APM Segregation of Duties APM Segregation of Duties – Sponsored Programs Focuses on Compliance requirements for Sponsored Programs Supplements the requirements from APM — Segregation of Duties Discusses the role of the PI to ensure only allowable and allocable costs are charged to an award Segregation of Duties  Senior administration is responsible to ensure segregation of duties. Provides two benefits: Mitigates risk of fraud Detection of errors or irregularities

Optimally, no person should have responsibility to complete two or more phases of a transaction or process. Authorization Recording Verification Custody of assets Managerial review When less than optimal segregation exists, compensating controls must be in place. Compensating controls include: More detailed reviews Monthly managerial review Suggested documentation to print and review: Income Statement or Budget Variance Report, AND Transaction Checklist Documented with signature and date For other options, discuss with your Accounting Office Share resources with other departments

AuthorizationRecordingVerificationManagerial Review 123Mgr Four people are involved Each performs unique function PS Security/Access precludes crossover of functions Optimal segregation - managerial review can be quarterly Optimal Segregation AuthorizationRecordingVerificationManagerial Review 12MgrNot needed Three people are involved Detailed verification is performed by Manager Authorization, recording and verification are separated PS Security/Access enforces segregation Good segregation - Manager is performing the detailed verification Good Segregation

AuthorizationRecordingVerificationManagerial Review 122Mgr Three people are involved Recording and verification are not separated Managerial review is performed monthly Managerial review is more detailed Checking Own Work AuthorizationRecordingVerificationManagerial Review Mgr22 Two people are involved Recording and verification are not separated DETAILED managerial review will be performed monthly Manager Authorizes

AuthorizationRecordingVerificationManagerial Review 111 Mgr Least preferred and should be avoided Only two people are involved One person controls the entire transaction DETAILED managerial review will be performed monthly To Be Avoided Segregation AuthorizationRecordingVerificationManagerial Review Mgr This scenario represents an unacceptable risk and is not allowed Unacceptable whether a Manager or any level personnel Unacceptable Segregation

AuthorizationRecordingVerificationPI (Managerial) Review PI1 In less than optimal circumstances, a PI may perform all 3 functions (authorization, verification, managerial review) PI cannot authorize (approve) his/her own reimbursements Verification and Managerial Review can be done concurrently if both done by the PI Recording must be segregated Exception to Segregation Segregation of Duties-Sponsored Activity The PI’s role includes: Ultimate responsibility for an award Ability to delegate authorization PI cannot delegate responsibility for award PI cannot delegate managerial review Managerial Review completed Monthly

Link to training presentations Link to policies— Information OSP Training Schedule (Location: Havener Center—2008 Missouri Rm Meramec Rm.) November 4, :00 AM – 10:00 AMDisallowed Costs December 2, :00 AM – 10:00 AMDisallowed Costs January 6, 20099:00 AM – 10:00 AMTBA March 3, :00 AM – 10:00 AM TBA May 5, 20099:00 AM – 10:00 AM TBA June 2, :00 AM – 10:00 AMTBA July 7, 20099:00 AM – 10:00 AM TBA September 1, 20099:00 AM – 10:00 AM TBA October 6, :00 AM – 10:00 AM TBA November 3, :00 AM – 10:00 AMTBA December 1, :00 AM – 10:00 AM TBA System Training Schedule (Location: Havener Center—St. Pat’s) January 29, 20099:00 AM – 10:30 AM and 1:30 PM – 3:00 PMEVR’s April 7, 20099:00 AM – 10:30 AM and 1:30 PM – 3:00 PM Allowability August 4, 20099:00 AM – 10:30 AM and 1:30 PM – 3:00 PM Cost Transfers