Compliance Monitoring

Policy 300-49 

• A deficit is defined as a negative financial net position at the close of the fiscal year. Net position-end of period is calculated as the net position-beginning of period plus revenues minus expenses plus other changes. For purposes of this policy, not including sponsored research activity, deficits are identified as the net position by fund and the Level 2 Department ID. 
• As a best practice, deficits should be resolved by the fiscal year end. If department(s) contains a deficit after fiscal year end, the department(s) in deficit will be asked to develop deficit resolution business plans (ensure an estimate deficit resolution date is provided) and submit them to control point for approval. 
• Deficit Monitoring - Non-Sponsored, Non-Recharge 
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In order to reduce the proliferation of Projects, SOM Control Point provides departments with a list of Projects meeting threshold criteria. Departments are to review their list and provide a response by the deadline. If there’s a failure to respond to the request, SOM Control Point will default to close out Project(s) on the list. This annual process takes place after the close of January.  

Departments may feel free to review and inactivate Projects outside of the annual process. A Project may be inactivated if there is ZERO balance on all chartfields of the Project, Fund, Dept ID, and combination of. 

• For Gift Projects: 
  Process for analysis 
  1. <$2500 balance Child projects should first be closed to the parent project.  
  2. <$2500 balance Parent projects may be closed to other gift projects with a similar purpose. 
  3. If no similar purpose project exists and there is no expectation of soliciting or using funds for that purpose in the foreseeable future, the parent project with a remaining balance of less than $2500 may be closed to other discretionary department gift funds. 
• For 2xxxxxx Projects: 
  Process for analysis: 
  1. +/- $1,000 balance transferable within original Fund (must stay in same Fund), selected Dept ID, and selected Project ID. 

Category 1 proposals, which include CCAs, Low, Low-Medium, and Medium-risk proposals should be submitted directly to Recharge Review for functional, financial and compliance reviews and approval, with a copy sent to the control point.  

Category 2 proposals, which include Medium-High and High-risk proposals, should be submitted to the control point for financial and functional review prior to forwarding to Recharge Review for a compliance review and final action. In addition, all projects with a plan of at least $500,000 need to obtain user committee endorsement of approval after Recharge Review has reviewed the proposal and is ready to approve the rates. 

The following is the responsibility of the control point: 

Provide financial and functional review for Category 2 recharge proposals. Once reviewed and approved, rate proposal will be forwarded to Recharge Review Team for compliance review and approval 

• Provide any questions or comments to Recharge Review Team with 2 weeks of submission for Category 1 recharge proposals 
• Assist departments in resolving outstanding issues and revising incomplete proposals for resubmission 

General Ledger (GL) verification is a key control of UCSF and is a requirement per Campus Administrative Policies. It is the responsibility of each department to ensure that financial transactions recorded in the general ledger are in accordance with all relevant policies, regulations, and sponsor or donor terms and conditions. This is accomplished through the combination of following campus-wide policies and procedures for financial transactions (preventative controls) and GL verification (a detective control). 

GL verification activities are conducted using the GL Verification online tool.  Users receive an email notification when the data for the latest closed month become available. Data are posted to the GL Verification tool monthly, approximately four days after campus month-end close is complete. The GL verification process must be completed in a timely manner: within 30 days of the previous month-end close. 

Award verification is UCSF's procedure to support Principal Investigators (PIs) in meeting the requirements of the Uniform Guidance for federal awards. One of the key goals of award verification is to reduce the time required of PIs for compliance activities. PIs will cease certifying effort using the Effort Reporting System and will use a new online tool for award verification.  

Award verification is part of a set of controls and practices intended to ensure proper stewardship of the University's resources including sponsored awards. UCSF's award verification procedure has two components. 

1. Documenting General Ledger (GL) verification using the GL Verification Online Tool 
2. Documenting Award Verification using the Award Verification Tool 

See Using the Award Verification Tool for additional details and instructions, and Get Ready for Award Verification for sample process diagrams and steps you can take to prepare for award verification.