Skip to main content

Internal Control - Sub-Certification Process

About this Policy

Internal Control - Sub-Certification Process

Policy Number: 21105

Effective Date:
Dec 12, 2017

Last Updated:

Responsible Office:
UM System Controller's Office

Responsible Administrator:
UM System Controller

Policy Contact:

Campus Accounting Office


  • Finance

Request additional information



This policy defines the University’s fiscal year-end financial sub-certification process.

Reason for Policy

The University of Missouri, as a public institution, has fiscal responsibilities and accountability to the State of Missouri, bondholders, rating agencies and its internal and external constituents.  In connection with the external audit of the University’s financial statements, senior management make certain representations as to the accuracy and completeness of the University’s financial statements and the adequacy of its internal control structure.

Policy Statement

In compliance with the spirit of Sarbanes-Oxley legislation requiring greater public accountability for information included in the financial statements, the University implemented a process for certifying the accuracy and completeness of its financial statements.  The process requires senior officers of the University to formally certify the accuracy and completeness of the financial data generated by their organizational units that are included in the financial statements of the University as a whole.  The certification, referred to as sub-certification, includes specific assertions relating to internal controls and financial accountability within the organizational units of the University.  The sub-certifications by senior management of the University, including System Administration and the campuses, are to be reviewed and signed as part of the certification process.

The University of Missouri’s financial organization extends beyond the campus and System accounting offices.  Key personnel from colleges and administrative divisions share the responsibility of managing the University’s financial resources.  It is the collective and shared responsibility of these areas to work cooperatively in ensuring the financial integrity of the University.

In order to make representations for the University as a whole, senior management must take into account the financial position of each of the campuses and other operating entities.  Due to the decentralized environment in which the University operates, senior management at the University of Missouri System and at the campuses must place reliance on internal controls that are in place, documentation of policies and procedures and monitoring of adherence to such policies by its academic and administrative areas.

At the discretion of each of the campus’s chief financial officers, the deans, department chairs, and their respective fiscal officers may be required to certify up to nine assertions as to the financial information and internal controls in the areas for which they are responsible.




Sign Representation Letter to the external auditors for consolidated financial statements of the University

  • President
  • Vice President for Finance and Administration
  • Controller
  • Associate Controller
  • Director, Financial Reporting and Taxation

Required Campus sub-certifications

  • Chancellor
  • Vice Chancellor for Administration & Finance
  • Assistant Vice Chancellor of Finance (if applicable)
  • Accounting Director

Discretionary levels of campus sub-certifications  

  • Deans
  • Department Chairs
  • Fiscal Officers

Additional Details


Campus Financial Sub-Certification
Campus Financial Sub-Certification - explanation

Related Information


Formerly Accounting Policy Manual 2.25.15 – Internal Control – Sub-Certification Process – (revised 7/5/2011)


Reviewed 2017-12-06