Audit Guidance

Campus Administered Construction Projects

2015.02 - September 9, 2015

Overview

Under the terms of a Memorandum of Understanding (MOU) between the State University Construction Fund (SUCF) and each campus, a campus may construct, rehabilitate, maintain, and repair its capital facilities. As part of the MOU, the campus must comply with certain SUCF and SUNY policies and procedures for the administration and management of Campus Administered Construction Projects (CAC Projects). CAC Projects are procured utilizing construction contracts (building, renovating, and reconstructing the Campus’ buildings and infrastructure) and consultant service agreements (architecture, engineering, and surveying services).

SUNY’s Office of the University Auditor (OUA) conducted several CAC Project audits and prepared this document to highlight improvement opportunities identified during these audits. These practices will help ensure that campuses have established key controls related to the administration and management of CAC Projects.

It should be noted that this document is not meant to be a comprehensive reporting of all requirements. It is representative of observed concerns.

Improvement Opportunities Identified

Develop and maintain comprehensive up-to-date written procedures for the management and administration of CAC Projects including procurement and contracting, field orders and change orders, project payments, project monitoring, and project closeout.
Establish procedures for soliciting Minority and Women Owned Business Enterprises (M/WBE) to help ensure that M/WBEs are given an opportunity to provide construction and consultant services.
Require those staff members responsible for opening and recording bids to sign the bid tabulation form as evidence of their participation in the bid opening process.
Provide each selection committee member with a list of consultants being considered and require each member to complete a conflict of interest disclosure form.
Publish a notice of award in the New York State Contract Reporter for each contract and agreement, and ensure that the notice includes (1) the name of each bidder and the amount of each bid for construction contracts awarded pursuant to an Invitation for Bid or (2) the name of each proposer and the proposal selected as the best value for consultant agreements awarded pursuant to a Request for Proposal.
Post the SUNY Procurement Certification form to the SUNY Procurement Officers document repository space (Confluence) for all contracts with a total dollar value over $250,000, as required by the Guidelines.
Utilize the SUNY Construction and Consultant Procurement Record Checklists to help ensure all required documents have been completed (see the “Useful Links” section of this document).
Require an employee independent of the procurement process to conduct a comprehensive review of the procurement record to ensure all required documents are maintained.
Ensure all selection committee members review each proposal submitted and initially rate each proposal to identify the five consultants with the highest ratings (short list) to continue in the selection process and be considered for the project.
Require contractors to submit monthly or quarterly M/WBE utilization reports in order to monitor the contractor’s progress in meeting the established M/WBE goals outlined in the contract.
Establish a formal review and approval process for field orders and change orders. The assessment should verify that:
- Labor rates, overhead, and profit are in accordance with the contract
- labor hours and material quantities are appropriate for the scope of work.
Require the prime contractor to provide the campus with a list of subcontractors and the amount each subcontractor is expected to receive during the life of the contract and conduct a vendor responsibility review for each subcontractor that is expected to receive $100,000 or more in payments over the life of the contract.
Conduct periodic reviews of CAC Project accounts and ensure payments are charged to the correct project and account.
Journal transfer employee labor costs initially charged to campus operation funds to the proper capital project account(s) on at least a monthly basis.
Sub-allocate each Minor Critical Maintenance (MCM) project within the SUNY accounting system and charge MCM projects under $5,000 to Campus operating funds.

Useful Links

SUNY Construction Contracting Procedures and Checklist

SUNY Construction-Related Consultant Contracting Procedures and Checklist

SUNY Office of Capital Facilities Guidance Documents

For additional information, please contact the Office of the University Auditor at 518-320-1533 or University.Audit@sysadm.suny.edu