Compliance Training Plan

 2017-2018 Compliance Training Schedule

Course Population Initial Requirement Recurrence
Annual Compliance Training (ACT) All employees, graduate assistants, and graduate fellows Within 30 days of beginning employment. New employees beginning work during the summer will be assigned the new course released in the fall. Annual, with a new course released each fall
Building a Safe Penn State: Reporting Child Abuse All employees, volunteers, independent contractors, graduate assistants, and graduate fellows Within 30 days of beginning employment or volunteer activity None (incorporated into ACT)
PA Mandated Reporters Prior to beginning employment or volunteer activity Annual, due one year from last completion
Understanding Title IX All employees, graduate assistants, and graduate fellows Within 30 days of beginning employment None (incorporated into ACT)
Clery Act Campus Security Authorities (CSAs) Within 30 days of beginning employment or volunteer activity None (incorporated into ACT)

 

Guidance Regarding Non-compliance

  • GSI-eligible employees who are overdue to complete the Annual Compliance Training (ACT) course as of February 23, 2018 will not receive GSI in 2018
  • Ineligibility for GSI is only tied to the ACT course. It does not apply to other compliance courses (Reporting Child Abuse, Clery, etc.) at this time
  • For individuals who are ineligible for GSI:
    • Non-compliant graduate assistants and fellows will be referred to the Graduate School
    • Tech Service employees will be referred to HR for discipline within bargaining unit guidelines
    • Wage employees who are non-compliant are either 1) terminated within 30 days after the deadline for training, or 2) not scheduled for further shifts until training is complete
    • FT2 employees who do not work with minors and are non-compliant are either 1) not renewed, or 2) do not have a salary increase in their new contract
    • FT2 employees who work with minors and are non-compliant will be 1) terminated within 30 days after the deadline for training, or 2) immediately removed from working with minors and notified they will not be renewed
  • New employees will be given at least 30 days to complete. Those assigned the training less than 30 days prior to the 2/23 GSI cutoff will remain GSI-eligible
  • Supervisors will be responsible for communicating training requirements for employees without email access. They also must provide time during the work day and computer access for their employees to complete training
  • Unit leaders and supervisors should be held accountable for ensuring their employees complete the training or are given the appropriate consequence. Failure to do one or the other should be taken into account during annual performance reviews
  • Executive leadership will be given a report of non-compliance shortly before and immediately after the deadline so that unit leaders can be held accountable for non-compliance or failure to administer the appropriate consequence within their units
  • HRSPs and HRCs will assist to the extent possible, but will not be held responsible for following-up on non-compliant individuals