Compliance Accountability Matrix - Original

Graphical Version

Compliance Accountability Matrix - Original

The Compliance Accountability Matrix provides information on compliance requirements and their handling at Mines. By expanding a compliance area, the user will see a brief description of the area, the general requirements included in that area, and the primary office responsible for compliance. If you have a question about compliance in an area that is not listed on this page, please contact the Internal Audit and Compliance Office.

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Academic Affairs

Compliance Area Academic Affairs
Area Description Issues relating to University academic programs.
Compliance Topics Academic Accreditation
Colorado Constitution Day
Copyright Act of 1976 /Technology Education And Copyright Harmonization Act (TEACH Act) of 2002
Copyright Royalty Board / Library of Congress and Webcaster Settlement Act of 2009
Responsible Office Provost (Interim)
Responsible Person Dr. Tom Boyd
Contact Phone x3020
Contact Email tboyd@mines.edu

    Admissions (Graduate)

    Compliance Area Admissions (Graduate)
    Area Description Issues relating to application and admission to University graduate and professional schools and programs.
    Compliance Topics  
    Responsible Office Graduate Studies (Interim Dean)
    Responsible Person Dr. Tina Volker
    Contact Phone 303-273-3020
    Contact Email tvoelker@mymail.mines.edu

      Admissions (Undergraduate)

      Compliance Area Admissions (Undergraduate)
      Area Description Issues relating to application and admission to University undergraduate schools and programs.
      Compliance Topics Colorado Higher Education Admissions Requirements (HEAR)
      Department of Education (DOE) Program Integrity Rules
      Responsible Office Enrollment Management/Admissions
      Responsible Person Heather Boyd; Kim Medina
      Contact Phone 303-273-3221
      Contact Email hboyd@mines.edu

        Athletics

        Compliance Area Athletics
        Area Description Issues relating to University intercollegiate athletics programs, including the rules and policies of the National Collegiate Athletic Association (NCAA) and the athletic conferences in which school teams participate.
        Compliance Topics NCAA Athletic Audit Bylaw 22.2.1.2
        NCAA/Conference Rules
        Responsible Office Student Life/Athletics
        Responsible Person David Hansburg; Dixie Cirillo
        Contact Phone  
        Contact Email dhansburg@mines.edu; dcirillo@mines.edu

          Audit & Compliance

          Compliance Area Audit & Compliance
          Area Description Issues relating to audit and general compliance for the school.
          Compliance Topics Federal Sentencing Guidelines for Organizations (FSGO)
          Responsible Office Internal Audit; Compliance & Policy
          Responsible Person Shannon Sinclair; Jane Rosenthal
          Contact Phone 303-384-2504; 303-384-2236
          Contact Email ssinclair@mines.edu; compliance@mines.edu

            Business Operations

            Compliance Area Business Operations
            Area Description Issues relating to compliance with University policies and procedures regarding the procurement of goods and services used in University business.
            Compliance Topics Business Utilization
            Colorado Revised Statutes - Fair Competition with Private Industry (24-113, 23-41-116, C.R.S.)
            Colorado Revised Statutes - Private Use of State Property/Protection of University Assets (5 C.F.R. 2635.101)
            Confidential Information - Guidance on Mitigating Risk Posed by Information Stored on Photocopiers, Fax Machines and Printers
            Contracts - Revenue
            Executive Order 1289 (E-Verify)
            Responsible Office Financial Planning and Business Operations
            Responsible Person Vicki Nichol
            Contact Phone 303-273-3763
            Contact Email vnichol@mines.edu

              Capital Planning and Construction

              Compliance Area Capital Planning and Construction
              Area Description Issues relating to the planning, design, construction, and space management of University land and buildings.
              Compliance Topics Building Permits
              Colorado Building Codes - Construction
              Colorado Revised Statutes - State Buildings
              Contractor Compliance
              Davis Bacon Act
              Executive Order 11246/Office of Federal Contract Compliance Programs
              The Contract Work Hours and Safety Standards Act (CWHSSA)
              City of Golden - Water Tap Permits
              Responsible Office  
              Responsible Person Chris Cocallas
              Contact Phone  
              Contact Email Cocallas@mines.edu

                Conflict of Interest

                Compliance Area Conflict of Interest
                Area Description Issues relating to actual or apparent financial conflicts of interests, including the university’s financial disclosure policies and procedures, and concerns about how such conflicts could affect objectivity.
                Compliance Topics
                • NHS Grants Manual
                • NFS Grants Manual
                • Uniform Guidance @ 2 CFR 200
                Responsible Office Compliance & Policy
                Responsible Person Jane Rosenthal
                Contact Phone  
                Contact Email compliance@mines.edu

                  Crime and Campus Safety

                  Compliance Area Crime and Campus Safety
                  Area Description Issues relating to the collection, storage, distribution and transmission of confidential information and matters relating to the privacy of such information.
                  Compliance Topics Campus Sex Crimes Prevention Act
                  Clery Act
                  Communications Assistance for Law Enforcement Act (CALEA)
                  PATRIOT Act of 2001 (Uniting and Strengthen-ing America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act)
                  Responsible Office Public Saftey Office
                  Responsible Person Greg Bohlen
                  Contact Phone  
                  Contact Email gbohlen@mines.edu

                    Environmental Health & Safety

                    Compliance Area Environmental Health & Safety
                    Area Description Issues relating to building safety, laboratory safety, hazardous materials, and fire safety.
                    Compliance Topics Centers for Disease Control
                    Chemical Facility Anti-Terrorism Standards (CFATS)
                    Colorado Department of Public Health and Environment (CDPHE)
                    Comprehensive Environmental Response Compensation and Liability Act of 1980 (CERCLA)
                    Emergency Planning and Community Right to Know Act of 1986 (EPCRA)
                    Environmental Protection Agency Laws
                    City of Golden - Fire Codes
                    Hazardous Materials Transportation Act of 1994
                    Industrial Alcohol User Permits and Special Tax
                    Mandatory Reporting of Greenhouse Gases Rule
                    Occupational Health & Safety Act (OSHA)
                    Public Health Security and Bioterrorism Preparedness and Response Act of 2002
                    Radiation Safety Regulations (10 CFR 20)
                    Radioactive Material Regulations
                    Residential Lead-Based Paint Hazard Reduction Act of 1992
                    Resource Conservation and Recovery Act (RCRA) of 1976
                    Toxic Substances Control Act (TSCA)
                    Water Pollution Control Act (Clean Water Act)
                    Asbestos
                    Responsible Office Environmental Health & Safety
                    Responsible Person Barb O'Kane
                    Contact Phone  
                    Contact Email bokane@mines.edu

                      Export Controls

                      Compliance Area Export Controls
                      Area Description Issues relating to the University’s compliance with laws and regulations relating to the export of goods and technology.
                      Compliance Topics Export Administration Regulations
                      Import, Export and Transport of Nuclear Equipment and Material
                      International Traffic in Arms Regulations (ITAR)
                      Responsible Office Office of Research Administration
                      Responsible Person Johanna Eagan
                      Contact Phone 303-384-2589
                      Contact Email jeagan@mines.edu

                        External Contracts

                        Compliance Area External Contracts (research); Purchasing
                        Area Description Issues relating to the disclosure, approval, and management of contracts signed by the university's faculty, students, and staff.
                        Compliance Topics Procurment Rules
                        Responsible Office Office Of Research Administration; Purchasing Office
                        Responsible Person Natalie Martinez
                        Contact Phone  
                        Contact Email nmartine@mines.edu

                          Financial Aid

                          Compliance Area Financial Aid
                          Area Description Issues relating to the provision of financial aid to include grants and scholarships, student loans, and student employment.
                          Compliance Topics Donor Scholarships
                          Free Application for Federal Student Aid
                          McKinney-Vento Act
                          Title IV Federal Aid - Pell Grants
                          Taxability of Scholarships and Fellowships
                          Title IV Federal Aid - Work Study
                          National Student Loan Data System Reporting
                          Responsible Office Financial Aid
                          Responsible Person Jill Robertson
                          Contact Phone 303-273-3207
                          Contact Email jirobert@mines.edu

                            Financial Reporting

                            Compliance Area Financial Reporting
                            Area Description Issues relating to reporting of revenues and expenditures and tracking of investments.
                            Compliance Topics Colorado Revised Statutes - Student Activity Fees:
                            Donor Terms and Conditions
                            External Consulting Contracts
                            Fair Credit Reporting Act
                            Fly America Act
                            Gramm-Leach-Bliley Act
                            Investment Laws & Regulations
                            Non-Delinquency on Federal Debt
                            Pension Protection Act of 2006
                            Fair and Accurate Credit Transactions Act of 2003 (FACTA, Red Flag Rules)
                            Bond Covenants
                            Responsible Office Controller's Office
                            Responsible Person Roger Cusworth
                            Contact Phone 303-273-3109
                            Contact Email rcuswort@mines.edu

                              Government Relations & Lobbying

                              Compliance Area Government Relations & Lobbying
                              Area Description Issues relating to the University’s interactions with the federal and state governments, including advocacy of the University’s interests.
                              Compliance Topics Foreign Corrupt Practices Act of 1977
                              Lobbying and Disclosure Act
                              Political Activity Prohibition
                              Responsible Office Chief of Staff to President 
                              Responsible Person Peter Han
                              Contact Phone  
                              Contact Email phan@mines.edu

                                Human Resources

                                Compliance Area Human Resources
                                Area Description Issues relating to labor laws including salary/compensation, accomodation for person's with disabilities, workplace conduct, worker's compensation, discrimination or harassment, employee benefits, or other laws regulated by the US Department of Labor.
                                Compliance Topics Age Discrimination in Employment Act of 1967 (ADEA)
                                Americans with Disabilities Act (ADA)
                                Cafeteria Plans
                                Colorado Revised Statutes - State Notification Laws (6-1-716, C.R.S.)
                                Consolidated Omnibus Budget Reconciliation Act (COBRA)
                                Consumer Credit Protection Act, Title II (CCPA)
                                Controlled Substances Act of 1970
                                Department of Labor Postering Requirements (see citations at right)
                                Drug and Alcohol Abuse Prevention Regulations (Education Department General Administrative Regulations [EDGAR])
                                Drug Free Schools and Communities Act of 1989
                                Drug Free Workplace Act of 1988 [41 USC §701]
                                Employee Polygraph Protection Act of 1988
                                Employee Retirement Income Security Act of 1974 (ERISA)
                                Employee vs. Independent Contractor
                                Equal Employment Opportunity Act
                                Equal Pay Act of 1963 (EPA)
                                Fair Labor Standards Act (FLSA)
                                Family and Medical Leave Act (FMLA)
                                Genetic Information Nondiscrimination Act (GINA)
                                Immigration Reform and Control Act of 1986
                                Insurance policies, Key Man
                                National Labor Relations Act of 1935
                                Omnibus Transportation Testing Act - Drug & Alcohol Testing of Transportation Employees
                                Privacy Act of 1974
                                The Veterans' Readjustment Benefits Act, amended by the Vietnam Era Veterans' Readjustment Assistance Act of 1974, and the Veterans Employment Opportunities Act of 1998
                                U.S. Citizenship and Immigration Services (USCIS) Form I 129 Deemed Export Certification
                                Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA)
                                Worker Adjustment and Retraining Notification Act (WARN)
                                Workers Compensation
                                Responsible Office HR & TIx/Equity
                                Responsible Person Mike Dougherty
                                Contact Phone  
                                Contact Email mdougher@mines.edu

                                  Immigration/Visas

                                  Compliance Area Immigration/Visas
                                  Area Description Issues relating to compliance with laws and regulations relating to international students, faculty employees and the visa requirements for studying or working in the United States.
                                  Compliance Topics Enhanced Border Security and Visa Entry Reform Act of 2002
                                  Immigration and Nationality Act
                                  Student and Exchange Visitor Program
                                  Immigrations and Customs Enforcement (ICE)
                                  Responsible Office International Student and Scholar Services
                                  Responsible Person Brandon Samter
                                  Contact Phone 303-273-3589
                                  Contact Email bsamter@mines.edu

                                    Information Technology

                                    Compliance Area Information Technology
                                    Area Description Issues relating to the protection and security of university information and the computer systems used to manage it.
                                    Compliance Topics Children's Online Privacy Protection Act of 1998 (COPPA)
                                    Colorado Revised Statutes - Security Breach Notification Laws
                                    Computer Security Act
                                    Digital Millennium Copyright Act
                                    Electronic Communications Privacy Act (ECPA, or "Wire Tap Act")
                                    Payment Card Industry (PCI) Standards
                                    Telephone Operator Consumer Services Improvement Act of 1990 (TOCSIA)
                                    Intellectual Property Laws - Software Licensing
                                    Responsible Office Campus Computing, Communications, and Information Technologies (CCIT)
                                    Responsible Person Mike Erickson
                                    Contact Phone 303-273-3866
                                    Contact Email ericson@mines.edu

                                      Legal

                                      Compliance Area Legal
                                      Area Description Issues relating to matters on which legal advice is sought or required, including communications with lawyers who contact the University on behalf of their clients, response to legal documents, and litigation in which the University is or may be involved.
                                      Compliance Topics Colorado Revised Statutes - Colorado Open Records Act (24-72-201, C.R.S.)
                                      Federal Rules of Civil Procedure
                                      Freedom of Information Act (FOIA)
                                      Responsible Office Legal Services
                                      Responsible Person Anne Walker
                                      Contact Phone 303-384-2321
                                      Contact Email aswalker@mines.edu

                                        Plant Operations

                                        Compliance Area Plant Operations
                                        Area Description Issues relating to the maintenance and repair of University buildings and other facilities.
                                        Compliance Topics City of Golden - Clearing of Snow and Ice
                                        City of Golden - Water System Maintenance
                                        Colorado Revised Statutes - Swimming Pools (Title 25)
                                        Colorado Department of Public Health and Environment - Elevators & Lifts
                                        Plant Operations Equipment Safety Including Vehicles
                                        Executive Order 13513 - Cell Phones in Vehicles
                                        Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
                                        Tax reporting of personal use of University-owned Autos
                                        Colorado Building Codes - Boilers
                                        Responsible Office Facilities Management
                                        Responsible Person Gary Bowersock
                                        Contact Phone 303-273-3535
                                        Contact Email gbowerso@mines.edu

                                          Property

                                          Compliance Area Property
                                          Area Description Issues relating to the use of university-owned real property, to the University’s purchase or leasing of real property and to interactions with other owners of real property.
                                          Compliance Topics  
                                          Responsible Office CPC-real property; Legal Services; Controller
                                          Responsible Person  
                                          Contact Phone  
                                          Contact Email  

                                            Research Financial Administration

                                            Compliance Area Research Financial Administration
                                            Area Description Issues relating to the administration of sponsored research agreements, including the appropriate charging of and accounting for costs, expenses and effort to grants.
                                            Compliance Topics

                                            America Competes Act
                                            American Recovery and Reinvestment Act of 2009 (ARRA)
                                            Federal Acquisition Regulations
                                            Federal Funding Accountability and Transparency Act of 2006 (FFATA)
                                            National Science Foundation (NSF) Requirements
                                            Non-Disclosure Agreements
                                            Office of Management and Budget (OMB) Circulard A-110, A-133, A-21
                                            Uniform Guidance 2 CFR 200
                                            Office of Management and Budget (OMB) Circular A-21
                                            Central Contractor Registration

                                            Responsible Office Office of Research Administration
                                            Responsible Person Ralph Brown
                                            Contact Phone 303-273-3538
                                            Contact Email rabrown@mines.edu

                                              Research Regulatory

                                              Compliance Area Research Regulatory
                                              Area Description Issues relating to the federal and other regulations applicable to the design, conduct and reporting of research, including the protection of human and animal research subjects, the use of hazardous materials in research, and research misconduct.
                                              Compliance Topics Department of Health and Human Services
                                              Intergovernmental Review of Federal Programs - Coordinated Proposal Review
                                              National Institutes of Health Requirements
                                              National Science Foundation - Data Requirements
                                              Responsible Office VPRTT; Office of Research Administration
                                              Responsible Person Ryan RIchards; John Spear; Ralph Brown
                                              Contact Phone  
                                              Contact Email rabrown@m

                                                Student Health

                                                Compliance Area Student Health
                                                Area Description Issues relating to the medical and mental health treatment of students and the provision of health-related information to students.
                                                Compliance Topics Colorado Health Insurance Provider Laws
                                                Colorado Health Services Licensing
                                                Colorado Revised Statutes - Professional Counseling Confidentiality (Title 12)
                                                Health Insurance Portability and Accountability (HIPAA)
                                                Medical Waste Tracking Act
                                                Medicare Secondary Payer Reporting
                                                Patient Protection and Affordable Care Act
                                                Responsible Office Student Health
                                                Responsible Person Deb Roberge; Derek Morgan
                                                Contact Phone 303-273-3297
                                                Contact Email droberge@mines.edu

                                                  Student Information and Enrollment

                                                  Compliance Area Student Information and Enrollment
                                                  Area Description Issues relating to student enrollment including student confidential information, student information reporting, laws regarding veteran enrollment, and transfer credit.
                                                  Compliance Topics College Opportunity Fund
                                                  Colorado Revised Statutes - Student Residency (23-7-101, CRS)
                                                  Department of Veteran Affairs Laws
                                                  Family Educational Rights and Privacy Act (FERPA)
                                                  Post 911/GI Bill
                                                  Solomon Act
                                                  Student Right to Know
                                                  Colorado Revised Statutes - Restriction of Public Benefits (CRS 24-76-101)
                                                  Colorado Revised Statutes - Transfer Policies (23-1-108)
                                                  Department of Defense - Tuition Assistance MOU
                                                  Responsible Office Registrar
                                                  Responsible Person Lara Medley
                                                  Contact Phone 303-273-3204
                                                  Contact Email lmedley@mines.edu

                                                    Student Life

                                                    Compliance Area Student Life
                                                    Area Description Issues relating to student services.
                                                    Compliance Topics Colorado Revised Statutes - Fair Housing Statutes (Title 38)
                                                    Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit CARD Act)
                                                    Fair Housing Act of 1968
                                                    Responsible Office Student Life 
                                                    Responsible Person Dr. Dan Fox
                                                    Contact Phone x3357
                                                    Contact Email dfox@mines.edu

                                                      Tax Matters

                                                      Compliance Area Tax Matters
                                                      Area Description Issues relating to the University’s federal and state tax status, the compilation and filing of tax returns, and other matters with tax implications.
                                                      Compliance Topics Accountable Business Expense Plan
                                                      Automobile Mileage Rates
                                                      Benefits Plans - IRS Requirements
                                                      Bond Covenants
                                                      Deferred Compensation Plans
                                                      Donations - Substantiation and Disclosure Provisions
                                                      Educational Assistance Programs
                                                      Exempt Organization Tax Returns
                                                      Federal and State Payroll Tax Withholding and Reporting
                                                      Lobbying Restrictions and Disclosure Requirements
                                                      Non-qualified Deferred Compensation
                                                      Non-Resident Alien Taxes, and Filing and Information Return
                                                      Prizes and Awards to Employees
                                                      Property Transferred to Employee as Compensation
                                                      Quid Pro Quo Rules for Donations
                                                      Reporting Receipt of Cash Greater than $10,000
                                                      Reporting Tuition Payment Credit
                                                      Retention period for employment tax records
                                                      Retirement Plans
                                                      Sales Tax Exempt Purchases
                                                      Sales Taxes - Collection and Payment
                                                      Student Loan Interest Reporting
                                                      Tax Laws for Exempt Entities
                                                      Taxability of Meals and Lodging Furnished to an Employee
                                                      Tuition/Educational Assistance Program
                                                      Unrelated Business Income Taxes
                                                      W-9 Collection and 1099 Reporting
                                                      Responsible Office Controller
                                                      Responsible Person Roger Cusworth
                                                      Contact Phone 303-273-3109
                                                      Contact Email rcuswort@mines.edu

                                                        Technology Development and Patents

                                                        Compliance Area Technology Transfer
                                                        Area Description Issues relating to the development and licensing of discoveries, inventions and technology, including the securing of patents for such inventions, the protection of intellectual property rights, and the commercialization of intellectual property.
                                                        Compliance Topics Animal Welfare Act
                                                        Bayh-Dole Act
                                                        Cooperative Research and Technology Enhancement Act of 2004 (CREATE Act)
                                                        Human Subjects Research
                                                        Intellectual Property Laws - Research data
                                                        Leahy-Smith America Invents Act (AIA)
                                                        Patent Accounting
                                                        Responsible Office VPRTT
                                                        Responsible Person Dr. Tony Dean; William Vaughan
                                                        Contact Phone  
                                                        Contact Email adean@mines.edu

                                                          University Administration

                                                          Compliance Area University Administration
                                                          Area Description Issues relating to University policy and planning.
                                                          Compliance Topics Civil Rights Act of 1964
                                                          Education Amendments of 1972, Title IX
                                                          Higher Education Act
                                                          Higher Education Reconciliation Act of 2005
                                                          Higher Education Act - Integrated Post-Secondary Education Data System (IPEDS) - Surveys
                                                          Smoking
                                                          Higher Education Opportunity Act (HEOA)
                                                          Higher Learning Commission - Pathways Response
                                                          Responsible Office Policy
                                                          Responsible Person Jane Rosenthal
                                                          Contact Phone 303-384-2236
                                                          Contact Email compliance@mines.edu

                                                            University Endowment

                                                            Compliance Area University Endowment
                                                            Area Description Issues relating to the solicitation, negotiation, receipt, management and stewardship of donations and gifts to the University.
                                                            Compliance Topics Uniform Prudent Management of Institutional Funds Act of 2006
                                                            Responsible Office Foundation
                                                            Responsible Person Brian Winklebauer
                                                            Contact Phone 303-273-3140
                                                            Contact Email bwinkelb@mines.edu

                                                              TBD

                                                              Compliance Area Contact compliance office for referral
                                                              Area Description  
                                                              Compliance Topics Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM Act)
                                                              Executive Order 13166 - Limited English Proficiency
                                                              Responsible Office  
                                                              Responsible Person  
                                                              Contact Phone  
                                                              Contact Email compliance@mines.edu

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