Michigan State University Interim President John Engler announced the appointment of Marilyn Tarrant as an associate vice president and permanent head of the newly organized Office of Audit, Risk and Compliance effective Nov. 1. Tarrant will report directly to the Board of Trustees and to the president.
“This appointment completes the work we began in June to develop an office of compliance and integrity,” Engler said. “Professor Nick Wittner, the acting chief compliance officer, has done a great job getting us started down the right path and I appreciate his expertise and work in developing the needed structure for our compliance office. As I worked with Nick and Marilyn, formerly our executive director of internal audit, it became clear that we needed to avoid creating overlapping responsibilities and duties. Marilyn’s experience and leadership skills impressed both Nick and myself, which resulted in my decision to implement an organizational structure that is used at other leading universities and will likely become the model for all universities in the future.”
Joint audit and compliance structures are used at universities such as Duke, Harvard, Princeton and Stanford as well as the University of Tennessee and Virginia Commonwealth University.
Earlier this year, Engler established the Office of Enterprise Risk Management, Ethics and Compliance with Wittner, a professor of law in residence at the MSU College of Law, as acting director and the university’s chief compliance officer. In that role, Wittner helped refine the components of a more robust and long-term university-wide compliance function.
“It’s been a whirlwind start to setting up the compliance efforts at the university and we’ve accomplished a lot in the last few months,” Wittner said. “Starting on the policy library, a code of ethics for the university and recommendations for a fuller compliance structure have been great starts to this important new effort. I have immense confidence in Marilyn and am pleased to see this new structure maintains reporting directly to the board along with the president, which is a ‘best practice’ and essential for independence.”
Wittner also noted the respective missions of the Internal Audit Department and Office of Enterprise Risk Management, Ethics and Compliance were complementary. Combining the functions of compliance and internal audit is an effective and efficient way to accomplish the established responsibilities of both offices while ensuring proper oversight and minimizing duplication of effort.
The new Office of Audit, Risk and Compliance will be responsible for the continued development of the MSU ethics and compliance program with a strong framework for identifying, prioritizing and managing risk. This will include revising the university’s policies to provide clear ethical principles and behavioral expectations for all MSU employees.
Included in the expanded responsibilities is the continued management of MSU’s Misconduct Hotline, a tool for the community to raise concerns about misconduct across the university. Previously overseen by the Internal Audit Department, the purpose is to provide an anonymous method to report known or suspected misconduct related to financial matters, conflicts of interest, employment, medical/HIPAA, research, safety, athletics, discrimination/harassment, privacy, retaliation or any other area of legal, policy or ethical concern.
The office will also continue the development of the MSU Policy Library, the official repository for all university policies which Engler recommended to the board in August.
The new combined structure has three deputies who will report to Tarrant:
- Ryan O’Rourke, internal audit, finance and operations director,
- Steven Kurncz, information technology internal audit director, and
- a new position for the institutional ethics and compliance director.
Additional positions, including an internal investigator, will be added in the near future. Importantly, the new Office of Audit, Risk and Compliance also maintains all existing compliance staff working in various units across the university while ensuring increased communication and coordination efforts among existing staff and the new unit. Wittner will continue to serve as a senior compliance adviser and he will return to his full-time teaching position at the MSU College of Law in January.
“I see this as an important time for the university. We have the ability, the resources and new personnel to really make an impact on our operations with an enhanced focus on ethics and compliance,” Tarrant said. “I feel my background makes me uniquely suited to accept this new position and take on the challenge. I look forward to the continued support of the university leadership and trustees.”
A certified public accountant, Tarrant began her career with the Michigan Office of Auditor General. Prior to joining MSU in 2015, she spent 13 years at NorthShore University HealthSystem in Evanston, Illinois, as assistant vice president of internal audit and corporate compliance.