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The University of Washington (UW) has a robust enterprise risk management (ERM) program that is moving into its seventh year. The program began with what administrators[1] at UW call a "sentinel event," settling a Medicare and Medicaid overbilling investigation by paying the largest fine by a university for a compliance failure – $35 million. This led the new president, Mark Emmert, to formally charge senior administrators in 2005 with the task of identifying best practices for "managing regulatory affairs at the institutional level by using efficient and effective management techniques" (UW ERM Annual Report 2008, p. 4). At the outset in 2006, the objective for UW was to "create an excellent compliance model built on best practices, while protecting its decentralized, collaborative, and entrepreneurial culture" (Collaborative ERM Report 2006, p. vi). The ERM process at UW has been what Ann Anderson, associate vice president and controller, terms "a journey of discovery." ERM has developed and evolved at UW, moving from what UW administrators describe as an early compliance phase, through a governance phase to a mega-risk phase. Currently, the University of Washington is focused on two objectives: (1) strengthening oversight of top risks, and (2) enhancing coordination and integration of ERM activities with decision-making processes at the university. This case study will describe the decision-making and implementation process at UW, as well as outline various tools and frameworks that UW adopted and adapted for use not only in the higher education setting in general, but to fit specifically within the university's decentralized culture.

  • [1] Many thanks to Andrew Faris, Enterprise Risk Management Analyst at the University of Washington, and Kerry Kahl, ERM Project Manager at UW. They provided information via an interview in April 2012 that is incorporated throughout this case study. Additional information for the case study comes from Annual Reports, memos, and other documents found on the University of Washington ERM website:
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