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APM 2.25.55 Segregation of Duties APM 2.25.55.01 Segregation of Duties – Sponsored Programs

Segregation of Duties. APM 2.25.55 Segregation of Duties APM 2.25.55.01 Segregation of Duties – Sponsored Programs Focuses on Compliance requirements for Sponsored Programs Supplements the requirements from APM 2.25.55— Segregation of Duties

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APM 2.25.55 Segregation of Duties APM 2.25.55.01 Segregation of Duties – Sponsored Programs

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  1. Segregation of Duties • APM 2.25.55 Segregation of Duties • APM 2.25.55.01 Segregation of Duties – Sponsored Programs • Focuses on Compliance requirements for Sponsored Programs • Supplements the requirements from APM 2.25.55— Segregation of Duties • Discusses the role of the PI to ensure only allowable and allocable costs are charged to an award • Senior administration is responsible to ensure segregation of duties. • Provides two benefits: • Mitigates risk of fraud • Detection of errors or irregularities

  2. 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

  3. Optimal Segregation Good Segregation

  4. Checking Own Work Manager Authorizes

  5. To Be Avoided Segregation Unacceptable Segregation

  6. Segregation of Duties-Sponsored Activity Exception to Segregation • 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

  7. Information Link to training presentations-- http://www.umsystem.edu/ums/departments/fa/controller/compliance/training.shtml#online Link to policies— http://www.umsystem.edu/ums/departments/fa/controller/accountingservices/manual/ OSP Training Schedule(Location: Havener Center—2008 Missouri Rm. 2009 Meramec Rm.) November 4, 2008 9:00 AM – 10:00 AM Disallowed Costs December 2, 2008 9:00 AM – 10:00 AM Disallowed Costs January 6, 2009 9:00 AM – 10:00 AM TBA March 3, 2009 9:00 AM – 10:00 AM TBA May 5, 2009 9:00 AM – 10:00 AM TBA June 2, 2009 9:00 AM – 10:00 AM TBA July 7, 2009 9:00 AM – 10:00 AM TBA September 1, 2009 9:00 AM – 10:00 AM TBA October 6, 2009 9:00 AM – 10:00 AM TBA November 3, 2009 9:00 AM – 10:00 AM TBA December 1, 2009 9:00 AM – 10:00 AM TBA System Training Schedule(Location: Havener Center—St. Pat’s) January 29, 2009 9:00 AM – 10:30 AM and 1:30 PM – 3:00 PM EVR’s April 7, 2009 9:00 AM – 10:30 AM and 1:30 PM – 3:00 PM Allowability August 4, 2009 9:00 AM – 10:30 AM and 1:30 PM – 3:00 PM Cost Transfers

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