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Internal Control Tip of Week – Business Purpose Documentation

By Thomas Canby posted 03-08-2018 13:20

  

Before signing off to approve or authorize select proposed procurements or vendor payments, do you slow down to ensure you have a clear understanding of the specific education-related purpose(s)? Does the information accompanying a purchase order or requisition explain how the proposed procurement is an appropriate expenditure of a specific program allotment or of local, state or federal grant funds, in addition to supporting relevant performance goals of academic or operational program, services or activities? A starting point is to assess whether the information supplementing basic transactional information contained on a purchase order or requisition sufficiently answers the five “Ws” (who, what, when, where and why), as follows.

  • Who – Does the documentation identify what target program(s) or operational areas will benefit; what student group(s) will receive services; and/or the staff person(s) that will participate? Are the vendor's name and full contact information provided?
  • What – Does the documentation itemize the goods and/or services provided and reference the district’s purchase order or requisition number, if issued? Does the invoice show unit prices and extended total prices of the goods and/or services that agree with prices in the procurement bid, proposal or quotation? Does the proposed payment authorization sufficiently explain the district is only paying what the vendor or service provider earned?
  • When – Does the documentation detail on what date(s) the goods were delivered, services were provided and/or when the event(s) took place? If there are multiple dates, are all of the dates included on the documentation?
  • Where – Does the documentation identify the campus or other location(s) where services were provided, work was completed or the location of an event?
  • Why – Does the documentation substantiate programmatic goals or strategies supported by the proposed procurement or contract (are strategies delineated from district improvement plan, campus improvement plan and/or comprehensive needs assessment)? Has the proposed procurement or contract been reviewed and approved by relevant program/operational directors for compliance with all relevant local, state and federal law, rules, policies and regulations, in addition to the district’s attorney on retainer (especially for new contract/agreements or extension)?

In all cases, proposed procurements or contracts must conform with legal and regulatory requirements, in addition to guidelines published by grantor or oversight agencies. The bottom line is to never sign anything you do not understand and be proactive with appropriate legal reviews.

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