Christie Stelling, CPA, CIAAssoc. Director, FinanceFinancial Controls

Objectives of this Training

Safeguarding Institutional Assets

Responsibility and Accountability

What Could Happen?

Questionable Conduct & Violations

Safeguarding Institutional Assets

We must all be good stewards of institutional funds and make decisions

based on several factors.

Safeguarding Institutional AssetsDecision-making should include ensuring all expenses are:

Consistent with institutional policies and procedures

Allowable based on fund source stipulations

Accurate

Reasonable

Supported by proper documentation

Directly benefiting the Institution’s mission

Financial PoliciesAlcoholic Beverages PolicyAsset Management Policy ManualBusiness Entertainment PolicyCash Handling Policy ManualEmployee Reimbursement PolicyGifts PolicyInternal Control PolicyInventory PolicyMemberships PolicyProcardSales Tax PolicyTravel Management Policy

Safeguarding Institutional Assets

Source: Institutional Policies and Procedures located on the intranet

Safeguarding Institutional AssetsDetermining Expense Allowability

Each fund group has specific restrictions based on the source of funds.

Fund Expenditure Guidelines

PRS Guidelines & Policies

Fund Group Overview

Education & General (E&G)

Company 1

Funds are provided by a combination of state appropriations and local institutional income. All expenditures from these funds must meet restrictions established by the State of Texas and be necessary to operate the department.

Designated Funds Company 3

Funds are from multiple sources: Unrestricted Gifts, IRG’s, Private Industry residuals, Internal Service Centers, Patent Royalty allocations. Expenditure restrictions are based on the specific funding source within the group and must be related to the specific purpose or program designated for the company base center.

Physicians Referral Service

(PRS) Company 4

Company centers within the PRS fund group are established for specific purposes as defined by PRS. Please visit the PRS website for more information.

Restricted Gifts Company 8

Funds are gifts with a legally restricted purpose designated by the donor. Expenditures from these funds must fall within the specific restrictions and must directly support the intended purpose of the fund.

Restricted Grants & Contracts Company 9

Funds are grants and contracts from organizations or agencies. These funds are covered by specific federal, foundation, industry grant or contract agreements. Expenditures must directly support the work of the grant and must adhere to any restrictions/terms outlined in the agreement.

Safeguarding Institutional Assets

For detailed guidelines on fund group expenditures, please see the Fund Expenditure Guidelines located on the Finance Division intranet site.

Safeguarding Institutional AssetsFund Group Contact

1 Financial Forecasting & Analysis (713-563-2242)

3 Gifts (31*): Development Office (713-792-3450 or 800-525-5841)Gift Allocations (34*): Research Finance (713-745-9464)Service Centers (37* or 38*): Controller’s Office (713-563-2282)Other: General Accounting (713-745-9550)

4 PRS (713-792-7600)

7 Financial Forecasting & Analysis (713-563-2242)

8 Gifts (81*): Development Office (713-792-3450 or 800-525-5841)Restricted Gift Allocations (84*): Research Finance (713-745-9464)894*: Research Finance (713-745-9464)

9 Grants & Contracts Accounting (713-745-9400)

Safeguarding Institutional Assets

Just because an expense complies with policy does not make it

reasonable or beneficial to the institution.

Safeguarding Institutional AssetsDefining ReasonableWiseSensibleNot excessive or extreme; moderateSound-thinkingFair; equitableRationalShowing reason or sound judgment

Safeguarding Institutional AssetsQuestions to ask yourself:1.Is this the best use of institutional funds?

2.Are institutional funds best spent on this instead of patient care, research, education, etc.?

3.Can I defend this decision to division and executive management if the expense is questioned?

4.How would individuals external to the institution view this expense?

Safeguarding Institutional AssetsAll expenses must directly benefit the Institution’s mission:

The mission of The University of Texas M. D. Anderson Cancer Center is to eliminate cancer in Texas, the nation, and the world through outstanding programs that integrate patient care, research and prevention, and through education for undergraduate and graduate students, trainees, professionals, employees and the public.

Responsibility & Accountability

Internal control is everyone’s responsibility

Responsibility & AccountabilityM. D. Anderson’s RoleThe Institution is responsible for encouraging the

establishment of strong internal controls by developing policies and procedures, setting goals and expectations, communicating responsibilities, and encouraging employees to act ethically.

Examples: Institutional Policies and Procedures, Code of Conduct, Core Values, Fraud & Abuse Hotline

Responsibility & AccountabilityDivisional & Departmental RolesDivision and department personnel are responsible for

developing an appropriate internal control structure within their area of responsibility and ensuring actions taken meet institutional guidelines, are in compliance with applicable rules and regulations, and properly safeguard institutional assets.

Delegating responsibility does not relieve an individual from being accountable for activities under his/her direction.

Responsibility & AccountabilityInternal controls affect every employee at

M. D. Anderson Cancer Center

All employees are responsible for

Adhering to institutional policies

Safeguarding institutional assets

Exercising sound business and financial practices

Ethically performing his/her responsibilities

(Video)

What Could Happen?Mission will not be achieved

Negative media attention

Loss of reputation and/or funding

Legal and/or disciplinary action

“It takes 20 years to build a reputation and 5 minutes to ruin it.” - Warren Buffet

Questionable Conduct & ViolationsIt is every employee’s responsibility to report any questionable conduct or suspected violations of the laws, regulations, or M. D. Anderson policies to the Institutional Compliance Office or Fraud and Abuse Hotline.

Questionable Conduct & ViolationsChecklist for Unethical Issues:Does the action comply with M. D. Anderson Cancer

Center’s policies and procedures? Is the action legal?How would the action look to your family, friends,

patients, and community if published on the front page of the newspaper?

Would the action make you feel bad if you did it?Are you being fair and honest?

Compliance ConcernsReport compliance concerns 24 hours a day, 7 days a week to:

• Fraud and Abuse Hotline at 1-800-789-4448

• Institutional Compliance Office directly at 713-745-6636

• Chief Compliance Officer via the Page Operator at 713-792-7090