SLIDE 47 Institutional Controls
COHORT INTERNAL CONTROL FRAMEWORK
Payroll Process Controls System Controls
- 1. IBS Policy: Pay Codes
- 2. 100% IBS is identifiable
- 3. Allocation of 100% IBS sources
- 4. Pay within Project Period
- 5. Cost Transfers identify earning period
ENFORCEMENT CONTROLS
- 16. Cost Transfer restrictions if
controls failed
- 17. Spending restrictions for
non-compliance COMPLIANCE MONITORING
- 22. Confirm controls work as
intended or perform additional controls for higher risk processes EDUCATION AND TRAINING
- 23. Responsibilities of individuals
performing controls are understood ADMINISTRATIVE (NON- FINANCIAL CONTROLS)
restrictions
- 19. Committed Cost Sharing
- 20. Minimum devotion of time
- 21. Reduction of 25% PI/PD time
ESTIMATE PAYROLL 6. Initial allocation
7. Allocation review and approval REVIEW PAYROLL 8. Reconciliations 9. Payroll Reports
- 10. After‐the‐fact review
(charged estimates determined accurate)
cross project coordination (if necessary)
Cohort For Efficiencies in Research Administration, J. Forsberg, L. Mosley, D. Ngo
UCSF already had all these existing controls, no improvement needed ADJUST PAYROLL
- 12. Reallocate estimates or
charges
- 13. Cost Transfers of payroll
already reviewed for accuracy
- 14. Cost Transfer over 90 days of
payroll determined accurate
- 15. Extra Compensation review
and approval UCSF already had all these existing controls, no improvement needed UCSF already had all these existing controls, no improvement needed
March 6, 2018 Award Verification Project 47