Financial Management of Non-Credit Bearing Professional Development Programs Policy

The University at Buffalo (UB, university) establishes and maintains non-credit bearing professional development program rates in accordance with the State University of New York (SUNY) Fees, Rentals, and Other Charges Policy.

A non-credit bearing professional development program is a UB instructional activity with established methods of assessment and articulated learning outcomes.

These general principles govern the development of new rates or changes to existing rates:

• Rates are set based on the full cost of the program for which the fee is charged, including allowable costs
• Rates must recover costs when no other dedicated funds are available for that purpose
• Rates for non-credit bearing professional development programs must be established a level that ensures programs are demonstrably self-supporting
• A consultation process with participants is encouraged, when appropriate; the consultation process may use a committee with representation from the impacted group

A non-credit bearing professional development program billing rate is the cost per participant to participate in the program. Costs included in the rate calculation must be:

• Allowable
• Directly attributable to the program
• A necessary and appropriate component of the rate
• Documented
• Reviewed post-program or annually for recurring programs

New rates and changes to existing rates must be reviewed and approved by:

• Financial Management
• Department chair or head
• Unit Business Officer (UBO)
• University Controller
• Provost Designee

Rates for recurring programs must be reviewed prior to the next program and adjusted as necessary.

Non-credit bearing professional development program rates must be developed so that program revenues offset costs.

With proper approval, program operations may be subsidized, if the program meets research or an educational mission to serve the university. When rates are lower than cost, the resulting deficit cannot be carried forward as an adjustment to future billing rates.

Internal Participants

Participants whose payment source is university funds (State, Research Foundation, UB Foundation) cannot be charged more than cost.

Subsidized Participants

With proper approval, the department may choose to allow attendance at no charge or at a lower rate than other participants, however, the program rate must be calculated for all internal participants based on total expenses and total participants. Variable rates must be based on clear and identifiable criteria.

Margins for External Participants

Departments are permitted to charge external participants a rate higher than the rate charged to internal participants. Departments are required to track revenues and costs associated with external participants separately to avoid the perception of overcharging.

Rates charged to external customers may include:

• Full direct costs of the program operation including direct costs not charged to internal users
• General University Service Fee (GUSF)
• Sales tax, where applicable

External rates cannot be significantly different than the prevailing rate for identical programs provided by other organizations in the area.

Revenue from external users may have Unrelated Business Income Tax (UBIT) implications.

All newly established non-credit bearing professional development program fees must be deposited in a separate account. An Income Fund Reimbursable (IFR) account should be established to record program activity. A Research Foundation (RF) income account, and/or a University at Buffalo Foundation (UBF) account may be established to record program activity with prior approval from Financial Management and the university controller.

Non-credit bearing professional development programs that provide services to a single external customer with multiple participants must have contracts in place.

For programs where funding flows through the State or RF, a university member may not sign or otherwise execute a contract that binds the university unless they have been delegated signature authority in accordance with the Approval Authority Policy. For programs where funding flows through UBF, a university member may not sign.

Refer to the Financial Management of Non-Credit Bearing Professional Development Procedures for additional information.

Registration must be collected using approved non-credit bearing professional development rates.

The department must reconcile accounts receivable against program accounts.

Revenue collection must be processed through a university approved method. Departments may elect not to accept internal methods of payment for the program.

Departments collecting revenue should ensure that the appropriate segregation of duties is maintained to safeguard funds and the university’s reputation, as required in the Safeguarding Cash and Cash Equivalents Policy.

When staffing resources make segregation of duties difficult, compensating controls must be implemented to provide the appropriate checks and balances to detect errors, deter fraud, and prevent concealment of irregularities.

The department must maintain rate development documentation. Documentation includes the actual costs of providing the program, number of participants, billings, collections, and the annual surplus or deficit.

These records are subject to external audit (e.g., federal, state, RF, other sponsors) and internal review.

In the event that a fee is imposed upon students without following the guidelines in this policy, funds collected will be refunded to the payee in full upon request made to the campus or by directive from SUNY System Administration. Requests for refunds must be made within three years of collecting the fee.

The SUNY Board of Trustees established levels of authority and requirements for university charges, as described in the SUNY Fees, Rentals and Other Charges Policy. Section 11, Campus Authorized Fees, states, “Campuses may establish fees for non-credit bearing instructional programs at such a level that the program is self-supporting, inclusive of salary, non-salary, and employee benefit costs.”

This policy provides a framework for consistent financial guidelines for non-credit bearing professional development programs that charge a fee.

This policy applies to all non-credit bearing professional development program rates administered through State, Research Foundation (RF), and UBF accounts.

The Provost Office has authority and oversight of all UB credit and non-credit bearing educational programs but does not oversee fee and fee rates for these programs. Financial Management has authority and oversight of fees and fee rates for all educational programs, including credit-bearing programs that carry an additional fee/fee rate above and beyond tuition.

Deficit

The amount determined when costs exceed revenues for a given fiscal year.

External Participant

Organization or individual whose ultimate source of funds is outside the university. External participants include faculty, staff, and students acting in a personal capacity. Affiliated hospitals and other individuals are also considered external participants unless the university has subcontracted with them as part of a grant or contract, in which case they are an internal participant.

Fee

Referring to the event, program, service or product as a whole. There can be multiple rates for each fee.

Fiscal Year

The 12-month period used for accounting purposes; the university’s fiscal year is July 1 to June 30.

General University Service Fee (GUSF)

Fee charged against external revenue. The service fee is a flat rate charged across all entities on funds generated through the use of university faculty or staff time or use of university facilities.

Internal Participant

An academic, research, administrative, or auxiliary unit whose originating source of funds is within or flows through the university including State, Research Foundation, and UB Foundation funds.

Non-Credit Bearing Professional Development Program

UB instructional activity with established methods of assessment and articulated learning outcomes. Non-credit bearing professional development programs (NCPDP) include:

Continuing Education Programs – Programs where post-bachelorette or post-professional degree holders earn Continuing Education Units (CEUs) used toward maintaining a professional license. CEUs are delivered to community members and alumni; CEUs are not delivered to current UB students.

MOOCs – Massive On-line learning opportunities, typically delivered by UB faculty using a third-party virtual vendor platform. While non-credit MOOCs are designed for non-students, some UB students may participate in these programs.

Micro-Credentials – Digital, short-format credentials that recognize a targeted range of knowledge and career-relevant skills. Micro-credentials may or may not carry academic credit and may be designed for current UB students or non-students

Non-Credit Academic Programs (NCAPs) - Educational workshops or seminars without academic credit offering program learning outcomes but no credentials or CEUs. Participants can be students or non-student (e.g., corporate entities with a revenue contract). NCAPs at UB exclude sports camps for pre-college ages, MOOCs (single-course non-credit programs), and conferences primarily for faculty and staff professional development.

Rate

Individual prices paid or charged (i.e., internal, internal +GUSF, external) for all the different pricing options under a fee; there can be multiple rates associated with one fee.

Subsidized User

User who is charged a lower rate or not charged at all.

Subsidy

Additional funding provided by a department or the university that assists in covering the costs.

Surplus

The amount determined when revenues exceed costs for a given fiscal year.

Unallowable Costs

Costs that cannot be included in calculating the cost of a service or activity.

Unrelated Business Income Tax (UBIT)

Taxes that result from income produced by the sale of goods or services to external users not substantially related to the university’s tax-exempt purpose.

• Obtain approval of the proposed micro-credential from the Office of Micro-credentials, as applicable.
• Complete the Non-Credit Bearing Professional Development Program Fee Approval form to begin the process of developing the rates.
• Provide Financial Management with documentation supporting new rate calculations and adjustments to existing rates using the appropriate fee forms.
• Assist Financial Management with break-even (pro-forma) analysis.
• Establish a separate account in the university's accounting systems to record the actual revenues, billings, collections, and surplus or deficit.
• Document the account and source of funding for subsidies.
• Monitor collections on accounts receivable.
• Review actual costs post program and billing rates annually; adjust when necessary.
• Maintain records to document the actual costs of the program, number of participants, revenues, billings, collections, and the annual surplus or deficit.

• Calculate non-credit bearing professional development program rates with assistance from the department.
• Calculate projected break-even (pro-forma) and perform annual reviews of break-even with assistance of departments.
• Review and recommend approval of new rates and changes to existing rates.
• Forward a copy of all approved fee rates to the Controller and Provost designee for final approval.
• Perform periodic reviews of non-credit bearing professional development program rates to determine consistency with this policy and SUNY guidelines.

• Review any compensation for extra service related to employees working on non-credit bearing professional development program rates.

• Review and approve program rates, including justification for subsidies.
• Provide guidance on establishing and reviewing:
  • Departmental fee accounts
  • Procedures for billing and collecting revenue
  • Standard operating procedures, segregation of duties, and compensating controls

• Review and approve all rates, as appropriate.

• Review and approve all rates, as appropriate.

• Review and approve micro-credential proposals.