University of Missouri System University of Missouri – Kansas City Bloch School of Management April 2015 cc: Brian Burnett, Vice President for Finance and Chief Financial Officer, UM System Leo Morton, Chancellor, UMKC Sharon Lindenbaum, Vice Chancellor, Finance and Administration, UMKC Carol Hintz, Vice Chancellor, Human Resources, UMKC Bob Crutsinger, Director, Accounting Services, UMKC Mary Morgan, Manager III, Business Administration, Bloch School of Management, UMKC Table of Contents AUDIT REPORT .............................................................................................................................................2 EXECUTIVE SUMMARY .................................................................................................................................3 OBSERVATIONS, RECOMMENDATIONS AND MANAGEMENT RESPONSES Develop an action plan to improve the current financial state of the School. (H) .............................6 Strengthen internal controls over expenditures and review historical transactions for appropriateness. (H) ..............................................................................................................................7 Improve communication and alignment of key stakeholders within the School. (M) .......................9 Improve compliance with University and department procurement policies and travel and expense guidelines. (M) ........................................................................................................................11 Improve monitoring of international expenditures. (M)................................................................... 13 Evaluate tax implications of compensation for teaching courses within Executive Education. (L).......................................................................................................................................................... 14 Ensure proper segregation of duties during the cash receipts process. (L)...................................... 15 1 Confidential information for the sole benefit and use of the University of Missouri. Report To: David Donnelly, Dean, Bloch School of Management, UMKC Ryan Rapp, Controller, UM System We have completed certain internal audit procedures related to the Bloch School of Management at the University of Missouri – Kansas City. Our Services were performed and this report was developed in accordance with the March 31, 2014 addendum to the engagement letter dated November 25, 2013 and is subject to the terms and conditions included therein. Our work was performed through interview, observation and limited testing of selected controls. Our Services were performed in accordance with Standards for Consulting Services established by the American Institute of Certified Public Accountants. Accordingly, we are providing no opinion, attestation or other form of assurance with respect to our work and we did not verify or audit any information provided to us. Our work was limited to the specific procedures and analysis described herein and was based only on the information made available through December 19, 2014. Accordingly, changes in circumstances after this date could affect the findings outlined in this report. This information has been prepared solely for the use and benefit of, and pursuant to a client relationship exclusively with, the University of Missouri. PwC disclaims any contractual or other responsibility to others based on its use and, accordingly, this information may not be relied upon by anyone other than the University of Missouri. Very truly yours, St. Louis, Missouri April 1, 2015 2 Confidential information for the sole benefit and use of the University of Missouri. Executive Summary Background The Fiscal Year 2014 Internal Audit Plan was amended to include an assessment of the Henry W. Bloch School of Management (“Bloch School” or “School”) at the University of Missouri - Kansas City (“UMKC”). The purpose of the audit was to analyze the effectiveness and efficiency of the School’s operations and to assess compliance with University and School policies and procedures. The Bloch School’s mission is to develop purposeful, entrepreneurial and innovative leaders to meet changing global demands, and advance knowledge and practice through excellent teaching, scholarship, outreach, and service. The School is comprised of six academic departments, including Accountancy, Finance, Management, Marketing, Public Administration, and Global Entrepreneurship and Innovation. The School offers several degree programs, including Bachelor of Business Administration, Bachelor of Science in Accounting, Master of Business Administration, Executive Master of Business Administration, Master of Public Administration, Executive Master of Public Administration, Master of Science in Accounting, Master of Science in Finance and Master of Entrepreneurial Real Estate, Doctor of Entrepreneurship and Innovation, and Doctor of Public Affairs and Administration. The School advances student learning through five strategic centers and institutes: The Cookingham Institute of Urban Affairs, The Executive Education Center, The Regnier Institute for Entrepreneurship and Innovation (“IEI” or “Institute”), The Lewis White Real Estate Center, and The Midwest Center for Nonprofit Leadership. IEI is a nationally ranked program and leader in innovation, connecting students with a comprehensive combination of world-class research, renowned faculty, cutting-edge curriculum, and experiential programs driven to deliver results. The Institute’s mission is to inspire and nurture entrepreneurs and innovators through transformational education and research. The School’s enrollment has increased 21% in the past five years. As of Fall 2013, the School consisted of approximately 60 faculty who served approximately 1,800 students. The School has had an operational deficit for several years. Revenues from anticipated enrollment growth were to cover some of the increased compensation expenses for new faculty. However, faculty compensation expenses have grown faster than allocated enrollment revenues. As of June 30, 2014, the cumulative operational deficit (operating fund) was approximately $10.6 million. Revenues for Fiscal Year 2014 totaled approximately $19.4 million, which was comprised of $10.7 million in operations, $1.8 million in continuing education, and the remaining $6.9 million in gifts, grants and endowments (all funds). 3 Confidential information for the sole benefit and use of the University of Missouri. Objectives, Scope and Approach Our procedures focused on assessing the financial internal controls and related business processes in the School. We also assessed compliance with selected University and School policies and procedures. Internal Audit (“IA”) utilized a risk-based approach to accomplish the project objectives within the defined scope. Through inquiry of management and performance of selected testing procedures, IA accomplished the following objectives: Scope Areas o o Summary Results Financial and Operational Areas Understand and analyze processes and internal controls utilized by the Bloch School and each of its departments in the following areas: Monitoring of financial activity, Procurement and expenditures, including travel expenditures, Payroll, including additional pay, Revenue, cash receipts, receivables and transfers, Restricted gift funds, Sponsored research funds and time commitments/reporting, and Records management. Other Provide recommendations to be considered by management for process improvements and/or changes to policies/procedures. See observation 1 and 2. See observation 4. See observation 6. See observation 7. No items noted. No items noted. No items noted. See observations 3 and 5. 4 Confidential information for the sole benefit and use of the University of Missouri. Key Observations 1. 2. 3. 4. 5. Description Risk The School has had an operational deficit throughout the entire scope period of the audit. The School, along with campus leadership have made historical decisions to invest in and build the School’s national and global brand. These decisions have contributed to the increase in School expenditures and the resulting deficit. Developing a formalized and defined action plan that balances growth, strategic investments and fiscal responsibility, the School can implement measures to decrease expenditures or increase revenues to improve their ending balance. High Recent improvements have been made in the School’s expenditure review and approval processes. However, the historical internal controls environment presented opportunity for inappropriate or unauthorized expenses to be incurred as an important control to review and approve expenditures was overridden by management. High Greater transparency is needed throughout Bloch relating to financial decisions, strategic investments, allocations and overall strategy. While some improvements have been made recently including enhanced communication and analysis in these areas, key stakeholders, including chairs of departments, within the School indicated a lack of alignment with regards to the strategic direction of the School. Medium Compliance with University and department procurement policies and travel and expense (“T&E”) guidelines should be improved. Instances were identified where purchases did not adhere to purchasing card usage policies, preferred method of payment guidelines, and T&E guidelines. By enforcing compliance with University and department policies and guidelines, the risk of unauthorized purchases is reduced and cost savings can be realized. Medium Several School faculty and staff regularly travel abroad for School operations. The School also contracts with an external consultant to recruit students and develop relationships in Asia. The controls in place to review international related expenditures should be enhanced through greater consideration of any applicable laws and regulations. Medium 5 Confidential information for the sole benefit and use of the University of Missouri. Observations, Recommendations, and Management Responses The management responses and any expected action dates have been reviewed by University of Missouri System management to ensure they sufficiently address the issue(s) noted. Internal Audit has not performed additional procedures to test items management has indicated as complete as of the report date. At the request of University of Missouri System management, we have assigned ratings to the various observations and recommendations in our report. The ratings are based on the risk and potential impact on business operations each particular item presents if not addressed by management. These ratings are “H” for high risk and impact, “M” for medium, and “L” for low. Observation 1: Develop an action plan to improve the current financial state of the School. (H) Recommendations to Management Description The School has had an operational deficit throughout the entire scope period of the audit. At the end of Fiscal Year 2014 the operational deficit totaled $10,594,594, up from $1,510,343 in 2009. The School, along with campus leadership has made historical decisions to invest in and build the Bloch School of Management’s national and global brand. These decisions are a primary factor in the increase in School expenditures and resulting deficit. Bloch management indicates expenditure decisions were made with regard to the longer-term stature of the School, including adding higher salaried professors. Under the budget model, which allows academic units to keep their net tuition (based in part on historical enrollment), revenues from anticipated enrollment growth were to cover some of the increased compensation expenses for new faculty. However, faculty compensation expenses have grown faster than allocated enrollment revenues. In addition, the budget model requires academic units to cover their support costs which have increased due to the growth the School has experienced. This deficit is in the operational fund and does not reflect gifts or endowments or other funds. By developing a formalized and defined action plan that balances growth, strategic investments and fiscal responsibility, the School can implement measures to decrease expenditures or increase revenues to improve their ending balance. Bloch leadership and campus central administration should continue their efforts to evaluate the School’s financial activities and establish a plan to resolve the operational deficit. This plan should include multiple methods of improving the financial health, including analysis of existing and new revenue streams as well as plans to better manage and reduce expenditures in all areas of the School. Management should also consider budgeting revenues and expenditures at a more granular level to allow for better monitoring of actual activity to budgeted balances. Along with campus central administration, Management should perform ongoing review of the business plan to verify progress is being made and determine if any updates are necessary. Management Response: Prior to the commencement of the audit, the Bloch School management was already focused on plans to improve performance. That work has started and will continue until the financial situation is resolved. Working with the central administration, a plan will be developed that reviews revenues and expenses with a focus on growing revenues and appropriately managing expenses. Operating performance will be improved and ultimately the deficit will be resolved. The plan will be monitored on a semi-annual basis and will be updated as needed. Changes have already been made with respect to fiscal reporting and additional central fiscal resources have been provided to assist in preparing budgets and forecasts, as well as monitoring performance. Due Date: July 31, 2015 Responsible Party: Dean, Bloch School of Management 6 Confidential information for the sole benefit and use of the University of Missouri. Observation 2: Strengthen internal controls over expenditures and review historical transactions for appropriateness. (H) Description Recent improvements have been made in the School’s expenditure review and approval processes; however, there were instances where the key control for reviewing and approving departmental expenditures was overridden by management. This type of override is an indicator of an improper “tone at the top” on internal controls. This created the opportunity for inappropriate or unauthorized expenses to be incurred and charged to general funds as well as private gift and endowment sources. Management has taken actions to improve the internal control environment and is developing a plan to perform a review of historical expenditures to ensure only appropriate expenses were incurred and those that were incurred are classified correctly. Additionally, as part of expenditure testing the following observations were identified: Travel and Expense Five expense reimbursements (totaling $39,160) occurring during Fiscal Year 2012 related to research services performed by consultants were paid personally and reimbursed, as opposed to establishing a contract with the third party and paying via Non-PO voucher. IA was unable to validate the legitimacy of these transactions based on information available in University records. The consultants did not have a current contract with the School and the preferred method of purchase guidelines were not followed. Per interviews, the work related to collecting research data, which is consistent with University work and external endeavors. Per UMKC and UM System guidelines, payments to a consultant totaling more than $500 require a current contract or consulting agreement to be in place. Additionally, UM System preferred method of purchase guidelines specify that consulting fees should be paid through a Non-PO voucher. In 14 business meals (totaling $1,690), the number of guests listed on the receipt did not agree to the number of attendees in the documentation submitted for reimbursement. The meal receipts typically indicated there were one or two more individuals present at the meal than what was documented for reimbursement purposes. Four T&E transactions (totaling $823) and one non-PO voucher ($179) has receipts provided that were not itemized when they should have been. Three of the above five transactions that did not include an itemized receipt occurred in Fiscal Year 2012 and two occurred in Fiscal Year 2013. Per T&E guidelines, itemized receipts are required for any expense incurred when the employee is not in travel status, regardless of the amount and for all expenses $75 or more. Per Business Policy Manual (BPM) 505, itemized receipts are required to be attached to the expense report for all expenditures $75 or more. Recommendations to Management Perform a review of the spend activity which could have been inappropriately influenced by management. This review should consider the historical review and approval environment within the School and University policies and procedures. Spend activity to include in this review should include travel and expense activity, extra compensation paid to UMKC staff and faculty, or any other resources which could have been inappropriately directed based on the internal controls environment. Performing a review of these transactions will help the University identify inappropriate, unreasonable or out of compliance transactions. 7 Confidential information for the sole benefit and use of the University of Missouri. Continued from previous page Observation 2: Strengthen internal controls over expenditures and review historical transactions for appropriateness. (H) Additional compensation Two faculty members were paid additional compensation that was processed based on documentation that could not be reconciled to supporting records. Management Response: An internal review of historical transactions has already occurred. The School has implemented steps to ensure compliance with University expenditure and approval policies. The steps include additional training for staff and administrators responsible for ensuring proper approval of expenditures; special training and increased review of transactions identified through the internal review as most problematic; administrative changes in areas most prone to non-compliance; and the implementation of a strict policy of rules enforcement. The Bloch School is committed to ensuring that the tone at the top is unequivocal in its support for a strong internal control environment and adherence to all policies. Due Date: Complete Responsible Party: Dean and Fiscal Officer, Bloch School of Management 8 Confidential information for the sole benefit and use of the University of Missouri. Observation 3: Improve communication and alignment of key stakeholders within the School. (M) Recommendations to Management Description Greater transparency is needed throughout Bloch relating to financial decisions, strategic investments, allocations and overall strategy. While some improvements have been made recently including enhanced communication and analysis in these areas, key stakeholders, including chairs of departments, within the School indicated a lack of alignment with regards to the strategic direction of the School. This has led to a divided environment in which some stakeholders do not fully understand the rationale of key financial investments. Throughout fieldwork, it became apparent there is a divide between several units within the School and IEI. Per inquiry of multiple faculty members and the Business Office, “Core Bloch” (i.e., Accountancy, Management, Public Affairs, Business Administration, Finance, etc.) personnel do not always understand and sometimes question the investments that have been made in IEI and whether or not they have produced an adequate return. The environment exists largely due to increased investments and expenditures relating to IEI. The divide within Bloch has created a morale issue in which some units do not feel they are being treated equally. Enhancing lines of communication and alignment of key stakeholders throughout Bloch and with campus central administration and ensuring strategic investments are accomplishing established objectives will allow for an improved understanding of the School’s strategic initiatives and investments. Further, it will facilitate better transparency into School financials. Implement processes to improve communication and alignment of key stakeholders within Bloch and UMKC. Senior level Bloch leadership (e.g., Dean, Assistant Deans and Department Chairs) should be included in the development and implementation of the Business Plan recommended in observation #1. Additionally, implement new and continue current processes to improve transparency within the School, such as: Periodic meetings, in which Department Chair’s and Directors are present, to discuss major financial decisions, investments and allocations throughout the entire Bloch School. Increased collaboration across units within Bloch concerning strategic decisions. Include campus central administration in strategic and financial discussions with Bloch leadership. Enhance current and implement new processes to measure return on strategic investments throughout the School. Management Response: The Bloch School management recognizes the importance of key stakeholders being involved in setting the strategy of the school. Communication and transparency with key stakeholders is critical as the School moves forward. Examples of recent activities are noted below: The Strategic Planning Committee of the Bloch School has decided it is time to perform an in-depth review of the current strategic plan and has developed a timeline in which to perform this review. As with the past plans there will be a comprehensive process of faculty, staff and external stakeholder involvement. The updated plan will be widely shared. 9 Confidential information for the sole benefit and use of the University of Missouri. Continued from previous page Observation 3: Improve communication and alignment of key stakeholders within the School. (M) This year a Balanced Scorecard approach was implemented with respect to measuring the performance of key strategic initiatives. The scorecard allows for evaluation and communication, as well as guiding internal activities in support of the strategies. In an effort to enhance transparency the Dean presented a detailed financial review of the school’s budget to the faculty. This will continue. The Bloch School’s Resource and Planning Committee serves as a communication link between the leadership and the faculty with respect to budget issues. Their work will continue. Special attention has been given to the improving the transparency and visibility related to the Institute for Entrepreneurship and Innovation. The new Director has improved communication with the rest of the Bloch School and the Institute’s academic activities are more integrated with the rest of the Bloch School. The Department Chairs and Direct reports now meet with the Dean on a monthly basis unless more frequent meetings are needed. The Dean also has regular meetings with central administration to review financial and budget activities. Due Date: Complete Responsible Party: Dean and Faculty, Bloch School of Management 10 Confidential information for the sole benefit and use of the University of Missouri. Observation 4: Improve compliance with University and department procurement policies and travel and expense guidelines. (M) Recommendations to Management Description Compliance with University and department procurement policies and travel and expense (“T&E”) guidelines should be improved. Instances were identified where purchases did not adhere to purchasing card (“p-card”) usage policies, and T&E guidelines. By enforcing compliance with University and department policies and guidelines, the risk of unauthorized purchases is reduced and cost savings can be realized. Insufficient Documentation Eight T&E transactions (totaling $312) and one Non-PO Voucher (totaling $123) did not have a receipt provided to validate that the items purchased were allowable. Eight of the nine transactions occurred in Fiscal Year 2013 or prior. Additionally, one T&E transaction (totaling $110) did not include an itemized receipt. This transaction occurred in Fiscal Year 2013. Per T&E guidelines, itemized receipts are required for any expense incurred when the employee is not in travel status, regardless of the amount and for all expenses $75 or more. Per Business Policy Manual (BPM) 505, itemized receipts are required to be attached to the expense report for all expenditures $75 or more. The gift card logs for two gift card transactions occurring in Fiscal Year 2014 (totaling $534) were not properly completed to evidence disbursement of the gift cards to the correct recipient. The logs provided for the transactions were not signed by the gift card recipients. Per Bloch School policy, a gift card log should be completed for each gift card purchase. The log should be signed by the gift card recipient to indicate the gift card was used for its intended purpose and to verify the individual actually received the gift card. One p-card transaction that occurred in Fiscal Year 2012 ($2,601) did not include technology approval prior to the purchase. Per Bloch School policy, technology approval should be obtained prior to purchasing a large technology item. Improve compliance with procurement policies and T&E guidelines by educating individuals throughout the School. Ensure education provides information on documentation requirements, allowability of using other individuals’ p-cards, and allowability of purchases to be reimbursed through the T&E system. For T&E reimbursements, ensure approvers are educated on the policies and procedures for allowability and documentation requirements within the system, as well. Allowability One p-card transaction that occurred in Fiscal Year 2012 ($315) related to an individual using someone else’s p-card. Per the Purchasing Card Policy Manual section 2.9, the only person authorized to use the p-card is the cardholder whose name appears on the face of the card. 11 Confidential information for the sole benefit and use of the University of Missouri. Continued from previous page Observation 4: Improve compliance with University and department procurement policies and travel and expense guidelines. (M) One T&E transaction that occurred in Fiscal Year 2013 ($141) related to a business dinner that included the purchase of alcohol. No additional documentation was provided as to the business purpose of the alcohol. Per BPM 217, a statement explaining how the expenditure that includes the alcohol benefits the University must be shown on each transaction that requests payment of, or reimbursement for, alcoholic beverages. Management Response: Compliance with procurement policies and travel and expense guidelines is very important and the Bloch School leadership has already committed to improvement. An internal review was conducted and the School implemented the following: Additional training for staff and administrators responsible for ensuring proper approval of expenditures, Special training and increased review of transactions identified through the internal review as most problematic, Administrative changes in areas most prone to non-compliance, and The implementation of a strict policy of rules enforcement. The Bloch School is committed to ensuring that the tone at the top is unequivocal in its support for a strong internal control environment and adherence to all policies. Due Date: Complete Responsible Party: Dean and Fiscal Officer, Bloch School of Management 12 Confidential information for the sole benefit and use of the University of Missouri. Observation 5: Improve monitoring of international expenditures (M) Recommendations to Management Description Several School faculty and staff regularly travel abroad for School operations. The School also contracts with an external consultant to recruit students and develop relationships in Asia. UMKC paid the consultant approximately $360,000 during Fiscal Years 2012 – 2014 for services related to recruitment of students and the furthering of UMKC’s relationships with international Universities. The controls in place to review international related expenditures for employees and the external consultant should be enhanced through greater consideration of applicable laws and regulations. Perform an assessment of applicable laws and regulations which may impact the UMKC employees or contractors performing work internationally and identify any training necessary for these employees. Implement enhancements to policies and internal controls to help ensure compliance as necessary. Management Response: The UM System Office of Finance will work with the campuses to assess current policies and training related to international expenditures and address any deficiencies as necessary. Due Date: December 31, 2015 Responsible Party: UM System Controller 13 Confidential information for the sole benefit and use of the University of Missouri. Observation 6: Evaluate tax implications of compensation for teaching courses within Executive Education. (L) Description Recommendations to Management The compensation process for teaching Executive Education sessions within the Bloch School should be evaluated. Executive Education offers custom corporate, open enrollment, networking and certificate programs. Faculty members, from various disciplines, develop materials for these courses, lead the sessions and then are compensated for their efforts. Instructors have the option to receive pay as additional compensation (i.e., in excess of their base salary) or to transfer the money to their faculty support account. Providing this option may constitute earned income and these funds would then be considered taxable compensation, regardless of the faculty election. Evaluate tax implications related to compensation for teaching sessions within Executive Education moving forward. Communicate with the appropriate UMKC and UM System personnel to verify funds transferred to faculty accounts are appropriately taxed in accordance with federal tax regulations. If a faculty member elects to receive additional compensation for their efforts related to leading an Executive Education session, the compensation is processed via payroll and is appropriately taxed. However, when a faculty member elects to transfer funds to their support account, funds are not taxed. In the past five fiscal years, faculty members have elected to transfer approximately $45,500 to respective faculty support accounts. These funds have not been taxed as compensation. This could create individual and university liability for their share of taxes. By evaluating the tax implications of compensation for teaching Executive Education courses, Management can help ensure compensation is being appropriately taxed. Management Response: The University has procedures in place surrounding the taxability of these types of arrangements. This specific instance will be reviewed by the Central Payroll Office and Campus HR. Due Date: July 1, 2015 Responsible Party: UM System Controller 14 Confidential information for the sole benefit and use of the University of Missouri. Observation 7: Ensure proper segregation of duties during the cash receipts process. (L) Description Recommendations to Management Cash receipts within the School have the opportunity to be reconciled by the same individual that deposits the receipts. Per Accounting Policy Manual section 2.25.55, no one person should have responsibility to complete two or more major functions, including authorization, recording, verification, custody of assets, and managerial review. Implement proper segregation of duties by ensuring deposit and reconciliation procedures within the cash receipts process are split between different individuals in the School. The student worker for the School’s Business Office or one of the office staff share responsibility for depositing cash receipts. The work study is also who performs reconciliation procedures for cash receipts. Segregating deposit and reconciliation procedures in the process will better safeguard University assets and help ensure improved compliance with the University policy. Management Response: While the finding does not disclose a direct policy violation it does identify an opportunity whereby internal controls can be strengthened through better segregation of duties. Changes have been made whereby responsibilities are now divided so that no one individual perform duties that are in conflict. Due Date: Complete Responsible Party: Dean and Fiscal Officer, Bloch School of Management 15 Confidential information for the sole benefit and use of the University of Missouri.