Master Vendor File Management
REG07.05.01 Current Version
History: New PRR - No History
Related Policies: ECU Policy on Social Security Numbers (SSNs) and Personally Identifiable Information (PII)
Additional Resources: ECU Data Standards Document; ECU Policy on Social Security Numbers (SSNs) and Personally Identifiable Information (PII); ECU Standard on SSN and PII; North Carolina Department of Administration?s Debarred Vendors
Contact Information: Faye Steele, CPA; Financial Services (737-1144; email@example.com)
Anne Jenkins, Associate Vice Chancellor, Financial Services (737-1133; firstname.lastname@example.org)
1.1.1 The purpose of this regulation is to outline the requirements for the appropriate set up and maintenance of the Master Vendor File. The regulation applies to all university vendors (accounts payable, materials management, student stores, patients and insurance carriers, employees, and students).
1.1.2 The primary purpose of setting standards for the appropriate setup and maintenance of vendor files is to prevent the master vendor file from having duplicate vendors, inactive vendors, inaccurate tax ID numbers, and debarred vendors.
1.2.1 The ultimate goal is to maintain a current, accurate and consistent vendor file to reduce the number of duplicate payments, to eliminate IRS notices and fines, to minimize the occurrence of fraud, and to minimize the likelihood of making payments to entities that have been debarred by either federal or state government agencies.
2. Vendor Setup
2.1 Purchasing Vendors, Contractual Vendors, Candidates, Research Participants, Residents/Fellows and Student Stores
2.1.1 The use of a consistent vendor request form is required for purchasing vendors, contractual vendors, candidates, research participants, residents/fellows, and student stores. The form must allow for obtaining “doing business as” designations.
2.1.2 A W-9 or equivalent for a U.S. citizen/business or a W-8BEN and a Foreign Visitor Information Form, if international, is required at the time a new vendor is setup. The Accounts Payable (AP) Department will not process a payment to a vendor until these forms have been received. The AP Department will retain W-9s and similar information in a centralized, secure location or manner.
2.1.3 The Vendor Coordinator within the AP Department will validate vendor data using an independent source, such as the internet or telephone directory, or by contacting the vendor by telephone. Vendor names and tax identification numbers (TINs) will be validated using the IRS’s free, online TIN Matching Program, or equivalent.
2.1.4 All personnel who key vendor setup data will follow the requirements contained in the ECU Data Standards Document.
2.1.5 Access to the master vendor file should be restricted to a limited number of persons, and segregation of duties must be considered. At a minimum, update access to the vendor file should not be permitted for individuals who process invoices, handle checks, nor who initiate purchase orders unless an adequate compensating control is in place.
2.2 Patient Vendors and Insurance Carriers
2.2.1 Patients and various insurance carriers are included in the master vendor file. While most patient vendors are set up with a Banner ID systematically, some are set up individually after a review of discrepancy reports and the information in the professional billing system. Insurance vendors are also set up with a Banner ID individually after a review of the information in the professional billing system.
2.2.2 The ability to set up Banner IDs for patients and insurance carriers should be limited to one individual and a back-up person.
2.2.3 All personnel who key vendor setup data will follow the requirements contained in the ECU Data Standards Document.
2.3.1 Banner IDs for the majority of employees are assigned systematically after application and selection of the candidate of choice.
2.3.2 SSNs for employees are verified by the Payroll Department. The Vendor Coordinator within the AP Department will verify the employee status in Banner prior to assigning an AP address. Prior to setting up an international employee as a vendor, the AP Department will contact the Payroll Department to obtain 1099 withholding information.
2.4.1 Banner IDs for students are assigned systematically at the time of the receipt of an application, transcript, or test score. In a limited number of cases, Banner IDs are created from a paper application. Access to create Banner IDs should be restricted to a limited number of personnel.
2.4.2 The Vendor Coordinator within the AP Department will determine if the SSN information is in the Banner system. If it is not, the Vendor Coordinator will obtain a W-9, or equivalent, prior to assigning an AP address to a student. The AP Department will retain W-9s and similar information in a centralized, secure location or manner. Prior to setting up an international student as a vendor, the AP Department will contact the Payroll Department to obtain 1099 withholding information.
2.5 All Vendors
2.5.1 Payments are placed on hold if complete vendor information is not received, is inaccurate, or is out of date.
3.1.1 Vendors listed on federal and state debarment and terrorist lists will not be added to ECU’s vendor system. The Vendor Coordinator in the AP Department will check websites for the following prior to creating a vendor:
a. North Carolina Department of Administration’s Debarred Vendors
b. Federal debarment and terrorist lists using the screening services of a contracted vendor
3.2 Procedure for Vendors Identified on a Debarment or Terrorist List
3.2.1 The AP Department will notify the Office of Research Compliance Administration (ORCA) within the Division of Research and Graduate Studies of any vendors identified on a debarment or terrorist list.
3.2.2 ORCA will coordinate the investigations of vendors whose name appear in the university’s screening for export control purposes.
4. Modifying Data for Existing Vendors
4.1.1 Treat changes to the data for existing vendors with the same due care as when setting up new vendors.
4.1.2 Retain documentation to justify changing a vendor’s data. If changes are made to the vendor’s legal name, the tax number, and/or ownership type, a new W9 form, or equivalent, is required.
4.1.3 Review reports of vendor data changes and verify for accuracy.
4.1.4 Payments are placed on hold if complete vendor information is not received, is inaccurate, or is out of date.
5. Vendor File Maintenance
5.1.1 The AP Department will review the master vendor file every six months for duplicate vendors and missing or incorrect vendor data. Sort the vendor file in three ways: by taxpayer identification number, by address and by vendor name. Use the IRS’s TIN Matching Program, or equivalent, to match vendor names and taxpayer ID numbers. Use the Postal Service’s National Change of Address Service, or equivalent, to identify address issues. Resolve differences and make corrections immediately.
5.1.2 Should the University receive a CP-2100 Notice from the Internal Revenue Service, the AP Department will investigate and resolve timely the discrepancies between the Internal Revenue Service data base and the University’s master vendor file, at least prior to beginning the 1099 tax reporting process for the next calendar year.
6. Vendor Inactivity
6.1 Inactive Vendors
6.1.1 The AP Department will review vendor activity quarterly to identify inactive vendors. Non-patient vendors and patient vendors without activity for the previous 18 months and 24 months, respectively, should be flagged in the Banner system which prevents the processing of invoices and unauthorized payments from being made. Reactivation should occur only after the completion of the verification procedures described in sections 2 and 3 of this regulation.