Collegiate and Auxiliary Budget Officers

Financial Subcertification

What is the formal sub-certification document that needs to be signed?

This is the annual Financial Sub-certification document which must be reviewed, completed and signed by Deans, VPs, Directors & Senior Fiscal Officers. It is expected that this document be submitted via email by September 15th of each year for the previous fiscal year.  The document must also be printed & signed by the appropriate personnel and sent via campus mail to Selina Martin at 4M Jessup Hall.

What is sub-certification and why are we implementing it at the University of Iowa?

At the University of Iowa, we are required to sign a document each year after the end of the annual financial audit. This document is called a Management Representation letter and it is signed by university officials in Finance & Operations (this is called “Financial Certification”). After the signed document is sent to the State Auditors Office, they will issue an audit opinion as to whether our financial statements are presented fairly, in all material respects, in conformity with generally accepted accounting principles.

By signing the Management Representation letter, the university is confirming the following:
  1. We are responsible for the fair presentation of our financial statements in conformity with U.S. generally accepted accounting principles.
  2. We are responsible for adopting sound accounting policies.
  3. We are responsible for establishing & maintaining internal controls.
  4. We are responsible for preventing and detecting fraud.

Furthermore, the letter specifically includes 24 separate statements or representations which we must affirm are accurate. These management representations fall primarily into one of the following categories:

  1. Compliance with laws, regulations & contracts
  2. Prevention & detection of fraud
  3. Proper recording, classification & valuation of transactions and balances
  4. Adequate documentation & disclosure

Higher education has a high degree of decentralization of financial operations. Historically there has been no formal collaboration with internal business units to assess their internal controls and the potential impact on financial results. Therefore, in an effort to clarify business units’ accountability for financial reporting and responsibility for establishing underlying internal controls, we are implementing “Financial Sub-certification”. Deans, Vice-Presidents, Senior Fiscal Officers and certain central administration Directors will be required to complete the Financial Sub-certification form. The sub-certification process is intended to serve two purposes:

  1. To provide reasonable assurance of the underlying numbers in the University's financial statements, and
  2. To provide reasonable assurance of a sufficient and effective internal control structure that can identify weaknesses in financial processes and systems

This PowerPoint presentation provides an overview of the background of the Sarbanes-Oxley Act and the events leading up to it. It also provides highlights of why financial sub-certification is beneficial to higher education.

What are the 16 sub-certification questions that need to be answered and what are the related policies? How can I learn more about the compliance with these policies?

For each sub-certification question, we have identified specific related policies which units are required to comply with in order to appropriately answer each question. Furthermore, for each question, we have provided a list of specific training/resource links to learn more about compliance with the specific topic. Finally, each question contains a list of control documents. Control documents, the existence of which indicates that a unit is compliant with the related policies. Units may have other control documents which are not on this list.

We also encourage you to review the FSC Discussion Document. The purpose of this document is to provide some “conversation starters” by addressing topics which are relevant to each question. They are intended as reference material for your own internal planning & consideration and are not a part of the Financial Sub-certification document required to be submitted to central administration. Finally, the Discussion Document is not intended to cover all relevant areas related to each specific FSC question.

Who is required to sub-certify?

Generally, collegiate units are required to have sub-certifications signed by Deans and Senior Fiscal Officers (Budget Officers). Auxiliary units’ sub-certifications will be signed by Vice-Presidents, Directors & Senior Fiscal Officers (Budget Officers).  Review our Certification List of individuals by unit.

Is there additional training available to learn more about sub-certification topics?

ICON courses are being developed for Financial Sub-certification.  When all courses have been developed, there will be a separate module for each question.  To enroll in available classes, please follow these steps:

Step 1: In Self Service, go to "My Training" & click on Available Online ICON Course.

Step 2: Click on the course link and in the next window, click "enroll in this ICON course".

Step 3: You are now in ICON and can begin taking the course.