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Office of Global Engagement AuditReport No. 19CF-AEN-13April 27, 2020Office of Audits & Consulting Services
April 27, 2020Dr. Guy Bailey, PresidentThe University of Texas Rio Grande Valley2102 Treasure Hills Blvd., Suite 3.115Harlingen, TX 78550Dear Dr. Bailey,The Office of Audits & Consulting Services has completed the Office of Global Engagement Audit. The objectives of this auditwere to: Review internal controls regarding the control environment, segregation of duties, approvals and authorizations, safeguardingof assets, and monitoring, to provide reasonable assurance that existing internal controls are adequate.Review controls that ensure compliance with relevant governmental regulations, policies, and procedures related tointernational programs.Review the admission process of international students to ensure compliance with applicable policies, laws, and procedures.This audit was conducted in accordance with The University of Texas System’s (UTS) Policy 129 Internal Audit Activities, theInstitute of Internal Auditors’ International Standards for the Professional Practice of Internal Auditing (Standards) and GenerallyAccepted Government Auditing Standards (GAGAS). The Standards and GAGAS set criteria for internal audit departments in theareas of independence, professional proficiency, scope and performance of audit work, and management of audits. We are required toadhere to these Standards and UTS 129.We concluded that the Office of Global Engagement did not adhere to all policies and procedures and internal controls over revenueand expenditures need improvement.Office of Audits and Consulting Services Vaquero Plaza C, 1.412Sugar Road Annex 1.101One West University Blvd.1201 West University Driveutrgv.eduBrownsville, Texas 78520-4933Edinburg, Texas 78539-2999(956) 882-7023(956) 665-2110
The recommendations in this report represent, in our judgment, those most likely to provide a greater likelihood that management’sobjectives are achieved. Implementation of the recommendations will strengthen and improve processes within International Programsand Partnerships.We appreciate the assistance provided by UTRGV’s management and other personnel. We hope the information and analysespresented in our report are helpful.Sincerely,Eloy R. Alaniz, Jr., CPA, CIA, CISAChief Audit Officercc:Dr. Parwinder Grewal, Executive Vice President for Research, Graduate Studies, and New Program DevelopmentMr. Alan B. Earhart, Director of International Programs and PartnershipsMs. Samantha Lopez, Director of International Admissions and Student ServicesUTRGV Internal Audit CommitteeUT System Audit OfficeGovernor’s Office of Budget, Planning and PolicyState Auditor’s OfficeLegislative Budget BoardSunset Advisory CommissionOffice of Audits and Consulting Services Vaquero Plaza C, 1.412Sugar Road Annex 1.101One West University Blvd.1201 West University Driveutrgv.eduBrownsville, Texas 78520-4933Edinburg, Texas 78539-2999(956) 882-7023(956) 665-2110
Office of Global Engagement AuditExecutive SummaryOverall Assessment:The Office of Global Engagementdid not adhere to all regulations,policies and procedures. Inaddition, OGE’s internal controlsover revenue and expensesneeds improvement.Background: The Office of Global Engagement’s (OGE) mission is to globalize UTRGV byidentifying, creating, and supporting global initiatives while opening a range ofopportunities for the faculty, students, the community, and senior leadership. OGEprovides funding, vision, logistics, and other support that helps the University realizeits strategic priorities.The Office of Global Engagement reports directly to the Executive Vice Presidentfor Research, Graduate Studies, and New Program Development. The Office ofGlobal Engagement is composed of two departments International Programs andPartnerships (OIPP), and International Admissions & Student Services (IASS).Objectives: Review the admission process of international students to ensure compliance withapplicable policies, laws, and procedures.Review controls that ensure compliance with relevant governmental regulations,policies, and procedures related to international programs.Risk LevelsAppendix IReview internal controls regarding the control environment, segregation of duties,approvals and authorizations, safeguarding of assets, and monitoring, to providereasonable assurance that existing internal controls are adequate.Scope/Period: The audit covered the period of September 01, 2017 to May 31, 2019.PriorityHighMediumLowKey Observations:High1. International agreements or contracts not properly executed based on Delegation ofAuthority.High2. Instances of non-compliance with Regents Rule 40401 as follows: J-1 Visa Processing Fee not approved by president and the OIPP chargedapproximately 4,300 in fees. Student fees not spent in accordance with authorized purpose. No institutional guidance for administration, processing, and approval of other feesand charges.1 Page
Office of Global Engagement AuditExecutive Summary ContinuedHigh3. Instances of non-compliance with the following regulations: 22 CFR §62.13 Notification 22 CFR §62.14 Insurance 22 CFR §62.10 Program administration- English Proficiency, OrientationHigh4. Instances of non-compliance with 22 CFR §62.10 Program administration Retention RecordsMedium5. Instances of non-compliance with purchasing and travel policies and proceduresas follows: Supporting documentation not maintained for some travel, entertainment andoperating expenses. Substantiation form not completed for entertainment expenses. Vendor hold verification for credit card purchases not completed. A purchase order created after invoice was submitted. Cost Center manager approved his own entertainment expense reimbursement.Medium6. A HOP policy related to international student health insurance requirements hasnot been adopted as required by UT System Policy.Root Causes:1. Lack of awareness of the delegation of authority as well as contracting requirements byOGE and others.2. Non-compliance due to: No guidance over assessment and approvals of the J-1 processing fees by RegentsRule 40401. Commingling of funds into one account and misunderstanding of fees and charges. Regents Rule 40401 Section 3.1. does not address other fees and charges.3. Minimal to no oversight of international exchange programs administration and OIPP isnot part of the employee separation workflow process.4. Minimal to no oversight of international exchange programs administration andOIPP is not part of the employee separation workflow process.5. Trust in employees with minimal to no oversight by management as well asineffective monitoring and training over purchasing and travel processes.6. UTRGV makes reference to UT System’s Health Insurance policy.2 Page
Office of Global Engagement AuditExecutive Summary ContinuedManagement Responses/Action Plans:1) The Associate Vice President of Global Engagement will follow the UTRGV approved delegation authority.2) The Office of Planning and Analysis will develop a HOP policy related to assessment, collection, delegation and charges of feesas required by Regents Rule 40401. Additionally, a formal process will be established and communicated to address other feesand charges currently not addressed in Regents Rule 40401.OIPP has suspended the collection of the 105 application fee for the J1 Exchange Visitor Program until approval from theUTRGV president’s office is attained.3) The Director of International Programs and Partnerships implemented new procedures to address non-compliance with: 22 CFR §62.13 Notification 22 CFR §62.14 Insurance 22 CFR §62.10 Program administration - English Proficiency, Orientation4) A semiannual audit of the J1 program will be carried out by the Director of OIPP each year.5) The Director of International Programs and Partnerships implemented procedures to adhere with purchasing and travel policiesand procedures.6) The Director of International Admissions and Student Services will adopt an International Student Health Insurance policy asrequired by UTS 186 Student Health Insurance.3 Page
Office of Global Engagement AuditDetailed ObservationsOffice of Global EngagementInternational Agreements and ContractsThe Office of Global Engagement did not followUTRGV’s Delegation of Authority or UT System’sPolicy (UTS) 108, Section 5 when executingagreements with foreign institutions. UTRGV’sDelegation of Authority solely gives the president theauthority to execute foreign agreements. Additionally,UTS 108 Section 5 Affiliation/Training Letter allowsthe use of affiliation/training letters without furtherreview only if the program does not involve theexchange of funds. If funds are involved, a contract isrequired.We reviewed 39 international agreements and foundthat: The Executive Vice President of Research,Graduate Studies and New ProgramDevelopment approved six agreements;however, he did not have the delegated ofauthority to approve these types of agreements. Cost center 31000941 - Global EngagementStrategic Account received 53,300 and 17,400 of non-sponsored billings in FY 2019and FY 2018, respectively without a requiredcontract.Recommendations1) The Associate VP for GlobalEngagement should ensurethat: The proper delegatedauthority executesexchange programagreements with foreigninstitutions. A contract is properlyexecuted when exchangeof funds is involved withforeign institutions.Management Action Plans1) Office of Global Engagement willfollow the UTRGV approveddelegation authority. In addition,Office of Global Engagement willfollow the Total Contracts Managerprocess which will have the delegatedauthority in the workflow process.Action Plan owner: Associate VicePresident of Global EngagementImplementation Date: As soon asTotal Contracts Manager isimplemented4 Page
Office of Global Engagement AuditDetailed ObservationsOffice of Global EngagementOther Fees and ChargesIn FY 2017, the Office of International Programs andPartnerships proposed and submitted a new fee of 105, a processing fee for the exchange visitorprogram. The fee was initially submitted to the Officeof Planning & Analysis but advised that this wasconsidered sales & services of educational activitiesand needed approval from Academic Affairs. Theformer provost approved the fee on March 02, 2017.The Office of International Programs and Partnershipscharged approximately 4,300 in processing feesbetween FY 2019 & FY 2018 to students withoutauthorization from the president.In FY 2018, the Office of International Programs andPartnerships commingled the processing fee with theStudy Abroad and International Exchange ProgramFee. As a result, the OIPP spent the fees not inaccordance with the authorized purpose.While this fee is not subject to the requirements ofRegents Rule 40401, Assessment, Collection,Delegation, and Waiver of Tuition, Fees, andCharges, we determined that UTRGV has no guidancefor assessment and collection of other fees andcharges. In addition, UTRGV has not adopted a HOPpolicy related to fees and charges as required byRegents Rule 40401 Section 3.Recommendations2) The Office of Planning andAnalysis should develop aHOP policy related toassessment, collection,delegation and charges offees as required by RegentsRule 40401. In addition, aformal process should beestablished andcommunicated to addressother fees and chargescurrently not addressed inRegents Rule 40401.Management Action Plans2) By March 31, 2020, the Office ofPlanning & Analysis will prepare andsubmit a draft Non-Mandatory FeeApproval HOP policy forconsideration. This policy will setforth the procedures for proposingand approving fees and chargesdescribed in Regents Rule 40401,Section 3. This policy will alsoprovide guidance for proposing andapproving charges not addressed inRegents Rule 40401. The exacttimeline for full implementation willbe dependent on the HOP reviewprocess.OIPP has suspended the collection ofthe 105 application fee for the J1Exchange Visitor Program untilapproval from the UTRGVpresident’s office is attained. Willseek approval from President tocharge 105 or a different amount,based on actual and projectedexpenses.Action Plan Owner: Director ofPlanning & AnalysisImplementation Date: August 31,20205 Page
Office of Global Engagement AuditDetailed ObservationsInternational Programs and Partnerships22 Code of Federal Regulations (CFR) §62.13Notification Requirements, sponsors must reportin the U.S. Immigration and Customs EnforcementStudent and Exchange Visitor Information System(SEVIS) any withdrawal from or early completionof an exchange visitor's program that occurs priorto the “Program End Date” listed in SEVIS on theexchange visitor's Form DS-2019.We selected 20 J-1 Visa Exchange Visitorapplicants for review and found that notificationrequirements to the U.S. Department of State werenot timely.A research scholar received a faculty appointmentfor FY 2018, FY 2019 and FY 2020 as a Lecturer Iby the Physics Department. The research scholarresigned, and a separation form was completed onJuly 03, 2018. SEVIS records shows the researchscholar with an active status as of June 13, 2019.UTRGV responsible officer updated the SEVISrecord on June 18, 2019. In addition, the researchscholar had three dependents.22 CFR §62.14 Insurance, sponsors must requirethat all exchange visitors have insurance in effectthat covers the exchange visitors for sickness oraccidents during the period of time that theyparticipate in the sponsor's exchange visitorRecommendations3) The Director of InternationalPrograms and Partnershipsshould develop a process to: Monitor the visitor’s staywhile in the United Statesand report change of statustimely in SEVIS, Ensure that the exchangeparticipants and theirdependents, if any, arecovered by health insurance, Verify that participants havethe education andcredentials necessary tocarry out the activity forwhich they are entering theUnited States and that theyhave sufficient proficiencyin the English language, Offer appropriateorientation for all exchangevisitors and theirdependents, if any, Maintain SEVIS records fora minimum of three yearsfollowing the completion ofeach exchange visitorprogram.Management Action Plans3) The Director of InternationalPrograms and Partnershipsimplemented new procedures toaddress the issues revealed by theaudit.a) Beginning Fall 2019 monthly,mandatory orientations have beenconducted for all incoming J1scholars. These meetings are ledby the Director of OIPP with guestspeakers from the Title IX officeand Export Control. Attendance istaken at these meetings and notedin each scholar’s record in theSharepoint site used by OIPP tostore information for the J1EVP.NOTE: Scholars are only requiredto attend one orientation. (22 CFR§62.10.)b) The length of stay in the J1EVP atUTRGV was reduced to 12months. The DS 2019 certificateswill only be issued for up to 12months, with subsequentextensions possible provided thatthe scholar gives proof of funding,proof of insurance updates homeaddress, and provides a rationalefor continuance in the J1EVP atUTRGV. This change has been6 Page
Office of Global Engagement AuditDetailed ObservationsInternational Programs and Partnershipsprogram including accompanying spouses anddependents.International programs did not obtain proof ofrequired insurance for 11 out of 20 files reviewed.22 CFR §62.10 Program administration –English Language Proficiency, sponsors mustverify an applicant's English language proficiency.International Programs and Partnerships did nothave a process in place to comply with code offederal regulations. Therefore, we found noevidence of the English language requirement metfor the 20 files reviewed.22 CFR §62.10 Program administration –Orientation, a sponsor must offer and recordparticipation in an appropriate orientation for allexchange visitors. Sponsors are encouraged toprovide orientation for the exchange visitor'saccompanying spouse and dependents, especiallyfor those exchange visitors who are expected to bein the United States for more than one year.International Programs and Partnerships did notprovide exchange visitors with a formalorientation required by federal regulations. OIPPwas conducting ad hoc orientations for scholarsupon arrival.Recommendations Timely identify exchangevisitors separated fromemployment via theseparation of employmentworkflow.Management Action Plansimplemented already in theQualtrix application used to start anew exchange visitor program atUTRGV. More frequent check-inshelp avoid the situation wherescholars have changed address orleft the university withoutnotifying OIPP. (22 CFR §62.13.)c) Procedures for routine SEVISoperations were created in aMicrosoft Teams site. Theseprocedures include bothgenerating a new DS2019 andvalidating the J1EVP for a new J1scholar. The procedures includehyperlinks to resources on the USDept of State websites foradministering the J1 program. Theprocedures also include links tothe documents that we use tocreate the packets that prospectivescholars use to secure their J visa.(22 CFR §62.10.)d) Following the initial auditconference in March 2019, theapplication process for new J1scholars was moved from apaper/pdf format to a Qualtrixsurvey. This has increased theprecision of the processingrequests. Hosting departments7 Page
Office of Global Engagement AuditDetailed ObservationsRecommendationsManagement Action PlansInternational Programs and Partnershipsupload all documentation requiredto bring an individual to UTRGVunder the J1 program, includingbiographical information, passportphoto page, proof of Englishlanguage proficiency, CV/resume,proof of funding. All of thisinformation is downloaded fromQualtrix and stored in theprospective J1 scholar's folder onthe Sharepoint site used by OIPP.(22 CFR §62.10.)e) OIPP weekly team meetings nowinclude discussions around J1EVPand new improvements in ourprocedures. (22 CFR §62.10.)f) Recently two of the AlternateResponsible Officers receivedSEVIS training from our nationalorganization, NAFSA. Moretraining is being scheduled forintermediate levels. (22 CFR§62.10.)g) Compliance with the insurancerequirement for both J1 scholarsand J2 dependents is now handledin the following manner. Proof ofinsurance is required upon arrivalto UTRGV. The J1 scholar’sprogram will not be validatedwithout proof of insurance. The8 Page
Office of Global Engagement AuditDetailed ObservationsRecommendationsManagement Action PlansInternational Programs and Partnershipsexpiration date for their insurancecoverage is entered into theSharepoint site, which sends anautomatic notification 10 daysbefore the insurance expires. Uponreceipt of this notification, OIPPsends a request for updatedinsurance information to the J1scholar as well as any J2dependents. (22 CFR §62.14.)h) The procedures on the MicrosoftTeams site list everything that theResponsible Officer or theAlternate Responsible Officersneed to do vet a prospective J1scholar, including checking theCV, English proficiency, andproof of funding. Additionally, theQualtrix survey has added in thecollection and processing of thedocuments required for issuing anew DS2019 through SEVIS. (22CFR §62.10.)i) To address the sixth bullet point,OIPP needs to be included in theseparation procedures for all J1visa holders that are employed byUTRGV. The Director of OIPPhas requested that ipp@utrgv.edube notified when any J1 scholarseparates through the separation9 Page
Office of Global Engagement AuditDetailed Ob
OIPP has suspended the collection of the 105 application fee for the J1 Exchange Visitor Program until approval from the UTRGV president’s office is attained. 3) The Director of International Programs and Partnerships implemented new procedures to address non-compliance
