Compliance-Related Externship Approval Policy
To count academic credits earned in an externship field placement and/or seminar toward the 15 credits required for the Health Care Compliance Certificate, students must receive approval from the Externship Director in consultation with the Health Law and Policy Program Director.
To seek approval of an externship placement as compliance-related, the student must submit the following materials to the Director of the Health Law and Policy Program (Professor Asha Scielzo, scielzo@wcl.american.edu):
(1) a one-page description of how the work performed (or to be performed) in the field placement relates to corporate compliance and ethics, with specific reference to one or more of the following topics:
- Application of management practices for the compliance professional
- Application of personal and business ethics in compliance (including corporate responsibility)
- Written compliance policies and procedures
- Designation of compliance officers and committees (compliance oversight)
- Compliance training and education
- Communication and reporting mechanisms in compliance
- Enforcement of compliance standards and discipline
- Auditing and monitoring for compliance
- Response to compliance violations and corrective actions AND/OR
- HIPAA privacy implementation
AND (2) any supporting documentation, including work products and other materials that the supervisor permits the student to share.
In addition to the materials submitted by the student, the Director of the Health Law and Policy Program will consult materials provided by the faculty supervisor regarding the content of the externship seminar in which the student is enrolled, if any.
For the externship to be approved as compliance-related, the Externship Director and the Director of the Health Law and Policy Program must determine that at least 50% of the student’s anticipated assignments in the field placement and externship seminar (if any) relates to one or more of the corporate compliance and ethics topics referenced in (1)(a)-(j), above.
The Director of the Health Law and Policy Program will inform the student regarding the approval determination within 30 days following the student’s submission. If the externship is not yet complete, the Director may inform the student that the determination will be deferred until completion and may ask for additional supporting documentation at that time. If approval is denied, the student may appeal via the Policy on Grading, Assessment, and Review. A determination that an externship is not compliance-related will in no way affect a student’s grade, but if the externship is not approved as compliance-related, the credits earned in the field placement and seminar (if any) will not count toward fulfillment of the requirements for the Health Care Compliance Certificate.