University of Minnesota compliance office reports 13,000 disclosures, 67 findings in FY25

John Guden, interim chief compliance officer for the University of Minnesota, presented the Office of Institutional Compliance’s FY25 annual report to the Audit and Compliance Committee, saying the office handled over 13,000 disclosure filings systemwide and closed 67 investigations with findings of noncompliance or misconduct.

Guden said the office oversees four systemwide programs — compliance, policy, delegations of authority and conflict of interest — and operates with about 6.5 full-time equivalent staff. "We handle over 13,000 disclosures annually," Guden said, and the compliance program coordinator manages the uReport intake system and most day-to-day risk reviews.

The report described how the office coordinates compliance risk reviews with internal audit to avoid duplicative work. Guden said the office has conducted 26 compliance risk reviews since 2017 and currently had two in progress focused on environmental protection and food safety. He said risk reviews begin with a review of the policy library and identification of subject-matter contacts across the university’s campuses.

On reporting channels, Guden outlined multiple venues for suspected-misconduct reports: supervisors, subject-matter offices, Equal Opportunity/Title IX, and the UReport system, which allows anonymous online or phone submissions. For difficult or unusual matters, the UReport consultative team — composed of the interim chief compliance officer, the chief auditor, the vice president for human resources and a general counsel representative — convenes to determine the appropriate office to handle the matter.

Comparing FY24 and FY25, Guden said overall report volumes were consistent given a system population near 95,000 and that the Twin Cities campus accounted for most UReports while Rochester historically has had few. Of investigated reports, the office reported 67 cases with findings; disciplinary outcomes included 12 employee terminations and other actions such as reprimands, counseling and non-disciplinary outcomes like policy revisions.

Guden also summarized institutional conflict-of-interest oversight, noting university officials must file both an external-professional-activities report and a financial disclosure. "We have a 100% reporting compliance for our REPA and our FEDUO, each year," he said; the transcript did not define the acronyms REPA and FEDUO. Guden said no matters under institutional conflict of interest required Board of Regents action in FY25 and the institutional conflict review panel approved management plans for five cancer trials, one medical device trial and for mechanisms to be used in microbiota transplant therapy trials.

The presentation closed with Guden reiterating the office’s posture of identifying gaps and opportunities for improvement rather than asserting systemic failure. He emphasized coordination with internal audit and subject-matter partners to allocate review resources efficiently. The committee received the report; Guden concluded his remarks and the presentation ended.