COM Business Office Compliance University of South Florida HSC 160
Compliance Defined • Effectiveness and efficiency of operations • Reliability of financial reporting • Compliance with applicable laws and regulations.
Overview of Compliance Fundamental concepts: Internal control is a process It’s a means to an end, not an end in itself Geared toward the achievement of objectives Internal control is affected by people at every level Not merely policy manuals and forms Provides reasonable, not absolute assurance
Key Components 5 Key Components of Internal Control System: • Control environment • Risk assessment • Control activities • Information and communication • Monitoring
Financial Compliance As USF employees, we have the Fiduciary Responsibility to: Confirm valid, authorized purchases are made from the appropriate funding sources, Validate accurate posting of all expenditures Validate all revenues are received and deposited timely Confirm staff have the appropriate training to fulfill their job responsibilities
Financial Compliance (cont.) • Safeguard University equipment • Identify and take action on fraudulent activity • Review and approve system security actions
Overview of Internal Controls • Definition of Internal Controls: • Systematic measures instituted by an organization to: • conduct its business in an orderly and efficient manner, • safeguard its assets and resources, • deter and detect errors, fraud, and theft, • ensure accuracy and completeness of its accounting data, • produce reliable and timely financial and management information, and • ensure adherence to its policies and plans.
Internal Controls • Remember: • Internal controls do not necessarily ensure success! • Poor internal controls can result in: • Bad Decisions • Poor managers • Unethical behavior • Collusion • Override of controls
Examples of Internal Controls • Segregation of Duties: Separate the duties among different individuals to reduce the risk of error or inappropriate actions. • Example: The person who charges expenses to a USF P-Card should not be the same person to approve those charges in the FAST System.
Examples of Internal Controls (cont.) • Physical Controls: Assets, inventories, securities and cash are secured physically and periodically counted and compared to amounts on control records. • Example: Review list of equipment annually to ensure that all equipment is documented and accounted for. • Reconciliations: Comparisons are made between source documents maintained by the document’s custodian and the official ledgers. • Example: Reconcile your source documents monthly with the ledgers available on Finance Mart.
Examples of Internal Controls (cont.) • Policies and Procedures: Established policies, procedures and job descriptions provide guidance and promote consistency. • Example: Provide job descriptions for each of your employees so that they know what their duties are. • Transaction and Activity Reviews: Managers compare information about current performance to budgets, forecasts, prior periods to measure if goals and objectives are being achieved. • Example: Compare all source budget with monthly reconciliations to make sure the department is still operating within their means.
Procedures for Purchasing • Requisitions/Purchase Orders must be in place prior to the ordering of goods or services. • If you are buying office supplies using State funds, they must be purchased through Office Depot. • Any technology/computer item must be purchased through the USF Computer Store • Independent Contractor agreements are reviewed and signed off my General Counsel and Purchasing before engaging in service.
Procedures for Purchasing (cont.) • Helpful Links: • Computer Store • http://www.computerstore.usf.edu/ • Purchasing and Property Services • http://usfweb2.usf.edu/purchasing/ • UTSB • http://www.it.usf.edu/purchasing/information/utsb
Procedures for Purchasing (cont.) • Remember Quote Requirements • Less than $5,000 – you must have one verbal quote documented. • Between $5,000 & $25,000 – you must have two verbal or written quotes documented. • Between $25,000 & $75,000 – you must have three written quotes documented. • Greater than $75,000 – Must be sent out for competitive bids. Purchasing must certify the bids.
Procedures for Purchasing (cont.) • Single Source: If an item or service is determined to be • non competitive in nature and is only available from one • particular vendor, you can purchase via • single source. • Memberships: Can be purchased via purchase • order if the membership is essential to the duties and • responsibilities of the University. • Contractual Services: Can be purchased via purchase • order, but the contract must be executed prior to the • rendering of the service. The Purchasing Department must • approve prior to initiating PO.
Procedures for P-Cards • Before you Purchase: • Check for any University policies or processes that you must follow • Check for any preferred vendors (i.e. Avis, Office Depot) • Purchase all technology items from the USF Computer Store • Make sure the total cost of the purchase does not exceed your single transaction limit • Have the USF tax exempt number available • Reference Website: http://usfweb2.usf.edu/pcard/index.html
Procedures for P-Cards (cont.) • P-Cards can be used for purchases with a single transaction value of $2,000 or less. • P-Cards have a monthly limit of $5,000 or less. • You can NOT purchase equipment (more than $5,000) with a P-card. • You can NOT purchase food on the P-card. • You can NOT pay for contractual Services • You can NOT pay for Independent Contractors
Procedures for P-Cards (cont.) • Things you CAN purchase: • Office Supplies • Computers less than $5000 • Computer supplies • Employment Advertising • Lab Supplies • Printing • Rental Fees • Software under $1000 • Subscriptions • Travel charges • Things you CAN’T purchase: • Alcohol • Attorneys • Cash Advances • Contractual Services • Flowers • Computers over $5,000 • Parking Permits • Personal convenience Items • Plaques/Awards • Shredders For a complete list of allowable and unallowable purchases, please see the P-Card website: P-Card Purchases
Procedures for P-Cards (cont.) • Misuse of Card includes: • Falsification of records • Fraud • Theft • Using the card for personal gain • Allowing another individual to use your card • Repeated non-compliance with processes and procedures • Divulging confidential information
P-Card Audit • What happens once you submit your receipts? • Reconciler will match the receipt to the incoming charge in FAST and approve within 7 business days. • Reconciler matches receipts to the monthly bank statement. • Reconciler gets cardholder and accountable officer signature. • Reconciler submits copy of bank statement and receipts to P-Card department • Once your P-Card receipts have been submitted, the P-Card department reviews all the charges and may contact you for any questions.
Travel Compliance • Travel Authorization (TA) • The completed Travel Authorization is the Traveler’s permission to incur expenses and to travel and is an estimate of what a specific trip will cost. The Authorization should list all anticipated Travel Expenses that are known, or can be projected, before the trip. The TAR should be submitted prior to any charges are incurred. • A Travel Authorization in advance of any travel to a conference or convention is explicitly required per Florida Statute. • Should authorized Emergency Travel be required of an employee that prohibits prior entry of a Travel Authorization into FAST, a memo is required indicating the details of the travel and the circumstances that prohibited adherence to the normal Authorization process, including evidence that the situation was out of the Traveler’s control.
Travel Compliance (cont.) • Expense Report (ER) • After travel occurs, an Expense Report is submitted in FAST to report expenses and/or request Traveler reimbursement. • The Expense Report will list all expenses associated with the Travel, whether paid directly by the University or reimbursable to Traveler. • Expense Reports must be submitted within thirty (30) days of last date of travel.
Travel Compliance (cont.) • USF Travelers will be reimbursed for coach/non-refundable airfare only • USF Travelers will be reimbursed for up to a maximum • of two (2) bags. • Travelers utilizing their personal vehicles are • authorized to be reimbursed at the Florida Statutory • Rate of .445 cents per mile. • Avis Rent a Car System, LLC, (AVIS) is the Preferred Vendor for USF Travelers in need of rental vehicles.
Travel Compliance (cont.) • Taxis, trains, buses, and other mass transit may be used when these modes of transportation result in a cost savings to the University. Receipts are required for all ground transportation regardless of the amount. • Parking, storage or toll fees under $25 may be reimbursed without receipts. • Domestic Travelers will be paid meal allowances pursuant to FS112.061 (6) (a-c) as follows: • Breakfast $6 • Lunch $11 • Dinner $19 • Total for day $36
Travel Compliance • For domestic lodging, justification is required at the time of reimbursement request if the nightly hotel rate (before taxes) exceeds $200. • Meals for all days of Foreign Travel will be reimbursed at the published Department of State rate for the destination area. • Foreign lodging should be obtained at or below the published Department of State rate for the destination area whenever possible.
Reconciliation • Reconciling gives you the opportunity to find errors and make corrections • Reconcile your ledgers on a monthly basis • Compare departmental source documentation to the official ledgers • Notate and follow up on any discrepancies you may find • Share reconciliation with key people (Supervisor, PI, senior management) • Make sure signature authorization and workflow forms are updated upon hire or termination of an employee
Sponsored Research • GBR is filled out after an award has been granted to distribute budget to the appropriate budget account codes based on the sponsor’s approved budget • Pay Distribution is updated in a timely manner to align personnel with the grant proposal/award • NIH salary caps are taken into consideration and if anyone exceeds the cap, cost share accounts are set up in a timely manner **** RETS should consider impact to NIH salary cap before submitting
Leave Tracking • All Sick and Annual leave is properly reported in the ALT system in a timely manner • Internal documentation is kept within the department as justification to the ALT leave record • Leave audits are performed annually
Nepotism • Definition: an employee has influence or decision making authority over the employment of a relative. • “relative” is defined as the husband; wife; parent; step-parent; child; step-child; brother; sister; half-brother; half-sister; spouse of child, brother, sister or parent; child, brother or sister of spouse; grandparent; grandchild; aunt; uncle; first cousin; niece; or nephew of the employee. “Relative” or “related” person also includes a person who is engaged to be married to an employee. • If relatives work in the same area, a nepotism memo must be signed and approved by the Vice President before work my commence.
Record Retention • Before disposing of any records, you must review the retention • schedule provided by the state: • http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm • After reviewing the retention schedule, you must submit the Record • Disposition Request Form to LazaraStinnette, Purchasing and Property • Services at AOC 200. • If your records contain only copies, you do not need to submit a record • disposition request form. These records can be destroyed as soon as • they have served their purpose.
Accounting Best Practices • Review all funding sources monthly • Look for errors • Look for fraudulent activity • Compare outstanding transactions to • previous transactions • Look for budget errors • Look for chartfield value errors • Look for chartfield combination errors • Become familiar with standard transactions • Payroll transactions • P-card transactions • Revenue transactions • Budget transfers • Corrected transactions
Accounting Best Practices • Be organized • Create electronic files for easy reference • Trust and verify • Check transactions for accuracy and • allowability • Review payroll for unknown individuals • Review reimbursements • Locate equipment • Keep a list of all property and include serial numbers and USF tag numbers
Accounting Best Practices • Network • Join any available list serve • FAST • GEMS • Foundation • DSR/RFM • Travel • Accounts Payable • Accounts Receivable • Check COMPASS • Enroll in Talent Management, TRAIN, or Business Office Training
EthicsPoint Hotline • USF has engaged EthicsPoint—a third party hosted hotline—to enable the safe, secure, and anonymous reporting of activities which may involve misconduct, fraud, abuse, and other violations of USF policies. You may file a report by clicking on the To Make a Report link on the chart or by calling toll-free 1-866-974-U411. • USF is committed to providing a safe, secure, and ethical place to work. As a member of the USF community, you have a responsibility to voice compliance and ethics concerns, so that we can work together to promptly resolve the issues while helping to cultivate a positive environment. • Website
Additional Resources • Audit and Compliance • http://usfweb2.usf.edu/uac/risks.htm • TRAIN • http://www.research.usf.edu/TRAIN/ • Controller’s Office Training • http://usfweb2.usf.edu/UCOTraining/ • Purchasing Policies • http://usfweb2.usf.edu/purchasing/reg_policy_proc.htm • Records Retention • http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm
Faculty Activity ReportingTraining USF Health Business Office
Objectives • What, Who, When, Where, and Why? • Category Names and Definitions • Navigation for Faculty • Questions and Answers
Who and What ? • Who has to report? • Faculty, graduate assistants, residents, and faculty administrators • What is Faculty Activity Reporting? • Faculty Activity Reporting (FAR) is a legislatively State mandated process to report faculty effort within educational, research, service and other categories.
When and Where ? • When does FAR have to be done? • Faculty Activity Reporting is required each semester - three times per year. Summer (05), Fall (08), and Spring (01). • Where do I report my effort? • Faculty Academic Information Reporting (FAIR)
Why? • Why do I have to do this? • Comply with F.S.S. 1012.945 (12 hour law) • Comply with Chancellor Memo 87-17.1 • Expenditure Analysis - determines funding • LCME reporting • Management reporting • Historically has been used in Asset Investment Management System (AIMS)
Categories And Definitions
Course Number Anatomy • Course numbers are in the following format BCC 7114 001 Prefix (GMS, BMS, BCC, MEL, etc) Section number (001, 002, 003, etc.) Number (7114, 7980, 7814, etc.) • In addition, each course/section has a unique course reference number: • Medical courses start with a 7 • Main campus course in summer start with 5 • Main campus course in fall start with 8 • Main campus course in spring start with 1
17 – Clinical Instruction • Time spent instructing, supervising, and evaluating House staff (Residents, Fellows, or Interns (including Clinical Research Fellows) in a clinical environment. Note: This would also include advising the above groups.
40 - Academic Advising * • Formal counseling with students on academic course or program selection, scheduling, and career counseling. • Academic advising assignments shall include such indicators as number of students formally advised by the faculty member, hours specifically designated for advising purposes and other appropriate indicators of advising activity. • This category is NOT for House staff advisement, which should be included in Clinical Instruction. * Backup Documentation Required
25 - Other Instructional Effort * Instruction-related activities which includes • development of new approaches • improvement/revisions of materials for credit courses • participation in planning • development or evaluation of total curricula, program services, • preparing, planning programs, • participation in non-credit generating instructional activities such as Learning Community, or • mentoring, etc. * Backup Documentation Required
25 - Other Instructional Effort Examples • Ex: Administrative assignments as Course Director, Clerkship Director or Residency Training Director are related to instruction • Ex: Supervision of student ARNP’s in clinical setting • Ex: Participation on the College Curriculum Committee or the Medical Student Selection Committee
22 - Departmental Research(Research/ Scholarly Activity w/o external grants) * • Research activities that are supported by department sources of funding (NOT Sponsored), • Duties may include: • the preparation, planning and conduct or research, • data analysis, • manuscript preparation, • presentation of results, and • supervision of postdoctoral trainees (not externally funded). ****Department Research may also include the preparation and publication of scholarly reviews, chapters, monographs and books, as well as the development of new educational approaches or techniques and other types of medically-related creative activity. * Backup Documentation Required
32 - Public Service * • Activities that extend the professional and/or discipline related services of individuals to the community, the state, or the nation. • This includes service in professional organizations and academic or professional student organizations. • The primary intent is to provide professional and/or discipline-related services, other than instruction, that are beneficial to groups and individuals. • Such public service shall NOT generate payment from third party. * Backup Documentation Required