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Section 1: Internal Control

Fiscal Management Sub-Certification Work Plan

Effective Date:

01/11/11

Approved By:

Lenora Chapman, Associate Vice President, Financial Affairs

Last Revised On:

02/22/12

For Assistance Contact:

Assistant Vice President, Financial Affairs and University Controller: 210-458-6914

PURPOSE/SCOPE

This guideline provides the work plan for the annual Fiscal Management Sub-Certification process.

AUTHORITY

UT System policy UTS142.1


UNIVERSITY GUIDELINES

Table of Contents

A. Management Certification and Fiscal Management Sub-Certification Survey

The Management Certification and Fiscal Management Sub-Certification Survey is required to be completed annually by Account Administrators for all of their accounts with activity of $3,000 or more. This guideline addresses the Fiscal Management Sub-Certification portion of the survey related to internal controls over financial reporting.

Below is a list of the items in the Fiscal Management Sub-Certification portion of the Survey with a brief explanation of each.

    1. I am responsible for the reconciliation of the accounts for the areas and/or departments and functions under my scope of organizational responsibility as listed on the Compliance Certification email notification.

      Account Administrators are responsible for reconciliation of all accounts for which they are designated as Account Administrator. The reconciliation activity may be delegated as appropriate, but the responsibility for the reconciliation remains with the Account Administrator.

    2. Please list the names of the reconciler(s) of the monthly Statement of Accounts for each of your accounts listed on the Compliance Certification email notification. Also, if you are not the reviewer/approver of the monthly Statement of Accounts reconciliations, list the person who is responsible for reviewing/approving the reconciliation for each account.

      List any employees who reconcile or review/approve in addition to the Account Administrator. Regardless of which employee performs/reviews/approves the monthly Statement of Accounts Reconciliation, the ultimate responsibility for the reconciliation remains with the Account Administrator and cannot be delegated.

    3. We have reconciled all of our Statements of Accounts for each month of the 12 months ended August 31, 20xx. (Please indicate any exceptions in the Comments box below.)

      Note any exceptions in Item 4, with explanations as to why the reconciliations have not yet been performed.

    4. Comments related to Item 3
    5. All revenues and expenses were appropriate, allowable, and properly recorded for each month of the 12 months ended August 31, 20xx. (Please indicate any exceptions in the Comments box below.)

      The Account Administrator is responsible for monitoring revenues and expenses for all of the Administrator's accounts throughout the year.
      Appropriate: In accordance with UTSA and UT System policies and procedures and applicable state and federal requirements.
      Allowable: In accordance with regulatory, grant and other contract provisions.
      List any exceptions in Item 6, with explanations and descriptions of how they have been/will be addressed.

    6. Comments related to Item 5.
    7. All reconciling items have been adjusted or satisfactorily resolved for each month of the 12 months ended August 31, 20xx. (Please indicate any exceptions in the Comments box below.)

      List any pending items and explanations in Item 8.

    8. Comments related to Item 7.
    9. As an account administrator, I reviewed and approved all reconciliations, or delegated such review and approval, for all those accounts for which I am responsible during the 12 months ended August 31, 20xx. (Please indicate any exceptions in the Comments box below.)

      See Item 1. Account Administrators are responsible for reconciliations regardless of whether another employee reviews/approves the reconciliations. List any exceptions, with explanations, in Item 10.

    10. Comments related to Item 9.
    11. My area and/or department maintains adequate segregation of financial duties; no single employee has responsibility for:
      1. entering transactions,
      2. approving transactions,
      3. receiving cash, and
      4. reconciling accounts.

    NOTE: If there are any exceptions, please explain controls which mitigate or compensate for the absence of adequate separation of duties. Alternately, for areas where a limitation of the system of internal controls exists, note your proposed plan to address this limitation.

    Certain duties should be performed by separate individuals to reduce the risk of fraud and/or concealment of errors, and no one individual should have responsibility for all aspects of a transaction.

    For example, one individual should not be able to initiate an order for equipment and also approve payment for the equipment. Another example of incompatible duties would be one person depositing cash and also performing the related bank account reconciliation.

    Managers must be aware of duties that are potentially incompatible and arrange assignments so that no employee has incompatible duties. Managers of smaller departments where segregation of some duties may not be feasible must implement compensating controls such as detailed management review of reconciliations. List any exceptions and compensating controls in Item 12.

    If your area/department has a limitation of this component of internal control (does not have adequate segregation of financial duties and does not have compensating controls in place), indicate this in Item 12 with a proposed plan to address the limitation.

    For more information on segregation of duties see Financial Management Operational Guidelines (FMOGs), Internal Control Overview and Monitoring Plan for Segregation of Duties and Reconciliation of Accounts.

    1. Comments related to Item 11.
    2. All significant deficiencies in the design or operation of internal controls over financial reporting which could adversely affect my area's ability to record, process, summarize, and report financial data and any material weaknesses in internal controls that have been identified have been appropriately reported and addressed. (Please indicate any exceptions in the Comments box below.)

      Significant deficiencies in the design/operation of internal controls, and material weaknesses in internal controls are generally reported as identified during the audit and/or Quality Assurance Review process and addressed accordingly. However, if you are aware of any apparent internal control deficiencies or material weaknesses that have not been reported or addressed, describe them in Item 14.

      For more information on internal control see FMOG, Internal Control Overview.

    3. Comments related to Item 13.
    4. To the best of my knowledge, there are no misstatements or omissions in the accounts for which I am responsible as noted in the Compliance Certification email notification. (Please indicate any exceptions in the Comments box below.)

      Misstatements result from the recording of incorrect financial information in an account, such as entering the wrong amount for an expense or revenue, entering information in the wrong account, or making an entry for a non-existent revenue or expenditure. Omissions occur when transactions are not recorded or are inappropriately deleted from an account.

      If you are aware of any misstatements or omissions in your accounts, explain them and describe how they have been/will be corrected in Item 16.

    5. Comments related to Item 15.
    6. To the best of my knowledge, there has been no:
        a. Fraud, whether or not material, involving any employees who have significant roles in internal controls, that has not been appropriately reported and addressed; or

        b. Fraud involving others that could have a material effect on the financial statements other than those previously reported to the Financial Reporting Officer in writing (if any).

      (Please indicate any exceptions in the Comments box below.)

      Fraud is intentional misrepresentation or deception related to UTSA's assets, records, or financial reporting. Examples include, but are not limited to:

      • Theft or other misappropriation of UTSA funds, supplies, employee time, or any other asset
      • Forging or altering a UTSA check or any other physical or electronic document, record, or account (time sheets, tuition billings, invoices, etc.)
      • Deliberately making an incorrect entry in the financial system or in a report
      • Inappropriate handling or recording of money transactions
      • Any other illegal or dishonest act involving UTSA property, records, or financial reporting

      Fraud should be reported to the Director of Audit and Consulting Services, who will notify the Financial Reporting Officer (Associate Vice President for Financial Affairs).

        a. Fraud involving employees who have significant roles in internal control that has not been appropriately reported and addressed: Significant roles in internal control would include activities such as approving or reviewing transactions and reconciliations, and other activities that could provide an opportunity to circumvent or reduce the effectiveness of controls. In Item 18 report any fraud involving employees who have a significant role in internal control that has not been appropriately reported and addressed.

        b. Fraud involving others that could have a material effect on the financial statements other than those previously reported to the Financial Reporting Officer in writing (if any): The amount that would have a "material" effect on the financial statements is determined annually by the auditors depending on total amounts in the UTSA financial statements. In Item 18 report any fraud that could have a material effect on the financial statements that has not been appropriately reported and addressed.

      1. Comments related to Item 17.
      2. All officers and employees in my area and/or department who are authorized to execute contracts on behalf of The University of Texas at San Antonio, or who exercise discretion with regard to the award of contracts or other pecuniary transactions of government are in compliance with UTS134 Code of Ethics for Financial Officers and Employees.

        Most departments are not authorized to execute or exercise discretion in awarding contracts on behalf of UTSA (if your department(s) do(es) not have such authority, answer this item with "Not Applicable").

        If any employees in your department(s) have such authority, be sure that you have read and understand UTS134 – Code of Ethics for Financial Officers and Employees before answering this item, and report any exceptions in Item 20. If you have questions on UTS134 contact the Office of the Vice President for Business Affairs.

      3. Comments related to Item 19.
      4. CERTIFICATION: I certify that all responses provided, to the best of my knowledge, are true, accurate and complete.

        Carefully review all of your responses and seek guidance on any item that you are not certain about before certifying. When you are ready, certify by checking the check box. If you are not able to certify, explain in Item 22.

      5. Comments related to Item 21.

B. Sub-Certification Process

The Sub-Certification process occurs each fiscal year end. An email notification is sent to Account Administrators with accounts that have $3,000 or more of activity. The notification includes a link to the online survey, and:

  1. A list of accounts with $3,000 or more of activity for which he/she is designated as the Account Administrator; and

  2. The due date for Survey submission (usually two weeks from the date of the email).

The Account Administrator then completes the Fiscal Management Sub-Certification (Items 1-22) and the Management Certification (Items 23-50) and submits one survey electronically for all applicable accounts. (Completion of the survey is not required for accounts with less than $3,000 of activity.)

Completion of the survey is monitored. One week before the deadline, a reminder is sent to each applicable Account Administrator who has not completed the survey. A list of these individuals is also sent to the next-level administrator.

If the wrong Account Administrator has been assigned or the Account Administrator position is vacant, the University Controller's Office will contact the next-higher level administrator to address all issues related to position vacancies and/or changes in organization. The University Controller will document the reason(s) for incorrect assignments/vacancies, and the survey will be re-assigned to the next-higher level administrator.

The University Controller will report all incorrect assignments/vacancies including any corrections, if applicable, to Institutional Compliance and Risk Services for appropriate action.

C. Sub-Certification Results and Actions

The University Controller will obtain a report summarizing the responses of the sub-certification for analysis, and make a determination as to whether an individual may require training, to include the type of training necessary to reinforce the requirements and responsibilities as specified by UTS142.1.

In addition to this analysis, Account Administrators may also be recommended for a Quality Assurance Review (QAR).

When an Account Administrator of an account with $3,000 or more of activity fails to complete the survey, the respective Vice President, Audit Director, Financial Reporting Officer, and the University Controller are notified. Account Administrators will receive advance notice of sub-certification requirements during mandatory management compliance training upon initial hiring and every other year.

Chart of accounts maintenance is regularly performed by Financial Affairs staff to ensure that:

  1. Account Administrators are updated when employees separate from UTSA, as changes are made to organizational structure, or when new accounts are established;

  2. Restricted fund accounts are inactivated if the project has been closed during the prior fiscal year; and

  3. For all other fund groups:

    • notification is sent to Account Administrators with inactive accounts and/or small balances requesting review and response for resolution;

    • if Account Administrators are not responsive to the notification, Accounting Services inactivates the account and transfers funds as appropriate; and

    • accounts with zero balances are inactivated.

D. Sub-Certification Training

The University Controller's Office provides training/presentations to review Sub-Certification requirements at the:


DEFINITIONS

Term

Description

Account Administrator

An individual with fiscal responsibility and decision-making authority for UTSA resources who has approval access to commit funding using the institutional financial accounting system. This is typically the department head for non-grant accounts and the principal investigator for grant accounts.

 

REFERENCES/LINKS

RELATED FORMS/WORKSHEETS

None at this time.


REVISION HISTORY

Date

Description

02/22/12

Revised Management Certification and Fiscal Management Sub-Certification Survey, Sub-Certification Process, and Sub-Certification Results and Actions sections to reflect requirement of Management Certification and Fiscal Management Sub-Certification Survey for accounts with $3,000 of activity.

06/29/11

Revised section title to reflect new title Internal Control. Revised title of referenced FMOG to reflect Internal Control Overview throughout. Added reference FMOG Monitoring Plan for Segregation of Duties and Reconciliation of Accounts.

01/13/11

Revised the definition for Account Administrator and completed minor corrections to list items 4, 6, 8, 10, 12, 14, 16, 18, 20 and 22 in the Management Certification and Fiscal Management Sub-Certification Survey section.

01/11/11

Guideline published.

 


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