Joseph Agins, CCEP, CFE, Institutional Compliance Officer at Sam Houston State University in Huntsville, Texas, USA
GZ: You’ve been in the higher education compliance arena for more than 12 years now. What are the biggest changes you’ve observed in how compliance has been approached over that time?
JA: Well, certainly there has been more importance placed on having compliance programs, and more and more institutions are realizing the added value that a robust compliance program can have, not simply by keeping the institution compliant, but also improving the institution’s culture. As with many industries, compliance is often looked at somewhat negatively and like a thorn in your side that you are occasionally forced to deal with. I think we are now seeing that institutions are starting to realize the real value proposition of having a good compliance program, and the compliance program is looked at as more of a positive as opposed to a negative.
GZ: Compliance in the higher education environment has many diverse elements, from student financial aid to research, privacy, and many other areas. How is this complexity reflected in how your compliance function is organized, how responsibilities are assigned, etc.?
JA: Managing compliance at a university is, in many ways, like managing compliance in a small city. We seem to have it all—from athletics to the Americans with Disabilities Act, student financial aid to Title IX, the Clery Act to campus safety. Yes, compliance in higher ed is indeed very complex. Did I mention we have a body farm here at Sam Houston State University (SHSU)? Universities have literally hundreds and hundreds of vastly varying compliance requirements they need to comply with. As such, SHSU has a very decentralized model where minimal compliance responsibilities are actually owned by this office. We focus more on identifying the experts (our compliance partners) in different areas and then work with them to understand where they are at, what the challenges and gaps are, and provide assistance to them as much as possible. My role is more of a problem solver, partnering with these experts and developing workable solutions to sometimes very complex compliance issues.