Approval Authority Policy

Only authorized individuals have the authority to obligate the University at Buffalo (UB, university) to receive or spend funds, provide or receive services, or otherwise commit its resources. Given the highly decentralized environment at UB, approvers play a critical role in ensuring that only appropriate activities occur. Those with approval authority are expected to exercise sound judgment in evaluating reasonableness of transactions in consideration of the scrutiny that is applied to our stewardship as a public university.

Transactions requesting payment to an individual, or that benefit an individual with approval authority, require approval by the next higher level of authority. No approver may authorize a payment to oneself or benefiting oneself, including but not limited to, personnel transactions, employee expenditure reimbursements, procurement card transactions, and travel or entertainment expenditures. This practice promotes accountability and helps to ensure the appropriate use of the university’s resources. 

To ensure good internal control, certain financial transactions, such as travel and expense reimbursement, must be authorized and approved. The authorizer will be the employee’s supervisor, as maintained by Human Resources; the approver is assigned based on the cost account charged in the transaction. There may be some instances where the supervisor and the cost approver are the same person. It is especially important that, in these cases, approvers act with personal integrity.

The State University of New York (SUNY) Board of Trustees and the Research Foundation (RF) Board of Directors have vested authority in the president, provost, and RF operations manager to contractually bind and commit the resources of the university. Authorities of the president, provost, and RF operations manager are strictly limited to the signature requirements outlined in the tables below. Each of these positions is authorized to delegate assigned authority as deemed necessary to improve operational efficiency. While approval authority may be delegated, accountability to safeguard the assets of the institution continues to lie with the original approver and all levels of subsequent delegation down to, and including, the final delegate. Without exception, the following delegation requirements must be followed:

• Delegations must align with the customary chain of decision-making at the university, while applying best practices and internal controls
• Delegations must be pertinent to the duties and responsibilities of the delegate
• Delegators may grant signature authorities only to a person within the delegator’s area of managerial control, and the authorities must be granted and exercised consistent with the terms and conditions of the original delegation
• The delegate must have sufficient competency in the subject matter to verify accuracy, allowability, consistency with policy, and support of the university mission
• Transactional delegations must not exceed an amount appropriate for the position held by the delegate
• In the event of delegate turnover, delegated responsibilities must be re-delegated, not assumed by the employee replacing the original delegate

Delegations of approval authority must be documented using the Delegation of Authority Form, recertified annually, maintained in departmental files, and a copy provided to the university business office charged with oversight of the transaction (e.g., Human Resources, Financial Management, Sponsored Projects Services). A delegation of approval authority may grant further delegation authority, provided the person to whom approval authority is delegated has the right to further delegate his or her approval authority and further delegation does not violate the requirements outlined above. The initial Delegation of Authority Form must include language that allows further delegation authority by the delegate.

Delegations of approval authority may be indefinite or for a limited period, as specified in the Delegation of Authority Form. Delegations will automatically terminate if the original approver either ceases to be employed or engaged by the university or ceases to hold the position specified in the delegation or a position that includes the duties contemplated by the delegation.

Each authorized person is responsible for ensuring that he or she has the appropriate approval authority to approve a transaction, and that such approval and the transaction itself complies with other policies of the university and of the applicable school, college, or unit.

Adequate segregation of duties is important for effective internal control. Segregation of duties provides necessary checks and balances to detect errors, deter fraud, and prevent concealment of irregularities.

In general, the approval, reconciliation, and record keeping functions should be separated among employees. When these functions cannot be separated, a detailed review of related activities is required by either a supervisor or the regulating office as a compensating control activity. Some examples of segregation of duties are:

• The person who initiates the purchase of goods or services should not be able to authorize payments
• The person who maintains and reconciles accounting reports should not be able to authorize purchases or payments
• The person who receives cash should not be the person who deposits cash or reconciles the account

To the extent that these controls are not realistic due to the size or expertise within a unit, best efforts should be made to develop and maintain other preventative or detective controls. The Director of Policy, Compliance and Internal Controls is available for consultation on the development of such controls.

All contracts, documents, decisions made regarding the university’s human resources, organizational development, and human relations must comply with all human resource policies and procedures and must have available funding within an approved budget.

The following charts list the transactions which (a) statutorily require the signature of the president, and (b) the president deems appropriate to review; therefore, signature by the appropriate provost, vice president, or RF operations manager is also required. All other transactions may be delegated as the provost or vice president deems appropriate following the customary chain of decision-making, maintaining good internal controls, documenting the delegations, and providing copies to the appropriate university business office.

Purchasing goods and services without authorization is in violation of this policy. Authorization to buy goods and services on behalf of the university is restricted to Purchasing and Contracts staff and select pre-authorized departmental staff. Further information regarding pre-authorization can be found on the Administrative Services Gateway under the Managing Procurement section. While the initiation and approval of eRequisitions may be signed by the authorized signatory on the account to be charged, all purchase orders must be issued through the Purchasing and Contracts
office.

No member of the university may sign or otherwise execute a procurement contract that binds the university unless he or she has been delegated signature authority. Signature authority must be documented in writing and on file as set forth in this policy. Contracts signed by employees without documented signature authority may be deemed void. In such circumstances, these individuals may be personally liable for the obligations assumed under such contracts and may be subject to disciplinary action. 

The university enters into and executes many decisions which obligate university resources. A sound internal control environment requires that only authorized individuals or their designees approve those decisions. Internal controls help to enforce decisions that are:

• Legitimate, appropriate, and allowable
• Executed in accordance with university policy and relevant financial, legal, and contractual requirements    
• Are factually and mathematically accurate

This policy applies to all university accounts and funding entities including all State, Research Foundation, and University at Buffalo Foundation (UBF) accounts.

Approval Authority

Permission to approve transactions for execution. This approval attests to the accuracy, validity, and appropriateness of the transaction within the university’s program objectives and budgetary authorizations. Transaction approval may be performed electronically, in accordance with system requirements, or manually with a handwritten signature.

Conflict of Interest

Any relationship or activity that has the potential to compromise or bias, or appears to compromise or bias, a person’s professional judgment or ability to make objective and fair employment,  academic, or procurement decisions. A conflict of interest may exist when an independent observer might reasonably question whether an individual’s professional actions or decisions are determined by considerations of family, personal, or romantic relationships.

Endowed Chair

An academic position of the highest faculty honor supported by earnings from invested funds.

Exception Approval

The approval required when hiring an individual under the specific situations for which an affirmative action search is not required.

Internal Control

The integration of the activities, plans, attitudes, policies, and efforts of the people of a department working together to provide reasonable assurance that the department will achieve its mission.

Lease

An agreement conveying the right to use property or equipment for a stated period of time.

Procurement Contract

Agreement in which UB acquires goods or services from a supplier in exchange for consideration. The agreement terms and conditions that outline parties’ responsibilities must comply with New York State laws and must follow the applicable rules and regulations of the selected funding source. 

• Execute the delegated authority within the limitations of their duties and this policy.
• Verify the transaction complies with university policies and federal, state, and local laws.
• Assess the impact of the transaction on other aspects of the university and the broader community, when appropriate; consult with constituencies who might be impacted.
• Confirm that funds have been allocated or are otherwise available within regularly approved budgets, special appropriations, or restricted or designated accounts.
• Ensure that there is no real or apparent conflict of interest on any individual or organization involved in the transaction.
• Resolve a real or apparent conflict of interest prior to processing the transaction.

• Complete the Delegation of Authority Form to communicate and document delegations of authority.
• Review delegations annually to ensure they are up-to-date, achieving ongoing consistency and alignment between management authority, responsibility, and accountability; revise as appropriate.
• Provide delegates with sufficient training to enable them to carry out their responsibilities and respective authorities effectively.

• Oversee the operations of their units.
• Delegate approval authority as necessary and appropriate.
• Determine that all actions requiring the approval of the provost also include the approval of the appropriate vice provost, vice president, or dean.

• Delegate approval authority as necessary and appropriate.
• Provide the business office with oversight of the transaction the most current listing of delegations.
• Notify or obtain approval from the Chancellor for personnel transactions when required by the Board of Trustees policy.