The TRAC process and data returns (the Annual TRAC return and charge-out rates and TRAC(T) return) require approval by a Committee of the Governing Body to confirm compliance with TRAC requirements prior to submission to the OfS/Funding Council. Using Chair’s action to gain approval after the TRAC submission deadline is no longer allowed.
TRAC requirements do not specify which Committee of the Governing Body should undertake the review, but the task falls most commonly to the Finance or Audit Committees. The Committee that approves the TRAC returns should have at least one lay, independent or co-opted member and will usually be chaired by a member of the Governing Body (see TRAC Guidance ref. 184.108.40.206).
Responses to questions received regarding the approval of the TRAC returns:
Q1 – My TRAC Oversight Group is composed of members of Senior Management Team, all of whom sit on Committees of the Governing Body. Could I add a lay member to the Oversight group to satisfy the TRAC requirements?
A1 – No, the extended TRAC Oversight Group is unlikely to be a formal Committee of the Governing Body.
Q2 – The meeting schedule for the Finance Committee does not align to the TRAC submission deadlines, could we hold an extraordinary meeting of the Finance Committee to approve the TRAC returns?
A2 – Yes, provided that the meeting is recognised as a formal committee meeting and is minuted, using an extraordinary meeting would satisfy TRAC requirements.
Q3 – It is common practice for my Audit Committee to hold virtual meetings via video conference. Does the Audit Committee need to attend a physical meeting to approve the TRAC return?
A3 – No, the TRAC Guidance only requires that a meeting is held. Therefore if virtual meetings are normal practice, a virtual meeting would be acceptable provided that the meeting is quorate, formally minuted and that Committee members can still access the relevant papers and reports from management to support a thorough consideration of the data return(s) and process followed to generate the returns.
Q4 – Could the Governing Body approve the TRAC Returns rather than a Committee of the Governing Body?
A4 – Yes, if the Governing Body could review the TRAC results directly, the task would not need to be delegated to a Committee of the Governing Body.
Q5 – I can’t identify an appropriate Committee of the Governing Body to approve the TRAC returns before submission. What are the implications?
A5 – If you are not able to meet the TRAC requirement to gain approval before submission, either by using an existing Committee meeting of the Governing Body, or via arranging an additional meeting then please discuss this with your OfS/ Funding Council contact as soon as possible.
Q6 – The University Council usually approves our TRAC returns. Could we establish a new Standing Committee of the Council to approve the TRAC return for this year only?
A6 – Yes, providing that the Standing Committee is a formally recognised Committee of the Governing Body and the membership meets the TRAC requirements.
Q7 – We can’t influence the Committee schedule this year and are seeking to set up specific arrangements to approve the TRAC returns. We cannot get sufficient members of each individual committee together to make the meeting quorate, but we can establish a meeting with some members of the Finance Committee and the Audit Committee in attendance. Could we hold an exceptional meeting with representatives from each committee to provide challenge and review of the TRAC data?
A7 – No, this would not meet the TRAC requirements for approval as the new exceptional meeting would not be a formal committee of the Governing Body. If the institution wants to adopt this approach it should consult the OfS/Funding Council to ascertain whether this would be an accepted way of gaining approval.