Guidance for Units and Departments
University of Kentucky Internal Audit (UKIA) has many resources that units and departments can use to aid them. These services can be provided through UKIA itself, or from other areas. Click here for more resources.
Academic Risk Template
To assist colleges with risk assessments that may be required as part of the accreditation process, UKIA has created a risk assessment template for your use. There are three tabs at the bottom of the template to help sort risks into the three main areas of the college’s activities: administrative, research and instruction
Each tab has a form where you can add the process, risk activity being rated, the policies and regulations, standard and criteria for each risk being assessed, as well as the responsible entity and the controls that are in place to monitor the activity. At the far right, there is a place to rank both the likelihood of the event actually happening and the impact such an event would have on the college/university on a scale of 1-3, with three representing a high likelihood or impact and one representing a low likelihood or impact. The Risk Rating is an average of those two numbers. Additionally, there are several examples on each tab to help you get started.
Download the Academics Risk Template here.
Hours and wages for university employees performing work in a department outside their primary unit should always be paid through Human Resources (HR) Compensation – never on a ProCard - per Business Procedures Manual (BPM) Section B-3-2 III.B. Delegated Procurement Policy for Departments and HR Policy and Procedure #30 Compensation Administration. Additionally, the following steps must be taken:
- The completion of a Worker Status Evaluation Form is also required to be completed and submitted to HR in order to determine if the worker is already an employee and if not, whether that person should be classified as a temporary worker or an independent contractor (BPM E-7-3 Worker Classification Employee or Independent Contractor).
- Non-exempt staff working in two or more departments of the University creates a concurrent employment situation which requires the advance approval of managers from both units. The employee should enter all hours worked in SAP and the department where the employee primarily works should bill the department temporarily requiring the employees’ services for the appropriate hours. The payment should be made via a funds transfer (BPM Section B-3-2 III.B. Delegated Procurement Policy for Departments; HR Policy and Procedure #30 Compensation Administration).
- When an exempt employee is needed to perform work in another department, the requesting department should complete a Staff Internal Overload Form and submit to HR for approval (Administrative Regulation 3:9 Consulting and Other Overload Employment).
Expense Reimbursements for Vendors
Food, catering and other expenses incurred by an employee while serving in an external vendor capacity should always be included as part of the total services being provided per the vendor quote or contract and therefore paid according to the type of service being provided, per the AP Quick Reference Guide. Vendor expenses should not be paid via the employee reimbursement process using the UK employee PERNER form.
Policies Related to Vendor Payments
The BPM Section B-2 General Purchasing and Contracting Authority prohibits purchases and contracts from being “made with an employee of the University of Kentucky for any item of supply, equipment, or service.” These situations clearly indicate this policy is not being followed. While certain exceptions may be made in the event of sole source providers and, in health care, when it is a medication or therapy deemed to be best approach for a patient, in general, using a company owned by a UK employee is unallowable. UKIA attributes use of employees as vendors to a lack of communication regarding the policy noted above and the ability to bypass the established processes for engaging and vetting vendors:
- Supplies: Units should always verify that the vendor they want to use is listed in the SAP vendor database. If the vendor is not listed, the unit should follow the steps to onboard a new vendor in the PaymentWorks system found here (see BPM B-3-1 Use of Existing Contracts).
- Services: Units should verify that a university unit or state personnel cannot provide this service. If it cannot be provided, the unit should complete a Standard Contract for Personal Services and submit it to Purchasing for approval.
Each quarter, UKIA hosts Lessons Learned, a virtual roundtable event that allows UK Internal Audit to share information about actual incidents or activities that have occurred here at UK (but not unit-identified) or at other institutions across the nation and the risks associated with these "hot topics." Faculty and staff who attended these events will come away with insights to improve their operations to prevent similar activities from occurring in their units.
Recently, UKIA completed several reviews across the university during which similar concerns pertaining to inappropriate payments to employees were noted. Each of these cases involved a UK employee being paid as a vendor to perform work or provide a service. UK policies were not being followed in any of these cases.