Straight and narrow, Vol. 5, Issue 24 (Mar. 2014)

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March 2014
The Office of Internal Audit & Compliance's (OIAC) mission is to support the University System of Georgia management in meeting its governance, risk management and compliance and internal control (GRCC) responsibilities while helping to improve organizational and operational effectiveness and efficiency. The OIAC is a core activity that provides management with timely information, advice and guidance that is objective, accurate, balanced and useful. The OIAC promotes an organizational culture that encourages ethical conduct.
We have three strategic priorities:
1. Anticipate and help to prevent and to mitigate significant USG GRCC issues.
2. Foster enduring cultural change that results in consistent and quality management of USG operations and GRCC practices.
3. Build and develop the OIAC team.
Inside this issue:

Volume 5, Issue 24 Office of Internal Audit & Compliance, BOR -- USG, (404) 962-3020
From the Chief Auditor Officer John M. Fuchko, III
What's on the horizon? The OIAC will be turning its attention to athletic programs.
Our work will include an enterprise-wide review of existing athletic programs at USG institutions. This work will include assessing various factors related to the operation of these programs for the purposes of identifying potential best practices and other similar efficiencies that may be relevant to USG operations. Similarly, we will determine the level of compliance of USG athletic programs with existing policies and procedures, especially those related to internal controls designed to mitigate significant risks (e.g. continued financial viability, inter-athletic conference program participation, safety and success of student-athletes, and so forth).
This effort will extend beyond athletic program housed within USG institutions, however. We will be developing a comparative analysis to athletic programming featured at other public post-secondary institutions and systems across the country. Ultimately, we hope to identify potential improvements to USG athletic programs by ensuring that our stakeholders have a well-informed perspective on the many variables and facets of operating these complex organizations.
Our review will incorporate many different aspects of the operations of athletic program, including the following:
Allocation and administration of out-of-state tuition waivers to studentathletes
Governance structure and characteristics for athletic programs Descriptive characteristics of the programs, such as the number of teams,
student-athletes, types and gender of sports Financial characteristics of athletic programs and teams Program and team staffing models

From the Chief Audit Officer
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The OIAC will provide additional information to institutions regarding this review in the near future.
2-5

Effec ve Communica on IT B.Y.O.D. Mobile

6-7 I look forward to hearing your thoughts. Please feel free to contact me at
john.fuchko@usg.edu or 404-962-3025. Our Rolling Audit Plan may be found on the 8 OIAC website located at: www.usg.edu/audit/internal_audit.

IRS Report on Colleges
Did You Know? Purchasing Report

9-10 John M. Fuchko, III 11 Chief Audit Officer & Associate Vice Chancellor

Contact Us

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Financial Aid--Calcula ng R2T4

Federal Student Aid
The Federal Student Aid (FSA) Handbook is the reference source used by Financial Aid Directors to manage the ins tu on's financial aid program and to report eligibility requirements to the Dept of Educa on. It provides guidance on financial aid eligibility requirements for students and parent borrowers and the ins tu on's responsibili es to ensure that recipients qualify for aid awards under Title IV of the Higher Educa on Act of 1965.
The FSA programs provide financial assistance for postsecondary students. The programs are administered by an agency called Federal Student Aid (also FSA), which is part of the U.S. Department of Educa on (ED). In financial aid circles, the term "FSA" is used to refer to both the aid programs and the ED office administering them.

Calcula ng a "Return to Title IV" appears decep vely simple:
If a student withdraws from the ins tu on during a semester, Then the student may not have fully "earned" the federal Title IV
financial aid they received to pay for their tui on and other expenses Therefore, the por on of the financial aid not earned should be
returned, A "Return to Title IV" (R2T4) financial aid calcula on is required to
determine the refund to the U.S. Department of Educa on.
However, other considera ons should be factored into the process and cri cal controls considered by the ins tu on to ensure accurate and
mely calcula on and repor ng. This ar cle will focus on a credit hour program, although the concepts apply to clock hour programs, modules or other program criteria.
The requirements relevant to the return of unearned federal financial aid are found in Title IV of the Higher Educa on Act of 1965, Title 34: Educa on sec on 668.22 - Treatment of Title IV Funds when a Student Withdraws. This cita on may be found using the Electronic Code of Federal Regula ons, at the following link: h p://www.ecfr.gov/cgi-bin/ text-idx? c=ecfr&SID=89d5048ebca12c33e51192c59f9901ea&rgn=div8&view=text &node=34:3.1.3.1.34.2.39.12&idno=34
The Federal Student Aid Handbook (FSA Handbook) also provides guidance and clarifica on about returning unearned federal financial aid funds to the U.S. Department of Educa on. The 2013-2014 FSA Handbook is the current version and can be found at the following link:
h p://ifap.ed.gov/ fsahandbook/1314FSAHandbookCompleteAc veIndex.html
Some key considera ons within financial aid requirements include:
The ins tu on has a fiduciary responsibility to accurately administer federal aid.
The amount of earned financial aid is directly propor onal to the number of days lapsed while the student a ended classes in comparison to the total number of days in the period, up to 60% of the period.

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A er the 60% point in the period is achieved, a student is considered to have earned 100% of their financial aid. The U.S. Department of Educa on allows for this to differ from the ins tu onal refund policy. However, the University System of Georgia requires the same 60% point for system ins tu ons, unless special policies have been approved by the Board of Regents. See USG BOR Policy 7.3.5.
The ins tu on needs to ensure it has correctly iden fied ins tu onal charges subject to the R2T4 calcula on, primarily tui on and fees. See 2013-2014 FSA Handbook page 5-17.
Even a er the 60% point, the R2T4 calcula on needs to be completed, as the student may be eligible for a post withdrawal disbursement. A post withdrawal disbursement of loan money may increase the amount of aid the student or the parent will be obligated to repay. A post disbursement of PELL money is a grant, and does not need to be repaid. This change requires the financial aid office to communicate with the student/parent prior to a post withdrawal disbursement of loaned funds.
The effec ve date of an official withdrawal is the date a student begins the withdrawal process per the ins tu on's policies and procedures.
Funds must be returned within 45 days of the ins tu on determining that the student has withdrawn. See 2013- 2014 FSA Handbook page 5-94.
The 2013-2014 FSA Handbook clarifies the situa on for students who leave the ins tu on without following the official withdrawal process. As stated on page 5-56 of the handbook:
"If a student who began a endance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an en re period, the ins tu on must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the ins tu on can document that the student completed the period."
Ins tu ons may use the 50% point as the effec ve date of an unofficial withdrawal unless later par cipa on in an academically related ac vity is adequately documented. See 2013-2014 FSA Handbook page 5-175, Step 2.
The impact of waivers must be considered within the R2T4 calcula on. If the ins tu on considers a waiver as a payment of tui on and fees that factor into the financial assistance offered to a student, they may need to reverse the impact of the waiver prior to comple on of the R2T4 calcula on. See 2013-2014 FSA Handbook page 5 -16.
Controls Control ac vi es to be considered by the ins tu on would include the elements listed below. This list should not be considered as a full list of possible controls and each ins tu on should fully consider its own unique situa on and react appropriately.
Appropriate records should be maintained regarding student withdrawal ac vity. The ins tu on should ensure that cri cal steps in the withdrawal process are properly recorded and communicated to interested par es. This would include the point at which the student officially begins the withdrawal process. For example, if procedures specify that students are to contact the enrollment service center as the first step in the withdrawal process, then the date of contact must be documented as the date of withdrawal.
Accountability should be assigned to ensure mely comple on of the R2T4 calcula on process. An ins tu on's R2T4 procedure should outline a procedure to track a student's withdrawal events to ensure filing is completed in a mely manner. The process should include specific communica on and monitoring ac vi es to ensure management is made aware when deadlines are at risk of being missed.
Required par cipa on verifica on. Recording a endance at each class period would provide consistent evidence of par cipa on. Alterna vely, verifica on at a date in the period a er the 60% point would provide a solid level of protec on against improper loss of ins tu on revenues. It would also validate sa sfac on of the

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ins tu on's fiduciary duty. If the ins tu on does not have data suppor ng the date of withdrawal, the FSA Handbook instructs the ins tu on to assume the student withdrew at the midpoint in the semester. Based on the ins tu on's refund policy, this could impact the recogni on of ins tu onal revenues as well as impact whether the student may be required to repay funding to the ins tu on. Ins tu onal management should also consider verifica on based on the ins tu ons' refund policy if different than the federal regula on of 60%. The ins tu on should periodically review refund policies to ensure the policies reflect the inten ons of the ins tu on and the choice of words does not create poten al problem areas. The 2013-2014 FSA Handbook instructs ins tu ons to assume unofficial withdrawals occur at the 50% point in the period unless verifica on data supports a different date. If the ins tu onal refund policy states that tui on is fully earned a er the 50% point, then the ins tu ons may incur a revenue risk because of the wording difference between the federal guideline of exactly 50% and the ins tu on wording of "a er" the 50% point. If the refund policy states that tui on is fully earned at the 50% point in the period, ins tu onal revenues would be protected as this would then agree exactly with the federal requirements for use of the 50% point. The use of the ins tu onal policy statement "a er the 50% point" creates a poten al conflict. The ins tu on should ensure that elements of tui on and fees are being properly categorized and documented within the R2T4 calcula on process as ins tu onal or non-ins tu onal charges. Ins tu onal charges must be included in the R2T4 calcula on process. These charges include educa onal charges that are paid directly to the school for tui on and fees. Schools need to consider the impact of any special programs or allowances that encourage students to purchase items from a school source even though the items may be available from an alterna ve source. See 2013-2014 FSA Handbook page 5-18 for addi onal details. Appropriate checks and balances should be incorporated into the process. Management should implement controls ensuring appropriate segrega on of du es relevant to the Return to Title IV process and clearly assign accountability for the accuracy of calcula ons. This will also include assignment of a single point of accountability for the compliance and accuracy of the overall process which cuts across any departmental silos that may be present.
The process will likely extend across mul ple organiza ons, possibly Academic Affairs, Registrar, Enrollment Services, Bursar and Financial Aid. If there is not a single point of overall accountability, the process could easily experience obstacles related to the communica on and monitoring of significant events and data elements.
Risks to Consider The ins tu on should consider Risks elements relevant to the R2T4 process. These may include:
Inaccurate determina on of the date students ini ate the official withdrawal process. Impact Errors in the effec ve date of withdrawal would result in repor ng incorrect ins tu onal revenue, incorrect return of funds to the U.S. Department of Educa on and could result in billing errors to the student.

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Return of funds past the 45-day requirement Impact Noncompliance with federal regula ons could result in the ins tu on's loss of ability to par cipate in the federal financial aid program.
Errors in categorizing the tui on and fees appropriately. Impact - Errors in categorizing tui on and fees may result in repor ng incorrect ins tu onal revenue, incorrect return of funds to the U.S. Department of Educa on and could result in billing errors to the student.
Absence of data or improper data collected about the student's last par cipa on date in an academically related ac vity. Impact Key for unofficial withdrawals. Lack of valid informa on regarding student's date of last par cipa on in an academic event could result in unnecessary loss of ins tu onal revenue, excessive return of funds to the U.S. Department of Educa on and could result in unnecessary billing to the student. If the ins tu on cannot document that a student a ended past the 60% point then funds will need to be returned even though the student may in fact have par cipated past this date. Accurate record keeping regarding withdrawal dates and class a endance can prevent an unnecessary R2T4 calcula on.
Data errors within the Banner (or other student record management system) update process or within the R2T4 calcula on result in Return to Title IV errors.
Impact Errors in the calcula on process would result in repor ng incorrect ins tu onal revenue figures, incorrect return of funds to the U.S. Department of Educa on and could result in billing errors to the student.
Other Noncompliance with federal requirements.
Impact - Noncompliance with federal regula ons could result in the ins tu on's loss of ability to par cipate in the federal financial aid program.
Proper implementa on and con nued monitoring of the controls noted within this ar cle should provide a solid basis on control over the Return to Title IV process and address the relevant risks. Answers to any ques ons are likely to be found within the 1000+ pages making up the 2013-2014 FSA Handbook, covering many financial aid related topics. It will benefit you and your ins tu on to become familiar with the FSA Handbook and the topics contained within it.
Ron Richards CPA, CIA, CRMA Director of Internal Audit
University of West Georgia (678) 839-6342 rrichard@westga.edu

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Ins tu onal Effec veness Components of Effec ve Communica ons
Jeanne Royal Severns, VSU

I know you're wondering what more can be said about governance. We have touched briefly on the core concepts of:
Leadership, guidance, and a tone at the top,
Achieving objec ves,
Overseeing and monitoring opera ons,
Ensuring compliance with laws and accountability for behavior, and
Legal and ethical behavior
Now let's think about the important part effec ve communica ons has on each of these competencies.
Effec ve organiza onal communica ons begins with clearly defined, easily accessible policies. These policies are the governing principles of the organiza on and are meant to guide the organiza on towards achieving its strategic objec ves, complying with laws and behaving ethically. They have a wide impact on broad segments of the organiza on. Does your organiza on have a clear set of policies? Do employees know where to find them? Is there a method for introducing, reviewing and approving

changes to policies?
Just as important as policies, are clearly defined procedures. Actually, procedures may be more important to the employee who is trying to do something or for the customer who expects service. A well wri en procedure defines the work, describes how the work is done, and just as importantly tells who does the work. Good procedures enable managers to oversee and monitor opera ons. They
ensure accountability, promote consistency in how the work is done, and prevent work stoppages in the event an employee is absent.
Not long ago I ordered a lobster salad at a restaurant and was told "the chef who makes the salad is not in today". What? He didn't leave the recipe?
Job descrip ons are another some mes overlooked aspect of good communica ons and governance in an organiza on. Job descrip ons help employees understand their roles and responsibili es and what is expected from them.
I remember an incident from several years ago when BBC news somehow mixed up two persons in their studio: one was an IT expert who was scheduled for

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an on-air interview; the other a taxi driver who was at the BBC to interview for a job as a janitor. The job applicant was interviewed on air and wondered why he was being asked such very difficult IT ques ons. This miscommunica on certainly made the applicant wonder about the job descrip on.
Communica ons is an important leadership quality. The Baldrige criteria for performance excellence stresses the importance of communica on as it applies to senior leadership with the following ques ons: How do senior leaders communicate with and engage the en re workforce? How do senior leaders achieve the following:
encourage frank, two-way communica on throughout the organiza on?
communicate key decisions?
take an ac ve role in reward and recogni on programs to reinforce high performance and student learning?
Another ques on asked by Baldrige is: How do you foster an organiza onal culture that is

characterized by open communica on, high- performance work, and an engaged workforce? And finally, a par al list of the effects of communica on: Good communica on helps a team to complete its projects on me, accurately and effec vely thereby saving money. Vague e-mails can slow down the work flow. A communica ve environment can increase morale and inspire employees to ac on. Clearly communicated expecta ons avoid the necessity of re-work. Listening is an important part of communica ng.
Jeanne R. Severns Director of Internal Audits Valdosta State University Telephone: 229-245-2491 Email: jrseverns@valdosta.edu
How Good Are Your Communica on Skills? Take a brief quiz to find out about your communica on style and how you rate on the communica on scale.
Mindtools: How Good Are Your Communica on Skills h p://www.mindtools.com/pages/ar cle/newCS_99.htm

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IT--BOR Mobile Device Policy

It is here! Cur s A. Carver Jr., Vice Chancellor/CIO recently an- nounced the implementa on of an official Informa on Technology (IT) Bring Your Own Device (BYOD) to work policy. ITS is also cur- rently in the process of providing training wireless network tutorials to USG staff on the using the new system.
The policy outlines standards and procedures for end users who are connec ng a personally-owned device to the University System of Georgia (USG) network for business purposes. The network in- cludes the 31 ins tu ons, the University System Office (USO) [which includes the Shared Services Center (SSC), the Georgia Public Library Service (GPLS), and the Georgia Archives.
The BYOD policy outlines the standards to empower USG staff to work on USG business more effec vely in- side and outside the office using a personally-owned device while protec ng the confiden ality, integrity, and availability of USG data.
Sec on 8.0 of USG Informa on Technology Handbook outlines the policy, h p://www.usg.edu/ informa on_technology_handbook/sec on8. Employees who decide to use their own personal device should:
1) obtain approval from their senior manager,
2) ensure their device is password /passcode protected,
3) maintain proper security for USG informa on by securing the device at all mes,
4) adhere to intellectual property rules and refrain from storing state-owned data on a personal de- vice, and
5) adhere to established USG security protocols and commit to maintaining the integrity of the USG opera ng system while using their personal device.
Employees are asked to complete, sign and submit an Employee Declara on confirming their commitment to the policy and par cipa on in the BYOD program.
For further informa on contact: USG IT Department Contact Informa on at ITS Helpdesk helpdesk@usg.edu or call 706-583-2000.

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IRS Report on Colleges and Universi es Compliance Project
By David Carson, Armstrong Atlan c State University

The IRS issued their final report on the Colleges and Universi es Compliance Project on April 25, 2013. The report is a mul -year project on tax-exempt colleges and universi es. The Project was launched in 2008 with the distribu on of ques onnaires to 400 randomly- selected colleges and universi es. The IRS received 344 responses to the ques onnaire that included 177 Private Ins tu ons and 167 Public ins tu ons.
The IRS has been reviewing the results of the ques onnaire over the past five years. They also selected 34 of the 400 ins tu ons for examina on. The 34 ins tu ons were selected based on their ques onnaire responses and because their tax repor ng indicated poten al noncompliance in the areas of unrelated business income and execu ve compensa on ("Colleges and Universi es Compliance Project Final Report" 2). While the compliance project and exams focused on many areas, a few are not applicable to our University System ins tu ons as they are public and do not file Form 990. However, USG ins tu ons are not exempt from income tax imposed on ac vi es that are substan ally unrelated to exempt purposes, called "Unrelated Business Income" or UBI, (USG BUSINESS Procedures Manual Sec on 23). Note: if applicable, our ins tu ons may be required to file Form 990-T.
Unrelated Business Taxable Income (UBTI)1 One issue that could poten ally affect all of our ins tu ons is Unrelated Business Taxable Income. During the exams, the IRS determined ins tu ons' were underrepor ng unrelated business taxable income (UBTI). Unrelated business income (UBI) is the income from a trade or business regularly conducted by an exempt organiza on and not substan ally related to its exempt purpose. The examina on of the 34 ins tu ons, which are nearly completed, resulted in;
Increases to UBTI for 90% of colleges and universi es examined totaling about $90 million;
Over 180 changes to the amounts of UBTI reported by colleges and universi es on Form 990-T; and
Disallowance of more than $170 million in losses and Net Opera ng Losses (NOL), which could

amount to more than $60 million in assessed taxes. ("Colleges and Universi es Compliance Project Final Report" 2).
The primary reasons for increases to UBTI in the completed exams were:
The IRS disallowed expenses that were not connected to unrelated business ac vi es: The IRS found that examined colleges and universi es were repor ng certain losses as connected to unrelated business ac vi es when they were not. The misrepor ng occurred in two ways: Lack of profit mo ve: The IRS found that organiza ons were claiming losses from ac vi es that did not qualify as a trade or business. Improper expense alloca on: The IRS also found that on nearly 60% of the Form 990- Ts examined had misallocated expenses to offset UBI for specific ac vi es. In many cases, the IRS found that claimed expenses, which generated losses, were not connected to the unrelated business ac vity.
Errors in computa on or substan a on: The IRS checked the calcula ons for all NOLs reported on returns under exam and found that NOLs were either improperly calculated or unsubstan ated on more than a third of returns. As a result, the IRS disallowed nearly $19 million in NOLs.
Reclassifying exempt ac vi es as unrelated: The IRS determined that nearly 40 percent of colleges and universi es examined had misclassified certain ac vi es as exempt or otherwise not reportable on Form 990-T. Fewer than 20 percent of these ac vi es generated a loss. The examina ons resulted in the reclassifica on of nearly $4 million in income as unrelated, subjec ng those ac vi es to tax. Expense deduc ons were disallowed on more than 60 percent of Form 990-Ts examined because they were based on improper alloca ons between exempt and unrelated business ac vi es

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("Colleges and Universi es Compliance Project Final Report" 3).
Examina ons resulted in more than 180 changes to UBTI reported for specific ac vi es by colleges and universi es. More than 30 different ac vi es were connected to the changes. The majority of these adjustments came from the following ac vi es ("Colleges and Universi es Compliance Project Final Report" 3): Fitness, recrea on centers and sports camps Adver sing Facility rentals Arenas, and Golf
The IRS also looked at employment tax returns at about a third of the colleges and universi es examined and found:
All of the completed exams have resulted in adjustments in wages leading to assessment of tax and, in some cases, penal es.
Wage adjustments total about $36 million, while taxes and penal es amount to over $7 million.
As a result, the IRS plans to look at UBI repor ng more broadly, especially at recurring losses and the alloca on of expenses, and to ensure, through educa on and examina ons, that tax-exempt organiza ons are aware of the importance of using appropriate comparability data when se ng compensa on.
Helpful advice with this new informa on: If you meet the requirements to submit Form 990-T, ensure it is being completed correctly and mely filed with the IRS, If the ins tu on doesn't have staff with the skills to prepare the 990-T, seek an outside exper se to assist, Have an independent review of how the Form 990-T is prepared (methodologies), If the Form 990-T is prepared in-house, have it independently reviewed before filing with the IRS, Ensure your employment tax returns are filed accurately.

David Carson Vice President for Business & Finance
Armstrong Atlan c State University Telephone: 912-344-2516
Email: david.carson@armstrong.edu
_______________________ 1 The unrelated business income tax applies to organiza ons that are exempt from income tax under sec on 501(a), which includes private colleges and universi es. Sec on 511(a)(2)(B) provides that the tax applies to any state college or university or any corpora on wholly owned by a state college or university. Reference: Internal Revenue Service, "Colleges and Universi es Compliance Project Final Report.", Internal Revenue Service Website, 2 May 2013.

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? DID YOU KNOW ? Annual College and University Procurement Officers Entity Spend
Report Due January 31st

A revision to the Georgia Procurement Manual, dated July 1, 2013, now requires all College and University Procurement Officers (CUPOs) to complete and submit an en ty spend report to State Purchasing by January 31st each year. The annual report instruc ons are very similar to the Compliance Self-Audit Course exam required for comple on by CUPOs. Other details about this required annual spend report are:
The report is required for CUPOs that are qualified for recer fica on.
CUPOs can complete the report at their office, on their computer.
The instruc ons for the Annual Spend Report are located in the State Purchasing Learning Management System (LMS) at: h p://doas.ga.gov/Training/Pages/Login.aspx.
CUPOs can obtain assistance from en ty staff to complete the report.

Other details about the annual spend report:
The report is comprised of the following analyses: Internal Controls Analysis (20% Extra Credit) Purchase Order (PO) Analysis (50%) Georgia Procurement Registry (GPR) Analysis (50%)
Each analysis is scored individually, but a combined total score of 80% from all the analyses must be achieved.
CUPOs will not be scored on their findings; they will be scored on how well they completed the steps and used the self-audit tools.
The State Purchasing Division Process Improvement Team has recently upda ng all of the self-audit tools published at: DOAS State Purchasing--Process & Performance [h p://doas.ga.gov/STATELOCAL/SPD/ process/pages/home.aspx.]
These tools are very important to a successful spend report. For ques ons regarding the annual spend report or self-audit tools, contact: DOAS Process Improvement Team, [processimprovement@doas.ga.gov].
Donna H. File, GCPA Audits and Training Director State Purchasing Division Phone: 404-651-9289 Email: Donna.File@doas.ga.gov

Reference Reading
Professional Aids Auditing : Concepts for a Changing Environment by Larry E. Rittenberg and Bradley J. Schwieger, 2004
Auditing: A Risk-Based Approach to Conducting a Quality Audit, Karla Johnstone and Audrey Gramling, 2013
Management Aids The Five Dysfunctions of A Team: A Leadership Fable by Patrick Lencioni, 2002
360 Degree Leader, John C. Maxwell, 2005

Board of Regents of the University System of Georgia
Office of Internal Audit & Compliance (OIAC) 270 Washington Street, SW Suite 7093 Atlanta, GA 30334-1450
Phone: (404) 962-3020
Fax: (404) 962-3033
Website: www.usg.edu/audit/

? Ask the Auditor ? If you have a governance, risk management, compliance or control ques on that has been challenging you, let us help you find the answer. Your ques on can help us to become be er auditors.
Want to Contribute to the Straight and Narrow? We invite you to send your ques ons and ideas for future ar cles to us for feature in upcoming Straight and Narrow newsle ers.
Contact Us: USG-OIACNewsle er@usg.edu
"Crea ng A More Educated Georgia" www.usg.edu