Administrative Procedures for Financial Resources

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4002 Purchasing

Purchasing Procedure Overview
The Purchasing Department serves the Mohawk Valley Community College community by placing all orders for goods and services. The Purchase Requisition form (found on the Intranet) is used to request items or services to be ordered.  The Coordinator of Expendable and Fixed Asset Procurement (Purchasing Agent) is responsible for the selection of vendors.  Although those placing an order are encouraged to indicate potential vendors on the requisitions, the ultimate selection authority rests with the Purchasing Agent. If the total dollar amount of the requisition is $1,000 to $19,999, additional quotations must be obtained, unless the source of the purchase is exempt (See Using Sources Exempt from Quotations and Competitive Bids).  Competitive bids are solicited when the aggregate amount for goods or services exceeds $20,000, or when the aggregate amount for a Public Works contract exceeds $35,000. A good faith effort is made to determine if the purchase is subject to competitive bid based on the annual estimated aggregate expenditures and past purchases. Contracts are awarded only after bids are solicited in compliance with Section 103 of the General Municipal Law.

At least one qualified local vendor shall be sought on all purchases of the College.  To the extent feasible, all local qualified vendors are invited to make bids where bids are being sought and to make proposals for services where services are being solicited.    A local vendor is defined as a business located within Oneida County, or maintaining a business presence within Oneida County.

The Purchasing Department is committed to ensuring that all purchasing procedures are met before placing the order.  The Department assists in finding supply sources and information on vendor performance.  Its goal is to expedite the procurement of approved goods and services for the College community.

The Purchasing Department has the responsibility of assuring that all purchases are made in compliance with all applicable laws and regulations governing the State of New York, the County of Oneida and Mohawk Valley Community College.  Additionally, the purchase is made for the lowest price available at the time the request is made.

Responsibility of the Employee/Requisitioning Department
It is the responsibility of the requesting department to fill out the proper forms, obtain the required signatures, attach supporting documents and submit the paperwork to the Purchasing Department for processing.   Purchases, agreements to purchase, or changes to issued purchase orders by any individual (other than purchasing staff) are not legally binding to Mohawk Valley Community College.  Such unauthorized purchases will not be paid by Mohawk Valley Community College and may become the financial responsibility of the individual who incurred the expense.

 

Conflict of Interest Policy
No employee can be financially interested in any contract which Mohawk Valley Community College establishes, pursuant to Sections 800-808 of the General Municipal Law and Board of Trustee Policy (Section 3.8).

Any College officer or employee who has, or will have, or later acquires an interest in any company or entity which forges an actual or proposed contract with the College shall publicly disclose the nature and extent of such interest, in writing, to the Board of Trustees as soon as he/she has knowledge of such actual or prospective interest.  No College officer or employee shall be interested financially in any contract entered into by the College.  This also precludes acceptance of gratuities, financial or otherwise, by the above persons from any supplier of materials or services to the College.   A written statement of disclosure should be addressed to the President of the College with a request that it be forwarded to the Board of Trustees.

Using Sources Exempt from Quotations and Competitive Bids
Ordering goods and services from current New York State contracts, SUNY contracts and U.S. Government price lists place the purchase under the terms and conditions negotiated by the government entity, providing Mohawk Valley Community College additional recourse in dispute issues.  Requisitions requests submitted under the following categories do not require additional price quotation and are exempt from competitive bid:

• Purchases made from New York State contracts(www.ogs.state.ny.us)  (Section 104 General Municipal Law), SUNY contracts, Oneida County contracts (Section 408A County Law) or U.S. Government price lists
• Purchases of parts/enhancements for existing equipment
• Purchases of materials or items that must "match exactly" with items purchased previously
• Membership fees
• Purchases made directly from the manufacturer
• Fees to accrediting organizations 
• Educational testing materials
• Preventative maintenance agreements for specialized equipment
• Advertisements
• Emergency situations as declared by the President or appropriate Vice President
• Consultant fees
• Purchases from correctional institutions (section 186 Corrections Law)
• Purchases from agencies for the blind or industries for the disabled (Section 175B Finance Law)
• Sole source (e.g., patented software); written justification required

Expenses Ineligible for State Aid Reimbursement
The expenses listed below are not allowed for reimbursement under the guidelines for NYS aid reimbursement.  Claims submitted in these categories will not be paid:

• Individual memberships in professional organizations and associations (exception: when institutional memberships beneficial to the educational purposes of the College are not available, or when the individual membership serves the same benefit to the College, and is more cost effective for the College)
• Contingency accounts
• Subcontracted food service and bookstore expenses and losses
• Dormitory operation/administrative expenses
• Penalty fees for overdue payment of legal obligations
• Collection agency fees for delinquent student accounts (fee is added to the student’s account)
• Student cap and gown rentals
• Student activities (e.g., student publications, student-faculty receptions)
• Faculty-Student association and activity expenses
• Rental and maintenance costs for property not used for College purposes
• Food, beverage and entertainment expense for College social functions
• Matching funds for off-campus College work study programs
• Administrative overhead expenses otherwise chargeable to federal programs (e.g., SEOG, NDSL, CWS, etc.)
• Service area educational program, non-State University approved expenses
• Reimbursement for alcoholic beverages

Requisitions
The requisition process includes a system of authorizations and safeguards so that improper or illegal purchasing is difficult both to initiate and to conceal.  The Purchase Requisition form is used to request a purchase order.  Forms are available in the MVCC Business Office and on the Intranet.  A completed form is the source document for the purchase order.  Incomplete requisition forms (e.g., those without the required signatures or supporting documents) will be returned.  Processing costs exceed $50 per purchase order; purchases should be planned to meet the minimum processing cost.  Exceptions are at the discretion of the Controller.   A requisition must be typewritten or printed legibly in ink and include the following information:

• Date/department/receiving department
• Quantity/cost/description of items requested ($50 minimum)
• Vendor name/address
• Budget account to be charged
• Processing instructions (e.g., fax the purchase order, prepayment required, etc.)
• Required signatures
• Quotations (if exempt, write “exempt” on the requisition) and any supporting documents
• All advertising requires “Tear Sheets or Notarized Affidavits Required” written on the requisition
• All labor requests require “Certified Payroll Required” to be written on the requisition

The original completed Requisition Form must be sent to the Purchasing Department; a copy should be kept.

Quotation Requirements and Exemptions
Verbal and written quotations are obtained by the requestor.  The Purchasing Department will provide assistance as necessary; it maintains a list of vendors for various types of equipment, materials and supplies. 

This information must be listed on the Purchase Requisition form:  Date, Vendor Contacted, Price and Delivery Terms. 

Quotations are required for all non-exempt purchases $1,000 and above:

REQUISITION                                           
ESTIMATED TOTAL VALUE  (incl S&H)  ACTION
$1,000 - $2,499 Two verbal quotes. Attach quotes to requisition.
$2,500 - $19,999 Three written quotes or written RFP. Attach quotes to requisition.
$20,000 and above Competitive Formal bid required.  Send specifications to Purchasing Department.

PUBLIC WORKS
(ESTIMATED TOTAL VALUE)                                        ACTION
$1,000 - $2,499 Two verbal quotes. Attach quotes to requisition.
$2,500 - $4,999 Two written quotes. Attach quotes to requisition.
$5,000 - $34,999 Three written quotes or written RFP. Attach quotes to requisition
$35,000 and above Competitive bid required. Forward specifications to Purchasing Department.

A good faith effort must be made to obtain the required number of quotations or bid proposals.  If the required number cannot be met, the attempts made must be documented with the requisition (e.g. fax requests, e-mail requests).

Purchases for goods and services costing less than the established ceilings may be price quoted, verbally, or through written/fax price quotations when the Purchasing Agent deems it to be in the best interest of the College.

Competitive Bids
Competitive bids are required by NYS General Municipal Law when the annual aggregate expenditure for a given good or service exceeds $20,000 or for Public Works projects when the annual aggregate amount exceeds $35,000.

The bidding process insures that public funds are spent legally and that the best possible value is received.  It also provides an equal opportunity to those qualified and responsible vendors who want to do business with Mohawk Valley Community College to compete with each other.  A standard bidding procedure assures the public that its money is properly safeguarded.

The competitive bid process requires that only sealed bids be considered. First, the bid is advertised in at least two newspapers. Specifications set the date, place, time and hour that bids must be received by the College.  The bids are opened and read aloud at the published date and hour; no bids are accepted beyond that.  Generally, the lowest responsible bidder is awarded the contract.  If no bid is acceptable, the entire bidding process must be repeated.  Contracts are awarded in compliance with NYS General Municipal law.

To submit a bid request:

• Plan in advance when submitting a request for a competitive bid.  Turn-around time is 14 days for competitive bid requests.  Legal notices, prepared by the Purchasing Department, must be submitted to the newspapers four business days in advance of the publication date.  A bid must be advertised for 5 to 14 days prior to the bid opening, depending on the goods or services being solicited.
• Email to the Purchasing Department the request and a detailed specification of the goods or services needed.
• Once the bid has been awarded, a completed Purchase Requisition form must be submitted to the Purchasing Department to complete the process.

Equipment
Equipment is defined as machinery, vehicles and apparatus costing $1,000 or more with a probable useful life of at least two years that is used repeatedly without any material impairment of physical condition.  All equipment is charged to Account 72100.

Prepayments
Prepayments for travel, goods and certain services are processed when sufficient justification for prepayment is included with the request.  “Prepayment required” must be written on the requisition form, and documentation attached (e.g., a photocopy of the order form) prior to submission to the Purchasing Department for processing.  The Accounts Payable office (ext. 5577) can answer any questions concerning prepayments.

Blanket Orders
Blanket purchase order requests require the approval of the Controller.  Blanket orders allow the purchase of an item on an “as needed” basis and are used primarily for frequent purchases from the same vendor.  “Blanket Order” should be written on the requisition form, as well as a “Not to exceed” dollar amount prior to submission to the Purchasing Department for processing.

Confirming Orders
Verbal or telephone orders, subject to subsequent confirmation by a written purchase order may be given in cases where the need for immediate action exists.  These orders are rare and require approval by the Vice President for Administrative Services or designee.  Lack of proper planning is not justification for confirming orders.   “Confirming Order, Do Not Duplicate” must be written on the Purchase Requisition form, which is submitted to the Purchasing Department for processing.

Purchase Orders
Mohawk Valley Community College uses program generated numbered forms for Purchase Orders for internal control.  The Purchasing Agent is the only person authorized to commit Mohawk Valley Community College to a purchase.  Vendors must be in possession of a properly executed purchase order before goods or services are delivered to Mohawk Valley Community College.

The source document for a purchase order is the Purchase Requisition form.  Requisitions are checked for accuracy, required signatures and supporting documents (e.g. quotations).  Appropriate changes are made in accordance with established procedures.  The Mohawk Valley Community College chart of accounts is used to match the account codes charged against the requested items.  The account code on the requisition must have unencumbered funds to cover the total projected cost.  All requisitions data is then entered into the Banner system and a six-part purchase order is generated.

All purchase orders are reviewed and signed by the Purchasing Agent or the Controller. The printed purchase orders are separated and distributed as follows:
• White copy- Vendor
• Pink copy (Receiving)- Ordering department
• Gold copy- Ordering department
• Blue copy- Business Office
• Yellow copy- Purchasing Department
• Green copy- Inventory Control

Receipt of Goods and Services
All goods from vendors are delivered to the receiving dock in the Facilities Department.  The Facilities Department sends the goods to the receiving department listed on the purchase order.  It is the responsibility of the person receiving the order to inspect the goods and the quantity and compare it to the detail referenced on the purchase order. 

When the goods (or the services rendered) are received:
• Match the items against the pink receiving copy
• Enter the quantity received
• Check the appropriate Material Safety Data Sheet (MSDS) box
• Sign the pink receiving copy
• Obtain a second signature as co-signer
• Return the pink receiving copy to Accounts Payable

When the goods received (or services rendered) are not acceptable:
• The Purchasing Department should be contacted as soon as possible. For goods, the shipping box is saved.
• The Purchasing Department contacts the vendor for a Return Material Authorization (RMA) number and return instructions.
• The Purchasing Department contacts the department with the return information.
• The items returned are denoted on the pink receiving copy as “Returned” and the completed pink receiving copy is sent to the Business Office.

The vendor is not paid until a completed pink receiving copy is returned to Accounts Payable and an original invoice from the vendor is received.

Insufficient Funds
Deans/Directors have the responsibility of verifying available funds prior to submitting a requisition.  Insufficient funds require a transfer of funds through the appropriate channels.  Requisitions are converted to Purchase Orders only after sufficient budget appropriations are made.  Failure to comply with this procedure will significantly delay the processing time of the purchase request.

Budgetary Appropriation Transfer Procedures
A Request for Budgetary Appropriation Transfer form (on the Intranet) is used to transfer funds.  The following must be entered:
• Account Description
• Account Code
• Amount Budgeted From/To
• Increase or Decrease
• Reason for transfer
• Sign and date

The appropriate Vice President /Dean must approve the form and forward it to the Vice President for Administrative Services. Final approval requires the Vice President for Administrative Services and/or the President's Signature (Section 602-4 Code of Standards and Procedures to the Administration and Operation of Community Colleges under the Program of State University of New York).  When approved, the completed document will be forwarded to the department and the Controller, who will make the appropriate amendments in the budget master file.

Transfers within the same organization code and object code do not require Board of Trustees approval.  All other transfers must be approved by the Board of Trustees.

There are four object codes; account numbers beginning with:
6  = PERSONAL SERVICES
72 = EQUIPMENT
74 = CONTRACTUAL
78 = EMPLOYEE BENEFITS

Cancel Purchase Order
To cancel a purchase order:
• Write the reason for the cancellation on the pink Receiving copy
• Sign and return to the Purchasing Department

The Purchasing Department will notify the vendor of the cancellation and liquidate the encumbrance.

Labor Contracts
A certified payroll is required on all labor contracts regardless of the dollar amount and is a condition of payment. A “Certified Payroll Required” notice appears on the purchase order.  The vendor must provide the certified payroll document before payment is made. Exception: a vendor who owns the business and performs all the work is exempt from certified payroll providing the vendor sends a letter to the College attesting to the same.

Travel (Refer to the Travel Procedure)
File a Travel Authorization with Accounts Payable before submitting any requisition relating to travel to the Purchasing Department.  The purchase requisition is not processed until after this document is on file.

For College sponsored bus trips, a list of the attendees must be attached to the requisition before the request is processed.

Approval Requirements
1. All college-wide printing and advertising must be approved by the Director of Marketing and Communications.

2. All computer hardware and software requests must be approved by the Executive Director of Information Technology.  Contact that department for the appropriate procedure to be followed.

3. All charges to other than home department must be approved by the person responsible for the account.  (e.g., if the Vice President for Learning and Academic Affairs wishes to charge a Facilities and Operations account, that charge must be approved by the Vice President for Administrative Services.)

4. The Controller has final approval/disapproval responsibility and authority for any expenditure he/she considers questionable.  He/she is authorized to obtain additional information/justification for any purchase order or voucher.

5. Purchases can be made only if sufficient funds are available in the budget line to be charged.  Should a transfer be required, it must be approved before a purchase is placed.

6. Purchases must be made in accordance with the most recent MVCC Purchasing procedures.

Payment Vouchers
Certain expenditures are exempt from the Purchase Order procedure and do not require a Purchase requisition.  Payment is made on a completed Payment Voucher form (found on the Intranet), with attached documentation. 
Voucher payments are processed for only these items:
• Employee expenses for travel (e.g., conference expenses, mileage, etc.); please see Travel Procedures
• Reimbursement of petty cash fund
• Utility bills
• Legal notices
• Postage meter costs
• Contracts for personal services
• Library materials (e.g. books, periodicals, etc.)

The completed payment claim must contain sufficient detail to satisfactorily audit the claim.  These procedures must be followed:
• The Payment Voucher must be completed in full
• The invoice must be attached
• The appropriate account code, which has sufficient funds, must be noted
• The Voucher must be signed by the petitioner and the supervisor
• The Voucher, with supporting documentation, must be submitted to the Accounts Payable Department

Vendor Access to Employees and Students
Individuals or organizations who wish to sell products or services to College employees may do so only under the following established procedures:

A. Employee Benefits
1. Organizations providing the basic retirement plans may have access to campus rooms as needed to provide services to existing clients.  These include ERS, TRS, TIAA-CREF and the alternate funding vehicles.
2. Vendors of tax-sheltered investment vehicles may offer their products to employees once a year at the spring benefits fair.
3. Vendors of insurance products (health, life, homeowners, auto, etc) may offer their products to employees at both the spring and fall benefits fairs.
4. Credit unions may offer their products to employees at both the spring and fall benefits fairs.
5. Campus visits will be limited to the above times.
6. Vendors of other services require the approval of the Director of Human Resources for campus visits.

B. Special Offers - Special offers will be distributed at a central point on each campus.  Announcements of availability will be made through such vehicles as MVCCToday.

C. Sales by Outside Vendors - Sales may be permitted only if the individual or organization has a contract with the College.

D. Student Groups Hosting an Outside Vendor will follow these established procedures:
1. Vendors must have a valid NYS tax certificate on display at time of sale.
2. Vendors will sell only legally copyrighted or trademarked merchandise.
3. The College at its sole discretion may prohibit vendors from selling products, such as, but not limited to:  phone cards, credit cards, “knock-offs” or products that may be considered “drug paraphernalia.”
4. The College at its sole discretion may end a sale at any time and may prohibit any vendor from future sales on campus.
5. Vendors will supply receipts of purchase to purchasers.
6. A mutually agreed upon contract between the vendor and the organization inviting them on campus must be on file in the appropriate college office.  This contract will contain a “hold harmless” clause for MVCC (Trustees and employees), Oneida County, the officers of Student Congress and officers of the sponsoring student organization.  The contract will have other information and terms as deemed necessary by the College.
7. Space allotted to a vendor will not exceed two 6 foot tables in length.  Said space will be scheduled with the appropriate office no less than 5 days in advance.  Vendors will not impede traffic, compromise safety, or violate fire codes, as determined solely by the College.
8. Clubs will be notified of their ability to negotiate contracts with vendors, in an effort to maximize profitability for the club.
9. The President of Mohawk Valley Community College, or designee, may waive any of these procedures as he/she deems necessary.
10. These procedures will not apply to fundraising done directly by student organizations.  These apply when a student group contracts an outside party to raise funds for them.
11. These procedures will not apply to artists, authors or other entertainers who wish to sell their own material on the day of their performance at the College.
12. A sign will be conspicuously posted indicating what group is sponsoring the vendor.
 

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4003 Travel

Travel expenses that are related to College business will be reimbursed according to the following guidelines.

I. Local Travel
Mileage between campuses and local work or meeting sites will be reimbursed for teaching or other job-related duties without prior approval.  This includes internship sites, business calls, and meetings within the County or a 30-mile range of either campus. This also includes recruitment activities regardless of distance or length of stay. 

Employees who have professional obligations at more than one site on the same day and who use their own motor vehicles for transportation shall be reimbursed at the IRS mileage rate for travel between work sites.  Employees who are assigned to fulfill their professional obligation at off-campus sites located ten miles in excess of the distance normally traveled to their primary worksites and who use their own vehicles for transportation will be reimbursed at the current Internal Revenue mileage rate for travel for the excess distance.

No meals will be reimbursed for same-day visits.

Travel to campus social events and community service meetings/events is not reimbursable.

A Travel Voucher and, as necessary, a Travel Register, is used to claim reimbursement for local mileage and expenses.  These forms can be obtained at (website.edu). 

II. Long-distance Travel
Long-distance travel is defined as travel that is for job-related duties or professional development and is:
• Beyond a 30-mile radius of the employee’s primary worksite, or
• Outside of the County, or
• For meetings/conferences for which there are fees, and/or
• For overnight stays

For such travel, all documented incurred expenses will be reimbursed with prior approval, contingent upon the following regulations.  For the purposes of travel reimbursement, members of the MVCC Board of Trustees are considered employees of the College.  All procedures, except those outlined in A, must be adhered to by Trustees to obtain reimbursement.

A. A completed Request for Travel Authorization form (wherever.website.edu) must be submitted to the Business Office prior to departure.  It is the responsibility of the employee to ascertain that it has been received.  The authorization must include the employee’s and another authorizing signature (generally, the employee’s supervisor, at Director level or above).  Depending upon the total cost of the travel, a second signature, at the next higher level, is required (supervisors are apprised of their signing limits).  The President’s approval is required for his direct reports, regardless of the amount of the travel.

B. A Purchase Requisition (wherever.website.edu) may be utilized to pre-pay such items as registration fees, airline tickets and hotel registrations.  A full description, including the attendee’s name, and the name, date and location of the conference must be stated on the form; copies of the Authorization and registration form or airline/hotel documentation must be attached.  Indicate “prepayment required” on the form.  Such requests must be submitted to the Business Office four weeks prior to the due date for the prepayment.  The Business Office will mail the check with the original registration form unless other arrangements are made.    

C. Travel advances may be obtained through the Auxiliary Services Corporation; the Application for Travel Advance is available at (wherever.website.edu).  Repayment must be made within 15 days of return to campus.

D. The method of travel should represent the greatest economic benefit to the College in terms of time and expense.  It is expected that reasonably priced airfare, lodging and meals will be selected.  Travelers will be requested to justify charges that appear to be excessive.  All reservations for air, hotel, and conference fees, and any changes or cancellations, should be made as early as possible to avoid unnecessary costs.  The supervisor and the Business Office must be notified of any changes.

E. Mileage reimbursement will be paid on the same basis as for local travel.

F. The following types of expenses are not reimbursable by the College: personal telephone calls, valet service, laundry, dry cleaning, personal services, parking and traffic tickets, movie rental, alcoholic beverages, room service, added costs because of guests in company of employees, and any expenses incurred by extending official travel into personal week-ends or vacations.  Lodging is reimbursed for single occupancy.  The employee is required to pay all costs for the guest(s), including transportation, lodging, meals and registration.  Submitted telephone charge receipts must be accompanied by an explanation of to whom the calls were placed, and the purpose of the call.

G. Meal reimbursement during travel will be made according to the following guidelines:

    (Click here to view meal reimbursement table)

H. There is no reimbursement for New York State tax.  Tax exempt forms are available in the Business Office.

I. Travel expenses are reimbursed upon submission of actual costs for applicable transportation, lodging, meals, registration fees, and other expenses, via a Reimbursement Voucher (wherever.website.edu).  The Voucher must include the travel destination, purpose of the trip including statement of “Benefit to the College,” and departure and return times and dates.  It must be signed by the employee and the appropriate supervisor, and a copy of the approved Request for Travel Authorization must be attached.  Original itemized receipts are required.  The only exception is the cost of meals; meals will be paid at the per diem rate when no receipts are supplied: $5.00 for breakfast, $10.00 for lunch and $15.00 for dinner. 

J. Reimbursement Vouchers, with all receipts, must be submitted to the Business Office within thirty days of the travel.  Travel that occurs near the end of the fiscal year must be submitted by August 15th of the current year. 


K. It is the responsibility of the employee to follow these guidelines, and of the supervisor to review the voucher and supporting receipts prior to signing approval.

L. For international travel:
i. Immunizations required by the country being visited will be paid by the College in excess of the amount covered by the employee’s insurance.  The “explanation of benefits” from the insurance company must be submitted to show the amount to be paid by the College.
ii. Passport issuance fees will not be reimbursed.
iii. Entrance visas and departure/exit fees required by some countries are reimbursable, as well as reasonable bills for visa application photographs. 
iv. In cultures where it is appropriate to bring gifts, the College will pay for such gifts, if discussed with and pre-approved by the appropriate Cabinet member in advance.
v. Foreign exchange rates must be documented by exchange receipts.  Use of major credit cards is encouraged for reporting purposes and fairness of exchange rates.

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4004 Meeting Refreshment Reimbursement

The College will pay for or reimburse a business meal or refreshment expense when it is deemed necessary, reasonable and appropriate for official business by the President or a member of the Cabinet.  This authority is not intended for use with the normal daily operations of the College, such as committee and informal meetings consisting solely of College employees.  College funds may be used to entertain guests, such as new employee candidates, speakers, and consultants, if the expense clearly benefits the College. Justification for appropriated funds must include the following:
• Purpose and necessity of the meeting, including the specific nature of College business
• Why the meeting needed to include a meal or refreshments
• The names of participants
• Cost
 

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4005 Outside Vendors

Sales by Outside Vendors - Sales will be permitted only if the individual or organization has a contract with the College.

Employee Benefits:
1. Organizations providing the basic retirement plans may have access to campus rooms as needed to provide services to existing clients.  These would be ERS, TRS, TIAA-CREF and the alternate funding vehicles (ING, Met Life and Valic).
2. Vendors of tax-sheltered investment vehicles may offer their products to employees once a year at the spring benefits fair.
3. Vendors of insurance products (health, life, homeowners, auto, etc) may offer their products to employees at both the spring and fall benefits fairs.
4. Credit unions may offer their products to employees at both the spring and fall benefits fairs.
5. Campus visits will be limited to the above times.

Special Offers: Special offers will be distributed at a central point on each campus.  Announcements of availability will be made in through such vehicles as MVCC Today.

Student Groups Hosting an Outside Vendor:
1. Vendors must have a valid NYS tax certificate on display at time of sale.
2. Vendors will sell only legally copyrighted or trademarked merchandise.
3. The College at its sole discretion may prohibit vendors from selling products such as but not limited to:  phone cards, credit cards, “knock-offs” or products that may be considered “drug paraphernalia.”
4. The College at its sole discretion may end a sale at any time and may prohibit any vendor from future sales on campus.
5. Vendors will supply receipts of purchase to purchasers.
6. A mutually agreed upon contract between the vendor and the organization inviting them on campus must be on file in the appropriate college office.  This contract will contain a “hold harmless” clause, for MVCC (Trustees and employees), Oneida County, the officers of Student Congress and officers of the sponsoring student organization.  The contract will have other information and terms as deemed necessary by the college.
7. Space allotted to a vendor will not exceed two 6 foot tables in length.  Said space will be scheduled with the appropriate office no less than 5 days in advance.  Vendors will not impede traffic, compromise safety, or violate fire codes, as determined solely by the College.
8. Clubs will be notified of their ability to negotiate contracts with vendors, in an effort to maximize profitability for the club.
9. The President of Mohawk Valley Community College, or designee, may waive any of these policies as he/she deems necessary.
10. These policies will not apply to fundraising done directly by student organizations.  These apply when a student group contracts an outside party to raise funds for them.
11. These policies will not apply to artists, authors or other entertainers who wish to sell their own material on the day of their performance at the College.
12. A sign will be conspicuously posted indicating what group is sponsoring the vendor.

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4008 Transfer of Funds

The Administration will establish a procedure for executing the transfer of funds within the budget. All transfers above $30,000 will be reported at regular meetings of the Board of Trustees. The specifics relating to this policy can be found at (link) or in the Business Office.

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4011 Red Flags Rule

Policy and Program Rationale:
Mohawk Valley Community College (“College”) has developed the Identity Theft Policy (“Policy) and Prevention Program (“Program”) pursuant to the Federal Trade Commission’s Red Flags Rule (“Rule”), which implements Section 114 of the Fair and Accurate Credit Transactions Act of 2003. The program was developed with oversight and approval of the Audit Committee of the Board of Trustees. 

Approval and Effective Date of the Policy:
Based on the size of the College’s operations and account systems, and the nature and scope of the College’s activities the Board of Trustees determined that this Policy and Program was appropriate for MVCC.

Approved by the Board of Trustees, effective May 1, 2009.    

Knowledge of this Policy and Program:
All Business Office and institutional personnel with access to data related to covered accounts should be knowledgeable of this policy. 

Responsibilities:
College’s Vice President for Administrative Services is responsible for the execution of the program

Policy:
The purpose of this policy is to establish an Identity Theft Prevention Program designed to detect, prevent and mitigate identity theft in connection with the opening of a covered account or an existing covered account and to provide for continued administration of the Program. The Program shall include reasonable policies and procedures to:

• Identify relevant  red flags for covered accounts it offers or maintains, and  incorporate those red flags into the program
• Detect red flags that have been incorporated into the Program
• Respond appropriately to any red flags that are detected to prevent and mitigate identity theft
• Ensure the Program is updated periodically to reflect changes in risks to consumers and to the safety and soundness of the creditor from identity theft

The program shall, as appropriate, incorporate existing policies and procedures that control reasonably foreseeable risks.

Definitions:
Identify theft means fraud committed or attempted using the identifying information of another person without authority.

Covered account means a consumer account that a creditor offers or maintains, primarily for personal, family, or household purposes that involves or is designed to permit multiple payments or transactions.  Covered accounts include, but are not limited to, credit (debit) cards, loans, and unpaid or partially unpaid student accounts.

Red flag means a pattern, practice or specific activity that indicates the possible existence of identity theft.

Creditor means any person who defers payment for services rendered, such as an organization that bills at the end of the month for services rendered the previous month.  A college or university could be considered a creditor by participating in the Federal Perkins Loan Program, participating as a lender in the Federal Family Education Loan Program, offering institutional loans to students, faculty, or staff, or offering a plan for payment of tuition throughout the semester rather than requiring full payment at the beginning of the semester.

Program:
The following information outlines the details of MVCC’s Identity Theft Program.

Identification of  Covered Accounts:
College has identified five types of accounts, four of which are covered accounts administered by the College and one type of account that is administered by a service provider.

College-covered accounts:

1. Refund of credit balances involving PLUS loans

2. Refund of credit balances, without PLUS loans

4. Emergency loans 

5. The service provider-covered account is a tuition payment plan administered by       Nelnet.


Identification of Relevant Red Flags:
College considers the following risk factors in identifying relevant red flags for covered accounts:

• Types of covered accounts offered or maintained
•  Methods provided to open covered accounts
• Methods provided to access covered accounts
• College’s previous history of identity theft

College will address the detection of red flags (1) when opening new covered accounts by obtaining identifying information about and verifying the identity of a person opening a covered account, and (2) with existing accounts by authenticating persons, monitoring transactions, and verifying the validity of change of address requests.

College considers the following risk factors in identifying relevant red flags for covered accounts:

1. The types of covered accounts as noted above;

2. The methods provided to open covered accounts-- acceptance to the College and enrollment in classes requires all of the following information:
• common application with personally identifying information
• high school transcript  ( GED )

3. The methods provided to access covered accounts:
• Disbursement obtained in person require picture identification
• Disbursements obtained by mail can only be mailed to an address on file

4. The College’s previous history of identity theft.

College identifies the following as red flags:
• Documents provided for identification appear to have been altered or forged;
• The photograph or physical description on the identification is not consistent with the appearance of the student presenting the identification;
• A request made from a non-College issued E-mail account;
• A request to mail something to an address not listed on file;
• Presentation of suspicious or altered personal identifying information or other documents
• Alerts, notifications or other warnings received from consumer reporting agencies or service providers
• Notice from customers, victims of identity theft, law enforcement authorities, or other persons regarding possible identity theft in connection with covered accounts
• Discrepancies in name, address, photograph or physical description on the identification being presented
• Attempts to access an account by unauthorized users
• Unusual use or other suspicious activity related to a covered account

Detection of Red Flags :
The Program will detect red flags relevant to each type of covered account as follows:

1. Refund of a credit balance involving a PLUS loan - As directed by federal regulation (U.S. Department of Education) these balances are required to be refunded in the parent’s name and mailed to their address on file within the time period specified. No request is required.
Red Flag – None as this is initiated by the College.

2. Refund of credit balance, no PLUS loan -  The refund check can only be mailed to an address on file or picked up in person by showing picture ID.
Red Flag – Picture ID not appearing to be authentic or not matching the appearance of the student presenting it. 

3. Emergency loan - Requests must be made in person by presenting a picture ID. The loan check can only be mailed to an address on file or picked up in person by showing picture ID.
Red Flag - Picture ID not appearing to be authentic or not matching the appearance of the student presenting it. Request not coming from a student issued e-mail account.

4. Tuition payment plan - Students must contact an outside service provider and provide personally identifying information.

SEE APPENDIX  A FOR EXAMPLES

Responses to Red Flags Detected:
College will provide for appropriate responses to detected red flags in each type of covered account to prevent and mitigate identity theft.  Responses may include:

• Monitoring a covered account for evidence of identity theft
• Contacting the account holder
• Changing the passwords, security codes, or other security devices that permit access to a covered account
• Reopening a covered account with a new account number
• Not opening a covered account
• Closing an existing account
• Denying access to a covered account until adequate information is available to eliminate the red flag
• Notifying law enforcement
• Determining that no response is warranted under the circumstances

SEE APPENDIX A FOR EXAMPLES

Oversight of the Program:
Responsibility for developing, implementing and updating this Program lies with the Vice President for Administrative Services.  The Vice President for Administrative Services will be responsible for the following:

• Program administration
• Training College staff members on specific responsibility for the Program
• Reviewing any staff reports regarding the detection of Red Flags and the steps for preventing and mitigating identity theft
• Determining which steps of prevention and mitigation should be taken in particular circumstances
• Providing guidance to the Audit Committee of the Board of Trustees as to periodic changes to the Program
• Preparing and delivering an annual report to the Audit Committee of the Board of Trustees  regarding compliance with Red Flag rules

Updating the Program:
This Program will be periodically reviewed and updated to reflect changes in risks to students and the security of the College from identity theft. At least once per year in October, the Vice President for Administrative Services  will consider the College's experiences with identity theft, changes in identity theft methods, changes in identity theft detection and prevention methods, changes in types of accounts the College maintains and changes in the College's business arrangements with other entities. After considering these factors, the Vice President for Administrative Services will determine whether changes to the Program, including the listing of Red Flags, are warranted. If warranted, the Vice President for Administrative Services will update the Program.

Staff Training:
College staff responsible for implementing the Program shall be trained either by or under the direction of the Vice President of Administrative Services in the detection of Red Flags, and the responsive steps to be taken when a Red Flag is detected.

Oversight of Service Provider Arrangements:
College shall take steps to ensure that the activity of a service provider is conducted in accordance with reasonable policies and procedures designed to detect, prevent and mitigate the risk of identity theft whenever the organization engages a service provider to perform an activity in connection with one or more covered accounts.

Currently the College uses Nelnet to administer the Tuition Payment Plan and ACS for the Perkins Loan. Students contacting Nelnet or ACS directly through its website or by telephone and provide personally identifying information to be matched to the records that the College has provided to them.


APPENDIX  A

Example Covered Accounts; Responsible Staff; Red Flags; Responses:

Covered Account: Student Accounts
Responsible Staff: Bursar Office
Red Flag 1:  Suspicious ID presented by a student who is trying to access or alter account. 
Response: Deny access to account until the student's identity has been established through acceptable means.
Red Flag 2: A change of address request occurs under suspicious circumstances.   
Response: Ask student to come in and personally verify address and any suspicious usage activity. 
Covered Account: Financial Aid Account
Responsible Staff: Financial Aid Advisor
Red Flag 1: Department of Education selects student's FAFSA for verification  
Response: Collect supplemental information from student and resolve any conflict between FAFSA and supplemental information provided by student
Red Flag 2: Student submits multiple FAFSAs containing conflicting information
Response: Contact student to resolve conflict and verify information

Covered Account: Email Accounts
Responsible Staff: Information Technology
Red Flag: Notification from student that email has been accessed without authorization 
Response(s): Freeze account; secure account; issue new account if necessary

Covered Account: Banner Accounts
Responsible Staff: Programming Manager/Coordinator
Red Flag: Multiple failed login attempts
Response: Freeze account and/or reset password

Covered Account: Emergency Loans
Responsible Staff: Bursar Office
Red Flag: Inaccurate information on application
Response: Deny loan request until verified with student


BACKGROUND:

The Federal Trade Commission (FTC) issued a Red Flags Rule requiring institutions and creditors to develop Identity Theft Prevention Programs aimed at recognizing and preventing activity related to identity theft.  SUNY campuses come within the definition of creditors as colleges defer payments pending receipt of aid and also engage in the issuance of loans.
The Program must include written policies and procedures for: 1) identifying “covered accounts”; 2) identifying relevant patterns, practices and forms of activity within those accounts that are “red flags” signaling possible identity theft; 3) detecting red flags; 4) responding appropriately to any red flags that are detected in order to prevent and mitigate identity theft; and, 5) administering the program in a manner that ensures proper staff training, implementation, oversight  and updating.
 

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