FISCAL YEAR 2015 INTERNAL AUDIT ANNUAL REPORT Andrew S. Groover, M.Ed., CPA, CIA, CICA, CISA, CFE Director of Internal Audits October 23, 2015 TEXAS WOMAN’S UNIVERSITY OFFICE OF INTERNAL AUDITS TEXAS WOMAN'S UNIVERSITY MEMBERS OF THE BOARD OF REGENTS Mary Pincoffs Wilson, Chair and Presiding Officer Anna Maria Farias, Esq., Vice Chair and Assistant Presiding Officer Debbie Gibson Vic Lattimore Ann Scanlon McGinity, Ph.D. Nancy Painter Paup Nolan E. Perez, M.D. George R. Schrader Melissa D. Tonn, M.D. Neftali Gomez (Student Regent) CHANCELLOR AND PRESIDENT Dr. Carine Feyten, Ph.D. OFFICE OF INTERNAL AUDITS Andrew S. Groover, M.Ed., CPA, CIA, CICA, CISA, CFE Director of Internal Audits Roy Mak, CIA, CISA, CICA Assistant Director of Internal Audits Maria D. Marroquin, CFE Staff Auditor TEXAS WOMAN’S UNIVERSITY OFFICE OF INTERNAL AUDITS TABLE OF CONTENTS I. Compliance with Texas Government Code, Section 2102.015: Posting the Internal Audit Plan, Internal Audit Annual Report, and Other Audit Information on Internet Web site .............................................................................................. 1-7 II. Compliance with the Benefits Proportionality Audit Requirements for Higher Education Institutions ....................................................................................... 7-8 III. Internal Audit Plan for Fiscal Year 2015 .................................................................. 8 IV. Consulting Services and Non-Audit Services Completed........................................ 8 V. External Quality Assurance Review ................................................................... 8-12 VI. Internal Audit Plan for Fiscal Year 2016 ........................................................... 13-14 VII. External Audit Services Procured in Fiscal Year 2015 .......................................... 14 VIII. Reporting Suspected Fraud and Abuse ................................................................ 15 October 23, 2015 Members of the Board of Regents, Texas Woman's University Dr. Carine Feyten, Chancellor and President, Texas Woman's University Kara Belew, Governor’s Office of Budget, Planning, and Policy Ed Osner, Legislative Budget Board Internal Audit Coordinator, State Auditor’s Office Ken Levine, Sunset Advisory Commission A report on the activity of Texas Woman's University's Office of Internal Audits for fiscal year 2015 follows. This report fulfills the requirements of Texas Government Code (Texas Internal Auditing Act), Sections 2102.009 and 2102.0091. The report provides information on the audit plan, audits completed, external quality assurance review, and other internal auditing activities. For further information about the contents of this report, please contact our Office at 940-898-3260 or by email at agroover@twu.edu. Andrew S. Groover, M.Ed., CPA, CIA, CICA, CISA, CFE Director of Internal Audits Internal Audit Annual Report for Fiscal Year 2015 I. Compliance with Texas Government Code, Section 2102.015: Posting the Internal Audit Plan, Internal Audit Annual Report, and Other Audit Information on Internet Web site The Office of Internal Audits has posted the Fiscal Year 2016 approved audit plan and the Fiscal Year 2015 Internal Audit Annual Report on the Office of Internal Audits website http://www.twu.edu/internal-audits/. The following provides a detailed summary of deficiencies related to the Fiscal Year 2015 Audit Plan and the current implementation status of the recommendations. Quarterly updates can be obtained by reviewing the quarterly Finance and Audit Committee agenda at http://www.twu.edu/regents/broadcast.asp. Details are located within the agendas under report item “Quarterly Status Report of the Office of Internal Audits”. Audit Number 15-01 15-02 Audit Name JAMP (Joint Admissions Medical Program) Institutional Research and Data Management Audit Report Date Follow-up Audit Report Date* 9/22/2014 N/A 12/5/2014 7/13/2015 Recommendation(s) NONE 1. IRDM should provide a feedback mechanism for data requesters to determine satisfaction levels. 2. Compliance with TWU Policy 3.30 Staff Employee Performance Management and Evaluations should be improved. 3. Compliance with TWU Policy 3.45 – Training and Development should be improved. 4. IRDM should ensure that job descriptions are reviewed and updated as prescribed by Human Resources. 5. IRDM should ensure that the official TWU academic degree inventory agree with Page 1 Status Comments N/A Responsible Party N/A I S Dr. Robert Neely I Follow-up audit completed. Dr. Michael Stankey Dr. Mark Hamner S I Internal Audit Annual Report for Fiscal Year 2015 the degree inventory listed in the Texas Higher Education Coordinating Board website. 1. The IT Strategic Plan should be enhanced to include specific actions and measurable performance metrics. 15-03 15-04 Information Technology Governance Fitness and Recreation 1/15/2015 1/28/2015 8/27/2015 9/23/2015 Follow-up audit completed. N 1. Management should ensure that Release Forms are obtained from all persons who agree to be included in marketing materials. 2. Management should revise the current application for student employment to exclude questions related to citizenship status. 3. Compliance with TWU’s Procurement Card Guidelines should be improved. 4. Compliance with the TWU Cash Receipts Policy and the TWU Credit Card Acceptance and Security Policy Page 2 The Office of Technology is currently awaiting the completion of the TWU Strategic Plan to ensure that the updated Office of Technology Strategic Plan is properly aligned. Once the TWU Strategic Plan is completed in the Fall of 2016, the Office of Technology Strategic Plan will be updated. Dr. Robert Neely Dr. Robert Placido I Dr. Monica MendezGrant I I S Follow-up audit complete. Dr. Heather Speed Michelle Reeves Karrie Fletcher Internal Audit Annual Report for Fiscal Year 2015 should be improved. 5. Compliance with TWU Policy 2.28 Procedures for Student Travel & OffCampus Activities should be improved. 6. Management should work with DPS to ensure the functionality of the panic button at the front desk of the Fitness and Recreation center. 7. Management should work with Property Control to ensure all capital and controlled assets are properly tagged. Also, management should ensure Property Transfer forms are completed when capital or controlled assets are transferred to another department. 8. Compliance with TWU Policy 3.45 – Training and Development should be improved. 9. Management should ensure that swipe card access listings are periodically reviewed to ensure appropriate access. 10. Management should change the combination to the safe when there is turnover in positions that require entry to the safe. 11. Management should formalize the reconciliation process for Fitness and Recreation budget accounts. 12. Management should ensure that job descriptions are reviewed and updated as prescribed by Human Resources. 13. Compliance with TWU Policy 7.01 – Access Key Control should be improved. Page 3 I I I S I I I I I Internal Audit Annual Report for Fiscal Year 2015 15-05 15-06 15-07 Clery Act Research Grants Marketing and Communication 3/24/2015 3/26/2015 5/7/2015 10/8/2015 N/A 14. Access to the TWU Fitness and Recreation Twitter account should be immediately revoked when employees with access are terminated. 1. Management should publicize its emergency response and evacuation procedures in conjunction with at least one test per calendar year to enhance compliance with 34 CFR 668.46 (g) (6) (ii). NONE 1. Management should ensure that Release Forms are obtained from all persons who agree to be included in marketing materials. Also, management should develop and communicate guidelines for the University related to the process and requirements for Release Forms. 2. Management should formalize the reconciliation process for Marketing and Communication budget accounts. 3. Management should comply with TWU Policy 3.30 – Staff Employee Performance Management and Evaluations. 4. Data should be backed up on the network drive to ensure continuity. 5. Access to TWU Marketing and Communication web based applications should be periodically reviewed to ensure appropriate access. Page 4 I I Follow-up completed. N/A B.J. Crain Elizabeth Pauley N/A Estimated follow-up audit start date – December 2015 Cindy Pollard Amanda Simpson Yolanda Franklin Internal Audit Annual Report for Fiscal Year 2015 6. Management should ensure that job descriptions are reviewed and updated as prescribed by Human Resources. 7. Management should comply with TWU Policy 7.01 – Access Key Control. 15-09 College of Nursing 7/16/2015 8. Management should develop a process to ensure former employees assignments are terminated timely. 9. Management should comply with TWU’s Procurement Card Guidelines. 10. Management should ensure all hyperlinks and information on the website are kept current. 1. Compliance with the TWU Cash Receipts Policy should be improved. 2. Compliance with TWU’s Procurement Card Guidelines should be improved. 3. Compliance with TWU Policy 3.45 – Training and Development should be improved. 4. Swipe card access listings should be periodically reviewed to ensure appropriate access. 5. The reconciliation process for College of Nursing budget accounts should be formalized. 6. Job descriptions should be reviewed and updated as prescribed by Human Resources. 7. Compliance with TWU Policy 7.01 – Access Key Control should be improved. 8. Access to Group One and SurScan accounts should be immediately revoked when employees with access are Page 5 Estimated follow-up audit start date – January 2016 Dr. Robert Neely Dr. Anita Hufft Internal Audit Annual Report for Fiscal Year 2015 15-10 15-11 Graduate School Tuition and Fees 6/12/2015 9/18/2015 terminated. 9. All hyperlinks and information on the website should be kept current. 10.Compliance with TWU Policy 9.09 – Authentication should be improved. 11.Data should be backed up on the network drive to ensure continuity. Also, the College of Nursing network drive access listing should be periodically reviewed to ensure appropriate access. 12.Compliance with TWU Policy 2.17 Centers or Institute Policy & Guidelines should be improved. 13.Compliance with the requirements for Faculty Annual Performance Review as stated in the Faculty Handbook should be improved. 14.Compliance with TWU Policy 3.30 – Staff Employee Performance Management and Evaluations should be improved. 1. Compliance with the TWU Cash Receipts Policy should be improved. 2. Job descriptions should be reviewed and updated as prescribed by Human Resources. 3. All hyperlinks and information on the website should be kept current. 4. The Graduate School network drive access listing should be periodically reviewed to ensure appropriate access. 1. Management should ensure that access to the tuition and fees rate tables in Colleague is appropriate. 2. Management should ensure that access to modify Page 6 Estimated follow-up audit start date – December 2015 Dr. Robert Neely Dr. Larry LeFlore B.J. Crain Estimated follow-up audit start date – March 2016 Pam Wilson Carolyn Whitlock Glen Ray Annie Philips Internal Audit Annual Report for Fiscal Year 2015 tuition exemptions in Colleague is appropriate. 3. Compliance with Texas Education Code section 54.501 – Laboratory Fees related to Lab Fees for Biology should be improved. Also, the Lab Fees Instruction Kinesiology account should be corrected. 4. Compliance with Texas Education Code 54, section 54.5132 – International Education Fee should be improved. I - Implemented - Recommendation is implemented and in place. S- Substantially Implemented - Recommendation is near completion with most aspects in place. P - Partially Implemented - Recommendation is in the initial stages with some aspects in place. N - Not Implemented - No action taken by management. II. Compliance with the Benefits Proportionality Audit Requirements for Higher Education Institutions In compliance with Rider 8, page III-39, General Appropriations Act (84th Legislature, Conference Committee Report), the Office of Internal Audits will conduct and complete an audit of Benefits Paid Proportional By Fund by August 31, 2016. We will utilize the methodology approved by the State Auditors’ Office which is as follows: 1. Ensuring that (a) payments for benefits that are paid from appropriated funds are made proportionately from the same source as the related salaries and (b) salaries paid from General Revenue funds are related to positions authorized for General Revenue funds. 2. Reviewing salary expense transfers and refunds of expenditure transactions to verify that, if the higher education institution reduced salary expenditures from General Revenue, it also made a corresponding reduction in benefit expenditures from General Revenue. 3. Disclosing in the audit report (a) the aggregate dollar amount of all instances of noncompliance with the proportionality requirements identified during the audit, regardless of materiality, and (b) the status of any resulting reimbursement payments to the Comptroller of Public Accounts. As required by the State Auditors’ Office, we will include in the audit report a statement certifying that the audit incorporated the methodology prescribed by the SAO. Page 7 Internal Audit Annual Report for Fiscal Year 2015 In response to Governor Perry’s letter dated May 29, 2014 requesting that internal auditors for higher education institutions conduct work to determine whether “proportionality is being applied according to the established guidelines”, the Office of Internal Audits conducted an audit of Benefits Paid Proportional By Fund (Report #1410, dated November 14, 2014). The audit scope covered fiscal years 2011, 2012, and 2013. The Office of Internal Audits certifies that the work performed included the above State Auditors Office approved methodology for all three fiscal years. III. Internal Audit Plan for Fiscal Year 2015 Report Number 15-01 15-02 15-03 15-04 15-05 15-06 15-07 15-08 15-09 15-10 15-11 15-12 Report Date 9/22/2014 12/5/2014 1/15/2015 1/28/2015 3/24/15 3/26/2015 5/8/2015 9/9/2015 7/16/2015 6/12/2015 9/18/2015 N/A Report Title Complete JAMP (Joint Admissions Medical Program) Institutional Research and Data Management Information Technology Governance Fitness and Recreation Clery Act Research Grants Marketing and Communication Texas Administrative Code 202 (TAC 202) College of Nursing Graduate School Tuition and Fees Career Services Y Y Y Y Y Y Y Y Y Y Y Draft Report Stage The following are deviations from the FY 2015 audit plan. Colleague – Not completed due to time constraints. This area is included in FY 2016 audit plan. Intercultural Services – Not completed due to the restructure of the area. The area was renamed Diversity, Inclusion, and Outreach and includes International Education and the Terry Scholar Program. Diversity, Inclusion, and Outreach is included in the FY 2016 audit plan. Career Services – Audit conducted in place of Intercultural Services. IV. Consulting Services and Non-audit Services Completed No consulting services or non-audit services were performed or completed during fiscal year 2015. V. External Quality Assurance Review (Peer Review) SEE PAGES BELOW Page 8 Internal Audit Annual Report for Fiscal Year 2015 Page 9 Internal Audit Annual Report for Fiscal Year 2015 Page 10 Internal Audit Annual Report for Fiscal Year 2015 Page 11 Internal Audit Annual Report for Fiscal Year 2015 Page 12 Internal Audit Annual Report for Fiscal Year 2015 VI. Internal Audit Plan for Fiscal Year 2016 The fiscal year 2016 audit plan was prepared using risk assessment techniques that identify the individual audits to be conducted during the year. The risk factors included: - Years since last audit - Statutory Requirements/Government Regulations - Loss/Litigation potential - Materiality/Size - Cost savings/Revenue potential - Prior recommendations - Multiple campus locations - Complexity/Changes/Technology - Visibility/Public Image - Other concerns The audits were chosen from high, medium and low risk areas, with greater emphasis given to the higher risk areas. This allows for broad audit coverage of campus areas, while concentrating on areas of higher risk. As a result, the following 13 areas were chosen for audit and approved by the TWU Board of Regents on August 14, 2015. Assistant Director Director 50 325 45 0 150 0 40 0 45 300 45 300 40 0 40 0 300 10 40 250 35 225 35 0 200 10 Audit Colleague Property & Surplus Benefits Paid Proportional By Fund Ethics Program Investments (Public Funds Investment Act) Scholarships Academic College, School or Department Diversity, Inclusion, and Outreach Office of Student Life Office of Academic Affairs and Provost Office of Enrollment Services Budget Office Facilities Development Projects Annual internal audit report Internal quality assurance Follow-up audits Investment Reports Review Special Projects Administrative Professional Development Holidays Vacation Sick Leave TOTAL Page 13 Staff Auditor 0 300 150 250 0 0 250 250 0 0 0 225 0 Total 375 345 300 290 345 345 290 290 310 290 260 260 210 1065 1420 1425 3910 40 150 150 5 100 162 40 112 156 100 0 5 125 0 100 46 40 112 132 100 0 5 125 35 100 30 40 112 108 100 40 160 400 40 300 238 120 336 396 300 1015 660 655 2330 2080 2080 2080 6240 Internal Audit Annual Report for Fiscal Year 2015 Risk areas ranked as “high” but not scheduled to be audited during fiscal year 2016. Cash & Cash Receipts Oracle – Human Resources module Environmental Safety & Health Oracle – Financial module Athletics Procurement Cards Red Flags Rule (FTC) Travel Bonds Construction Payroll PCI/DSS Public Safety (Police) Purchasing/Cash Disbursements/Accounts Payable Telecommunications TAC 202 Accounts Receivable Admissions Admissions Processing Automotive Services Building Maintenance Financial Aid Information Technology Governance Lab Safety Multihazard Emergency Operations Plan Safety and Security Research Grants Student Health Services Teaching & Learning with Technology There are no audits in the Fiscal Year 2016 Audit Plan that address expenditure transfers, capital budget controls, or any other limitation or restriction in the General Appropriations Act. There are also no audits in the Fiscal Year 2016 Audit Plan that address contract management and other requirements of Senate Bill 20 (84th Legislature). We will consider these in future audit plans. However, we do plan on including the contract management requirement of Senate Bill 20 in the Fiscal Year 2017 Audit Plan. Texas Administrative Code 202 was audited as part of the Fiscal Year 2015 Audit Plan. Routine audits of Texas Administrative Code 202 will be conducted as required by statute. VII. External Audit Services Procured in Fiscal Year 2015 No external audit services were procured during fiscal year 2015. Page 14 Internal Audit Annual Report for Fiscal Year 2015 VIII. Reporting Suspected Fraud and Abuse Actions taken to implement the requirements of: Fraud Reporting. Article IX, Section 7.09, page IX-37. Fraud Reporting, General Appropriations Act (84th Legislature, Conference Committee Report). TWU has placed a link on the TWU homepage that states “Report Fraud, Waste, or Abuse in Texas”. This link takes the user directly to the State Auditor’s Office webpage for reporting fraud, waste, and abuse. The Office of Internal Audits has also paced the same link on its webpage. TWU has also incorporated into its “Fraud and Fraudulent Activities” policy information on how to report suspected fraud involving state funds to the State Auditor’s Office. This information includes a link to the State Auditor’s Office website http://sao.fraud.state.tx.us. Texas Government Code, Section 321.022, Coordination of Investigations. TWU has procedures incorporated into its “Fraud and Fraudulent Activities” policy to ensure that the State Auditor’s Office is notified of any fraud, waste, or abuse of state funds received by the University. Page 15