Policy Manual

It is the policy of the University of Pennsylvania to support an internal audit function within the University and University of Pennsylvania Health System to provide independent, objective assurance and advisory services to management and the Board of Trustees to assist them in fulfilling their fiduciary governance and oversight responsibilities and to add value and improve operations and the internal control environment. The Office of Audit, Compliance and Privacy (OACP) has been established under the direction of the Vice President (VP) for Audit, Compliance and Privacy and reports functionally to the Trustee Committee on Audit and Compliance and the Penn Medicine Audit and Compliance Committee. The VP of OACP has full and free access to the Chair of the Board, the Board of Trustees, and the full Committees. Both University and Health System management and the Board of Trustees have approved the role of the Office of Audit, Compliance and Privacy as described in this policy and outlined in the OACP departmental charter.

Reconciliation, verification and substantiation are essential for an effective internal control environment to ensure: Accumulated general ledger account balances can be substantiated by supporting detail records; Accuracy and completeness of individual transactions that have been posted to the general ledger; The information transmitted to, contained in, and reported from the University's financial systems is accurate, complete and recorded in a timely manner; The information can be relied upon for making financial and administrative decisions; Efficient and effective audit process; and Fraud, theft, compliance violations and other irregularities are quickly detected and reported to the appropriate authorities.

To minimize the legal and practical complications for the University resulting from individuals without proper authority proceeding on behalf of the University.

The rental of leased property is intended to support the University’s mission of instruction, research and public service. In certain cases, the University leases owned property to third parties for other legitimate and legal purposes.

To ensure that external activities undertaken by University schools, departments, and centers are consistent with the University’s mission of instruction, research, and public service and that such activities comply with the University’s financial policies.

This policy establishes procedures for the authorization and approval of joint ventures between the University of Pennsylvania including its exempt affiliated entities, and unrelated taxable entities. The purpose of this policy is to manage and monitor joint venture activities to safeguard the tax exempt status of the University and its exempt affiliated entities. Reference to “University” below shall be read to include the affiliated exempt entities of the University, as appropriate.