• KSU maintain its own records documenting expenditure requests and amounts the Foundation paid.

Response: KSU has implemented this recommendation.

• KSU require monthly or quarterly reporting of available funds held at the Foundation be submitted to institutional support or accounting so that reports can be reconciled to KSU's documentation to ensure charges and deposits are applied to the appropriate accounts as intended.

Response: KSU has not yet implemented this recommendation. KSU staff members are setting up an internal structure for tracking funds in and out of each KSU-held account at The KSU Foundation, Inc. ("the Foundation"). Once the internal structure is in place, KSU staff will meet with the Foundation to implement the recommendation.

• MOU should be updated to reflect actual operations/procedures between KSU and its Foundation.

Response: KSU has not yet implemented this recommendation. KSU has prioritized memorializing the processes for making deposits to, and requesting disbursements from, The KSU Foundation, Inc. (“the Foundation”). KSU will work with the Foundation to agree to modifications to the current MOU and establish amendments to reflect the actual operations and procedures now that updated processes have been put in place through Interim Policies.

Finding 14: Former EVP for Finance and Administration Failed to Notify KSU of His Dual Employment Creating a Conflict of Commitment.

Recommendations:

• KSU seek legal guidance to determine options that may be available to recoup any payment for services not rendered by the employee.

Response: KSU has implemented this recommendation.

• KSU provide annual training to all staff with a focus on select KSU policies, to include at a minimum Ethics, Conflicts of Interest, and Conflicts of Commitment.

Response: KSU has not implemented this recommendation. The University is establishing training procedures on select KSU policies to include, at a minimum, ethics, conflicts of interest, and conflicts of commitment.

• KSU create an explicit dual employment policy that requires KSU employees to obtain approval before acquiring secondary employment, whether through revision of the Conflict of Commitment policy or by adoption of a separate stand-alone policy.

Response: KSU has implemented this recommendation.

Kentucky State University – APA Special Examination 90-Day Response – Pa