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Fiscal Training. This slide isn’t intended to be part of the presentation…. Fiscal Training. Fiscal Policy Manual. The District has a Fiscal Policy Manual in accordance with State Administrative Rule R277-113-4.
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Fiscal Training This slide isn’t intended to be part of the presentation…
Fiscal Policy Manual • The District has a Fiscal Policy Manual in accordance with State Administrative Rule R277-113-4. • No training session can touch on every issue related to every fiscal policy. For that reason, each district employee is individually responsible to read, understand, and comply with the district’s fiscal policies pertaining to their job function. • Get a copy at: • www.graniteschools.org/accounting/fiscal-policies • Call us if you want a printed copy…(385) 646-4300.
Additional Compliance Requirements In addition to the district’s fiscal policies, all Granite employees are expected to be aware of and comply with:
* Use the ‘Potential Conflicts of Interest’ form (available from Policy & Legal) or at https://gsdsites.graniteschools.org/departments/businessservices/accounting/Pages/Forms.aspx • District employees are prohibited from activities that either do or might present a conflict of interest. • District employees who have or might have a conflict of interest must: • Fully disclose* the interest to their supervising fiscal administrator, and • Remove themselves from any exercise of influence or decision making regarding the interest.
Examples: Doing business with a vendor while being related to or having a relationship with someone who works for that vendor. Working for a vendor with whom the school does business. Owning part of a business that sells goods or services to the school. Taking advantage of information learned on the job for your own benefit. Accepting gifts from a vendor with whom the school might do business. Using work time to do personal business.
Who is a Fiscal Administrator? • There is one fiscal administrator at each school (the Principal) and department (the Director). They have the responsibility to ensure that all financial matters at their site are: • Transparent • Well managed • Conducted in accordance with laws, rules, and district policies and procedures. • Such responsibility is non-delegable. Fiscal administrators do not have authority to instruct or permit either by action or omission violation of district policy and procedure.
Reporting Financial Abuses • Financial Fraud Hotline: • (385) 646-2049 to leave a voicemail (not a live person). • Anonymous email at http://forms.graniteschools.org/. • The purpose of the hotline is to provide a means whereby anyone can communicate knowledge of, or concerns about; 1) waste or misuse of public funds or property, 2) violation of a law, rule, or regulation, or 3) gross mismanagement. • Employees who report such matters are protected by Section 3 of the Utah Protection of Public Employees Act (found in Utah Code 67-21). • Any district employee who becomes aware of or suspects willful violation of any district fiscal policy is obligated to report such to the Business Administrator or Director of Accounting immediately.
MisuseofPublicFunds • “Public funds” means money, funds, and accounts, regardless of the source from which the funds are derived, that are owned, held, or administered by the state or any of its political subdivisions, including LEAs (Utah Code 51-7-3(25)). • “Misusing public funds” (Utah Code 76-8-402) is: • A third degree felony if under $5,000 • A second degree felony if above $5,000 • Misuse of public funds occurs when a steward: • appropriates the money or any portion of it to his own use or benefit or to the use or benefit of another without authority of law; • loans or transfers the money or any portion of it without authority of law; • fails to keep the money in his possession until disbursed or paid out by authority of law; • unlawfully deposits the money or any portion in any bank or with any other person; • knowingly keeps any false account or makes any false entry or erasure in any account of or relating to the money; • fraudulently alters, falsifies, conceals, destroys, or obliterates any such account; • willfully refuses or omits to pay over, on demand, any public money in his hands, upon the presentation of a draft, order, or warrant drawn upon such money by competent authority; • willfully omits to transfer the money when the transfer is required by law; or • willfully omits or refuses to pay over, to any officer or person authorized by law to receive it, any money received by him under any duty imposed by law so to pay over the same.
How to Prevent Fraud • Be aware that fraud can and does happen. • Don’t tolerate bad financial habits (e.g. cash left around, late paperwork, etc.) • Keep a watchful eye on the finances. • Know what you are signing. • Ask for a report of checks written every month and review it (vendors, descriptions, amounts). • Ask for a report of deposits made every month and review it (source, timing, descriptions, amounts). • Review the monthly bank statement and reconciliation. • Let employees know you keep a watchful eye on the finances. • Pay particular attention to high risk areas and red flags…you should know what they are.
Internal Control *When it is not possible to adequately segregate duties due to limited staffing and related constraints, the fiscal administrator shall ensure that monthly independent internal reviews of the documents and transactions related to the duties performed are conducted and documented. The Fiscal Administrator at each location shall* separate the three key duty types among available staff so that no one employee performs more than two.
School-Level Budgeting • During the spring of each year, the fiscal administrator at each location shall establish a balanced budget for each Fund 21 program at their location for the coming year. • The fiscal administrator in each school may enlist the assistance of specific employees, especially those with responsibility for a team, club, class, or program to prepare a proposed budget for the same in the format determined by the Director of Accounting. • The fiscal administrator in each school shall review each proposed budget and make any necessary adjustments before approving. • The fiscal administrator in each location should use each program’s approved budget to inform their decisions whether to 1) authorize activities that generate funds and 2) approve expenditure of funds.
Incoming Cash Receipts “Cash receipt” means anything that represents resources flowing into the district to include: currency, coin, checks, money orders, credit card transactions, transfers in, ACH transactions, and redeemed account credits. Whenever possible, receipt of public funds shall be restricted to one of the following pre-authorized cashiers: • At the school level: • the School Lunch Secretary or Lunch Manager (for lunch related cash receipts only); or • the Financial Secretary or Bookkeeper (for all other receipts). • At the district level, staff within the accounting department designated by the Director of Accounting. For specific functions where it is not possible or reasonable for a pre-authorized cashier to be present, substitute cashiers may be authorized as follows: • At the school level, the fiscal administrator may authorize responsible individuals to act as substitute cashiers. In this case, the fiscal administrator shall ensure that each substitute cashier is trained in his/her duties by the Financial Secretary or Bookkeeper. • At the district level, the fiscal administrator may request authorization from the Director of Accounting to have one or more substitute cashiers. In this case, the Director of Accounting shall ensure that each substitute cashier is trained in his/her duties by the accounting staff. “Under no circumstances shall a district employee who is not a pre-authorized cashier or substitute cashier accept a cash receipt.”
Timely Deposits All public funds shall be deposited within three business days after receipt. - Utah Code 51-4-2(2)(a) A ‘Safe Harbor’…make a deposit: • Every Wednesday • Every Friday, and • Any day the dollar amount collected exceeds: • $500 for Secondary Schools • $300 for Elementary Schools • If these amounts are exceeded due to after school activities, the funds should be secured and deposited the next business day.
Sales Tax Administering sales tax can be complicated. Refer to Procedure ACC-3 on the Accounting intranet site for details.
Restricted Authority to Make Purchases Procurement • The Board of Education establishes procurement authority at all levels. • Schools and departments are authorized to make necessary purchases within stated dollar thresholds. • The Business Administrator and the Director of Purchasing are the only ones who can: • Enter into contracts that go beyond the current school/fiscal year. • The only exception being vending contracts which may have a term up to 3 years. Remember you must obtain at least two competitive quotes for these services. • Transfer or dispose of surplus equipment.
Dollar ThresholdsThe dollar thresholds for purchases are to be applied to the whole purchase [from a single vendor], not individual items. Procurement (Exhibit 1 in the Fiscal Policy Manual)
Competitive Prices Procurement Competitive prices shall be sought from all available sources whenever possible before negotiations for purchase are entered into, and preference shall not be given in such a way that one vendor has an advantage over any other vendor. Use the District Quote Form when required to obtain vendor quotes – available on Purchasing webpage. The district will not recognize employees as independent contractors for services that are related to or an extension of their employment job duties.
Artificially Dividing a Purchase Procurement Artificially dividing a purchase to avoid competitive quotes or district thresholds is a violation of State law. Penalties for dividing purchases range from a class B misdemeanor to a second degree felony, depending on the total value of the divided procurements. When in doubt, please contact Purchasing prior to making a purchase. They will help to ensure you do not make this error.
Procurement Ethics Procurement • It is an offense for a public officer or public employee to knowingly receive, accept, take, seek, or solicit, directly or indirectly for himself or another a gift of substantial value or a substantial economic benefit tantamount to a gift: • that would tend improperly to influence a reasonable person in the person's position to depart from the faithful and impartial discharge of the person's public duties; • that the public officer or public employee knows, or that a reasonable person in that position should know, under the circumstances is primarily for the purpose of rewarding the public officer or public employee for official action taken; or • if the public officer or public employee recently has been, is now, or in the near future may be involved in any governmental action directly affecting the donor or lender, unless a disclosure of the gift, compensation, or loan and other relevant information has been made in the manner provided in Section 67-16-6. • (See exceptions in Section 7.H.3.) • Without regard to the above, all district employees are bound by The Utah Public Officers’ and Employees’ Ethics Act. All educators are also bound by The Utah Educator Standards. All Granite School District employees are expected to be aware of and comply with Procurement Ethics Law (63G-6a-2304.5) as applicable given your job function.
Gratuities and Kickbacks Procurement • When using public funds to purchase an item or service, it is against State law to ask for, receive, offer to receive, accept, or ask for a promise to receive a gratuity from a vendor or prospective vendor. • Exception for “Hospitality Gifts”. • Penalties for an interested person and contractors range from a class B misdemeanor to a second degree felony. Penalties for a procurement participant and contract administrator range from a class B misdemeanor to a second degree felony and make employees subject to disciplinary action up to and including dismissal from employment.
Cash Disbursements • *District purchasing instruments: • District/school check • EFT from district/school account • Interdepartmental billing form • Pay Voucher • Purchasing or Teacher Supply Card • Purchase Order Under no circumstances is cash to be withdrawn from a school or district bank account.
Tracking “Control Risk Assets” • An asset is a “control risk” if it has a high risk of being stolen. School and Department Responsibilities • There is a list of control risk assets that can be found at: • Accounting intranet-Control Risk Assets link under the heading of ‘District Process (Fixed Assets)’, or • https://gsdsites.graniteschools.org/departments/businessservices/accounting/Drawer/Fixed%20Assets/Ctrl_Risk_Assets.aspx
Charging Student Fees(R277-407)Be aware that the law and rules for student fees changed in 2019. The implementation details are still being worked out, but there are significant changes coming. Current Rules Governing Student Fees:
Refunding Student Fees Refunds of fees assessed to students in grades 7-12, basic fee including book rental, driver education, and extra-curricular activity fees are to be given according to the schedule. Participation fees are non-refundable. In the event of unpaid student fees or negative lunch balances, money scheduled to be refunded to a student may be first applied to satisfy the amounts due to the district.
Collecting Money Owed to the School • The Fiscal Administrator at each school shall be responsible for the collection of unpaid student fees. • Fiscal Administrators shall ensure that notes about informal collection efforts and copies of associated letters are kept on file. • Formal collection of student fees should only be authorized by a Fiscal Administrator when a student graduates or is otherwise unenrolled from the school where the fees are owed. • Fiscal Administrators are authorized to implement monthly payment plans as necessary.
Federal Grants • Federal grants may only be applied for by Administrators or those higher in authority. If the grant is awarded, the applicant Administrator assumes the duties of the ‘Grant Administrator’. • Grant Administrators shall know and understand: • Uniform Administrative Requirements (2 CFR Part 200). • The specific requirements of the grant being applied for. • State laws and regulations applicable to the grant being applied for. • All district policies and procedures relevant to the grant.
Gifts andTokens of Appreciation • ‘Tokens of Appreciation’ are only for recognizing a single employee (or a small team of such) for exceptional service, not recognition for a group of employees.” • Not for staff gifts, not for teacher (or secretary, counselor, etc.) appreciation week, not for staff meals, not to acknowledge an employee’s major life event, etc. • Limited to annual maximum of $25. • What funds can be used to pay for tokens of appreciation? • This question is only relevant once it is determined that a specific token of appreciation is appropriate. • School Operations • Vending Funds • Other Unrestricted Local Funds • Consider issuing ‘School’ gift certificates (a certificate that says the school will buy $XX of additional supplies for your classroom).
Food & Beverage Purchases There are occasions and circumstances (see the policy for details) when using public funds to provide food and beverage to staff is allowed. These occasions have a common thread…the primary justification for doing so is that it meets or facilitates a District objective and thus the District is the primary beneficiary. While boosting morale is a District objective, the Board has carved out and funded a different program to boost employee morale. (Employee Morale funds.) Other than for those specific occasions and circumstances identified in policy, using public funds to feed public employees is inappropriate. Whenever thinking about using public funds to buy food for staff, ask a simple question, “Why do I want to do this?” To the extent that your answer is to reward/recognize your staff, be perceived by your staff in a more positive light, or because you feel pressure to live up to expectations, you should recognize that it doesn’t meet the spirit of the policy. If you find yourself getting creative to make an occasion or circumstance meet the criteria established in the policy to be considered an appropriate time to feed your staff, you should recognize that as a red flag.
What Makesa Good Transaction Description? A good description = What it was AND what it was for. Bad descriptions cause additional questioning. If anything unusual, more description is better.
Internal AuditThe underlying tone of an internal audit is to help you identify where improvements need to be made.It is not punitive.
