Scope
This policy establishes a framework for a system of internal controls and communicates the College’s internal control objectives.
Policy Statement
The State University of New York, College at Geneseo (SUNY Geneseo, College) is committed to a strong system of internal controls focused on accountability and oversight of operations to reasonably assure that the College:
- Meets its mission
- Promotes performance leading to effective accomplishment of objectives and goals
- Safeguards assets
- Provides accurate and reliable financial and other key data
- Promotes operational efficiency and economy
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Encourages adherence to applicable laws, regulations, policies, and practices
Policy
All employees are expected to comply with the generally applicable policies and standards listed below, as well as the policies and standards applicable to their specific duties and responsibilities. The Vice President for Administration is the designated College Internal Control Officer.
All employees are expected to comply with the following policies and standards:
A. Specific job description and performance program
B. Policies of the Board of Trustees, where applicable
C. Pertinent collective bargaining unit Agreement
D. NYS Civil Service Rules and Regulations
E. Public Officers Law
F. College Policies and Procedures Manual
SUNY Geneseo’s internal control program is a system of accountability and includes all the plans and actions that ensure reasonable control over college operations. Control activities, which occur throughout the organization at all levels and functions, help ensure that necessary actions are taken to address risks while achieving the College’s objectives. Internal controls are owned by the individuals performing the College’s operations and every employee is responsible for ensuring that the program is effective in achieving the College’s mission. Employee competence and professional integrity are essential components of a sound internal control program.
While internal controls themselves, are owned by the employees responsible for the control, along with their managers or supervisors, the internal control program is supported at the highest levels of SUNY Geneseo management. Senior leadership provides guidance and the resources to maintain a successful program. The internal control program is enforced through thoughtful, risk-based assessments.
The College has adopted this policy in accordance with the State University of New York Internal Control Policy and the New York State Government Accountability, Audit, and Internal Control Act.
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Responsibility
1. President
a. Promote a culture that embraces an effective internal control program.
b. Support the internal control program by providing the necessary resources
c. Internal Control Officer (Vice President for Finance and Administration)
d. Champion the campus-wide effort to establish, implement, and maintain a system of internal controls and a program of internal control review.
e. Evaluate the overall internal control program and risk assessments for applicability to the College’s strategic objectives.
2. Internal Audit
a. Review and report on the adequacy of departmental and institutional internal controls.
3. Compliance Officer under direction of the Vice President of Finance and Administration
a. Coordinate and communicate the College’s internal control program.
b. Facilitate documenting an inventory of internal controls in the College.
c. Develop and coordinate all policies related to the internal control program.
d. Implement an on-going training process for employees.
4. Subject Matter Experts (SME) (SMEs are identified across the College and specifically in high-risk areas including, but not limited to, Accounting Services, Student Accounts, Financial Aid, Procurement & Property Control, Human Resources, Computing and Information Technology, Environmental Health and Safety and Athletics)
a. Develop, implement, and review internal controls policy and training in their area of expertise.
b. Perform internal control reviews on an ongoing basis.
c. Promote the internal control program within their area of expertise to gain consistency in the way the College thinks about risk.
d. Encourage a culture that self-identifies gaps in internal controls and aids in mitigation of the identified risk.
5. Managers and Supervisors
a. Establish, maintain, and support an effective system of internal controls within their areas of responsibility. Collaborate with the Compliance Officer under direction of the Vice President of Finance and Administration, as appropriate.
b. Create a control environment that encourages compliance with college policies and procedures.
c. Coordinate with the Compliance Officer under direction of the Vice President of Finance and Administration to periodically review and test the system of internal controls.
d. Identify and implement appropriate corrective actions.
6. All Employees
a. Fulfill the duties and responsibilities established in their performance program.
b. Monitor their work to ensure it is done properly and that errors are corrected promptly.
c. Follow College and departmental policies and procedures.
d. Safeguard resources against waste, loss, unauthorized use, and misappropriation.
e. Attend education and training programs to increase awareness and understanding.
f. Report breakdowns in internal control systems and related issues to their supervisor.
Copies of specific policies and standards may be obtained from the Human Resources Office. Also, please visit the Internal Control website for further discussion and guidance on internal control policies and activities.
Related Information:
SUNY Geneseo Social Security Number Policy
Office of the New York State Comptroller – Internal Control
Frequency of Review and Update
Every 5 years.
Approval
Date of Approval