May a compliance officer who reports outside athletics (to the president) provide the outside review of the compliance program?
No. The periodic evaluation must be done by an individual who does not do compliance work on a day-to-day or ongoing basis. Further, the review must be done by an authority outside of the compliance process. As a result, a compliance committee, including any individual performing ongoing compliance duties (e.g., compliance coordinator, registrar), would not meet the committee’s expectations because that group is not external to the compliance process. Finally, the committee has determined that acceptable compliance reviews must be conducted by an authority outside the athletics department who is knowledgeable of NCAA legislation and compliance practices.
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