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Compliance


Table of Contents

Introduction
Compliance Duties
NCAA, Conference, and University Rules & Violations Procedures
Rules Education
Rules Interpretations
Philosophy on Self-Reporting Rules Violations
Reporting & Investigating Rules Violations

Compliance Sections

Ethical Conduct
Personnel
Amateurism
Recruiting
Eligibility
Financial Aid
Awards & Benefits
Playing & Practice Seasons


Introduction

The Compliance Office is responsible for assuring the successful day-to-day operation of all aspects of the intercollegiate athletics program within the rules and regulations of the NCAA, the West Coast Conference, the NorPac Conference, the Mountain Pacific Sports Federation Conference, the Golden Coast Conference, the University, and the Department of Intercollegiate Athletics.

The Compliance Office staff consists of the Associate Director of Athletics for Student Services & Compliance, the Associate Director of Athletics for Internal Affairs, and the Assistant Director of Compliance.

Compliance Duties

  • Evaluate current athletics programs to determine and assure the highest levels of compliance and record keeping.
  • Provide administration of NCAA compliance programs, including but not limited to, initial and continuing eligibility, financial aid, and recruiting.
  • Monitor and record student-athlete eligibility, recruiting, and financial aid information to assure compliance with all NCAA, conference, and institutional rules and regulations.
  • Provide a program of continuing rules education and an interpretation center for student-athletes, athletics staff, coaches, boosters, alumni, and institutional staff.
  • Plan and implement a program of in-service training and staff development for coaches and administrative staff.
  • Identify, investigate and report, as necessary, any and all NCAA and conference rules violations.
  • Provide  periodic  reports  to  the  Director  of  Athletics,  the  Faculty  Athletics  Representative, institutional officials, the Athletics Advisory Board, and others, as necessary.
  • Serve as a liaison between the Department of Intercollegiate Athletics and the offices of Admissions, Registrar, Student Business Services, and Financial Aid for all compliance related services for athletics.
  • Work with Controller's Office during NCAA review by external auditors each year.
  • Other duties as assigned by the University President, Vice President for External Relations or the Director of Athletics.

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NCAA, Conference, and University Rules & Violations Procedures

Introduction
All Department of Intercollegiate Athletics staff and Representatives of Athletics Interests are expected to abide by NCAA, Conference, and University rules.  The Associate Director of Athletics for Student Services & Compliance or the Assistant Director of Compliance should be contacted on matters involving actual or suspected violations of University and/or NCAA rules and procedures.

In accordance with NCAA regulations, all suspected NCAA violations shall be investigated. If the investigation indicates that a violation has occurred, the Director of Athletics and either the Associate Director of Athletics for Student Services & Compliance or the Assistant Director of Compliance will report the violation to the NCAA and the Big West Conference Office.  Furthermore, when the violation involves prospects and/or student-athletes, the institution must declare the individuals ineligible and seek restoration of their eligibility through NCAA Student-Athlete Reinstatement.

What Should Be Reported
The University encourages the reporting of any behavior or action, suspected, rumored or observed, that might in any way seem to conflict with what one knows or believes to be University, Conference, or NCAA rules or policies, or that simply seems inconsistent with how one believes an ethical and purposeful intercollegiate athletics program should be operated.  Additionally, coaches are expected to self-report to the Compliance Staff any violations they commit.

Who May Report a Violation
Anyone (staff, faculty, coaches, student‑athletes, alumni, community members, etc.) can and should report any suspected mistakes or misconduct.  The report may be made either directly or anonymously.

To Whom an Alleged Violation Should be Reported
If an alleged or rumored violation is reported to an Intercollegiate Athletics staff member, the staff member is required by NCAA regulations to notify the Director of Athletics immediately. The Director of Athletics will then notify the Associate Director of Athletics for Student Services & Compliance and/or the Assistant Director of Compliance for investigation. Individuals other than Intercollegiate Athletics staff members should report alleged violations to the Associate Director of Athletics for Student Services & Compliance, the Assistant Director of Compliance, or the Director of Athletics.

How an Alleged Violation Should be Reported
The NCAA Rule and University Policy Violation Report Form (see Appendix) can be used for reporting purposes.  If an individual chooses to report a possible violation some other way, he or she should be sure to include the information requested on the form.

Investigation of Potential Violations
The Faculty Athletics Representative, the Associate Director of Athletics for Student Services & Compliance and/or the Assistant Director of Compliance are responsible for conducting investigations of possible violations.  In conducting such inquiries the investigator will consult regularly with the Director of Athletics and will keep the University President apprised of any developments.

Alleged Violations at Other NCAA Member Institutions
If an individual has knowledge of an alleged violation that has occurred at another NCAA member institution, he or she should report the alleged violation to the Associate Director of Athletics for Student Services & Compliance, the Assistant Director of Compliance, or the Director of Athletics.  The person receiving the report should discuss the violation with the accuser and then contact an administrator at the accused member institution to request that the alleged violation be investigated. The Associate Director of Athletics for Student Services & Compliance, the Assistant Director of Compliance, or the Director of Athletics may also contact the Big West Conference Office and request that the Commissioner or Associate/Assistant Commissioner contact the accused institutions.

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Rules Education

The Compliance Office shall provide the necessary programs and materials to the athletics staff and other parties that have athletically-related departmental responsibilities. To assure that all areas are kept up-to-date, the Compliance Office on a regular basis will provide them with the most recent NCAA legislation and interpretations that may affect them.

The Compliance Office has identified the following areas as those that require priority communications:

President's Office
The Director of Athletics will meet periodically with the President and/or the President's representative to review and report on the Department's compliance with and the President's role in NCAA regulations.

Vice President for External Relations
The Vice President for External Relations has direct oversight of the Department of Intercollegiate Athletics and works with the Director of Athletics to ensure institutional control and proper and sound management of the entire program.

Faculty Athletics Representative (FAR)
The Director of Athletics, Associate Director of Athletics, and Assistant Director of Compliance will maintain regular contact with the Faculty Athletics Representative (FAR) to assure this individual is fully informed of all relevant aspects of Department of Intercollegiate Athletics programs. The FAR will receive rules updates, rules interpretations, and distribution of Big West Conference materials, as necessary.

The FAR will be provided the report on all NCAA rules violations. The FAR will oversee the recruiting examinations of all coaching staff eligible to recruit off campus. The FAR will coordinate the process for student-athlete grievances and financial aid appeals. The FAR will also be actively involved in all investigations of alleged rule violations. Finally, the FAR will assist in conducting student-athlete exit interviews.

Student-Athletes
The Compliance Office will review regulations with student-athletes pertaining to eligibility, financial aid, amateurism, recruiting, gambling, drug education, and drug testing.

The Compliance Office will strive to maintain open lines of communication with student-athletes to encourage them to ask questions regarding NCAA rules and regulations, and reporting possible alleged violations.

Prospective Student-Athletes
The Compliance Office will work to ensure that prospective student-athletes (PSAs) recruited by the University have the highest possible awareness of NCAA rules and regulations. To help meet this goal, the current edition of the NCAA Guide for the College Bound Athlete will be available to coaches to distribute to recruits.

As a regular part of the continuing rules education process, the Compliance Office will review all pertinent recruiting legislation with coaches. Coaches will be reminded of the need to ensure their PSAs understand and comply with recruiting regulations.

Representatives of Athletics Interest (e.g., Boosters)
The Compliance  Office  will  produce  a  brochure  that  specifically  outlines  regulations  affecting booster organizations and any other representatives of athletics interests at the University. In addition, the  Compliance  Office  will  provide  departmental  officials  with  any  materials  or information they may need to present to groups at local or regional meetings. Athletics staff and coaches will be encouraged to remind the boosters and alumni of their restricted roles in recruiting at all such meetings.

To ensure boosters and alumni receive regular updates, the Compliance Office will publish, as available, educational reminders in University publications and programs (alumni magazines and newspapers, booster publications, athletic game programs, Athletics website, etc.).

The Compliance Office will contact booster organization administrators to provide reminders and information concerning NCAA legislative restrictions affecting their activities.

Coaches and Staff
The Compliance Office shall conduct a meeting prior to the academic year with all coaches and applicable staff members to review NCAA rules and regulations, and changes in procedures. The meeting shall include, but is not limited to:

  1. Rule updates
  2. Distribution of synopsis of main topic areas (e.g. phone calls to prospects, official and unofficial visits, playing and practice seasons, camps and clinics, etc.)
  3. Overview and distribution of new reporting, record keeping, and approval request forms and procedures
  4. Opportunities for questions from coaches and staff
  5. Distribution of latest NCAA legislative assistance columns
  6. The Compliance Office shall explain the roles of the Registrar, Admissions and Financial Aid

During monthly coaches meetings, the Compliance Office shall provide reminders and updates on pertinent legislative issues and compliance efforts. Likewise, a monthly compliance newsletter will be distributed highlighting important dates and compliance updates.

Updates will be provided throughout the year regarding proposed NCAA legislation and its potential impact on the University's athletics program.  Coaches' input will be taken under consideration in determining the institution's position. Materials will be distributed periodically to review information on legislation decisions, their impact on the athletics programs and implementation.

The Compliance Office will assist in coordinating efforts by coaches to propose new legislation. An opportunity for discussion on topics raised by the coaches will be presented at all meetings.

Registrar, Admissions, and Financial Aid Officials
The Compliance Office shall serve as the liaison between the coaches and the Registrar, Admissions, and Financial Aid Officials.

Coaches are encouraged to communicate with the Department's contacts in both the Financial Aid and Admissions Offices. However, all communication with the Registrar's Office (i.e., eligibility, transfer work, progress towards degree calculations) must be directed through the Associate Director of Athletics for Student-Athlete Services & Compliance.

The Associate Director of Athletics for Student-Athlete Services & Compliance and/or the Assistant Director of Compliance will meet at least once  a  semester  with  the  Registrar,  Admissions,  and Financial  Aid  Officials  to  discuss  rules applications,  changes,  new   interpretations  and  problem areas  that  have  recently  developed. Maintaining open communication between these offices and the Department of Intercollegiate Athletics is essential.

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Rules Interpretations

The Compliance Office will provide rules interpretations to the Department.  Any questions concerning compliance, the NCAA Division I Manual, or rules interpretations should be directed to the Compliance Office. An interpretation request will always receive a written reply, even if the request was originally submitted via telephone or in person. This procedure will ensure proper documentation of all interpretation requests.

Philosophy on Self-Reporting Rules Violations

"Any system that heightens the institution's awareness as to potential problem areas and illustrates institutional control  is  far  superior  to  any  'surprises'  that  may  take  the  form  of  an  official  inquiry" - NCAA  Rules Compliance Seminar

An important  aspect  of  NCAA  compliance  is  the  self-reporting  of  secondary  rules  violations. Athletics Administration recognizes that periodic, inadvertent NCAA violations will occur. Self-reporting these violations reflect a solid program of institutional control.

Secondary  violations  result  in  minor,  if  any,  penalties,  especially  if  they  are  infrequent  and correctable. Therefore coaches and athletics staff should take a proactive stance in reporting such violations. Self-reporting is important for several reasons: immediate awareness of possible violations provides an opportunity for the Department to correct the situation before it develops into a major infraction. Immediate awareness also identifies areas that can be addressed in departmental policy and/or continuing education programs. Unidentified problems, on the other hand, cannot be corrected.

Depending on the nature of the alleged violation, a speedy, objective and thorough investigation will be completed by the Compliance Office, the Director of Athletics, or University Counsel.

The primary role of the Compliance Office in the self-reporting process will be to assist the FAR in investigating, identifying, and reporting violations. If the Compliance Office determines the situation demands more in-depth investigation, University Counsel will assist in the process.

The Department of Intercollegiate Athletics, University staff, student-athletes, and any representatives of athletics interest who may be involved or called on are expected to cooperate fully with the investigation process. Should an alleged violation be initiated by the Big West Office and/or NCAA enforcement staff, the institution will conduct its own investigation simultaneously and will turn in all pertinent findings to the conference or NCAA investigators.

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Reporting & Investigating Rules Violations

  1. An alleged violation is brought to the attention of the Assistant Director of Compliance, Senior Athletics Administrator, or the Associate Director of Athletics for Student-Athlete Services & Compliance from any source (e.g., self-report, outside report).
  2. The  Assistant  Director  of  Compliance  and/or  Associate  Director  of  Athletics for Student-Athlete Services & Compliance informs  the Director  of  Athletics  of  the  alleged  violation  and  investigates  and  with the active involvement of the FAR interviews  the  individuals implicated in the alleged violation to determine the validity of the complaint.
  3. If the preliminary inquiries reveal that a possible major violation took place, the Associate Director of Athletics, Director of Athletics, and Faculty Athletics Representative shall be notified of the possibility that a major violation took place. The Director of Athletics shall notify the Vice President for External Relations, University President and University Counsel.
  4. Based on the information gathered in the investigation, the Faculty Athletic Representative, the Assistant Director of Compliance and/ or the  Associate Director of Athletics for Student-Athlete Services & Compliance determine which NCAA regulations may have been violated, if any.

    If the university violates an NCAA Bylaw, it may self-report that violation to the NCAA Enforcement Staff. The Compliance Staff along with the assistance of the Faculty Athletic Representative are responsible for investigating self-reports, as well as third party allegations of wrongdoing. If a violation is deemed secondary (one that provides only a limited recruiting or competitive advantage and that is isolated or inadvertent in nature), the penalty is specific and limited. If a violation or violations are reported or found that are major (anything not secondary) the school must go before the Committee on Infractions. The Committee is the body that hears the evidence and imposes penalties.

    Penalties for secondary and major violations are varied and depend on the particular situation. An institution may lose scholarships, be on probation, receive public reprimand and censure, owe fines, be required to fire staff or disassociate from boosters, lose eligibility for championships, or even be prohibited from competing against outside sports teams for a specified period (the "death penalty").

    It is expected that Department of Intercollegiate Athletics staff and Representatives of Pacific's Athletics Interests will do everything they can to avoid committing major rules violations.  Should any violations occur, though, staff members and coaches must self report to the Associate Director of Athletics for Student Services & Compliance or the Assistant Director of Compliance in order to minimize potential negative consequences for the University.

    If the investigation reveals a Level II violation took place, the Assistant Director of Compliance shall prepare and submit a report of the findings to the Associate Director of Athletics for Student-Athlete Services & Compliance, the Director of Athletics, the Faculty Athletics Representative, the sport administrator (if applicable), and the Conference Office. This report will include the following:

    * A complete synopsis of how the violation took place, the parties involved, the bylaw violated, and the sanctions/restitution for the infraction;

    * Recommendations for policy and procedure changes to be implemented in order to prevent such a violation from occurring in the future; and,

    * Once the report is complete, the appropriate information and documentation shall be provided to the NCAA and/or Conference Office. A copy of the report and recommendations shall be provided to the Associate Director of Athletics, Director of Athletics, Faculty Athletics Representative, University President, and University Counsel (if applicable).

    If  the  investigation  reveals  a  major  NCAA  violation  has taken place,  the  Assistant  Director of Compliance  and/or the Associate Director of Athletics shall inform University Counsel and Internal Audit. A more extensive investigation will then be conducted to discover the exact nature and/or severity of the violation. The Director of Athletics shall be updated on the pending investigation. Once the investigation is complete, the report should include the following:

    * A complete synopsis of how the violation took place, the parties involved, the bylaw violated, and the sanctions/restitution for the infraction;

    * Recommendations for policy and procedure changes to be implemented in order to prevent such a violation from occurring in the future;

    * Once the report is complete, the appropriate information and documentation shall be provided to the NCAA and/or Conference Office. A copy of the report and recommendations shall be provided to the Associate Director of Athletics, Director of Athletics, Faculty Athletics Representative, Vice President for External Relations, President, and University Counsel (if applicable).

    If the alleged violation is not substantiated, but athletics policy or procedures need modification to prevent possible future violation, the recommendation shall be implemented by the appropriate department personnel. Rules education sessions regarding policy changes will be conducted with the appropriate staff.

  5. All involved parties will be notified of the findings and proposed sanctions resulting from the investigation.
  6. The  Director  of  Athletics  will  implement  any  penalties  called  for  in  the  final  report.  If applicable, a letter of admonishment or reprimand will be kept in the file of all departmental staff involved.
  7. The Compliance Office will ensure implementation of any changes in policy or procedures called for in the final report.
  8. The Compliance Office will continue to establish a thorough rules education program for all parties involved to ensure a sound and thorough understanding of NCAA regulations.