KU Lawrence Financial Certification FAQs

When submitting the university’s financial statements to the Kansas Board of Regents and State of Kansas Department of Administration, the chancellor, university chief financial officer, and campus finance leaders must certify the accuracy and completeness of the statements. This includes their representation that: 

• the financial statements are presented fairly and in conformity with U.S. generally accepted accounting principles; 

• appropriate internal controls are in place to ensure accuracy and reliability in accounting and financial data and compliance with established policies; and 

• they are not aware of any fraud or suspected fraud affecting the university or its employees who have significant roles in maintaining internal control. 

To support their certifications, we ask individuals who have significant operational and financial management responsibilities to make certain representations and disclosures related to their respective areas. Additionally, this process helps clarify roles and responsibilities pertaining to financial management and underlying internal controls. 

The results provide the chancellor and the chief financial officer with some level of assurance when making their representations of the university's financial statements. Financial Analysis and Reporting as well as Internal Audit review the responses to determine whether changes to or additional training on key financial policies are warranted. 

We selected employees in positions with significant oversight or financial management responsibilities. These positions include dean, vice provost, associate or assistant vice provost, executive director, center or institute director, finance or budget manager, and SSC director or manager. 

Examples include locker fees for students, faculty and staff, fitness programs, or student service programs (transcript charges, student i.d. card, etc.) The common feature of these charges is that they are intended to generate additional income to the department and the university by charging individuals for services. The university is concerned about the proliferation of such charges and is attempting to provide oversight and control over these charges. 

Any fees for goods and services collected from students, faculty, staff, or the public that do NOT fall into one of the following categories must receive approval from Financial Reporting Services before the fee may be imposed.  

• Required campus fees and other fees approved by the Board of Regents. 

• All fees or charges for activities of the following separate corporations: the Kansas Memorial Unions, the Kansas University Athletic Corporation, the Kansas University Alumni Association, and the Kansas University Endowment Association.  

• Fees for educational or training workshops and seminars sponsored by university departments through Continuing Education. 

• Fees by the Housing Department and Watkins Health Services.  

• Course charges through third party vendors that are handled on an individual basis through the Provost Office.  

Oracle Financials in the Cloud (FITC) is the university’s enterprise billing and accounts receivable system. However, Financial Analysis and Reporting has granted some campus units approval to use systems outside of FITC on an as needed basis (approved list). If your campus unit is using a system to bill internal or external customers that is not FITC and has not been approved by Financial Analysis and Reporting, you must answer “Do Not Agree” on the certification.  

Examples include payments received for application fees, seat deposits, reimbursements, and course-related charges. These charges should be assessed and collected by Student Accounts & Receivables in Financial Services. 

Campus units that collect money are required to remit those funds (cash, check) to Financial Services within one week of receipt. These funds are then deposited into a university-controlled bank account. Under rare circumstances, Financial Services has granted approval for a campus unit to open an account on its own, but this must be approved and monitored by Financial Services.  As such, accounts with external financial institutions include accounts solely controlled by a campus unit or a KU employee.   

Students may receive payments for things such as scholarships, employment compensation, emergency assistance, prizes, participant payments, and awards. It is important that the campus unit providing these payments are knowledgeable about university, federal, and state laws and regulations so the receiving student’s financial aid eligibility is not in jeopardy. 

Employees receive a budgeted salary for work that is in their job description when hired. Generally, an overload payment is for an activity conducted by an employee which contributes to the mission of the organization for which the individual is uniquely qualified to perform, but is not included in their job description. Any compensation made to an employee that supplements the designated, annualized, salary requires approval from the administrative hierarchy within the unit, appropriate budgetary authority, and the Office of the Chancellor or Provost prior to payment being issued. All requests should be made in advance of the work activity being completed and require supplemental documentation regarding the reason, timeframe, and funding source.    

Examples of federal and state regulatory agencies which could contact your campus unit: National Science Foundation, U.S. Department of Health and Human Services, U.S. Department of Labor, Environmental Protection Agency, Internal Revenue Service, Federal Bureau of Investigation, Kansas Legislative Division of Post Audit, Kansas Department of Health and Environment, and Kansas Department of Child and Family Services. 

Uniform Guidance is an authoritative set of rules and requirements for Federal awards that addresses allowable costs, internal controls over certifying time expended on sponsored projects, cash management, subrecipient monitoring, period of availability, and grant reporting requirements.  

The Board of Regents has authorized state universities, including KU, to enter into contracts to acquire or provide goods or services, which may involve an exchange of funds or other consideration, if such contracts are related to the university's operation, function, or mission. The Office of the General Counsel provides legal representation regarding the university’s contractual obligations. Anyone who is not authorized by written delegation, and who signs a contract that purports to bind KU or any of its units, or a controlled affiliate, is acting without authority and may be held personally liable for the contract and all costs incurred thereunder. The following areas are excluded from this policy or have special circumstances: processing of grant-funded contracts related to sponsored programs; contracts related to KU intellectual property; and real estate transactions.  

The definition of a "lease" includes contracts and agreements to use land, office space, buildings, mechanical or computer equipment, software, and other tangible or intangible assets. It would also include financing arrangements consisting of multiple payments that extend more than a year time-frame to a vendor for the purchase of tangible commodities (i.e., physical goods).

All proposals for funding submitted by investigators on the Lawrence Campus (except for some individual fellowship applications) must be submitted through the Pre-Award Services unit within the Office of Research. This is to help ensure that appropriate compliance reviews have taken place; that budgetary information requested by the sponsor is correct; and that any contractual terms or other conditions specified unilaterally by the sponsor that may be inconsistent with university policy have been identified. 

The presence of any one of the following factors generally distinguishes the resulting funds from a sponsored project and classifies the award as a gift.  

• The gift is from a private individual, corporation, or foundation, and no sponsored project deliverables are specified or expected.  

• The gift is from a non-governmental source and is for facility enhancement ("bricks and mortar") or for the university's endowment.  

• The donor specifically intends the contribution to be a charitable gift with no sponsored project deliverables specified or expected.  

• The conditions or stipulations placed on the intended use of the gift are reasonable and serve to direct the funds to areas such as scholarships, facility enhancement, or general research support. The donor may request a summary of how the funds were utilized.  

• The donor intends the gift to be irrevocable and, therefore, relinquishes the right to reclaim the gift or any unused portion thereof.  

• The donor makes the gift to the university without expectation of economic benefit or other tangible benefit commensurate with the worth of the gift.  

Fraud is the deliberate misrepresentation of fact for the purpose of depriving the university permanently of property or legal right to property. Examples include, but are not limited to: 

• Corruption: conflicts of interest, bribery, illegal gratuities, and economic extortion. 

• Cash asset misappropriation: larceny, skimming, check tampering, and fraudulent disbursements, including billing, payroll, and expense reimbursement schemes. 

• Non-cash asset misappropriation: larceny, false asset requisitions, destruction, removal or inappropriate use of records and equipment, inappropriate disclosure of confidential information, and document forgery or alteration. 

• Fraudulent statements: financial reporting, employment credentials, and external reporting. 

• Fraudulent actions by customers, vendors or other parties include bribes or inducements, and fraudulent (rather than erroneous) invoices from a supplier or information from a customer.