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Compliance Investigations

The UTHealth Chief Compliance Officer is the UTHealth official responsible for receiving and processing all confidential reports of suspected non-compliance that involve the activities or operations of UTHealth. Other UTHealth officials who receive reports of suspected non-compliance are responsible for notifying the Chief Compliance Officer of the report at the earliest possible time and transferring all information regarding the report to the Chief Compliance Officer immediately.

Reports with Sufficient Information

The Chief Compliance Officer, in coordination with the Triage Team investigates or coordinates the investigation of all reports of suspected non-compliance when sufficient information has been reported. A summary report of all investigations is provided to the Executive Compliance Committee. The Executive Compliance Committee provides guidance regarding investigations and corrective actions as appropriate.

Reports with Insufficient Information

The Chief Compliance Officer, in coordination with the Triage Team reviews all reports of suspected non-compliance. Specifically, the Triage Team conducts an initial review of each report to first identify whether more information is needed. Sufficient information is needed to determine if a comprehensive investigation is required and whether the scope of the investigation can be established. The scope of an investigation depends upon what specific incidents have occurred and the seriousness or severity involved. As a note, generally stated allegations do not provide sufficient information because they are described at too high a level, and are missing supportive detail of what specific incident(s) have occurred. The information that is needed for a report of suspected non-compliance includes:

  • What date did each incident occur?
  • What is the name of each individual involved and how was each person involved?
  • Where each incident occurred?
  • What specifically happened during each incident (i.e., what was said or done and by whom)?
  • Are there related records (provide the records or describe them)?

UTHealth Houston’s Compliance Hotline provides the option for anonymous reporting. With anonymous reports, we may also be limited in our ability to gather the information needed. As such, it is so helpful when reporters are willing to speak directly to the Office of Institutional Compliance (OIC). OIC will honor a reporter’s request for anonymity.  Any reporter is able to contact the Chief Compliance Officer or any OIC team member to request a time to talk. Any reporter can also email to directly reach the OIC team. Otherwise, the Triage Team will do it best to gather the needed information within its initial review.