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Ivory Tower Whistleblowers and Hotlines: Higher Education Institutions' (HEI) Voluntary Implementation of NACUBO-recommended Sarbanes-Oxley (SOX) Act of 2002 Whistleblowing Best Practices Provisions: A Web-Based Survey Instrument and Exploratory Research to Determine HEI Level of Implementation, Expectations, Effects and Barriers




McMillan, Kenneth

Type of Degree



Political Science


The purpose of this exploratory study is to determine Higher Education Institutions’ (HEIs) level of implementation, expectations and effects from voluntarily implementing National Association of College and University Business Officers’ (NACUBO)-recommended Sarbanes-Oxley (SOX) Act of 2002 whistleblowing Best Practices (BP) provisions (Anti-Retaliation & CCM). Following a series of high-profile corporate financial scandals, the U.S. Congress enacted SOX for publicly traded companies. At present, SOX is not federally-mandated for public and private universities and colleges. However, data indicate fraud can be an even bigger issue in HEIs than in publicly traded corporations. Utilizing a quantitative (Web-based survey) research method with a Modified Rational Actor Model (MRAM), I gained the following insight into key topical elements and policy implications. The level of HEI CCM implementation has risen from 65% (2007) to 81% (2013). Many HEIs expected Financial, Governance, and Ethics benefits in CCM implementation, despite the existence of significant Barriers. HEIs’ assessment of whistleblowers’ motivation was not found to be associated with their Institutional level of SOX BP implementation. Locally-tailored HEI SOX BP policy implementation resulted in positive self-assessed tangible/intangible results. There is a correlation between HEIs with impartial investigators of fraud complaints and/or alleged retaliation and the HEI’s satisfaction with voluntarily continuing CCM implementation. High-level decision maker involvement in CCM implementation is correlated to HEI self-assessed CCM program effectiveness.