(1) This Procedure supports the General Ledger Governance Policy by: (2) This Procedure applies to all officers and directors, members, employees, consultants and contractors of Macquarie University and its Controlled Entities (collectively referred to as the University Group) and to all staff involved in the: (3) Refer to the General Ledger Governance Policy. (4) This Procedure document has five parts: (5) The Director, Financial Operations, Tax and Treasury has overall accountability for ensuring adherence to this Procedure for all entities in the University Group. (6) Manual Journals are used to adjust the financial results of an entity. Strong protocols around the use and quality of journals are a vital internal control which assists in ensuring accuracy and reliability of financial information. (7) The Journal Preparer is responsible for ensuring that the journals they create and upload: (8) The Journal Approver is accountable for ensuring the Journal Preparer has complied with the Procedure requirements listed above. The Journal Approver will only approve journals that comply with this Procedure. (9) All Manual Journal entries must have Supporting Documentation that substantiates the amount and purpose of the journal to a standard that enables the Approver or Reviewer to understand its purpose and validate its accuracy. (10) All calculations must be clearly documented, with methodology and assumptions clearly defined. Information relied on from external sources (e.g., reports) must be documented in sufficient detail, including source and relevant parameters (e.g., dates and other filters) such that a report could be re-extracted or re-obtained, and any associated calculations could be reperformed. (11) All Supporting Documentation must be uploaded into the General Ledger as an attachment to the Manual Journal. (12) All recurring Manual Journals will be documented using a standard recurring Manual Journal Template. This Template will capture the purpose, requirements, key inputs, overview of calculations and expected frequency of the journal, and the location of any supporting material that details the step-by-step instructions for completion of the journal. (13) All Manual Journals must be prepared and approved in accordance with deadlines communicated each month by the Financial Operations Team within Group Finance. (14) Each foreseeable Manual Journal will be listed as a separate task in Blackline, with the expected frequency, due date, Journal Preparer and Journal approver identified. Journal Preparers and Approvers will mark each journal task as complete as they progress through month-end activities in accordance with the published timetable. (15) The relevant Manual Journal Template as well as the step-by-step instructions for completion of each Manual Journal will either be attached to the Blackline task, or the digital location of these documents will be included in the Blackline task. (16) All Accrual journals must use a journal format which auto-reverses in the following period, such that the full Accrual balance needs to be approved each month. (17) The Manual Journal adjustment of prior year externally audited financial results is not permitted without the written authorisation of the Vice-President, Finance and Resources. (18) The Manual Journal adjustment of a prior month’s results within the same financial year is not permitted without the written authorization of the Deputy Group Chief Financial Officer. (19) High quality and timely Balance Sheet account reconciliations are a vital internal control which assists in ensuring accuracy and reliability of financial information. (20) The following Balance Sheet Account types must be reconciled monthly (classified as Key accounts in Blackline): (21) All other Balance Sheet accounts must be reconciled at least quarterly. The quarterly cycle need not follow the default calendar quarter cycles, to enable the spread of the review over the twelve (12) periods. (22) All Balance Sheet accounts must be reconciled for the December reporting period. For accounts subject to auto-certification rules in Blackline, the reconciliation must be manually reconciled in the December reporting period by the Balance Sheet Reconciliation Preparer and Approver without application of the auto-certification rule. (23) Timelines for completion of Balance Sheet Account Reconciliations for all University Group entities will be determined by the Director, Financial Operations, Tax and Treasury. These timelines must be formally communicated as part of month-end timetabling communications and configured in Blackline for all Balance Sheet Reconciliation Preparers, Approvers and Reviewers. (24) A Balance Sheet Account Reconciliation must include: (25) All Balance Sheet Account Reconciliations must include Supporting Documentation that explains the account, substantiates the Closing Balance and enables the Balance Sheet Reconciliation Approver to understand its purpose and validate its accuracy. (26) Examples of Supporting Documentation include, but are not limited to: (27) For sensitive and confidential information, relevant Balance Sheet Reconciliation Approvers will document and implement protocols around document storage and retention in compliance with the Records and Information Management Policy. (28) Segregation of duties between Balance Sheet reconciliation Preparer and Balance Sheet reconciliation Approver is mandatory. (29) The Balance Sheet Reconciliation Preparer must ensure their allocated Balance Sheet Account Reconciliations are completed in accordance with the communicated timelines and include all content required by this Procedure. (30) The Balance Sheet Reconciliation Approver is accountable for reviewing the reconciliations, including performing an assessment on the accuracy, completeness, and validity of the reconciliations according to the requirements of this Procedure. (31) Reconciliations that do not meet the standards of this Procedure must not be approved. The Balance Sheet Reconciliation Approver will advise the Balance Sheet Reconciliation Preparer of remedies required to revise the reconciliation for compliance with this Procedure. (32) The Balance Sheet Reconciliation Approver will oversee the action plan for the resolution of any identified Unreconciled Items. (33) A second quality review of the completed Balance Sheet Reconciliations will be performed by the Balance Sheet Reconciliation Reviewer. This review provides an additional level of scrutiny and evaluation to maintain the integrity of the reconciliation process. The selection of accounts for review and the frequency of these reviews will be determined at the discretion of the Director, Financial Operations, Tax and Treasury. (34) All entities will use Blackline (where this service is activated) to prepare and approve all Balance Sheet Account Reconciliations. Supporting Documentation must be attached to the reconciliation within Blackline. For entities where Blackline is not activated, the Manager, Controlled Entities will manage an alternate digital storage solution, as approved by the Director, Financial Operations, Tax and Treasury. (35) Certain Balance Sheet Account Reconciliations have expected balances that can be predicted in advance due to their inherent nature. Blackline includes a feature to load expected balances and auto-certify accounts which are within a $10 tolerance of this balance. (36) A variety of other auto-certification and account grouping features exist within Blackline. Initial use of these features for each account requires approval by the Director, Financial Operations, Tax and Treasury for each impacted Balance Sheet Account. Approvers for impacted accounts are then required to attest to the Director, Financial Operations, Tax and Treasury, annually, that the auto-certification rules applied to their account, including any preloaded expected balances, are still appropriate for the underlying nature of the account. (37) Unreconciled Items are any component of an account balance that is incorrect, unexplained, has been confirmed as an error or requires further investigation. (38) The tolerance thresholds for temporary Unreconciled Items are set at $50,000 per Balance Sheet Account Reconciliation for the University, and 0.1% of full year expenditure for Controlled Entities. Unreconciled Items within this tolerance limit do not require a formal action plan for investigation unless they persist for more than three months. (39) Unreconciled Items with a value above the tolerance thresholds noted above require an action plan for investigation and resolution, in accordance with the following timeframes: (40) The following information will be reported monthly by the Director, Financial Operations, Tax and Treasury to the Deputy Group Chief Financial Officer: (41) Natural Accounts are used in the General Ledger to group transactions by nature (e.g., wages, income, debtors). These Natural Accounts are then further grouped by hierarchies for internal and external reporting. Appropriate controls around the creation and modification to Natural Accounts and their hierarchies is essential to ensure that financial information is reported accurately and consistently for internal and external stakeholders. (42) Within the University, two Natural Account hierarchies exist: (43) Within the Controlled Entities, other hierarchies exist to cater for internal and external reporting. (44) Requests for new Natural Accounts, modifications to existing Natural Accounts, as well as alterations to the description, purpose or MR and FA Reporting Hierarchies of Natural Accounts, must be made using the Natural Account and Reporting Hierarchy Request Form. (45) Requests must be submitted for review to the Financial Operations Team. (46) Requests for New Natural Accounts must include: (47) Requests for changes to existing Natural Accounts must specify the nature of the requested change, for example: (48) Requests for changes to the MR or FA Hierarchical mapping of existing Natural Accounts must specify: (49) Requests for changes to the narrative description of MR or FA Hierarchical mapping code, with no change to the mapping of the underlying Natural Accounts of existing Natural Accounts must specify the rationale for why the change of mapping is required. (50) Approvals for changes are determined by the level of impact of the change, as detailed in clause 54. (51) A nominated representative within the Financial Operations Team will receive and review all Change Requests and will ensure all necessary finance leadership approvals (as detailed in clause 54) are secured before engaging with the teams responsible for updating the relevant finance systems. Changes will not be made in any system until all necessary approvals are obtained. (52) Once the changes are approved, updates to relevant systems will be processed by the following teams, using standard ticketing processes as relevant for each system: (53) All documentation associated with the Change Request, including all relevant required information specified in this Procedure, plus evidence of required approvals, will be retained on file, noting: (54) Use the table below to identify all impacts of the proposed change, and seek approval from all relevant approvers: (55) Provision of goods, services and other transactions are routinely made between entities within the University Group. These transactions must be identified and eliminated upon consolidation of the University Group financial statements, such that the University Group financial results only reflect transactions with third parties to the University Group. (56) Efficient and accurate identification of Inter-Company Transactions is critical to ensure the accurate elimination of these transactions to enable accurate University Group reporting. (57) All Inter-Company Transactions must be recorded using designated inter-company Natural Account codes, which are used exclusively for this purpose. (58) All Intercompany Natural Accounts will be clearly designated as such in their description and can only be used for these purposes. (59) All Inter-Company Transactions must be classified as either an ‘Inter-company Recharge’ or a ‘Pass-Through’ and the relevant accounting should be followed accordingly. (60) Transactions where there has been a provision of Goods or Services between two entities within the University Group. (61) In these instances, both sides of these transactions need to be recorded in separate Revenue and Expense (P&L – Inter-company) Natural Accounts, in the respective entities. Eg: MQSL provides catering/conferencing services to the University (62) Transactions where one entity has paid for Goods or Services on behalf of another and wants to pass-through the cost of this to the other entity. (63) The initial paying entity should record the transaction in the Receivable (BS-Inter-company) Natural Account and raise an invoice. (64) If the item has already been posted to the P&L, it should be reversed and recorded in the Receivable (BS-Inter-company) Natural Account. (65) The receiving entity should book a Payable (BS-Inter-company) Natural Account an a NON Inter-company expense account.Eg: University pays a supplier on behalf of MQ Health and is then reimbursed by MQ Health via the inter-company. (66) Where feasible, Inter-Company Transactions will be raised via standard Accounts Receivables invoicing procedures and settled via standard Accounts Payable processes, for ease of identification. (67) Cut-offs for the raising of inter-company invoices will be communicated by the Financial Operations department as part of month-end timetable communications and must be adhered to by all entities. (68) Inter-Company Transactions that miss the cut-off for invoicing in a particular period may be accrued via Manual Journal, in accordance with Part A - Manual Journal Entry. Evidence of acceptance of the value of the Accrual by the counterparty must be included by the Journal Preparer as part of the Supporting Documentation for the journal. (69) Cut-offs for the inter-company Accruals for all entities in the University Group will be communicated by the Financial Operations department as part of the month-end timetable communications. (70) The Financial Operations Team will ensure that closed Trial Balances, each month, for each entity within the University Group, contain complete and reciprocal Inter-Company Transactions. (71) The Financial Operations Team will oversee the identification and elimination of Inter-Company Transactions to aid the production of University Group financial reports that exclusively reflect third party transactions. (72) Disputed Inter-Company Transactions will be escalated by the Financial Operations Team member(s) assigned to oversee Inter-Company Transactions to the Director, Financial Operations, Tax and Treasury with an action plan for resolution, in accordance with the following timeframes: (73) The financial statements provide financial information about the University Group that is useful to a wide range of external stakeholders (i.e., existing and potential lenders, rating agencies, Government agencies and donors) in making decisions about providing resources to the University Group. (74) Information in these financial statements is deemed to be material if omitting, misstating or obscuring it could reasonably be expected to influence decisions that the primary users of the financial reports make based on those reports.* (75) Materiality may depend on the nature or the magnitude of information, or both. An entity assesses whether information, either individually or in combination with other information, is material in the context of the financial statements taken as a whole.* (76) Auditing standards provide a range of materiality guidance to enable the auditor to carry out their audit procedures and obtain reasonable assurance about whether the financial statements are free from material misstatement, specifically: (77) Financial Statement Materiality represents the maximum cumulative numerical misstatements in an account balance, class of transactions or other disclosure that the auditor would regard as not influencing the decisions of those financial statements. (78) Benchmarks are used to set materiality and a percentage range is applied based on the nature of the entity and the requirements of the users of the financial statements. (79) Not-for-profit entities typically reference materiality against gross benchmarks (e.g., total assets, revenue or expenses) rather than profitability benchmarks (e.g., profit, net assets).** (80) Due to the judgement required for financial statement materiality, a percentage range is not defined in accounting or auditing standards. (81) A misstatement that is qualitative in nature may still be material if it affects the judgement of a user of the financial statements. Such a qualitative misstatement may include missing or misstated information or notes to the financial statements. Examples include misstatements affecting: (82) All financial statements of all entities within the University Group are audited by the Audit Office of NSW (AONSW). (83) The Audit Office of NSW (AONSW) model materiality for the University sector at 2-3% of expenses. Both quantitative and qualitative characteristics are considered when determining materiality of information. Whilst a financial threshold for materiality can serve as a useful guide, materiality ultimately remains a matter of professional judgement when applied to specific items. (84) AONSW communicates to the University’s Audit and Risk Committee and to each Controlled Entity Board any uncorrected misstatements identified during the external annual audit and the effect that these misstatements, individually or in aggregate may have on the financial statements. (85) Misstatements may result from either error or judgement such as: (86) Auditors typically apply a range of 5-10% of their official materiality limit and also consider qualitative considerations when determining individual misstatements to be communicated to the Audit and Risk Committee. (87) The Audit and Risk Committee is then able to consider if the uncorrected misstatements identified would, either individually or in aggregate, cause a material error in the financial statements. (88) The Audit and Risk Committee generally adopts a lower internal materiality range of 1.5%-2% of expenses for use as a guide when assessing the University Group financial statements and when reviewing any errors identified during the annual external audit and reported to the Audit and Risk Committee by the AONSW. (89) Further to the concepts detailed above, in order to produce materially accurate and complete financial statements, materiality thresholds for correcting individual transactions that may have been either incorrectly calculated or omitted during routine month-end scripts/processes are set-out below.* These thresholds assume that all routine month-end scripts/processes are operational and effective. Thresholds may be temporarily reduced by the Financial Operations Director if any of these routine month-end processes become temporarily ineffective. (90) On occasion financial transactions may be posted into the General Ledger using incorrect chart parameters (incorrect Natural Accounts, Major account). (91) Materiality thresholds for correcting individual transactions with these types of chart geographical errors are as follows: (92) The above financial materiality thresholds discussed in this chapter are summarised as follows: (93) 0.1% - 0.15% of expenses (94) Note that the table below is a guide, due to the qualitative assessments of materiality that will be made dependent on the nature of the error, as detailed in this Part. (95) Nil. (96) The following definitions apply for the purpose of this Procedure:General Ledger Governance Procedure
Section 1 - Purpose
Scope
Top of PageSection 2 - Policy
Section 3 - Procedures
Contents
Accountability for adherence to Procedure
Part A - Manual Journal Entry
Responsibilities and Required Actions
Journal Preparer Responsibilities
Journal Approver Responsibilities
Supporting Documentation
Timetable for Submission and Approval of Manual Journals
Use of Blackline as a repository and tracking tool for Manual Journals
Accrual Journals
Prior Period Adjustments – between financial years
Prior Period Journals (months within the same financial year)
Part B - Balance Sheet Account Reconciliation
Responsibilities and Required Actions
Frequency of Reconciliations
Due Dates
Content of Balance Sheet Account Reconciliations
Supporting Documentation
Segregation of Duties
Responsibilities for Balance Sheet Reconciliations
Balance Sheet Reconciliation Preparer
Balance Sheet Reconciliation Approver
Balance Sheet Reconciliation Reviewer
System for Storing Reconciliations
Pre-set Expectations of Balances and Auto-certification against these Expectations
Tolerance Thresholds for Unreconciled Items
Timeframe for Resolution of Unreconciled Items
Reporting
Part C - Natural Account and Associated Reporting Hierarchy
Responsibilities and Required Actions
Types of Permitted Changes
Requests for New Natural Accounts
Requests for changes to existing Natural Accounts
Requests for changes to the MR or FA Hierarchical mapping of existing Natural Accounts
Requests for changes to the narrative description of MR or FA Hierarchical mapping code, with no change to the mapping of the underlying Natural Accounts to existing Hierarchies
Approvals Process and Evidence of Approvals
System to be updated
Person responsible for overseeing update of relevant system
Approvals for Changes to Natural Accounts or Associated Reporting Hierarchies – for all entities in the University Group
Impact of change
Approval required from:
Director, Financial Operations, Tax and Treasury, or nominee
Director, Group Financial Control, or nominee
Head of Group Financial Planning and Analysis
Other approver
Part D - Inter-company
Responsibilities and Required Actions
Recording of Inter-Company Transactions - Permitted Natural Accounts
Classification of Inter-Company Transactions
Intercompany Recharge (for provision of Goods or Services)
Pass-Through (Payment to a third party on behalf of another entity within the University Group)
Recording of Inter-Company Transactions – Invoices
Recording of Inter-Company Transactions – Accruals
Elimination of Inter-Company Transactions for University Group Reporting
Dispute Resolution of Inter-Company Transactions
Part E - Financial Materiality Guideline
Concepts of Materiality
Financial Statements Materiality
Quantitative Factors - Materiality Thresholds
Qualitative factors in assessing materiality
Materiality and the external audit process
Materiality for completeness of entity level financial statements
Materiality for re-allocation of transactions within an entity – for management reporting
Summary – Financial materiality thresholds
Materiality for completeness of entity level financial statements
Materiality for re-allocation of transactions within an entity – for management reporting needs
Risk Matrix as applied to concepts of financial materiality
Top of Page
Section 4 - Guidelines
Section 5 - Definitions
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University $ value of unreconciled item
Controlled Entities value of unreconciled item as % of full year budgeted expenditure
Time frame for resolution from initial identification of Unreconciled Item
$0 - $50,000
0 – 0.1%
Three months
$51,000 - $100,000
0.1 – 0.5%
Two months
> $100,000
> 0.5%
One month
> $500,000
> 1%
Two weeks plus immediate notification by Approver to Director, Financial Operations, Tax and Treasury
> $1,000,000
> 2%
Two weeks plus immediate notification by Approver to Director, Financial Operations, Tax and Treasury and Deputy Group Chief Financial Officer
General Ledger, Calumo, Blackline, Purchase-to-Pay
Manager, Finance IT
Accurri
Manager, Financial Control
Additions/changes to name and/or purpose of Natural Account
Change to Natural Account name only
Yes
No
No
Approval by manager who owns either the system interface or the Manual Journal procedure that impacts this account
Change to Natural Account name and business purpose
Yes
Yes
No
New Natural Account
Yes
No
No
Impact on MR Hierarchy Mapping – management reporting
Change to mapping in MR Hierarchy – at level 1 - 4 of Hierarchy*
Yes
No
Yes
n/a
Change to mapping in MR Hierarchy – at level 5 or 6 of Hierarchy**
Yes
No
Yes
n/a
Impact on MR vs FA Hierarchy reconciliation template
Yes
No
Yes
n/a
Changes to FA Hierarchy Mapping and Accurri mapping – external reporting
Change to mapping in FA Hierarchy – at level that impacts the face of a Primary Statement or a row within a Note to a Primary Statement in Accurri
Yes
Yes
No
n/a
Prior year Accurri impact
Yes
Yes
No
n/a
Changes to general accounting month-end scripts and processes
Impact on teaching revenue deferral
Yes
No
No
Revenue Manager, Financial Operations
Impact on non- teaching revenue deferral script
Yes
No
No
Revenue Manager, Financial Operations
Impact on indirect costs script
Yes
No
No
Manager, Expenditure Operations Opex/Capex, Financial Operations
Impact on interest allocation script
Yes
No
No
Revenue Manager, Financial Operations
*This is the level that will impact the Calumo report Profit & Loss Account and Balance Sheet Report at a Compact roll-up level. **This is the level that will impact the Calumo report Profit & Loss Account and Balance Sheet Report at a Detailed report level.
$ value of disputed item
Timeframe for resolution from initial identification of disputed item
$0 - $10,000
Three months
$11,000 - $50,000
Two months
> $50,000
One month
Threshold per omitted/incorrectly calculated transaction/invoice
When threshold applies
General Ledger major accounts with no external reporting requirements by major account
0.0025% of annual expenses for the entity
e.g., $25,000 for the University
Every month-end
General Ledger major accounts with external reporting requirements by major account [e.g., research funding acquittal]
1% of annual income for the relevant major account
Minimum: month-end before the next external reporting period
*Including for the University: accurate assignment of prepayment criteria when raising Purchase Requisitions; timely and accurate receipting of invoices in P2P to enable accurate P2P Accruals and prepayments; cash allocation and receipting; effective execution of scripts for deferred revenue, infrastructure costs, payroll interface, payroll Accruals and depreciation; plus routine major revenue and expenditure Accruals. Including for Controlled Entities: Timely and accurate journals to transfer financial data from various source systems into the relevant General Ledger (including for all key revenue streams, cost-of-goods-sold, debtors, deferred revenue, cash allocation, receipting and creditors) plus routine major revenue and expenditure Accruals.
Threshold per incorrect location of transaction/invoice
When threshold applies
General Ledger major accounts with no external reporting requirements by major account
0.0025% of annual expenses for the entity
e.g., $25,000 for the University
Every month-end
General Ledger major accounts with external reporting requirements by major account [e.g.,research funding acquittal]
0.5% of annual income for the relevant major account
Minimum: month-end before the next external reporting period
Party
Topic
Threshold as a % of total entity annual expenses
Example $ threshold for University entity
AONSW
Guide for assessing material error to entity level financial statements in the University sector
Modelled at
2-3% of expenses
$20-$30m
AONSW
Guide for any identified error individually large enough for reporting to Audit & Risk Committee
Typically, 5-10% of 0.1-0.15% of the AONSW overall materiality threshold noted above i.e.
$1m - $1.5m
Audit and Risk Committee
Guide for assessing material error to financial statements
Typically
1.5% - 2% of expenses
$15m - $20m
Finance team
Threshold for Manual Journal correction of missing transaction – refer Part B of this paper - [assuming no external reporting needs by major account]
0.0025% of expenses
$25k
Finance team
Threshold for Manual Journal correction of missing transaction – refer Part B of this paper [where external reporting is required by major account to a funder provider]
0.5% of annual income for the relevant major account.
Accuracy frequency: as a minimum, the month-end before the next external reporting period.
n/a
Finance team
Threshold for Manual Journal correction of incorrect General Ledger location of transaction – refer Part C of this paper - [assuming no external reporting needs by major account]
0.0025% of expenses
$25k
Finance team
Threshold for Manual Journal correction of incorrect General Ledger location of transaction – refer Part C of this paper [where external reporting is required by major account to a funder provider]
0.5% of annual income for the relevant major account.
Accuracy frequency: as a minimum, the month-end before the next external reporting period.
n/a
Potential impacts of a financial error in the entity-level full-year draft Financial Statements, as presented by management for audit
Type of consequence
Consequence Rating
Minimal
Minor
Moderate
Major
Severe
Impact on entity level full-year reported results in audited Financial Statements.
< 0.1% of full year entity-level expenses
For Uni: $<1m
0.1% - 1.5% of full-year entity expenses
For Uni: $1-15m
1.5% - 2% of full-year entity expenses
For Uni: $15-20m
2-3% of full year entity expenses
For Uni: $20-30m
>3% of full year entity expenses
For Uni: $>30m
AONSW – external auditors
Likelihood of receiving qualified [‘non-clean’] audit opinion if corrections not made to financial statements
very unlikely
unlikely
possible
likely
Very likely / certain.
Concerns about the entity may be raised to the Auditor General
Impact for Audit and Risk Committee (ARC) and Council
No errors reported by AONSW at ARC.
Several (individually non-material) errors reported by AONSW at ARC.
ARC may require non-material amendments to financial statements before recommendation to Council.
ARC may require significant amendments to financial statements before recommendation to Council.
ARC likely to require significant amendments to financial statements before recommendation to Council.
ARC very likely/certain to require significant amendments to financial statements before recommendation to Council.
Impact for control environment
n/a
Management assessment of any necessary control remediation.
Internal Audit into area of concern possible.
Changes to processes and controls likely.
Internal Audit into area of concern likely.
Major changes to processes and controls likely.
Internal Audit into area of concern almost certain.
Major changes to processes and structures and controls likely.