing the External Review and is responsible for planning, organizing, and administering the University’s interactions and communications with the regulatory or other external entity.
Upon conclusion of the External Review, the Coordinator must report the disposition of the review to the Institutional Compliance Leader and provide any final correspondence or report regarding the review for purposes of central tracking, follow up for corrective actions, and regular reporting to the senior leadership and the Board of Visitors.
V. Forms
N/A
VI. Dates
A. Effective Date:
7/30/2021
B. Date of Most Recent Review:
7/30/2021
VII. Timetable for Review
This policy, and any related procedures, shall be reviewed every three years or more frequently as needed.
VIII. Signatures
Approved:
____/S___________________
Carol Dillon Kissal
Senior Vice President for
Administration and Finance
____/S_________________
Mark Ginsburg
Provost and Executive Vice President
Date approved: 7/30/2021