Rles and Respnsibilities - Accunting and Financial Reprting Sectin: Accunting and Financial Reprting Title: Rles and Respnsibilities - Accunting and Financial Reprting Number: 05.001 Index POLICY.100 POLICY STATEMENT.110 POLICY RATIONALE.120 AUTHORITY.130 APPROVAL AND EFFECTIVE DATE OF POLICY.140 KNOWLEDGE OF THIS POLICY.150 DEFINITIONS.160 HIGH LEVEL ROLES AND RESPONSIBILITIES.200 ANNUAL FINANCIAL STATEMENTS.205 FINANCIAL REPORTING ENTITY.210 FINANCIAL ACCOUNTING & REPORTING STANDARDS.215 OFFICIAL ACCOUNTING RECORDS.220 PREPARATION OF ANNUAL FINANCIAL STATEMENTS.223 MONTHLY ACCOUNTING PERIOD.225 MONTH END CLOSING OF THE BOOKS.230 QUARTERLY CLOSING OF THE BOOKS.235 ANNUAL CLOSING OF THE BOOKS.240 AUDIT OF ANNUAL FINANCIAL STATEMENTS.245 END OF FINANCIAL STATEMENT PROCESS.300 SYSTEM WIDE CHART OF ACCOUNTS.350 INTERNAL CONTROLS.400 UNIFORM AND CONSISTENT CODING OF ACCOUNTING TRANSACTIONS.450 OTHER FINANCIAL REPORTING.690 CONTACT INFORMATION.695 HISTORY Nne. APPENDIX
POLICY The annual financial statements are prepared frm the fficial accunting recrds f OUS. The Banner Finance Infrmatin System (FIS) at each OUS institutin and the Chancellr's Office is the fundatin f the OUS fficial accunting recrds. Infrmatin in FIS is further supprted by the fllwing subsidiary ledgers that integrate with FIS: Institutins are required t maintain recnciliatins between FIS and the subsidiary ledgers that integrate with FIS. Institutins als have ther subsidiary recrds t prvide mre detail f the amunts in Banner FIS. These subsidiary recrds prvide additinal detail and must agree, but d nt autmatically integrate, with Banner FIS. Each university is required t maintain the recnciliatins between Banner FIS and the nn-integrated subsidiary recrds. Summary infrmatin frm each institutin's Banner FIS is laded int Hyperin Financial Management (HFM) fr financial reprting purpses. HFM is maintained by the OUS Cntrller's Divisin..220 PREPARATION OF ANNUAL FINANCIAL STATEMENTS The annual financial statements are prepared frm Hyperin Financial Management (HFM), which is a cnslidated financial reprting tl, using each institutin's Banner FIS accunting recrds as f "perid 14." The Cntrller's Divisin is respnsible fr administering HFM; and creating the financial statements, including the captins within the financial statements and develping the HFM lgic fr ppulating each captin. The Cntrller's Divisin may make reclassificatins within HFM between financial statement captins. All HFM reclassificatins shuld be viewable by each institutin's business ffice. Occasinally the Cntrller's Divisin must make a HFM adjustment t a university's financial statements. A HFM adjustment results in a change t a university's fund balance between the clsing f the accunting recrds and the issuance f the financial statements. All HFM adjustments must be reviewed with the applicable university's business ffice. The Cntrller's Divisin cmpiles the ther infrmatin needed fr the annual financial statements, e.g. Ntes t the Financial Statements and Management Discussin and Analysis..223 MONTHLY ACCOUNTING PERIODS The Banner FIS accunting recrds are divided int accunting perids 01 thrugh 12. Each perid refers t ne mnth. Fr example, perid 01 runs frm July 1 thrugh July 31; perid 02 runs frm August 1 thrugh August 31, etc. In additin t perid 01 thrugh 12, Banner FIS has a "perid 14" fr recrding institutinal year-end adjustments. OUS fllws the accrual methd f accunting. Revenue is realized in the perid it is earned, and expenses are recrded in the perid they are incurred.
.225 MONTH-END CLOSING OF THE BOOKS T allw fr accrual accunting, the accunting recrds fr each mnthly perid are nt clsed until the 10th day f the fllwing mnth 1. An annual calendar f mnthly clsing dates is prepared by the Cntrller's Divisin. Adherence t the clsing dates is critical t prvide fr immediate cnslidatin f each institutin's and the Chancellr's Office accunting data in t the OUS system-wide accunting databases. Any extensin f a clsing date must be apprved by the Cntrller's Divisin. A. ELECTRONIC DATA DOWNLOADS The auditrs ften require electrnic dwnlads f data t assist them in perfrming the audit. The dwnlads cntain vast quantities f electrnic data. T ensure that the dwnlads cntain cmparable data and are btained the same way frm each institutin's accunting recrds, all electrnic dwnlads requested by the auditrs are perfrmed by the Cntrller's Divisin. B. MANAGEMENT REPRESENTATION LETTERS The auditrs require a signed management representatin letter. The Chancellr's Office reviews and signs the management representatin letter fr the OUS cnslidated financial statements. The Chancellr's Office may request institutinal representatin letters requiring institutinal executive management review and signature. C. MANAGEMENT LETTER COMMENTS The audit f the annual financial statements may result in management letter cmments fr imprving the internal cntrls and plicies ver accunting and financial reprting. The Chancellr's Office prvides a written respnse t all final management letter cmments..100 POLICY STATEMENT The plicy sets frth high-level accunting and financial reprting rles and respnsibilities fr the Chancellr's Office (CO) and the Institutins..110 POLICY RATIONALE OUS seeks t ensure that the high-level rles and respnsibilities f the Chancellr's Office and the Institutins related t accunting and financial reprting are dcumented, cmmunicated, and clearly understd, and applied..120 AUTHORITY ORS 351.085 Duties and Pwers f Chancellr OAR 580 040 0005 Delegatin and Assignment f Respnsibility IMD 6.001 Finance and Business Affairs Accunting Plicies Assignment f Respnsibility
IMD 6.002 Finance and Business Affairs Accunting Plicies Institutinal Respnsibility.130 APPROVAL AND EFFECTIVE DATE OF POLICY Apprved by the Budget and Finance Cmmittee f the Bard n 2/15/02 as part f the Fiscal Accuntability Framewrk Final Reprt. The effective date f the plicy is 3/1/02. Additins t this plicy were apprved by the Assciate Vice Chancellr fr Finance and Administratin/Cntrller n 11/27/06..140 KNOWLEDGE OF THIS POLICY All Chancellr's Office and institutinal persnnel with accunting and financial reprting respnsibilities shuld be knwledgeable f this plicy..150 DEFINITIONS Nne..160 HIGH LEVEL ROLES AND RESPONSIBILITIES A. CHANCELLOR'S OFFICE High level rles Crdinatin Cmpliance Management System-wide Accunting Plicies Chart f Accunts Maintenance Internal Cntrl Management General Accunting Hyperin Accunting System High level respnsibilities Crdinates system-wide accunting and financial reprting needs with institutinal business ffices and State f Oregn State Accunting and Reprting. Ensures that the System's financial recrds are in cmpliance with Generally Accepted Accunting Principles (GAAP). This includes interpretatin f standards and establishing plicy and prcedure t ensure cmpliance with GAAP. Establishes, dcuments, and cmmunicates system-wide accunting and financial reprting plicies. Maintains a baseline standard chart f accunts fr the System. Establishes and mnitrs internal cntrl plicies and prcedures pertaining t system-wide accunting and financial reprting. Perfrms general accunting functins, including primary liaisn t institutinal business ffice accuntants and prepares inter-institutinal accunting transactins related t capital cnstructin prjects and special OUS-wide prgrams. Develps and maintains the Hyperin accunting system which is the surce fr system-wide and OUS-cnslidated annual financial statements, and ther OUS financial reprting.
Financial Data Cllectin Mnitring> Clsing f the Bks Financial Statement Preparatin Year End Financial Statement Entries Recnciliatin Financial Results Interpretatin External Audit Crdinatin SEFA Reprts Cst Accunting IPEDS Preparatin Other Reprts and Analyses Accunting Financial Reprting Prjects Expsure Draft Respnse Crdinatin B. INSTITUTION Perfrms electrnic data dwnlads int Hyperin and recnciles the data t the institutins' Banner financial systems. >Perfrms peridic high-level mnitring and review f the OUS accunting recrds. Issues annual clsing f the bks instructins and prvides system-wide crdinatin f the annual clsing f the bks prcess. Prepares the cmplete annual financial statements fr the System. Prepares and enters Hyperin entries fr financial statement purpses. These include any necessary adjusting entries, cnslidating entries, and reclassificatin entries t present the financial statements and supplemental schedules in accrdance with GAAP. Prepares recnciliatin f the net assets reprted in the annual audited financial statements t the unadjusted net assets recrded in the institutin Banner FIS accunting recrds at the System level and institutin level and prvides a cpy t the institutins. Assists in analyzing financial psitin and results. Crdinates external audit f financial statements between the Internal Audit Divisin, State Audits Divisin, external audit firm, institutins and the Chancellr's Office. Prepares and certifies annual Schedule f Expenditures f Federal Awards (SEFA). Prepares r assists in preparatin f cst accunting studies, including preparatin f facilities and administrative cst prpsals t the Federal gvernment. Cmpletes annual IPEDS survey f financial data fr OUS institutins and the Chancellr's Office. Prvides ther reprts and analysis as needed (fr bth external and internal purpses) that pertain t the financial status and activity f OUS entities. Leads r assists in prjects t imprve the accunting and financial reprting f OUS and the OUS institutins. Crdinates/develps System respnses t expsure drafts frm standardssetting bdies, assists in develpment f State respnses, and als wrks with NACUBO n respnse develpment. Cmmunicates psitins taken t the institutins via the Administrative Cuncil and the Directrs f Business Affairs. High level rles High level respnsibilities Institutinal Accunting Establishes, dcuments and cmmunicates institutin-specific
Plicies Chart f Accunts Maintenance Internal Cntrl Mnitr Accunting Mnitring and Review f Accunting and Financial Data Recnciliatins External Audit Crdinatin Cst Accunting Other Reprts and Analysis Accunting and Financial Reprting Prjects Fact Bk and Ad Hc Reprt Prductin accunting and financial reprting plicies. Maintains institutinal chart f accunts in accrdance with OUS baseline charts and OUS plicy n Chart f Accunts Administratin. Establishes and mnitrs effective internal cntrls at the institutin level pertaining t accunting and financial reprting. Systematically recrds transactins thrughut the year in accrdance with GAAP and System plicies and prcedures, fllws year end clsing prcedures, prepares necessary Perid 14 clsing adjustments, and prduces varius recnciliatins and reprts at year end. Reviews accunting and ther financial data fr accuracy at the institutinal level. Institutins will als research financial infrmatin n behalf f the CO and at the request f auditrs and ther stakehlders. Perfrms nging recnciliatins f subsidiary ledgers t the cntrl accunting recrds. Crdinates external audit f financial statements at the institutinal level. Prepares r assists in preparatin f institutinal cst accunting studies, pssibly including preparatin f facilities and administrative cst prpsals t the Federal gvernment. Prvides ther reprts and analyses as needed (fr bth external and internal purpses) that pertain t the financial status and activity f the institutin. Leads r assists in prjects t imprve the accunting and financial reprting f OUS system-wide and OUS institutins. Prduces and publishes ad hc reprts and selected financial data within the institutin's respective fact bks. This infrmatin is unaudited, and may include presentatins that are incnsistent with the System's audited financials and the institutins' supplemental schedules..200 ANNUAL FINANCIAL STATEMENTS The Chancellr's Office Cntrller's Divisin prepares the annual financial statements fr the Oregn University System. The annual financial statements fllw the fiscal year July 1- June 30, and are issued within six mnths f the end f each fiscal year. The financial statements are audited and presented t the State Bard f Higher Educatin fr their review and acceptance..205 FINANCIAL ACCOUNTING ENTITY The OUS annual financial statements are prepared n a cnslidated basis, and include all funds and accunts f Eastern Oregn University, Oregn Institute f Technlgy,
Oregn State University, Prtland State University, Suthern Oregn University, the University f Oregn, Western Oregn University and the Chancellr's Office. The OUS annual financial statements als reprt the financial activity f university fundatins based n the nature and significance f their relatinship t OUS. These include Eastern Oregn University Fundatin, Oregn Tech Fundatin, Oregn State University Fundatin, Prtland State University Fundatin, Suthern Oregn University Fundatin, University f Oregn Fundatin, Western Oregn Develpment Fundatin, and Agricultural Research Fundatin. Financial activity f the fundatins are reprted n separate pages within the financial statement as discretely presented cmpnent units t emphasize that they are tax-exempt nn-prfit rganizatins legally separate frm OUS. The OUS annual financial statements d nt include rganizatins that are nt financially accuntable t OUS institutins, such as bster and alumni rganizatins. OUS is a part f the primary gvernment f the State f Oregn and is included as a prprietary (enterprise) fund in the State f Oregn Cmprehensive Annual Financial Reprt (CAFR)..210 FINANCIAL ACCOUNTING & REPORTING STANDARDS The OUS financial accunting recrds are maintained in accrdance with generally accepted accunting principles (GAAP). GAAP is in the frm f a hierarchy f Levels A, B, C and D, with the understanding that higher levels (e.g., GAAP Level A) take precedence ver lwer levels (e.g., GAAP Level D). OUS adheres t the accunting standards, principles and plicies f the fllwing rganizatins: A. GOVERNMENTAL ACCOUNTING STADARDS BOARD (GASB) GASB was created in 1984 and is charged with the respnsibility f establishing accunting principles fr state and lcal gvernments, including gvernment-cntrlled clleges and universities. The OUS Cntrller's Divisin reviews the GASB Statements f Gvernmental Accunting Standards (GAAP Level A), and designs and cmmunicates OUS accunting plicies fr implementing the GASB statements. B. FINANCIAL ACCOUNTING STANDARDS BOARD (FASB) FASB was created in 1973 and is the designated rganizatin fr establishing accunting and financial reprting standards fr the private sectr. OUS applies FASB Statements f Financial Accunting Standards (GAAP Level A) issued n r befre Nvember 30, 1989, unless thse statements cnflict with r cntradict GASB standards. OUS als
applies the frmer Accunting Principles Bard (APB) Opinins and the frmer Cmmittee n Accunting Prcedures (CAP) Accunting Research Bulletins, unless thse standards are superseded by FASB r cnflict with r cntradict GASB standards. GASB statement N. 20 prvides the ptin f adpting FASB standards issued after Nvember 30, 1989, except fr thse that cnflict with r cntradict GASB standards. OUS has chsen nt t adpt this ptin. C. AMERICAN INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS (AICPA) OUS fllws the recmmendatins in the 1975 secnd editin f the AICPA Audits f Clleges and Universities (GAAP Level B), unless thse recmmendatins cnflict with r cntradict GASB standards. D. NATIONAL ASSOCIATION OF COLLEGE AND UNIVERSITY BUSINESS OFFICES (NACUBO) OUS fllws the Financial Accunting and Reprting Manual fr Higher Educatin (FARM) (GAAP Level D) published by NACUBO, unless thse recmmendatins cnflict with r cntradict GASB standards. E. STATE OF OREGON The fllwing State f Oregn references impact OUS's applicatin f generally accepted accunting principles: Oregn Revised Statutes (ORS's), primarily Chapter 351 pertaining t Oregn Higher Educatin. ORS's are created by the State Legislature. The ORS's pertaining t accunting and financial issues impact the OUS financial accunting and financial reprting plicies. Oregn Accunting Manual (OAM), issued by State f Oregn Department f Administrative Services (DAS). OUS is nt required t fllw the DAS OAM, but uses the manual as a reference fr develping its financial accunting and financial reprting plicies. Unifrm Management f Institutinal Funds Act (UMIFA) as adpted by the Oregn State Legislature. UMIFA gverns the management and distributin f endwment funds and thereby affects the accunting f OUS investments. F. FEDERAL GOVERNMENT OFFICE OF MANAGEMENT & BUDGET (OMB) OUS fllws the cst principles required by OMB Circular A-21, Cst Principles fr Educatinal Institutins. G. OREGON UNIVERSITY SYSTEM
The fllwing OUS references impact applicatin f generally accepted accunting principles: Oregn Administrative Rules (OARs), Chapter 580 - Chapter 580 OARs are created by the State Bard f Higher Educatin (the Bard) and published by the Secretary f State's Office after apprval at public meetings. OAR 580-040-0005 delegates general supervisin f fiscal and administrative activities t the Chancellr and designated staff and is the basis fr preparing the OUS financial accunting and reprting plicies. OUS Internal Management Directives (IMD's) - IMD's are created and issued by the Bard and supprt specific cmpnents f the OUS financial accunting and reprting plicies. OUS Fiscal Plicy Manual (FPM) - The FPM is written and issued by the OUS Chancellr's Office and is used t recrd and cmmunicate fiscal plicies f the Chancellr's Office. The fiscal plicies pertaining t financial accunting and reprting are issued by the Cntrller's Divisin..215 OFFICIAL ACCOUNTING RECORDS Banner Fixed Assets Accunts receivable recrds in the Banner Student Infrmatin System (SIS) Human resurce and payrll recrds in the Banner Human Resurces Infrmatin System (HRIS) Interim wrk which includes the review f the internal cntrls f each institutin Infrmatin Technlgy (IT) wrk in reviewing the internal cntrls ver IT as they relate t the annual financial statements and Federal grants and cntract cmpliance OMB Circular A-133 cmpliance audit f Federal grants and cntracts Financial statement wrk A clsed accunting perid with Banner FIS means that n additinal accunting transactins may be recrded in that accunting perid. Once an accunting perid is clsed, it may nt be repened, except in an extreme and unusual circumstance and requires apprval f the Cntrller's Divisin. 1 If the 10th f the mnth falls n a weekend r a hliday, the clsing date is the clsest wrkday that precedes the 10th..230 QUARTERLY CLOSING OF THE BOOKS Quarterly clsing f the bks ccurs with the clsing f perid 03 (September), perid 06 (December), perid 09 (March), and perid 14 (June). The quarterly clse becmes the basis fr preparing the quarterly management reprts presented t the Bard..235 ANNUAL CLOSING OF THE BOOKS
The annual clsing f the bks is perfrmed by each university frm apprximately July 12 thrugh July 25. The annual clsing f the bks becmes the basis fr the annual financial statements. Annual clsing f the bks instructins and assciated due dates are develped and cmmunicated by the Chancellr's Office Cntrller's Divisin..240 AUDIT OF ANNUAL FINANCIAL STATEMENTS The OUS annual financial statements are audited by the Oregn Secretary f State Audits Divisin. The Audits Divisin may cntract ut the annual audit t an external CPA firm. The annual financial statement audit begins with an OUS-wide entrance phne cnference between the Audits Divisin, the external audit firm, the Chancellr's ffice and the institutinal business fficers. The annual financial statement audit is crdinated thrugh the OUS Internal Audit Divisin and the Cntrller's Divisin. The scpe f the annual financial statement audit includes: General plicies fr crdinating the annual audit include the fllwing: Effectiveness and efficiency f peratins Reliability f financial reprting Cmpliance with applicable laws and regulatin.245 END OF FINANCIAL STATEMENT PROCESS The annual financial statement audit ends with a presentatin by the external audit firm t the Bard f Higher Educatin..300 SYSTEM-WIDE CHART OF ACCOUNTS The Chancellr's Office maintains a system-wide baseline chart f accunts t ensure unifrmity f the financial accunting and reprting f the seven institutins and the Chancellr's ffice. Institutins are required t fllw the system-wide baseline chart f accunts. Fr additinal infrmatin, see OUS Fiscal Plicy Manual sectin 05.110 pertaining t Chart f Accunts Administratin..350 INTERNAL CONTROLS Management at each institutin and the Chancellr's Office is respnsible fr establishing and maintaining sufficient internal cntrls. Internal cntrls are designed t prvide reasnable assurance regarding the achievement f bjectives in the fllwing categries: In September 1992, the Cmmittee f Spnsring Organizatins (COSO) f the Treadway Cmmissin issued the "Internal Cntrl - Integrated Framewrk" reprt. OUS uses the COSO mdel as a basis fr designing sufficient cntrls ver its financial accunting and reprting prcess. The COSO mdel includes five interrelated cmpnents:
A. CONTROL ENVIRONMENT The cntrl envirnment sets the tne f an rganizatin, influencing the cntrl cnsciusness f its peple. It is the fundatin fr all ther cmpnents f internal cntrl, prviding discipline and structure. Basic t the cntrl envirnment are rganizatin structure, assignment f authrity and respnsibility, and human resurces plicy. Mre difficult t quantify are ethics, cmmitment t cmpetence, and management perating style. B. RISK ASSESSMENT Risk assessment is the identificatin and analysis f risks relevant t achievement f bjectives, frming a basis fr determining hw the risk shuld be managed. Management's respnsibility is t define cmpatible, relevant bjectives and the risks related t achieving thse bjectives. Management shuld have a basis fr determining which risks are mst critical. Management is als respnsible fr ensuring mitigatin f key perating risks. C. CONTROL ACTIVITIES Cntrl activities are the plicies and prcedures that help ensure management directives are carried ut. Cntrl activities reflect management's risk mitigatin strategy in the frm f directive, preventive and detective cntrls. Fcus is n achieving effective and efficient resurce usage as measured by the degree f achievement f cntrl bjectives. Cntrl activities help ensure necessary actins are taken t address risks relevant t achievement f bjectives. Examples are physical cntrls and segregatin f duties. D. INFORMATION AND COMMUNICATION Infrmatin and cmmunicatin are the identificatin, capture, and exchange f infrmatin in a frm and time frame that enable peple t carry ut their respnsibilities. Infrmatin systems deal with bth internally generated data and infrmatin abut external events, activities, and cnditins. Cmmunicatin invlves prviding an understanding f individual rles and respnsibilities pertaining t internal cntrl. Management is bligated t cmmunicate the standards f measurement fr evaluating peratins. In ther wrds, sufficient relevant cmmunicatin prmtes awareness f internal cntrl bjectives s emplyees understand hw their individual actins interrelate and recgnize hw and fr what they will be held accuntable. E. MONITORING Mnitring is a prcess established by management that assesses the quality f internal cntrl perfrmance ver time. Mnitring prvides external versight, either nging r
in the frm f independent checks f internal cntrls by management r ther parties utside the prcess..400 UNIFORM AND CONSISTENT CODING OF ACCOUNTING TRANSACTIONS A financial entity the size f OUS, cmprising seven institutins and a chancellr s ffice, results in a large number f accunting transactins. A key t the accuracy f the accunting recrds is the crrect cding f each accunting transactin. Each accunting transactin must be recrded t the crrect fund and accunt. As need be, each accunting transactin must als be recrded t the crrect cdes applicable t that transactin, such as rganizatin cde, prgram cde, bank cde, asset type cde, earnings cde, etc. Each institutin and the Chancellr s Office must have sufficient preventive and/r detective cntrls in place t ensure the crrect unifrm and cnsistent cding fr like types f accunting transactins. T help supplement each institutin s review f their accunting transactins, the Cntrller s Divisin reviews summary accunting recrds fur times each year, ne mnth befre the clse f each quarter (as f August 31, Nvember 30, February 28, and May 31). This frm f mnitring searches fr accunting transactins with incmpatible fund and accunt cdes. Results f the mnitring alng with a requested institutinal respnse are cmmunicated t the institutinal business ffices n a quarterly basis..450 OTHER FINANCIAL REPORTING Other financial reprts prepared fr external stakehlders include the fllwing: A. SEFA REPORT The Schedule f Expenditures f Federal Awards (SEFA) is a State f Oregn reprt required by the Federal Gvernment. The SEFA reprts the annual expenditures made by State f Oregn agencies f Federal awards. The Cntrller s Divisin prepares the SEFA fr OUS n a cnslidated basis. The OUS SEFA is frwarded t the Department f Administrative Services, wh cmpiles the SEFA data frm all state agencies int the SEFA fr the State f Oregn. The SEFA fr the State f Oregn is issued by the Oregn Secretary f State Audits Divisin each year n February 28, eight mnths after the clse f the fiscal year. B. IPEDS REPORT The Integrated Pst-secndary Educatin Data System (IPEDS) is a system f surveys designed t cllect data frm all primary prviders f pst-secndary educatin. The Cntrller s Divisin cmpletes the prtin f the annual IPEDS survey cntaining financial data f the OUS institutins and the Chancellr s Office. Each institutin
reviews the IPEDS data pertaining t its institutin befre data input t the IPEDS survey is finalized and clsed..690 CONTACT INFORMATION Direct questins abut this plicy t the fllwing ffices: Subject General questins frm institutinal persnnel General questins frm institutinal central administratin and Chancellr's Office persnnel Cntact Institutin Office f Business Affairs Chancellr's Office Cntrller's Divisin.695 HISTORY 2/15/02 - Apprved 10/15/03 - Refrmatted 11/27/06 - Additins Apprved Plicy Last Updated: 11/27/06 APPENDIX Appendix Last Updated: 10/15/03