Annual Unit Internal Control Certification Process
What is the annual unit certification?
The Certification of Financial Results & Internal Controls process is designed to help develop a broader understanding and accountability of unit financial results and internal controls. This is especially important given the decentralized nature of administrative operations throughout the university. The process began in FY2005 leveraging best practices from Sarbanes-Oxley Act.
The certification includes the following topics:
- Financial Results
- Conflict of Interest/Conflict of Commitment
- Internal Controls
- IT Security
- Red Flag Identity Theft (click here for a list of applicable units)
The Certification form is sent to Deans, Directors and Vice Presidents in early September and the signed form is to be submitted (via email or campus mail) to the Office of Internal Controls by the end of September of each year. The results are then summarized and presented to the Regents in the Finance, Audit and Investment Committee in November.
For additional information regarding the annual unit certification process, click here for a power point presentation.
What are the key internal control related elements of the certification?
The three key internal control related elements are as follows:
- Gap Analysis – assessing key control points
- Written Procedures – written documentation of control points and responsibilities
- Management Oversight Reporting – monitoring key trends and exceptions
See below for additional information on each key element.
1) An annual gap analysis for each applicable financial related process should be completed to fulfill Certification requirements. Performing a gap analysis involves reviewing key internal control points for each financial related process and determining whether or not the appropriate controls are in place. If a control is not in place, a corrective action plan should be developed to ensure the control gap is remediated in a timely manner.
How should units complete the gap analyses?
There are two options to complete the gap analysis process. Units can choose to use the Gap Analysis Tools found here. Each document lists the controls that should be in place for a given process. Units may also choose to complete the gap analysis online using MReports (located under the Internal Controls menu within the Compliance tab). By using this method, units can easily summarize and highlight common issues for multiple departments as well as maintain all gap analyses and view answers from prior years. See the Online Gap Analysis Step-by-Step handout for instructions on how to use this tool. For either option, units should maintain evidence/documentation of their completed gap analysis, including corrective actions for any gaps identified.
2) Written procedures should also be developed for each financial related process. These procedures should outline the steps in the process, key controls, and define roles and responsibilities. Written procedure templates can be found here to assist units in developing documentation. These templates can be used as a starting point and revised as necessary to reflect the unit’s actual processes and also include many helpful links to training material, websites, etc.
3) Management oversight reporting is another key internal control element. These reports were designed for Deans and Directors to review and highlight trends and exceptions as well as provide high level summaries. Some reports are available in MReports and feature “drill down” capabilities. Others are located in Business Objects. To access these reports, click on the report links on the Gap Analyses and Written Procedures Templates page.
Are there other reports a unit should be reviewing?
There are a number of other reports that should be reviewed to help units monitor key control points in their processes.
Who is required to certify?
Deans, Directors and Vice Presidents from 46 units across campus are required to certify to their financial results and internal controls. For a listing of certifying units, click here.
What about “sub-certification”?
Some units now conduct a departmental level “sub-certification” process. This allows units, particularly larger ones, to include other leaders within their organization in the awareness and accountability process. By implementing a sub-certification process, Deans/Directors/Vice Presidents can gain more confidence in the accuracy of the Certification for their unit.
To help streamline the sub-certification process, units can utilize the Sub-Certification functionality available in MReports (located under the Internal Controls menu within the Compliance tab). See the Online Departmental Sub-Certification handout for instructions on how to use the tool and the Online Sub-Certification Approvals handout for instructions on how to approve/certify.