Regents Risk Report

Introduction: This report is a tool used by Purchasing Services to identify purchases that appear to violate Regents Purchasing Policy by by-passing the competitive bid process or the approved exception process. Most items appear on the report because the payment was $10,000 and over and somehow the purchase order did not correctly get identified to the invoice in CUFS. This makes the transaction appear to be a violation.

  1. The Report
  2. The report is pulled by the Systems and Process Buyer once a month after the soft close in CUFS.

    1. Pulling the Initial Data - Go to DATA WAREHOUSE
    2. Using ORACLE - Choose Saved Query - New Oracle - $9,999

    3. This pulls the Goods and Standard Services transactions.
      FUTURE: (Choose Saved Query $99,999 - use this later when we start running the Professional Services through FFN and new policy on bidding over $100,000 is started. Will be saved as RISK.dbf)
    4. Use the saved query and run the request as a FoxPro file - not Excel like for other files.
    5. Once the data is pulled from the Data Warehouse, save it to:
      P:/Dis_Pur/RgtsRiskRptQuery/BidRisk/SQL.dbf
      FUTURE: (Or as RISK.dbf if Prof Svc)
    6. The ACCESS Report - Go to ACCESS - Sign into Access 2000
    7. Open P:/Dis_Pur/RgtsRiskRptQuery/BidRisk/SQL.dbf
    8. Go to FORMS and click the isolate button. (This triggers a multitude of queries to run and import data and append information to tables, etc.) Save the current file over the previous month's file pulled in the last accounting period. (Save this month's report over last month's report).
    9. Go to TABLES and open $9999 Table. Verify the table shows the new accounting period. This makes sure that the data just pulled from the Data Warehouse was successfully added to this database.
    10. Be careful not to load the data twice. There is an accumulation archive report that is adding each month's data to a total report in case you ever need it. If you add a month's data twice, then this report will be doubled for that month.
    11. Preview the data. Preview the data as a spreadsheet. Sort by Comment field so that all B orders and like comments appear together. Also double check that the accounting period represents the correct month to be reported on.
    12. Delete any unnecessary records (ie: central PO referenced, B Award Notice referenced, U-Wide Contract vendor referenced (on a different address?), State or Federal Agency orders, etc.)
    13. Print the report - Go to REPORT view and print.
    14. Review the printed report. Check that correct accounting period (month) prints. The average report is 2-3 pages and $800,000 to $1 Million over the the one month period.

  3. PASM Update
  4. At least once a year (usually January), pull the current PASM records from CUFS and add them to the PASM UPDATE TABLE in ACCESS. This will make sure that the report deletes any invoices from the report that are for vendors that have U-Wide Contracts.

    During the year, if you find additional vendor numbers are showing up on reports and they really have a contract, verify that the correct vendor number is on PASM UPDATE TABLE. If not, correct and/or add it.

  5. Help
  6. Initial programmer for the Access Database was Linda Ribbach in Disbursement Services at 4-9315. She is a good resource if there are problems pulling the report.

  7. Support Staff - Initial Review
  8. The Systems and Support Buyer reviews the report and tries to identify those that appear to be the most likely candidates for violations. These are identified and a copy of the report is given to both the Lab Buyer (Or Director's designee) and the Files Position.

  9. Support Staff - Document Research
  10. The Files Position will perform the initial research to determine if there really was a valid purchase order.

    1. Find the area number for the checked transaction on the Report. Search through the current and past fiscal year of paper purchase orders to see if there is any existing purchase orders on file for that vendor for a similar dollar amount.
    2. If a possible order is found, write the PO# on the File Copy of the Report and hold the PO with the report until research is done for the month. Give the completed Report and any identified purchase orders to the Lab Buyer.
    3. If no purchase orders are found on file, prepare an e-mail to the area's chief accounting person or area manager. See sample wording below.
    4. The following transaction is on a report of purchases made $10,000 and over that appears to have not been bid competitively through Purchasing Services.

      Record Date PV# Acct Pd
      Vendor Name $$ Line Description

      Please review your files and return this e-mail with the purchase order assigned to the reference PV.

      If you are not the person to respond to this, please forward this e-mail on to the appropriate person in your area.

    5. Files Position will track these e-mails so one follow up e-mail can be sent one (1) week later.
    6. If no response is received within 1 week after the 2nd e-mail is sent, let the Lab Buyer know that the specific transaction is still outstanding.
    7. If a response is received, and a purchase order is referenced, pull the purchase order (or Professional Service) and give to the Lab Buyer.
    8. Forward any FM or UMD FM research e-mails to the Facilities Management Buyer. This Buyer will take care of the research for both of those areas and get back to Purchasing Services.

  11. Reports
  12. Once all of the identified transactions have been addressed, the report should be filed in a folder in chronological order. These completed reports should identify the appropriate documentation to explain that the purchase was valid or document that the Violation process was followed.

  13. Buyer Procedure for Regents Policy Violations - (List here or Link to the Internal Site?)
  14. The procedure is intended to encourage compliance with the policy by citing, educating and/or applying restrictions to departments who do not observe policy. The procedure will be effective for violations occuring after the date of its implementation. Violations shall be considered "second" or "subsequent" violations if they occur within one year of the first violation.

    1. Violations Identified

    2. A monthly Risk Report from CUFS will identify transactions which need review as possible violations to policy. Purchasing Services will review the report, seek more information as necessary, and identify violations.

    3. Notification

    4. A letter will be sent to departments whose purchase did not conform to policy, informing the department that the violation will be reported to the Board of Regents. The Dean/Director/Department Head, as well as the Area Manager and Chief Financial Officer of the VP or Provost unit are all copied on this letter.

    5. Reporting

    6. Regents Policy on Board Operation and Agenda Guidelines requires that Regents Purchasing Policy violations be reported to the Financial Operations Committee of the Board of Regents on the Quarterly Purchasing Report. Reporting to the Board of Regents shall include the department name, the dollar amount of the violation, a reason/explanation for the violation as cited by the department, whether this is a first, second, or third violation by the same department, action taken by the department to prevent further violations, and whether a fee has been applied for the current violation.

    7. Restrictions
      1. First Violation

      2. The Notification and Reporting (see #2 and #3 above) shall be considered sufficient for the first violation. Also, the appropriate individual(s) will be required to attend classes on purchasing policy and procedures which are offered by Business Services Training.

      3. Second Violation

      4. Notification and Reporting will be applied. In addition, an administrative processing fee shall be applied, which shall be payable by the department and shall be equal to 10% of the dollar amount of the purchase which did not conform to the policy.

      5. Subsequent Violations

      6. Notification, Reporting and Fee(s) shall all apply. In addition, the department shall be identified as an Exceptional department. The Notification and Reporting shall identify them as such and shall copy the Provost, or the applicable Vice President, the CFO/UFO, and the University Controller. Together, they will determine appropriate action at this point up to and including suspension of purchasing authority for the department.


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Last Revised: February 12, 2002
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