Overview
The University routinely monitors departmental and individual compliance with supply chain/procurement policies by conducting spot assessments of purchasing records throughout the year. Departments are required to provide transaction documentation to Assessments staff upon request. Penalties may apply for individuals and/or department found to be out of compliance. Periodic reports will be provided to campus and department administration to summarize findings and analyze compliance.
Selection of transactions for assessment
Three sampling methods are used to select transactions for spot assessments:
1) The majority of transactions are selected from activity found in high-risk categories, such as type of vendor used.
2) A smaller number of transactions are selected to follow up on cardholders and/or reconcilers and/or approvers found to be non-compliant in previous assessments.
3) Throughout the year some transactions are selected at random from the recent activity of individuals and/or departments that otherwise have not been assessed.
All three methods of selection (high risk category, follow-up monitoring, and random) are considered routine and are used for spot assessments throughout the year.
In certain circumstances a department may be subject to a more complex assessment. For example, when multiple assessments show a pattern of non-compliance, or if errors found in a single transaction raise significant concerns regarding general departmental controls, a more in-depth assessment involving multiple transactions may be required along with a corrective action plan.
Consequences of non-compliance
Depending on the type of policy infraction(s) found, penalties may apply to cardholders, reconcilers, and/or approvers. There may be consequences for the business unit as well, depending on the frequency, severity, and scope of the problems found.
Assessment results are generated for each spot assessment and sent by email to the Department Authorized and Delegated signers. The individuals identified as directly involved (cardholder, reconciler/verifier in BFS, approver in BFS) will receive separate notification that assessment results have been sent to the Authorized/Delegated Signers.
Repeated non-compliance will result in an escalating series of consequences, including notification to higher levels of administration of assessment results. All penalties are enforced at the discretion of Card Program Services, in consultation with Assessments, using the guidelines found here.
Assessment recordkeeping when errors are found
Assessment findings and associated consequences are tracked separately for each individual and for the departmental overall:
- If subsequent assessments find an error in the same category for the same individual acting in the same role, even if it occurs in a different department, it will be counted as a repeat infraction if it occurs within twelve months of the date of the previous assessment results memo.
- However, if a subsequent assessment finds an error in the same category for the same individual in the same role, but the error occurred before the date of the previous assessment findings, it will be considered part of the previous findings and not count as a repeat error. See Consequences for a detailed description of assessment categories and the system of escalating penalties that apply as a result of finding repeat infractions.
Frequency of assessments
A department may be asked to provide transaction documentation at any time during the year. The chance of being selected for routine assessment increases as a result of high risk factors such as vendor type, incomplete processing in BFS, or prior findings of non-compliance. Follow-up selections may focus on the original individuals or others in the department.
This page last updated 07/10/2014