It has always been UVM’s practice to cooperate with all lawful inquiries, inspections, audits, and investigations conducted by federal, state, or local government regulators. We call these “government reviews”. A government review can be an in-person visit or it can be a request for information. It can be announced or unannounced. It can be routine monitoring or “for cause”. Since 2011, UVM has had an operating procedure in place that outlines the steps that must be taken whenever you are notified of a government review.

Who do I notify when I receive a notification of a government review?

Contact the Office of Compliance and Privacy Services at compliance@uvm.edu.

Do I need to notify Compliance every time a government agency comes in or requests information?

No. If the purpose of the visit/request for information falls into one of these categories, we don’t need to be notified. But, if it is anything outside of these exceptions then yes, let us know. Exceptions include:

• Accreditation visits or monitoring activities conducted by accrediting bodies
• Regularly scheduled and routine monitoring visits or inspections conducted by industry sponsors or other non-governmental agencies
• Peer reviews and other programmatic site visits related to sponsored agreement awards or renewals
• Routine facilities visits by the State Health Department or any local Fire Marshal
• Routine communications between a government agency and the University received in the course of regular business activities, performance of a sponsored project, or a collaborative or cooperative effort
• Routine communications between elected officials or their staff and the University’s Director of Federal and State Relations

If you’re ever not sure, contact compliance@uvm.edu and if we don’t need to know, we’ll tell you.

What if I receive a subpoena?

If being served in your capacity as a UVM employee, decline service and direct the official seeking to serve you to the Office of General Counsel (OGC) at 357 Waterman or contact OGC at general.counsel@uvm.edu and await instruction from a member of that Office. If you have unknowingly or erroneously accepted service, notify the Office of General Counsel immediately. More information is in UVM’s Subpoenas, Complaints, Warrants, and other Legal Documents University Operating Procedure.

What if I receive a search warrant?

If presented with a search warrant, politely request that the individual display law enforcement credentials. If the individual displays law enforcement credentials, the employee should ask the law enforcement officer to wait until the Office of the General Counsel (OGC) has been contacted regarding the proposed search, and the employee should then immediately contact the OGC at (802) 656-8585. If contact cannot be made with the OGC, or the law enforcement officer declines to delay the search, the employee should comply with directives from the law enforcement officer and as soon as possible contact Police Services. More information is in UVM’s Subpoenas, Complaints, Warrants, and other Legal Documents University Operating Procedure.

What if I receive written notice of a government review?

Notify the Office of Compliance Services at compliance@uvm.edu immediately.

What if a government agent shows up in-person without advance notice?

Take these steps:

1. Request identification from the individual and a copy of any document stating the purpose of the visit.
2. Ask the individual to wait in a comfortable (and preferably non-public) space while you secure someone from the Office of Compliance Services to assist the agent. Call (802) 656-3086 or contact anyone from the office via Teams. If someone is not immediately available from Compliance Services, contact the Office of General Counsel.
3. Do not produce any documents or allow a site inspection until you have been given the OK from Compliance Services or an attorney in the Office of General Counsel.

Please visit the UVM Policies website for a list of all institutional policies and operating procedures. If you have any questions about this PolicySpotlight, contact the Office of Compliance and Privacy Services at compliance@uvm.edu.