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Compliance and Ethics

14201 School Lane, Room 202B
Upper Marlboro, MD 20772
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Contact Information

Robin Welsh, Esq.
Director, Office of Compliance and Ethics
Joeday F. Newsom, Esq.
Ethics Compliance Officer
Dr. Ramona Burton
Compliance Administrator
Gina Harrison
Administrative Assistant

About the Office

The primary responsibility of the Office of Compliance and Ethics (OCE) is to create a more compliance oriented school system by working collaboratively with schools and offices to enhance safe and supportive learning and working environments, meeting financial responsibilities, and following policies and administrative procedures.

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Compliance Involves:

Compliance Culture

Every large organization has a compliance culture.  A compliance culture is a workplace’s collective perception of their internal policies, and procedures.  A compliance culture may be positive--that is, it is taken for granted by employees that administrative procedures are routinely consulted and followed.  A compliance culture may also be toxic -- that is when employees ordinarily ignore policies and procedures.  This may occur for a number of reasons.  The procedures may not have been reviewed by employees. The procedures may also be considered irrelevant because management has indicated its own indifference by expressly or tacitly preferring 'work-a-rounds' to official procedure and by management failing to hold employees accountable for violations of the procedures. 

 In these toxic cultures, rules exist only in theory or as a suggestion, rather than familiar, internal and compulsory.  Policies and procedures are estranged from actual operations. A toxic compliance culture makes managing operations exponentially more difficult.  Workers lose the sense of shared commitment to broad, institutional objectives.  The sense of a work-community progressing toward a shared outcome does not exist — it is replaced by an 'every man for himself' attitude.  Even where employees retain their sense of obligation to follow procedures, a toxic compliance culture creates uncertainty:  When am I required to follow rules?  Which rules require observance and which can be ignored?  Why should I take on the extra work required by following rules when others ignore rules with impunity?

  The OCE seeks to combat toxic compliance culture and encourage a positive compliance culture.  Improvement may be accomplished many ways; chief among them is training and education.  We seek to help employees and management to learn the procedures which govern their work, to routinely consult the procedures and by helping the employees perform their work while adhering to the policies and procedures.  We encourage all employees to take pride in educational achievement through their fidelity to rule-following.

  Another important way we can improve our compliance culture is to encourage ownership of the procedures by employees and management.  Often procedures become outdated and need revision.  In these instances, every employee should be encouraged to tell management of the problem and the need for revision.  Additionally, regular discussion of procedures helps facilitate employees’ ability to internalize and follow established procedures. Sometimes the problem with procedures is their absence.  Procedures do not always keep pace with changing work environments.  In positive compliance cultures, employees speak up and suggest new procedures to eliminate or reduce risk.

Employees should always be encouraged to consider compliance to be a community effort. So many of PGCPS operations are dependent on various departments working cooperatively.  That is, one department must complete its tasks in the exact manner prescribed so that another department may more easily meet its own obligations.  Record-keeping is a good example.  Accurate and thorough record keeping may not help the record keeper but it helps other parts of the organization who rely on the information contained in the records to discharge their important obligations.  Compliance is dependent on employees helping each other in their work community.  Compliance is community.

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Student Safety and Welfare

The safety of students and staff is a priority for our school district. Safe learning environments, both physically and emotionally, are necessary for student learning and academic achievement.

The Prince George’s County Public Schools’ Board of Education is committed to providing a quality education to all students in a safe and supportive environment.  Everyone in the school district has a shared responsibility to ensure the safety of our students and instill confidence in our parents and our community that we all have the wellbeing of their children foremost in our minds. One of the major responsibilities of the Office of Compliance and Ethics (OCE) is to help our district leaders and employees, regardless of the employee’s position or location, be accountable within the employee’s respective spheres of influence for adhering to the Board of Education policies and the district’s administrative procedures promoting school safety and a safe and supportive school climate for all students and staff.

The OCE helps schools to manage their physical and emotional environments in a manner that prevents unsafe environments for students.  Our team assesses the physical and situational parameters of the schools, monitors and collects data on schools’ performance of safety related requirements, and utilizes the information obtained to develop training for schools staff and administrators.

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Prevention of Waste, Fraud and Abuse

 Our school district depends on the generous financial support in the form of tax dollars we receive from fellow Prince Georgians.  In exchange, Prince George’s County Public Schools (PGCPS) gladly accepts the responsibility for ensuring the conscientious use of these funds, guaranteeing the money is used for the purpose for which it is intended:  the education of our students.

 No one wants their money wasted.  Part of the mission of the Office of Compliance and Ethics (OCE) is to help our district’s leaders and employees to meet PGCPS obligation of being good stewards of the resources bestowed upon us.

The misuse of resources exacts a burdensome toll on the school district in many ways.  It erodes the public confidence in our professed commitment to conscientiously manage that which is allocated to us.  It saps resources needed to educate our students.  Misuse of resources may also serve to demoralize our employees when our school district suffers a loss by way of waste, fraud or abuse when it’s clear that strict compliance to rules would have prevented the loss.

The OCE seeks to prevent these outcomes.  The OCE helps prevent fraud, waste and abuse of its resources by helping to identify regulatory and compliance weaknesses, suggest ways to ameliorate or eliminate these weaknesses and improve our work culture's collective attitude toward complying with rules, often called Compliance Culture (see below).  We also help identify instances where a referral to law enforcement is appropriate and, where able, facilitate the recapture of funds lost to fraud, waste and abuse.  Our team assists with reporting and investigating when called upon.  We help with accountability by making recommendations in these areas.  When needed, we work as a liaison with auditors and coordinate audit remedial efforts. We also provide gentle reminders of the importance of compliance as a demonstration of our unwavering commitment to the responsible use of our resources.

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Compliance Risk Assessment

No organization is perfect.  Policies and procedures are designed to minimize human error. However, the risk of human error remains. All organizations are subject to change--sometimes gradual, sometimes drastic.  Every change potentially alters the myriad of risks an organization must take into account. 

One of the missions of the Office of Compliance and Ethics (OCE) is to remain vigilant in identifying organizational risk and changes which impact risk so that management can better decide how to allocate resources to prevent the bad outcomes resulting from a given risk.

Risks appear everywhere in everything we do.  Compliance Risks are those risks either which arise when policies and procedures are not followed or when they are insufficient or ineffective. Some compliance risks are significant; others are comparatively trivial.  They come in many forms. Compliance risks may be safety-related, such as the outcomes associated with violating administrative procedures .  They may be finance-related, such as the risk of loss by way of waste, fraud or abuse associated with violating, for example, procurement procedures or conflict of interest policies.  Compliance risk may even be academically related, such as where our students’ education and our reputation is jeopardized when graduation rules are misapplied or ignored.

When compliance risks are identified by the OCE we communicate the risks to management.  Management may act to eliminate, mitigate, transfer or monitor the risks. In some instances, the OCE can assist management directly with the risks.  Subject to our own resources, we can sometimes provide oversight or help to train employees or assist in revising procedures which govern the identified risks.  Often we can provide assistance in coordinating efforts by different departments to reduce risk. 

Our ongoing tasks include regular review of Administrative Procedures and Board of Education Policies and the laws and regulations on which they are based.  Changes to operations are noted and examined.  We pay attention to particularly dangerous risks, significant changes in operations, which may result in new compliance risks, audit results and communications from Internal Audit about Hotline tips, and areas where different departments must interact cooperatively in order to affect the desired result.

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