Comparison of Federal Sentencing Guidelines, OIG Guidelines, and 果冻传媒 "Action Plan to Ensure Institutional Compliance"

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CRITERIA	UTOLEDO ACTION PLAN	FEDERAL SENTENCING GUIDELINES	OIG GUIDELINES FOR HOSPITALS, ETC.
Written policies and procedures	Step 14:听 Develop a compliance manual which provides documentation of management鈥檚 considerations of compliance, sets forth expectations and standards of conduct and outlines methodologies to be employed to annually assess the effectiveness of the plan and the compliance officer 听	Compliance standards and procedures	Written policies and procedures, including a standard of conduct
Designated high-level manager as responsible for compliance program	Step 2:听 University-Wide compliance officer 听 Step 3:听 Component compliance officers 听	Specific individual within high-level personnel of the organization must have been assigned overall responsibility to oversee compliance with the standards and procedures 听	Designation of a compliance officer responsible for operating and monitoring the compliance program
Training	Step 10:听 Ensure that appropriate general compliance training for all employees and specialized training for appropriate employees is provided on a regular basis 听	Communicate effectively its standards and procedures to all employees and other agents by requiring participation in training and by disseminating publications explaining the program 听	Regular employee education and training programs
Auditing and Monitoring	Step 9:听 Establish鈥μ� and develop a support structure to ensure accomplishment of the plan for each activity that is deemed high-risk 听 Step 15:听 Annually audit the design and effectiveness of the 果冻传媒 compliance function and the component units 听	听听听听听听听听听 Auditing and monitoring	听听听听听听听听听 Periodic audits to monitor compliance
Anonymous reporting mechanism	Step 13:听 Establish a confidential reporting mechanism 听	A method of reporting noncompliance without fear of retribution 听	A reporting mechanism to receive complaints anonymously
Consistent discipline for noncompliance	Step 12:听 Follow-Up to determine that appropriate corrective, restorative, and/or disciplinary action has been taken in the event of noncompliance 听	Standards must be consistently enforced through appropriate disciplines of responsible individuals	Corrective action policies and procedures, including disciplinary policies, to respond to allegations of noncompliance
Responsible steps to correct any identified problems with compliance	Step 12 (see above)	After noncompliance is reported the organization must take reasonable steps to respond and prevent	Investigation and correction of identified systemic problems, including policies addressing the non-employment of sanctioned individuals