November 6, 2019
The Office of Compliance Services
Chief Compliance Officer
This procedure implements The Research Foundation for The State University of New York’s ("Research Foundation" or "RF") Delegation of Authority Policy.
This procedure outlines the process to ensure delegations are properly executed, documented and maintained, pursuant to the RF’s Delegation of Authority Policy.
The three required elements of effective delegation of authority at the RF are:
I. Delegating Authority
II. Updating Delegations
III. Record Keeping
Submit a delegation of authority form, consistent with the method for your location detailed below:
Delegations of authority at Central Office:
1. Submit a completed Central Office Transaction Authority form to the Office of Compliance Services ("OCS") for each Designee.
2. If there is a need to delegate authority not addressed in the Central Office Transaction Authority form, specific delegations via delegation of authority memorandum is suggested.
- For guidance and assistance with this, contact the RF OCS via RFCompliance@rfsuny.org or 518.434.7145.
Delegations of authority at campus operating locations:
1. Operations Manager ("OM") must submit a completed Campus Delegation of Authority form through the RF Compliance Management System to designate Key Employees and individuals with specific authority. For example, any Sponsored Program Office Director(s) or equivalent at the campus operating location.
a. Any Deputy Operations Manager appointments will also require a formal appointment using the Deputy OM Letter Template.
2. OM or Designee must complete and maintain detailed delegations to be made available upon request. This will capture all Designees with authority including specific delegated job functions at the campus operating location.
a. Campuses may use the following template Detailed Delegation (Template) or a similar form of the campus’ design.
3. OM or Designee must complete an RF Campus Authorized Signatures Form.
a. Send to the Office of Compliance Services via RFCompliance@rfsuny.org.
4. OM or Designee must notify all Designees of their granted authority in writing, including, but not limited to:
a. the date authority will be effective;
b. list of authorities delegated;
c. any limits to authority; and
d. the following statement:
"No person may authorize a payment to oneself or benefitting oneself, including but not limited to: personnel transactions, reimbursements, and travel expenditures. Any transaction that benefits, or could be perceived as benefiting, an individual with
approval authority requires approval by another Qualified Designee of equal authority or greater.”
All delegations of authority must be reviewed at the beginning of each fiscal year, consistent with the annual delegation of authority process administered by the OCS.
Changes to existing delegations of authority must be submitted consistent with the steps outlined in section I above.
EXCEPTION: Consistent with the Delegation of Authority Policy, the campus must immediately notify the RF Office of Compliance Services when a Deputy OM assumes the role of Acting OM. Campus should make every effort to provide advanced notice if any OM transition is likely.
The RF Office of Compliance Services is the office of record for Campus Delegations of Authority submitted through the RF Compliance Management System, all Central Office delegations of authority and any delegations of authority that are submitted to the attention of the OCS.
The Operations Manager or Designee must maintain record of completed detailed delegations for their operating location.
Appointed Officer- An individual appointed by the Research Foundation President pursuant to the RF Bylaws. For example, RF Vice Presidents and Operations Managers.
Delegator- An individual to whom authority has been either vested by election or appointment as an Officer, or to whom authority has been delegated pursuant to this policy.
Designee- Any individual that has been delegated authority pursuant to this policy, who may delegate their authority to other Qualified Designees, consistent with his or her own authority pursuant to the RF Bylaws.
Elected Officer- An officer elected by the Board of Directors pursuant to the RF Bylaws. For example, the Research Foundation’s President, Chief Operating Officer, Chief Financial Officer, Secretary, and General Counsel.
Key Employee- A "Key Employee" per the RF Conflict of Interest Policy includes:
1. At the campus;
- Vice presidents
- Operations managers
- Deputy operations managers
- Chief research officers when fulfilling RF obligations
- Technology transfer directors
- Sponsored program office directors or equivalent
- RF Human Resources Officer or SUNY representative carrying out RF human resources functions
- Other appointed officers
2. At the Central Office; and
- Vice presidents
- Senior directors
- Assistant vice-presidents
- Other appointed officers
3. Any other persons who have RF procurement authority equal to or exceeding $100,00 per transaction.
Officer- “Officer” shall include both Elected Officers and Appointed Officers as defined in this section.
Qualified Designee- A person who could reasonably be expected to understand and act in respect to the powers being delegated.
Transaction- A commitment by the Research Foundation involving the exchange of money or property; an obligation to perform services requiring payment, commitment, or use of Research Foundation resources; personnel transactions including promotions and salary; or the assumption of a financial liability.
Delegation of Authority Policy
RF Compliance Management System
Central Office Transaction Authority form
Deputy OM Letter Template
Detailed Delegation (Template)
RF Campus Authorized Signatures Form
Summary of Change
Added exception under "Updating Delegations" for the transition of delegated authority from a departing Operations Manager. Added "RF Human Resources Officer or SUNY representative carrying out RF human resources functions" to the definition of Key Employees at the campus.
Revised for clarity and broke down procedure into the three required elements of an effective delegation of authority: Delegating Authority, Updating Delegations, and Record Keeping.
Added instructions for Central Office.
Added the link to the Central Office Transaction Authority form.
Updated definitions that were updated in the Delegation of Authority Policy.
Updated for new process
New document created from CO procedure
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