Philadelphia University + Thomas Jefferson University

Coordination with Other Departments

Due to some overlap of responsibilities of Internal Audit, Billing and Reimbursement, Compliance, IT Security and Research Administration, appropriate Internal Audit activities will be coordinated with the Associate Counsel for Compliance and Enterprise Risk Management, IT Security Officer and Vice President for Research, as applicable.  Internal Audit's activities have a focus of financial and operational controls which are often affected by laws and regulations. Respective department efforts will be coordinated in the following ways:

  • For audits of departments or systems subject to a high level or regulatory risk, Internal Audit will request the Associate Counsel for Compliance and Enterprise Risk Management to review the planned audit approach and internal control risk assessments. Based upon this review, the Associate Counsel for Compliance and Enterprise Risk Management may recommend any additional audit procedures to be performed or will assume responsibility for certain audit procedures him or herself or will recommend that the IT Security Officer and/or the Vice President of Research participate in the audit.
  • If concerns regarding compliance with laws and regulations are identified during the course of an Internal Audit, the Associate Counsel for Compliance and Enterprise Risk Management will be notified and an agreed-upon course of action will be followed.
  • If during the course of the Associate Counsel for Compliance and Enterprise Risk Management’s testing, the Officer becomes aware of situations which may be considered internal control weaknesses, the Officer will report such situations to the Director of Internal Audit
  • From time to time, the Associate Counsel for Compliance and Enterprise Risk Management may request financial or information technology audit support from Internal Audit or refer financial investigations reported through the Compliance Hotline to Internal Audit.
  • Any external audit which is for the specific purpose of evaluating compliance with laws and regulations will be coordinated through the Office of University Counsel.

From time to time, suspected improprieties are identified by employees, management, Security, and Human Resources. Responsibility for investigation of such improprieties will depend on the circumstances and the financial amounts involved.

  • For loss or theft of physical assets, Security will be contacted for investigation.
  • For loss or theft of cash (currency, checks or other cash equivalents), Security will also notify Internal Audit to consider whether a review of internal control is necessary and/or to quantify the loss if it is not an isolated incident.
  • For any other suspected financial improprieties, including timekeeping, Internal Audit should be contacted.
  • For any suspected security breach, the IT Security Officer will be responsible for the investigation and will request assistance from the Privacy Officer as applicable.
  • For any improprieties regarding billing and reimbursement, Associate Counsel for Compliance and Enterprise Risk Management will be responsible for the investigation.
  • If any suspected issues arise with respect to grants/administration, such as effort reporting or sub-recipient compliance, Internal Audit will conduct the investigation.
  • For any improprieties which may affect the University's compliance with laws and regulations, is a potential conflict of interest or is an ethical issue, the matter should be reported to University Counsel and the investigation will be conducted at the direction of University Counsel.
  • If there is a question of responsibility for the investigation, the Senior Vice President and University Counsel will be consulted and will determine the Department responsible for the investigation.
  • To the extent that any Internal Audit investigation provides evidence that an employee has misappropriated funds or other assets, both Human Resources and University Counsel will be contacted for further action. Any investigation which provides evidence that an external party has misappropriated funds or other assets from the University will also be reported to University Counsel to arrange for recovery and/or other actions.