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statements, it is clear her efforts were to revise and update the 2010 policies, not to just expound upon or explain old, outdated policy, to university personnel.

The lack of an updated policy and procedures manual, compounded by significant employee turnover, made it difficult to determine the actual procedures used for purchasing at KSU and whether University leadership were aware of the practices followed by employees. An example is the issue of approval limits, which was used to determine what purchases supervisors must approve based on the cost. In interviews, the approval level amounts provided by staff did not agree with KSU’s Business Policies and Procedures Manual established in 2010. When we asked for documentation of the levels used for approvals, staff were only able to provide the “cheat sheets,” or quick referencing guides developed by the former Purchasing Director as informal guidance to staff. Staff also stated that Banner must be programmed to know these approval levels because the system automatically sends the requisition document to the required supervisors. It was then found that the approval level thresholds are historically entered in Banner by the person in the Purchasing Director position. It is concerning that there was no record that the former EVP for Finance, former President, or former Board were aware or had approved the amounts. See Finding 19, for further discussion of this separation of duties concern.

Human Resources

KSU’s Human Resources (HR) Policy Manual was last updated on March 26, 2013. This policy manual contains KSU’s employment policy, description of employee benefits, leave policy, conflict of interest policy, and termination policy among many others. In addition to the HR Policy Manual, KSU has presented on its public website various other policies such as grievance, sick leave sharing, and telecommuting policies. Some of the individual policies presented are contained in the HR Manual but some conflict with what is presented in the manual.

For example, the HR Policy Manual dated March 26, 2013, contains a section which states “employees separating from KSU will be paid for all hours worked and for time in lieu of vacation earned but not taken as of the last day worked [emphasis added].” The new vacation policy, revised December 3, 2020, by the Board, limits the payout of accumulated vacation leave “not to exceed one year’s accrual of their annual vacation leave allowance.” While the vacation policy was officially revised, this policy was not incorporated into the policy manual to replace the prior policy.

TOPS Initiative

Additionally, review of HR policies and the Faculty handbook found KSU had failed to incorporate within its policies, a hiring initiative approved by the Board in June 2017 as part of an academic outreach strategy. The initiative permitted KSU’s Provost to target potential candidates deemed to be “purely exceptional candidates” for faculty positions in lieu of doing an open search for a candidate. The HR Director noted that the policies were not updated to incorporate this initiative as she was not aware of the program. During the examination period, the HR Director would receive a personnel action form with “Tops Initiative” identified, but she thought it might be referring to a grant. According to KSU’s Provost, who began at KSU in June 2021, he has not used this initiative since coming to KSU and does not believe the criteria as established for this program are well-defined. While the initiative is not currently in use by the Provost, it does not appear this matter has gone back to the Board since his arrival at KSU to address whether this is