SAMs in Component Executive Review for the 1st Quarter, Fiscal Year 2017

The following SAMs have been recommended by University of Houston System subject matter experts for Executive Review.  To review the proposed changes, please select each policy name to view the linked document and send comments/suggestions, if any, to
uhpolicies@uh.edu by November 7, 2016 (Monday).

Note: SAM 06.A.07, Procedures for the Operation of Institutes and Centers, has been removed for additional redlines. It will be part of a future revision cycle. Also, SAM 01.B.08, Third-Party Construction, was also removed for additional redlines.

To review the proposed changes, please select each policy name to view the linked document. The column titled "Proposed Changes" briefly explains the updates that have been submitted. The column titled "Review Comments" indicates the comments/suggestions received during the Component Draft Review, Campus Review, and the System Executive Review of the policies listed below.
SAM Number and Name Proposed Changes Review Comments
SAM 01.B.05 - Signature Authority for Construction Contracts Applied revised SAM template and added new Revision Log. Removed Section 5, Index terms. Changed responsible party. No other additional changes were made by the Subject Matter Experts (SMEs).
SAM 01.B.05 was originally in the
Quarter 1, FY 2011 review cycle, but was not approved. Per SAM 01.A.01,
Section 7.2 on redlines received after the scheduled review date for a document, this document will receive a full review cycle.

Campus/Executive Review Comment:
SAM 01.D.01 - Requests for Services from the Office of the General Counsel Applied revised SAM template and added new Revision Log. Updated links and titles as needed. Removed letter being filed with General Counsel from Section 2.1. Added communication in writing for legal services in Section 2.3. Revised Section 3 per current operating practices. Updated Section 4 information regarding open record decision requests. Changed review period from every two years on or before March 1st to every five years on or before March 1st.

Campus/Executive Review Comment:
For Section 4, Open Records Decision request link needs to be updated to current link for Texas Public Information Act.
Response: Change incorporated.
Additional Redlines: General Counsel made additional redlines, including adding a new Section 7 with related statutes and documentation.
SAM 01.D.02 - Employment of Outside Legal Counsel Applied revised SAM template and added new Revision Log. Updated links and titles as needed. Added biannual agreement to Section 2.5. Revised Section 2.7 process for payment of services of outside legal counsel to reflect current operating requirements. Changed review period from every two years on or before March 1st to every five years on or before March 1st.

Campus/Executive Review Comment:
For Section 2.7, could you make the redlines clearer, so that Item d can be read more easily?
Response: Change incorporated.
SAM 01.D.03 - Trademark Management Updated links and titles as applicable. No additional changes were indicated by the Subject Matter Experts (SMEs).
Per SAM 01.A.01, Section 7.2 on redlines received after the scheduled review date for a document, this document will receive a full review cycle.

Campus/Executive Review Comment:
SAM 01.E.01 - Office of Intellectual Property Management Updated links as applicable. No additional changes were indicated by the Subject Matter Experts (SMEs).
Per SAM 01.A.01, Section 7.2 on redlines received after the scheduled review date for a document, this document will receive a full review cycle.

Campus/Executive Review Comment:
SAM 03.C.03 - Repair and Construction Funds Corrected title in Sections 2.2 and 3 and corrected links as applicable. No additional documents changes made by Subject Matter Experts (SMEs).
Per SAM 01.A.01, Section 7.2 on redlines received after the scheduled review date for a document, this document will receive a full review cycle.

Campus/Executive Review Comment:
SAM 03.G.03 - Financial System Verification of Cost Center Transactions Modified Section 2.2 to remove specific verification information, and indicated the review and approval of the verification report must be documented. Revised Section 2.6 for verifications and approvals to be completed no later than 60 days after the close of an accounting period.

Campus/Executive Review Comment:
Questions from Staff Council:
Question:Can "its" be removed from the first sentence in Section 1? It is confusing to readers on what "its" is referencing.
Response: Change incorporated.
Question:Could we rephase Section 2.3.a to the following: "Verification that transactions on the UGLS1074 report are accurate and in accordance with department records. Transactions include the following:
- Revenue
- Expense
- Fund Equity
- Budget Transactions
- Open Commitments Balances
- Soft Commitment Balances
- Asset & Liability Transactions
o Note: does not apply to system-generated offsets to revenue and expense."
Response: Change incorporated..
Question:Section 2.7: can we change "electronically at the department" to either "electronically at the department level" or "electronically within each department"?
Response: Implemented "electronically within each department." Change incorporated.
Question: The documents on the general accounting and audits are well revised. They are useful particularly to the faculty members who receive large grants. PIs and Co-PIs should know how the cost centers are operated and monitored (General Accounting, SAM 03.G.03) and how the auditing processes at different levels are executed. Their knowledge in these areas will promote collaboration and efficiency of the work with the financial and business administrators at all levels at UH.
Response: Procedures on how to read the 1074 report (the most commonly used Finance System Report) and how to verify cost centers are located on the Finance References page at http://www.uh.edu/finance/pages/References.htm. In addition, the Finance PI Portal was very recently added to AccessUH with the goal of providing faculty members with a summary of their cost center balances. Faculty members who are listed as the "Cost Center Manager" of one or more cost centers already have access to the Finance PI Portal; they can drill down to see more detail on any cost center by clicking on any of the Subtotal amounts. The Finance PI Portal will be expanded to include more information that is helpful to faculty members, and Finance will provide instructors and training on how to access the information. The plan is to eventually use the Finance PI Portal for online cost center verification as well.

SAM 03.H.02 - Open Records Updated links and titles as needed. Made minor modification to Section 2.4 regarding requests from Attorney General "in most cases." No additional redlines were indicated by the Subject Matter Experts (SMEs).
Per SAM 01.A.01, Section 7.2 on redlines received after the scheduled review date for a document, this document will receive a full review cycle.

Campus/Executive Review Comment: The Office of General Counsel made minor housekeeping redlines to Section 2.3.
SAM 04.A.01 - Audits by External Auditors Updated links and position titles as applicable. Changed title for document in Section 2. Rephrased Section 4.2, and changed reference document. Revised Section 5.1 on periodic audits, with the addition of Houston Public Media, Cancer Prevention Institute of Texas Grant Awards, and Financial Statement Reviews for the Southern Association of Colleges and Schools.

Campus/Executive Review Comment:
Question from Don Guyton to Beverly Rymer: What is the correct reference to OMB Circular A-81, Uniform Administrative requirements, Cost Principles, and Audit Requirements for Federal Awards? UH System Purchasing Guidelines has a different web site address.
Response:

SAM 04.A.02 - Audits by Internal Auditing Updated links as applicable. Added contracts to Section 2.1. Revised
Section 2.3 regarding the composition of the long-range audit plan, including risk-based testing of contract administration. Added Section 3.6 on investigating reports of defalcation, misappropriation or other fiscal irregularities. Added long-range audit plan to risk analysis in Section 4.1. Added Section 5.6 on written responses of reports of suspected fraud, waste, abuse and/or ineffective operations to be distributed to the Chair of the Audit and Compliance Committee and the Chancellor.

Campus/Executive Review Comment: Question about using the word "defalcation" in Section 3.6. Isn't that word the same as "misappropriation?" Or is it being used as "embezzlement?"
Response: Defalcation is the correct word for this section; it is used by specific auditing personnel to mean misappropriation, embezzlement, or any other act such as falsification of time or leave reports to obtain an unearned or unintended benefit.


*Please note that the policies contained in this section are not official.  The changes have been submitted to University Policies and Procedures and are currently under review.  To view official System Administrative Memoranda, go to
http://www.uh.edu/af/universityservices/policies/sam/index.htm.





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Peggy Levy
713-743-6636

uhpolicies@uh.edu