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Creating an entire compliance plan from the ground up was a lot of hard work. Prior to
completing this capstone, I wouldn’t have ever completed an assignment that was anywhere near
similar to this project. In retrospective, this project was the best way I could have completed my
Master’s Degree. It was a great way to review, and implement all of the information, and skills
that I have learned and acquired over the past two years. Well, enough of the small talk. Let’s
jump right into it.
Welcome to the Compliance University Athletics Department. Compliance University is a
NCAA Division I member institution. Our Mission, is to provide guidance to the entire
Compliance University community about the rules, regulations and standards which regulate the
integrity and fair play in all of our affairs and events. Amongst all else, we exist to promote and
protect the health and welfare of all of our student-athletes, and protect the integrity of our
Department of Athletics here at Compliance University. A key goal within our purpose and
fundamental policy is to run a program that is totally compliant with all NCAA rules and
regulations. We pride ourselves on having behaviors that promote a culture of compliance. Our
administrators, coaches, staff, and student-athletes have worked very hard to develop a program
that represents Compliance University with class and dignity at all times. The institution believes
in strengthening compliance efforts through the availability and easy access of proper resources
and tools, and the application of efficient education and training. One of our most user friendly
and easily accessible resources is our compliance website. Its sole purpose is to help all affiliated
with Compliance University Athletics, maneuver through and understand the key elements of
staying compliant with NCAA rules. We have provided information for current and prospective
student-athletes, coaches, staff, and boosters. If you are unable to find information you are
looking for, please feel free to contact us.
Compliance University Athletics is made up of 6 Men’s intercollegiate team sports and 5
Women’s intercollegiate teams. The men’s sports at Compliance University are soccer, football,
basketball, baseball, cross country and indoor and outdoor track and field. For the women’s side
we have, soccer, volleyball, basketball, cross country and indoor and outdoor track and field. The
athletic department is made up of 10 key departments that are vital to the success of our athletics
program, which do not include any members of our coaching staff or any current student
athletes. The departments are, Athletic Academics, Athletic Training, Business, Accounting,
Ticketing, Compliance, Facility Operations, Marketing, Media Relations, and Technical
Services/Information Technology. Using my previous knowledge and experience in
intercollegiate athletics, these departments are essential to covering every aspect and demand
needed to run a successful athletics department. Keep in mind that not every athletic department
is going to have the same exact departments and positions, but you can bet your bottom dollar
that they will have a position/s and departments that are very close to the examples that I have
provided for my compliance structure. The structure itself will also differ, but the job and
department functions remain the same. As compliance officers you are responsible for the
compliance training and culture of compliance for every person in the Compliance University
Athletics community, as well as accountability.
One of the key functions of an athletic compliance officer is to ensure that all athletics personnel
are properly trained, educated, and knowledgeable of all need to know information that pertains
to their job function. Although there are so many positions within our athletic department that
come with huge responsibilities, and require hefty time and effort sacrifices, the position of head
coach of any sport comes with the most responsibilities, and is one of the most challenging jobs
3. 3
to have, when it comes to compliance. Head coaches are responsible for not only coaching and
athletically related activities, but are responsible for and held accountable for so many other
aspects that are completely unrelated to coaching and physical activities and performances. Head
coaches are responsible for everything that is going on with his/her team, including, but not
limited to: student-athlete well-being, per-diem, recruiting, meeting training and academic
standards, planning travel, and budgeting expenses. The head coach is also responsible for any
noncompliant behavior or actions on his/her team, and coaching staff whether they are aware or
unaware about the behaviors and actions. All of this and more responsibilities fall directly into
the head coaches lap. It is common for head coaches to have assistance coaches, secretaries,
graduate assistants and volunteers that help them steer the boat, but ultimately if anyone drops
the ball, not only will the staff member or athlete be held accountable, but the coach will have to
answer to any superior. The NCAA manual states in Bylaw, Article 11.1.1.1 Responsibility of
Head Coach, “An institution’s head coach is presumed to be responsible for the actions of all
institutional staff members who report, directly or indirectly, to the head coach. An institution’s
head coach shall promote an atmosphere of compliance within his or her program and shall
monitor the activities of all institutional staff members involved with the program who report,
directly or indirectly, to the coach.” One important note to make is that head coaches are required
to promote an atmosphere of NCAA compliance. Head coaches and staff members have an
obligation to, report suspected rules violations and actual rules violations, consult with
compliance staff to determine if their actions are consistent with NCAA rules, identify situations
where circumstances could result in NCAA violations, and continue to monitor the situation
closely. A head coach must always ensure that his or her program’s monitoring systems are
operating properly.
At Compliance University Athletic Department, we take advantage of resources and tools that
are available for the enhancement and growth of our athletic department. Our most important
resource that compliance uses as a reference and a tool to educate, is our NCAA Division I
Manual. In undergrad I was a student-athlete. I used to do a few modeling gigs here and there
and when my head coach caught wind of what I was doing, he immediately called me into his
office to discuss what he needed from me, so that the team did not have an occurrence of any
violations. I had to report all of my activity, work, pay, and description of each gigs to our
compliance department, every time, and I had to do it in a prompt manner. At the time, as a18
year old undergraduate student, reporting to the compliance officials all the time was highly
annoying. However, in retrospective I now understand why my coach needed to report to
compliance to see if I had committed a violation or not, and if not, what are the next steps to take
to ensure that I remained in compliance. The NCAA Division I Manual is the equivalent to the
intercollegiate athletics Bible, not only is owning one a necessity for compliance officers, but I
found that athletic directors, senior level administration, head coaches, athletic academic
advisors and personnel that deal with athletically related financial aid make reference to the
manual more often than not. The information within this book is considered the law! It’s our
version of the constitution, complete with our own version of the Bill of Rights and
Amendments. This information is constantly being changed, updated, and amended, especially in
the past three years. More than likely this is result of the Division I of the NCAA creating an
entirely new governance structure. This manual is official updated and redacted twice a year, at
the beginning of each fall and spring semester. The manual is available to anyone by download,
pdf, and hard copy. It is a requirement that all staff members stay up to date on all information
that applies to their responsibilities, one wrong move could result in a violate on.
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Let’s get right to it and dive into the manual head first! I’d like to start with the foundation of
what principles the NCAA has centered its legislation around. There are eighteen Principles of
Conduct for Intercollegiate Athletics:
A very important part of NCAA legislation is Title ix: Opportunity, Equity, Participation,
Fairness, Access, Education, Dreams, Respect, Inclusion. Title XI was implemented for women
and the federal civil rights law is known as Title IX. The evolution of Title IX is very
informative and has a long history dating back to the 1960’s legislation and the supreme court.
More specifically, title IX of the Education Amendments of 1972, 20 U.S.C. Sect. 1681 (20
United States Code section 1681) et seq. (Title IX), is a Federal statute that was created to
prohibit sex discrimination in education programs that receive Federal financial assistance.
Nearly every educational institution is a recipient of Federal funds and, thus, is required to
comply with Title IX. The regulation implementing the Title IX statute is at 34 C.F.R. (34 Code
of Federal Regulations) Part 106. The next important aspect of the NCAA, is highly
implemented into the compliance framework for Compliance University Athletics. Student
athlete well-being is at the core of all of our programs, policies, and procedures, for not only our
Compliance Department, but for the entire Compliance Athletics Department as a whole.
Participating in sports always come with inherent risks, but through partnerships, education and
innovations we can provide student-athletes with the best environment for success at Compliance
University. “The NCAA’s Sport Science Institute (SSI) is leading a national effort to partner
with member schools like Compliance University, national governing bodies, key medical and
youth sport organizations, the Department of Defense and the public sector to conduct research,
promote policies and develop educational materials that benefit the safety, excellence and
wellness of all athletes. (www.NCAA.org).” The SSI has advanced the following strategic
priorities in close consultation and coordination with medical experts, student-athletes and our
membership: Cardiac health, Concussion, doping and substance abuse, mental health, Nutrition,
sleep, and performance, overuse injuries and periodization, sexual assault and interpersonal
violence, athletics healthcare administration, and data-driven decisions. Another way that
Compliance University Athletics helps promote student athlete well-being is by implementing
the NCAA’s mandatory Student Athlete Advisory Committee and Life Skills Program. The
• General Principle
• The Principles of Institutional Control
and Responsibility
• The Principle of Student-Athlete-
Well-Being
• The Principle of Sportsmanship and
Ethical Conduct
• The Principle of Sound Athletic
Standards
• The Principle of Nondiscrimination
• The Principle of Governing the
Economy of Athletics Program
Operation
• The Principle of Diversity Within Governance
Structures
• The Principle of Rules Compliance
• The Principle of Amateurism
• The Principle of Competitive Equity
• The Principle of Governing Recruiting
• The Principle Governing Eligibility
• The Principle Governing Financial Aid
• The Principle Governing Playing and Practice
Seasons
• The Principle Governing Postseason
Competition and Contest Sponsored by
Noncollegiate Organizations
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NCAA states, that “The mission of the National Student-Athlete Advisory Committees is to
enhance the total student-athlete experience by promoting opportunity, protecting student-athlete
welfare and fostering a positive student-athlete image.” Student-athletes have a voice in the
NCAA through advisory committees at the campus, conference, and national level. Each
committee is made up of student-athletes assembled to provide insight on the student-athlete
experience and offer input on the rules, regulations and policies that affect student-athletes' lives
on campus. During my collegiate athletic experience, I noticed that SAAC members were made
up of the most intelligent and motivated student-athletes that our institution had to offer. They
worked really hard to give their fellow student-athletes a voice when it came to issues that we
experienced regarding student-athlete well-being. They also planned the most amazing events
and fun things for us to do. The SAAC reports directly to the Athletics Board of Administrators
and they kind of push through legislation like delegates who representative the student athlete at
their home institution. But the role of a SAAC member does not stop there. SAAC members
travel all over the United States with staff members and act as delegates for their home
Institution’s on platform’s at the conference level as well as NCAA conventions. The NCAA
has recently incorporated a SAAC into their new governance structure that is made up of
student-athletes from each conference, that represent as the voting powers in legislation for all
Division I student-athlete. Student- Athletes now have a weighted vote under the recent changes
made to the legislative process. On the institutional level, the SAAC at Compliance University’s
general functions are included but not limited to; Promoting communication between athletics
administration and student-athletes, disseminate information, providing feedback and insight into
athletics department issues, generate a student-athlete voice within the campus athletics
department formulation of policies, build a sense of community within the athletics program
involving all athletics teams, solicit student-athlete responses to proposed conference and NCAA
legislation, organizing community service efforts, creating a vehicle for student-athlete
representation on campus-wide committees (e.g., student government), and promoting a positive
student-athlete image on campus.
It is very important that compliance officers enforce and honor an effective code of
conduct. All employees that are governed under the code must adhere to all policy and
procedures that are laid out in conjunction with the code of conduct. Compliance University
provides all personnel and student athletes with their own copy of the code of conduct taken right
from the Division I NCAA Manual at the beginning of each academic semester. It is also always
accessible online. Bylaw, Article 10 of NCAA Division I Manual states that “Honesty and
Sportsmanship. Individuals employed by (or associated with) a member institution to administer,
conduct or coach intercollegiate athletics and all participating student-athletes shall act with
honesty and sportsmanship at all times so that intercollegiate athletics as a whole, their
institutions and they, as individuals, shall represent the honor and dignity of fair play and the
generally recognized high standards associated with wholesome competitive sports.” A key
component when teaching employees about the code of conduct is, you also have to thoroughly
educate them on the consequences of violating that code, not only to deter them from violating it
but to give them a structure of penalties that correlate with violations. This shows them a cause
and effect structure that will allow them to weigh outcomes and become informed on violations
prior to committing them. Bylaw 10.4 explains the disciplinary action for violation of standards:
Prospective or enrolled student-athletes found in violation of the provisions of this regulation
shall be ineligible for further intercollegiate competition, subject to appeal to the Committee on
Student-Athlete Reinstatement for restoration of eligibility. (See Bylaw 10.3.2 for sanctions of
6. 6
student-athletes involved in violations of Bylaw 10.3.) Institutional staff members found in
violation of the provisions of this regulation shall be subject to disciplinary or corrective action
as set forth in Bylaw 19.9, whether such violations occurred at the certifying institution or during
the individual’s previous employment at another member institution. It is the mission of the
NCAA infractions program to uphold integrity and fair play among the NCAA membership, and
to prescribe appropriate and fair penalties if violations occur. One of the fundamental principles
of the infractions program is to ensure that those institutions and student-athletes abiding by the
NCAA constitution and bylaws are not disadvantaged by their commitment to compliance. The
program is committed to the fairness of procedures and the timely resolution of infractions cases.
The ability to investigate allegations and penalize infractions is critical to the common interests
of the Association’s membership and the preservation of its enduring values. Here are two
bylaws that are relevant to the accountability and penalty structure for violation.
19.01.2 Accountability. The infractions program shall hold institutions, coaches,
administrators and student-athletes who violate the NCAA constitution and bylaws
accountable for their conduct, both at the individual and institutional levels
19.01.4 Penalty Structure. The infractions program shall address the varying levels of
infractions and, for the most serious infractions, include guidelines for a range of
penalties, which the Committee on Infractions may prescribe, subject to review by the
Infractions Appeals Committee. Penalties shall depend on the relative severity of the
infraction(s), the presence of aggravating or mitigating factors and, in some cases, the
existence of extenuating circumstances.
What I like so much about the Division I NCAA Manual is that it provides excellent descriptions
and details for everything. For example, the manual gives a description of almost every position
within an athletic department, and details of that positions’ duty, expectations and responsibility
for volunteer and non-volunteer positions. Bylaw, Article 11 of the manual also provides
information on compensation, remuneration, contractual agreements, and athletically related
income. Bylaw, Article 11 continues on to outline the expectation of Athletics Personnel, as well
as accountability. Institutional staff members found in violation of NCAA regulations shall be
subject to disciplinary or corrective action as set forth in Bylaw 19.9. The NCAA also provides a
detail of the penalty structure according to level:
Violation Structure Defined:
19.1.1 - Severe Breach of Conduct (Level I). A severe breach of conduct is one or
more violations that seriously undermine or threaten the integrity of the NCAA
Collegiate Model, as set forth in the constitution and bylaws, including any violation
that provides or is intended to provide a substantial or extensive recruiting,
competitive or other advantage, or a substantial or extensive impermissible benefit.
19.1.2 - Significant Breach of Conduct (Level II). A significant breach of conduct is
one or more violations that provide or are intended to provide more than a minimal
but less than a substantial or extensive recruiting, competitive or other advantage;
include more than a minimal but less than a substantial or extensive impermissible
benefit; or involve conduct that may compromise the integrity of the NCAA
Collegiate Model as set forth in the constitution and bylaws.
19.1.3 - Breach of Conduct (Level III). A breach of conduct is one or more violations
that are isolated or limited in nature; provide no more than a minimal recruiting,
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competitive or other advantage; and provide no more than a minimal impermissible
benefit.
19.1.4 - Incidental Infraction (Level IV Violation). An incidental infraction is a
minor infraction that is technical in nature and does not constitute a Level III
violation. Incidental infractions generally will not affect eligibility for intercollegiate
athletics. Multiple or repeated Level IV violations collectively may constitute a
Level III violation.
Institution control is one of the most important factors when considering an institution as
in compliance with NCAA policy and procedure. Many times this policy is at the core of the
NCAA’s worst violations, “lack of institutional control.” The actual policy itself is what
separates varsity athletics at the collegiate level, with what one may consider child’s play. At its
core, this policy is what holds NCAA member institutions accountable for any and all violations
that may occur, knowingly or unknowingly. Any athletics program must reflect the ideals of the
institution it represents, and it is up to the athletics director to constantly inform the president (or
the person to whom the athletics director reports) of all relevant developments within the
program. Here are the general principles and bylaws that the manual has outline for us regarding
institutional control. All personnel must understand and promote good institutional control.
6.01.1 Institutional Control. The control and responsibility for the conduct of intercollegiate
athletics shall be exercised by the institution itself and by the conference(s), if any, of which it is
a member. Administrative control or faculty control, or a combination of the two, shall constitute
institutional control. Bylaw 6.1 of the manual begins to define Institutional Governance. Noting
that the President or Chancellor of a member institution, has ultimate responsibility and final
authority for the conduct of the intercollegiate athletics program and the actions of any board in
control of that program. The term “president or chancellor” refers to the individual with primary
executive authority for an institution and does not include an individual who has executive
responsibility over a system of institutions. Bylaw 6.1.2, regarding an athletics board states,” A
board in control of athletics or an athletics advisory board, which has responsibility for advising
or establishing athletics policies and making policy decisions, is not required. However, our
institution requires that there is a board. The Athletics Board of Administrators here at
Compliance University consist of 10 members with the following titles: Director of Athletics,
Senior Associate Director, Senior Women’s Administrator, Senior Associate Director for
Business, Executive Director- Compliance University Athletic Foundation, Associate Director
for Media Relations, Assistant Director for Ticket & Facilities Operations, Assistant Athletic
Director for Marketing, Director of Information Technology, and Director of Athletic Facilities
and Event Operations.
Earlier I mentioned that I was a former student athlete at a NCAA Division I member
institution. I was also blessed with the opportunity to be able to shadow compliance officers in a
five-week program for athletes interested in pursuing athletic compliance. I gained so much
valuable knowledge and was able to pick the brains of a compliance officer and really see what
the career was like. I loved it. One of the most important skills for a compliance officer to learn
is risk management and risk mitigation. Being able to find the weaknesses and vulnerabilities
within the program, and having a culture of education and training compliance as well as
integrity is highly beneficial. There are so many violations that can occur, the possibilities are
endless. There is no way that the entire compliance department will be able to police and deter an
entire athletic department and community. Being good at risk management does not only mean
being able to predict violations, or prevent them but being prepared to deal with different impact
8. 8
levels for different violations, ranging from minute to tremendously severe. Adaptability is a
major key for a successful risk mitigation plan. The ability to keep moving while ratifying is
vital. I have come up with a list of the highest and frequent risk factors for Compliance
University Athletics and also provided remedies that could help modify or amend each risk as an
example for you.
1. Use of Banned Substances
Institution issued drug screenings, random and more often than NCAA official drug
screenings
2. Playing and Practice Season Violations
Playing and practice season calendar available for everyone on compliance website
under our “Quick Links” tab.
Have coaches document and sign a log making note of each individual student
athlete’s practice schedule and type of practice for every practice session that they
attend weekly. The student athlete must then review and sign off on it, stating that it
is valid. Each week this must be turned into the compliance office for potential audits
and evidence.
3. Eligibility & Recruiting
Mandatory Training and Education for coaches and student athletes
Information available to all at any time on compliance website in the “Quick Links
Section”
Yearly recruiting exam, mandatory for ALL coaching staff, must be passed with a
100% passing rate (3 attempts only)
4. Receiving Extra Benefits, Lack of Institutional Control & Ethical Conduct violations
Hold mandatory information sessions about past violations cases, and place emphasis
on the after effect and negative consequences that came from the violations for
coaches, student athletes and the institution. I would also provide tactics of how to
identify common violations before they occur and protect yourself and your
institution from negative impact. and life skill events monthly for student athletes
Rewards for compliant behavior and give recognition for individuals who give extra
efforts to stay compliant.
Encourage reporting any knowledge of violations
Compliance officials must have mandatory access to view and monitor all student
athlete’s social media accounts
Implementing and advertising our famous “Ask Before You Act” presentation at big
games.
All though the examples that were provided are examples of common NCAA violations,
compliance officers often never know what violations will actually occur. The only way to
protect the integrity of our athletics department’s culture of compliance is to educate, train and
encourage doing the right things. Starting with our Chancellor, board of directors, coaching staff,
all the way down to our trainers, doctors, student athletes, interns and so many others. For our
documentation, we require the student-athlete’s statement of compliance education and NCAA
requirements must be signed and kept on file and a certification of compliance training for staff
member form, which must be signed and kept on file every year.
Monitoring, auditing and investigation are three important factors that help keep the
institution under control, and compliant with NCAA legislation. A comprehensive system for
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reviewing all entities within the Athletics department is a necessity that would include but is not
limited to:
Periodic review of personnel practices and progress
bi-annual financial department wide audits
observations of athletic practices by an anonymous contracted 3rd party
mini quarterly audits that challenge the validity of documents and record keeping
procedures
ability for anyone, anywhere to file an anonymous report of any violation right on the
home page of our website without fear of retaliation
Peer-Reviews, student-athlete surveys, questionnaires
random drug screenings
the Compliance Assistant will also follow, monitor, and research all student athlete
social media accounts from a Compliance University Athletics account’s only, and
document any unethical behaviors or violations discovered.
Hire a firm that does private auditing and investigations and have them do an annual
audit. After completion of the internal audit of ALL departments in Athletics. We will
need a detailed and thorough report including the following information for each
individual department: Overview, executive summary, source and purpose of audit,
scope of audit, background information, findings of the audit and observation,
summary conclusion, an action plan and future recommendations. The firm must also
note patterns, trends, and changes on a year to year comparison basis for each
department. This is used to collect and study data over time.
Major Investigations Committee: 7 Non-board members consisting of 3 lawyers, The
Director of Compliance, The Chancellor, and 2 private investigators who are familiar
with NCAA terms and legislation (former lawyers or government official)
Compliance officers are responsible for conducting preliminary investigations into
the merit of any and all violations that are reported.
The NCAA audits on an annual basis 3 reports that must be factual and submitted by
each NCAA member institution by set deadlines: 1. a mandatory NCAA athletics
certification self-study and peer review, 2. an annual financial audit, and 3. an Equity
in Athletics Disclosure Act Report.
Compliance University Athletics has an obligation to report all instances of infractions, major
violations, audits and investigations, financial details and all other information considered
beneficial to department progression, to the Athletics Board of Administrators. All routine audit
and observation reports, standard monitoring data, general updates and progress reports will be
presented to the board quarterly. The medium will vary between hard copy, presentations, and
dashboards. All reports of major infraction cases (Level 1 & 2) will be handled in confidence,
and thoroughly investigated by our Major Investigations Committee in a timely fashion. Once
the investigation has been completed or if it takes a substantial amount of time, a report or
preliminary findings report will immediately be sent to the board via email. The board then has
up to 5 business days to decide if they feel the need to convene into the matter or continue to
leave the compliance department and major investigations committee in charge of steering the
investigation. If a meeting is scheduled it must occur within 10 business days of the date the
original email was sent. Self- Reporting to the NCAA is a lot different and information is
handled and reported with discretion. The NCAA mandates the self-reporting of all intuition
10. 10
infractions, minute and major. In Bylaw, Article 2 is states “Each institution shall comply with
all applicable rules and regulations of the Association in the conduct of its intercollegiate
athletics programs. It shall monitor its programs to assure compliance and to identify and report
to the Association instances in which compliance has not been achieved. In any such instance,
the institution shall cooperate fully with the Association and shall take appropriate corrective
actions. Members of an institution’s staff, student-athletes, and other individuals and groups
representing the institution’s athletics interests shall comply with the applicable Association
rules, and the member institution shall be responsible for such compliance.” The NCAA has
already created a tool called Requests and Self-Reports Online (RSRO). RSRO allows institution
compliance officer with log in credential to, log onto an NCAA portal and detail and submit
suspected or known violations in just five easy steps. How convenient is that?
