This policy governs reconciliation, verification, and substantiation of GL transactions which are essential for an effective internal control environment to ensure:
- The information transmitted to, contained in, and reported from the University's financial systems is accurate, complete and recorded in a timely manner
- The information can be relied upon for making financial and administrative decisions
- Fraud, theft, compliance violations and other irregularities are quickly detected and reported to the appropriate authorities
The University’s official book of record for financial transactions
Transactions are to be verified to provide reasonable assurance those financial transactions are valid and allowable per policy and properly classified. The verification encompasses the following three activities:
- Reconciliation: Examining detailed transactions in the GL to ensure these are the transactions that are expected to appear. Look for any suspicious transactions or abrupt changes from an established trend. Any errors that are identified, including transactions, that contain incorrect or inappropriate chartfields must be corrected. Additionally, ensure all transactions are supported by source documentation and that the source document matches the GL transaction.
- Review: Examining management GL trend reports for perceived anomalies and errors of substance, based on the reviewer’s experience and knowledge of the department’s operations. This activity should be at a more summarized level compared to the detailed reconciliation discussed above.
- Acknowledgement: Confirmation by the fund owner that they have reviewed the financial information, errors have been corrected, and they can provide reasonable assurance of the validity of the information. Documentation of this acknowledgement is through signing the GL Verification Acknowledgement form.
The entire verification process must be completed in a timely manner according to the following deadlines:
- Sponsored funds: within one month of the previous calendar month end; for example, the verification process for transactions recorded during the month of August must be complete by September 30th
- Non-sponsored funds: within two months of the previous calendar month end; for example, the verification process for transactions recorded during the month of August must be complete by October 31st
Departments are required to ensure supporting documentation exists for all verified transactions. The source document needs to be reproducible upon request.
Detailed procedures have been created to provide guidance on how to obtain GL transaction detail reports, filter this data for reconciliation, and document the procedures performed. Please see the links in the Procedures section below.
Accountability and procedures must be assigned and in place for each department to ensure that inaccuracies or incomplete financial information identified during the reconciliation or verification process are investigated and corrected in a timely manner.
Department administrators must comply with the requirements of this policy to ensure that an effective internal control environment is maintained.
Materiality, compliance risk, transaction detail volume, knowledge and experience of personnel performing analyses, and other factors should be considered for reconciliation, verification and substantiation and the subsequent review process.
Duties should be separated between reconciliation, review, and acknowledgement whenever possible. As a minimum, two individuals are required.
- Reconciliation: Typically, this role is filled by the department’s financial administrator.
- Review: It is expected that someone familiar with the financial activities, of the department, such as the MSO, performs the ledger review.
- Acknowledgement: Typically, acknowledgment is completed by the MSO, Department Head or designee for non-sponsored funds and the Principal Investigator (PI) or designee for sponsored funds
If separation is not feasible or practical due to staffing levels (e.g., the MSO may also be the financial administrator), it would advisable to separate the reconciliation and review function, with the reviewer acknowledging that the verification was performed, and monitoring if any reconciliation items are resolved on a timely basis.
If the reconciliation and review functions are combined, the acknowledger could sign off that both functions were performed.
If the verification, review, and acknowledgement functions are combined, an assessment should be performed to ascertain the level of risk and whether or not alternative detective controls are necessary.