Reporting Fraud, Waste & Abuse
FRAUD: The intentional perversion of truth in order to induce another to part with something of value or to surrender a legal right; an act of deceiving or misrepresenting. Merriam-Webster
Fraudulent activities include but are not limited to:
- Misapplication, destruction, removal or concealment of property, or conflicts of interest;
- Forgery or alteration of checks, drafts, promissory notes, and securities;
- Forgery or alteration of employee benefit or salary related items such as timecards, billings, claims, surrenders, assignments, changes in beneficiary, etc.;
- Forgery or alteration by employees, of student related items such as grades, transcripts, loans, fee or tuition documents, etc.;
- Theft of funds, securities, supplies or any other asset;
- Illegal or fraudulent handling or reporting of money transactions;
- Acceptance or solicitation of any gift, favor, or service that might reasonably tend to influence the employee in the discharge of his/her official duties (conflict of interest);
- Destruction or disappearance of records, furniture, fixtures, or equipment where theft is suspected;
- Acts which are against or not authorized by Federal, State, or Local Law;
- Authorizing or receiving payment for hours not worked;
- Authorizing or receiving payment for goods not received or services not performed.
WHAT IF I SUSPECT FRAUD?
Legal ramifications for the Auditor and the University dictate strictly confidential treatment of information obtained in connection with fraud, misuse, or illegal act investigations. The University Policy on Employee Fraud states that the employee should report suspected incidences to his/her superior (or the next higher level if the supervisor may be involved), or the Office of Internal Audit and Assurance. You may also contact one of the following persons to report any suspected improprieties:
Texas Southern University
Office of Internal Audit & Assurance
Mrs.Charla Parker-Thompson, Chief Audit Executive; 713.313.7415
Mr. Keith Beckford, Fraud Manager; 713.313.7419
Office of General Counsel 713.313.7950
Department of Public Safety; 713.313.7000(emergency)
UNIVERSITY WHISTLEBLOWING POLICY
Texas Southern University Operating Manual Section XXXI, Whistle Blowing Policy, pursuant to Government Code Chapter 554, Protection for Reporting Violations of Law, states that the University may not suspend or terminate the employment of, or otherwise discriminate against, a staff member who reports a violation of the law to the appropriate law enforcement authority if the employee’s report is made in Good Faith. Legal Remedies are made available to resolve any form of retaliation.
Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid incorrect accusations or alerting suspected individuals that an audit is underway and also to avoid making statements which could provide a basis for a suit for false accusation or other offences. Accordingly, the reporting individual should:
A. Not contact the suspected individual to determine facts or demand restitution;
B. Not discuss any facts, suspicions or allegations associated with the case with anyone, unless specifically directed to do so by the Offices of Internal Audit and Fraud, University Police, or the Office of General Counsel.
All inquiries from the suspected individual, their representatives, or their attorney shall be directed to the Office of General Counsel. Proper response to such an inquiry should be:"I'm not at liberty to discuss this matter". Under no circumstances should there be any reference to "what you did", "the crime", "the fraud", "the forgery", "the misappropriation", etc.
To the extent permitted by the applicable provisions of the Texas Public Information Act, Texas Government Code, Chapter 552, confidentiality of those reporting dishonest or fraudulent activities will be maintained. However, confidentiality cannot be maintained if that individual is required to serve as a witness in legal proceedings.
The Office of Internal Audit & Assurance will determine the validity of allegation by completing the following steps:
A. Notify the employee that the information obtained may be discussed with the President and/or Board of Regents prior to conducting detail discussions with University employees.
B. Inform the employee that the source of the information provided is strictly confidential except for possible disclosure to the aforementioned parties.
C. When appropriate, immediate action will be taken to secure and protect all pertinent documentation from destruction or alteration.
D. Discuss findings with management and appropriate administrators for action.
All reproduction of documents, evidence and reports shall be performed within the secured work area of the Offices of Internal Audit and Fraud, General Counsel, or University Police. The Internal Audit Office will keep its work papers secure and limit access to only those individuals designated by the Director of Internal Audit and Fraud. No written communications will be issued by the Internal Audit and Fraud Department until the investigation is complete.
Management is responsible for establishing and maintaining a system of internal control that provides reasonable assurance that improprieties are prevented and detected. Each Manager should be familiar with the types of improprieties that might occur in his/her area and be alert for any indication that such fraud or dishonest or improper activities are or were in existence.
UNIVERSITY POLICE DEPARTMENT
In order to avoid the use of investigatory techniques that might prevent evidence from being used in a criminal prosecution, University Police will coordinate the criminal investigation once probable criminal activity has been detected. The Office of Internal Audit and Fraud shall assist the University Police in investigations of suspected theft, misappropriation and other fiscal irregularities that require accounting and auditing knowledge of system records.
ACTS NOT INVESTIGATED BY INTERNAL AUDIT
Alleged illegal acts that will not be investigated by the Office of Internal Audit and Fraud include suspected incidences of substance abuse and sexual harassment. Knowledge of such incidences will be referred to the Office of General Counsel for disposition.