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Culture of compliance

A.T. Still University (ATSU) is committed to compliance with laws, regulations, and University policies, and seeks to build a culture of compliance.

A culture of compliance:

  • encourages people to speak up when mistakes have been made.
  • creates the confidence and trust in the process to self-report mistakes and to encourage others to self-report.
  • gives a voice to everyone, regardless of position or title, and holds everyone accountable for their actions.
  • does this while providing protection from retaliation for good faith reports or questions.

ATSU expects members of the campus community to inform the appropriate contacts if they observe unethical, illegal, or suspicious activity. Those who have concerns about possible noncompliance with federal, state, or local laws and regulations or University policies are expected to report promptly.

ATSU prohibits retaliation against individuals who report or seek guidance on possible ethical or compliance issues in good faith, as stated in ATSU Policy No. 90-210: Prohibition of Discrimination, Harassment and Retaliation and ATSU Policy No. 10-216: Whistleblower (pdf).

  • Code of ethical standards +

    • ​As a learning-centered university dedicated to preparing highly competent healthcare professionals, all members of ATSU’s community are responsible to promote and adhere to the highest ethical standards of professional, academic, and community conduct. This includes compliance with laws, regulations, University policies, and other topics addressed in ATSU Policy No. 10-220: Code of Ethical Standards (pdf). This policy includes sections on reporting potential violations, academic integrity, respect for the rights and dignity of others, ethical code of faculty activity, standards for faculty and staff interactions with students, and community conduct and freedom of expression.

  • Reporting potential violations +

    • ​ATSU relies on employees, students, vendors, and the general public to report observations of unethical, illegal, or suspicious behavior. The University does not tolerate retaliation against individuals who report concerns in good faith.

      Imminent threats against persons or property should be immediately reported by dialing 911.

      ATSU prefers non-emergency reports be made in person to enable the University to respond fully and appropriately. In-person reports may be made to supervisors, Human Resources, Student Affairs, or the Office of Vice President & General Counsel. Reports of discrimination or harassment based on gender may also be made to the University’s Title IX Coordinator. See contact information below.

      For anonymous, confidential reporting, call the 24-hour service at 1-855-FRAUD-HL, or submit a secure report online. Reference Company ID (“ATSU”) when making a report.

      Tonya Fitch
      Director of Human Resources
      Deputy Title IX Coordinator
      5850 East Still Circle Mesa, AZ 85206-3618

      Donna Brown
      Assistant Vice President of Human Resources
      Deputy Title IX Coordinator
      800 West Jefferson Street Kirksville, MO 63501

      John Gardner
      Director Title IX & Training
      800 West Jefferson Street
      Kirksville, MO 63501

      Lori Haxton
      Vice President of Student Affairs
      Deputy Title IX Coordinator
      800 West Jefferson Street
      Kirksville, Missouri 63501

      Matthew R. Heeren

      Vice President & General Counsel

      800 West Jefferson Street
      Kirksville, MO 63501


  • University policies +

    • ​All members of ATSU’s community should be aware of and compliant with University policies (also known as “general orders”). New and amended policies are submitted to the General Order Review Committee for review prior to submittal to the President for approval. The General Order Review Committee meets monthly and is chaired by the vice president & general counsel.

      ATSU policies are accessible on ATSU’s portal (login required) to all University employees and students.

      Questions about ATSU policies may be referred to the Office of Vice President & General Counsel.

  • Compliance matrix +

    • ​ATSU’s compliance matrix was developed by the Office of Vice President & General Counsel in collaboration with responsible departments. The matrix includes federal, state, and local laws and regulations with reporting deadlines. The matrix is organized by responsible ATSU departments and by calendar month. The compliance manager utilizes the matrix to initiate deadline reminders and monitor status.

  • Clery Act compliance +

    • ATSU Security works with offices across the University to coordinate activities in compliance with the Clery Act. For additional information, please contact Eva Howard, director of safety & security.

      The law

      In 1990, Congress enacted the Crime Awareness and Campus Security Act of 1990, which amended the Higher Education Act of 1965. This act requires all colleges and universities participating in Title IV financial aid assistance programs to disclose campus crime statistics and security information. The act was renamed the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act in 1998 in memory of a student who was raped and murdered in her dorm room in 1986. The act is generally referred to as the Clery Act. The Violence Against Women Reauthorization Act of 2013 (VAWA) amended the Clery Act. The changes from VAWA require institutions to disclose statistics, policies, and programs related to dating violence, domestic violence, sexual assault, and stalking. Hate crimes based on bias against persons of certain categories must also be reported.

      Annual security reports

      The Clery Act mandates the publication and distribution of Annual Security Reports (ASR) by October 1st of each year. ATSU publishes 20 location-specific ASRs, including the Kirksville, Mo. and Mesa, Az. campuses, the St. Louis Dental Education and Oral Health Center, and ATSU-School of Osteopathic Medicine in Arizona distance sites. The ASRs include information about safety and security in each location, available resources, crime statistics, policies, and prevention and awareness programs. The Office of Vice President and General Counsel is responsible for publishing the ASRs, which are distributed twice a year by email to all employees (by Human Resources) and students (by Student Affairs). ATSU’s Annual Security Reports

      Campus security authorities

      ATSU has designated campus security authorities (CSA) to whom students, employees, or anyone else, may report criminal offenses.

      CSAs include:

      1. campus security personnel;
      2. other individuals responsible for campus security;
      3. persons designated in the Annual Security Report as someone to whom crimes should be reported; and
      4. ATSU employees who have significant responsibility for student and campus activities.

      ATSU behavioral health wellness counselors are not CSAs and are exempt from reporting requirements under Clery. For a complete list of CSAs, contact Eva Howard, director of safety & security, at or 660.626.2121.

      CSAs are required under law to receive and report crime report information. CSAs are not responsible for investigating a reported crime or for any responsibilities typically performed by law enforcement. A CSA should not to try to convince a reporter to contact law enforcement if the reporter chooses not to do so. When a crime is reported to a CSA, they should immediately complete a Crime Report Form ( or immediately contact ATSU Security.

      Timely warnings and emergency notifications

      The safety of our campus community is the highest priority at ATSU. Timely warnings will be issued in response to reported crimes committed either on campus, or in some cases, off campus, if in the judgment of ATSU, the situation constitutes an ongoing or continuing threat to students, staff, and faculty of the University.

      Emergency notifications will be issued upon confirmation of a signification emergency or dangerous situation occurring on campus that involves an immediate threat to the health or safety of students or employees.

      Options for notification may include campus-wide emails and/or text messages. Where appropriate and available, other methods, such as overhead paging systems or postings on the University website, may be used. All students, faculty, and employees with an ATSU email will be notified by campus-wide emails. Students and employees must register to receive notifications by text message. All students and employees are strongly urged to register for text message notifications.

      Clery crimes

      ATSU encourages reporting all crimes, whether or not they are Clery crimes. Clery-reportable crimes include:

      • Murder and Non-Negligent Manslaughter
      • Negligent Manslaughter
      • Sexual Assault – Rape
      • Sexual Assault – Fondling
      • Sexual Assault – Incest
      • Sexual Assault – Statutory Rape
      • Robbery
      • Aggravated Assault
      • Burglary
      • Motor Vehicle Theft
      • Arson
      • Hate Crime (criminal offense motivated by bias against a person based on race, religion, sexual orientation, gender, gender identity, ethnicity, national origin, or disability)
      • Dating Violence
      • Domestic Violence
      • Stalking
      • Weapons – arrests and disciplinary referrals
      • Drug Abuse – arrests and disciplinary referrals
      • Liquor Law Violations – arrests and disciplinary referrals

      For federal and state definitions of Clery crimes, see the applicable ATSU Annual Security Report.

      Other Clery resources