The University of California, San Francisco (UCSF) is home to four professional health schools: dentistry, medicine, nursing, and pharmacy. Although we don’t have any undergraduates, we do have more than 3,300 students enrolled in degree programs, 1,500 clinical residents or fellows, and 1,000 postdoctoral scholars in three main clinical sites and more than two dozen ancillary sites throughout northern California.
Because of its singular focus on advancing health worldwide, UCSF also conducts research in 137 countries. This extensive global presence ranges from South America to Europe, and from Africa to Asia. The university’s Institute for Global Health Sciences (IGHS) coordinates a significant share of the international work, which includes programs undertaken with various partners or by one of UCSF’s own nongovernmental organizations (NGOs).
In 2015, IGHS was preparing to register its third NGO. Each NGO was structured differently, based on the particular country’s requirements, which was proving burdensome for the offices that provided support. IGHS staff saw an opportunity to take a holistic look at international operations, including the accompanying business risks. They convened a working group of campus experts from these functions: human resources, research administration, compliance, audit, accounting, purchasing, tax, risk management, researchers, provost, and legal.
The working group evaluated the existing infrastructure supporting UCSF’s global presences, inventoried the business risks, identified needs, and benchmarked other universities’ international operations. For example, we reviewed UCSF’s existing NGO structures to determine commonalities as well as gaps. Because UCSF is part of a university system, we also identified the limitations of the delegated authorities issued by the University of California Office of the President (UCOP).
The group completed its work in nine months. Its recommendations included:
- Have a single core governing board for all NGOs. Some institutions have a single NGO that operates in multiple locations; to conform to the delegated authorities, however, UCSF has stand-alone NGOs. One core board provides consistency among the NGOs’ policies, particularly as similar concerns or issues come up in different countries. Additional country nationals are added to the core board where required by law. The board UCSF established essentially serves as an adviser to the provost, recommending policies that apply to all international activities, not just NGOs.
- Create a technical advisory group. Most of the NGO board members do not have detailed knowledge of international operations, so they look for information from subject matter experts. UCSF’s ad hoc working group made an easy transition to a permanent technical advisory group that meets quarterly to review and offer assistance on global policy, procedures, and activities. The advisory group initially had members drawn from the functional areas of the 2016 working group, but soon expanded its membership to include representatives of six more functional areas: public relations, real estate, communications, UCOP, information technology, and investment services.
Subcommittees of the advisory group meet frequently to address specific issues. For instance, one subcommittee identified the need to better educate procurement staff on how the definition of an independent contractor—and the related withholding responsibilities—can vary from one country to the next. The procurement workflow was rearranged so staff now must evaluate compliance with the country’s requirements before signing a contract.
Similarly, another subcommittee found inconsistencies in how UCSF handled taxes and benefits for expatriate employees; it was possible that an expatriate in one country could be losing money while one in another country was benefiting from the tax structure. The advisory group recommended that the campus adopt a policy that treats all expatriates the same, regardless of their country assignment.
Legal counsel is a critical participant in the advisory process. UCSF has a deputy counsel at the campus level who specializes in international projects, plus access to an expert in the president’s office. The deputy counsel reviews program needs, local laws and practices, entity maintenance requirements and costs—such as audits and reporting—taxes, foreign capital, and dissolution rights to decide if and what type of registration is appropriate. Our campus counsel also looks at the country’s general index of integrity or corruption and its ease of doing business, in addition to selecting in-country counsel to handle the requisite paperwork.
- Dedicate staff and resources to international operations. UCSF aims to take a more proactive approach with international projects. This requires the technical advisory group to become involved before or immediately after a faculty member applies for a grant—which doesn’t always happen because UCSF currently lacks a single point of contact.
This drawback was emphasized not too long ago, when the contracts and grants office determined a vendor had begun the NGO registration process on UCSF’s behalf—in a country still awaiting the regents’ approval of the university’s presence there. A dedicated office could better enforce the criteria—which include a project’s length, level of activity, and costs—developed by the advisory group to govern the creation of an NGO. In 2016, and again in 2017, funding was requested to support an international office, located within IGHS. We just received notification that funds to support a central office will be allocated in the FY18–19 budget.
A Growth in International Operations
Since undertaking the initial assessment of its international operations nearly four years ago, UCSF has experienced considerable growth in these operations. One UCSF in-country office, for instance, has gone from processing one grant of $1 million to processing 15 grants that total nearly $20 million annually. The university now has five NGOs—all registered in Africa—and two legal office registrations, in Africa and Asia; these are continents where UCSF typically must do its own capacity building because of a lack of partners.
The technical advisory group’s work has made it possible for those NGOs to develop manuals for HR, IT, procurement, and finance operations that are standardized and consistent with UCSF policies in the United States. Another sign of progress is the heightened awareness of international activities exhibited by UCSF leadership. As just one example, UCSF’s internal audit department recently added an international assessment component to its annual plan. All NGOs will be treated like any other department and be assessed for their effectiveness in implementing university policies.
SUBMITTED BY Mary Catherine (MC) Gaisbauer, assistant controller, contracts and grants accounting, University of California, San Francisco