POLICY

A. Purpose

This policy defines the types of approvals for the use and disbursement of funds, and / or the recording of adjustments and accruals for materials, goods and services ("financial transactions") at Lawrence Berkeley National Laboratory (Berkeley Lab) and how the authority for those approvals is established. It also defines the roles and responsibilities of Berkeley Lab employees who have been designated as authorized approvers of such financial transactions.

B. Persons Affected

This policy applies to persons who initiate or manage the approvals for the use and disbursement of funds and / or the recording of adjustments and accruals for materials, goods, and services ("financial transactions") on behalf of Berkeley Lab, including persons who have been delegated approval authorities.

C. Exceptions

Not applicable.

D. Policy Statement

1. General
   1. Financial transactions must be properly approved by Laboratory employees with appropriate authority. The required authority will be dependent on the type of transaction.
   2. Authority to approve financial transactions is delegated from the President of the University of California (UC) to the Laboratory Director. The Laboratory Director further delegates this authority to the positions with responsibility for carrying out the related duties. Within Berkeley Lab, Delegations of Authority to approve are subject to the following key principles:
      1. While certain actions can be delegated, accountability cannot be delegated.
      2. A person cannot delegate greater responsibility than he or she has.
      3. Tasks shall only be delegated to people who are qualified to perform them.
      4. A qualified person must:
         1. Be actively involved in the tasks being performed.
         2. Have the appropriate knowledge and technical skills to perform those tasks, including knowledge of relevant regulations and policies. This includes understanding of what their approval means.
         3. Have the authority to carry out the tasks.
      5. A person delegating tasks is responsible for ensuring that those tasks are being properly performed.

   3. In general, delegations of authority to approve are made in conformance with the table below.

      Approver	Receives Authority From
      Lab Director	UC President
      Associate Lab Directors	Lab Director
      Division Director	Lab Director/ Associate Lab Director (ALD)
      Department Head	ALD/Division Director
      Program Manager	ALD/Division Director/Department (Dpt) Head
      Business Manager	ALD/Division Director/Dpt Head
      Chief Financial Officer	Lab Director
      Controller/ Budget Officer/Chief Procurement Officer/Field Finance Head	Chief Financial Officer (CFO)
      Field Finance Manager	CFO/Field Finance Head
      Resource Analyst	CFO/Field Finance Manager
      Department Administrator	ALD/Division Director/Dpt Head
      Disbursement Accountants	CFO/Controller
      General Accountants	CFO/Controller

2. Responsibilities of Authorized Approvers
   1. Individuals authorized to approve financial transactions are responsible for assuring the following:
      • There is an understanding of what is being approved.
      • The information and supporting documentation are accurate and complete.
      • The transaction is allowable, reasonable, and justified.
      • The transaction is charged to the correct project/activity.
      • There are adequate funds to cover the expense.
      • The funding is available and the funding source is appropriate for the expenditure.
   2. Individuals may approve only financial transactions within their authorized dollar limit.
   3. Financial transactions may be approved only by Laboratory employees with the appropriate authority:
   4. By personally signing the required document, or
   5. By personally endorsing their approval online (if appropriate).
   6. Individuals with financial approval authority must comply with all applicable Department of Energy (DOE), UC, and Laboratory policies, laws, regulations, and special restrictions on the use of funds. Unauthorized transactions will be subject to management review. Failure to comply may result in financial and/or criminal liabilities for the individual or the UC.
3. Approval Types
   1. Specific Types of approval authorities and the core responsibilities of individuals who hold those authorities are outlined in the table below.

   2. Approval authorities listed below are not the same as Procurement authority. Only Procurement staff who have delegated Procurement authority may commit Laboratory funds. This commitment of funds occurs when Procurement dispatches the purchase order (PO) after it has all other necessary approvals.

      Type of Approval	Core Responsibility	System(s)
      Time and Labor Approval Authority	Validates that worked hours certified were charged to the benefitting project/activity. Confirms leave taken is charged. Refer to the Time and Labor Reporting policy (“Section D.5”)	LETS
      Resource Adjustments (non-labor and labor)	Validates the adjustment is necessary, appropriate, and timely and includes adequate documentation.	FMS/Manual
      Accruals	Validates the accrual is necessary, appropriate, and timely and includes adequate documentation. Ensures that costs are accounted for in the period in which the benefit is received. Ensures that accruals are made subject to materiality considerations as documented in the Accruals policy.	FMS/Manual
      Travel Approval Authority	Validates the business necessity of the requested trip. Reviews submitted reimbursement for expenses for allowability and allocability for the project / activity being charged.	TREX/FMS
      Requisitions	Ensures that funding is available, the correct item category is selected (may need to consult with Tech Rep), and that benefitting project/activity codes are used. Validates that the items requested are supported by a business justification, and are allowable and reasonable. For purchase of sensitive items, a secondary approval is required by a subject matter expert who ensures the items are appropriate and allowable.	FMS
      Invoice Certification	Validates that invoices adhere to the terms and conditions of the purchase order/subcontract. This includes validating that all required supporting documentation is attached to the invoice before approval. For services, validates they have been satisfactorily performed per purchase order/subcontract requirements. For goods flagged for acceptance in the purchase order, validates any required testing and acceptance is complete, including confirmation that it meets quality assurance requirements. For invoices greater than $100K having a purchase order/subcontract greater than $1M, additional approval levels are required. High-Value Approver validates the appropriateness and necessity of the high-value purchase and Buyer validates the invoice conforms to the terms and conditions of the purchase order / subcontract.	FMS
      Certification of PCards	Validates that the items requested are supported by a business justification and are allowable and reasonable. Validates the correct item category is selected and that benefitting project/activity codes are used. Ensures that necessary documentation is maintained and available for support of the transaction.	FMS

4. Approval Methods
   1. Authorized approvers are identified/captured in the following:
      1. Approval matrices in the Financial Management System (FMS), including Signature Authority System ("SAS") (e.g., requisitions, certifications).
      2. Functional roles established in Berkeley Lab financial systems, (e.g., non-labor adjustments, service accruals).
      3. Published manual approval matrices (e.g., non-service accruals).
      4. Formal delegations of authority, (e.g., formal procurement authority).
5. Administration of Authorities
   1. FMS Signature Authority
      1. Individuals must complete online Laboratory Signature Responsibility Training prior to obtaining signature authority. Department or division managers are responsible for submitting a Delegation of Signature Authority form to the Controller's Office for each of the following actions:
         1. To establish signature authority within the financial systems. This authority must be approved by the Controller for authorization amounts requested greater than $500K.
         2. When an employee having signature authority transfers to another department or division (the employee's new department or division submits the form).
         3. When the signature authority limit of an employee with signature authority has changed.
         4. When an employee is delegated signature authority.
         5. When signature authority of an employee is cancelled.
      2. On an annual basis, the Office of the Chief Financial Officer (OCFO) will formally request that each department/division managers or supervisors review their list of individuals with signature authority. The review consists of identifying whether (1) the assigned approvers require continued access or should be removed and (2) assigned approval limits are appropriate.
   2. FMS Role-Based Authority
      1. Roles in FMS will be assigned based on the individual's required job duties.
      2. Assignment of FMS functional roles will give consideration to segregation of duties.The OCFO's Business Systems Analysis group will maintain roles in the FMS system in accordance with established FMS User Access Control policy.
   3. Published Manual Approval Matrices
      1. Published manual approval matrices are used when the transaction mechanism is not integrated with an FMS approval matrix or role assignment.
   4. Formal Delegations of Authority
      1. UC Office of the President issues formal memos to provide delegated authorities. These delegations remain in effect until superseded or revoked.
      2. The Lab Director determines when to further delegate authority, giving consideration to any limitations set forth in the delegation memos.
      3. The Chief Procurement Officer delegates Procurement Authority to Procurement staff based on qualifications and job requirements.

E. Roles and Responsibilities

Managers, supervisors, and employees have the responsibility to adhere to the provisions of this policy.

F. Definitions/Acronyms

G. Recordkeeping Requirements

none

H. Implementing Documents

I. Contact Information

Controller

J. Revision History

DOCUMENT INFORMATION

Source Requirements Documents

• University of California Office of the President, UC Delegation of Authority (DA) 2100
• UC Standing Order of the Regents 100.4
• Contract 31, Clause I.153, DEAR 970.5232-7, Financial Management System (DEC 2000) (prev. I.107)