Fraud Awareness and Reporting

1.0    Purpose

This policy establishes guidelines for reporting and investigating potential fraud, misuse of resources, or criminal conduct at Casper College.

2.0    Revision History

3.0    Persons Affected

3.1    Casper College Board of Trustees

3.2    All college employees

3.3    All students

3.4    Volunteers

3.5    Contractors and vendors

4.0    Policy

The policy of Casper College is to ensure the following.

4.1    All affected persons have a responsibility to ensure that the college’s resources are used for valid and appropriate college needs.

4.2    The college establishes and maintains proper internal controls to protect the college’s resources from misuse.

4.3    The college abides by all applicable federal, state, and local laws regarding funding and resources.

5.0    Definitions

5.1    Fraud. Any illegal act of deceit, concealment, or violation of trust. This may include gross mismanagement or misuse of funds or resources, conduct violations, illegal or regulation violations, or falsification of data. These acts are not dependent upon the threat of violence or physical force. Individuals or organizations participate in fraud to obtain money, property, or services; avoid payment or loss of services; or secure a personal or business advantage.

5.2    Gross Mismanagement. Actions or situations arising out of management ineptitude or oversight that leads to a major violation of law, regulations, contracts, or grants provisions. This includes unauditable records, unsupported costs, inaccurate fiscal or program reports, payroll discrepancies, and lack of proper internal control procedures.

5.3    Misuse of Funds or Resources. Any alleged deliberate use of funds or resources not authorized by legislation or regulation, contracts, or grants. This includes, but is not limited to, nepotism, political patronage, use of participants for political activity, ineligible enrollees, conflict of interest, failure to report income from funds, violation of contract or grant procedures, and use of funds for other than specified purposes.

5.4    Incident Report. This form is provided by the Office of the Inspector General to report an allegation of fraud or improper activities in federal grant programs to the federal government.

5.5    Retaliation. This behavior includes any form of intimidation, reprisal, or harassment against an individual for reporting or participating in an investigation of fraud. Retaliation may include, but is not limited to

• Firing, refusing to hire, or refusing to promote an individual;
• Departing from customary employment or academic practice regarding the individual;
• Transferring an individual to a lesser position in terms of wages, hours, job classification, job security, or employment or academic status;
• Informing anyone who does not have a need to know that an individual has reported fraud or participated in an investigation;
• Impeding an individual’s academic advancement.

6.0    Responsibilities

6.1    Administrators and any employees who have management responsibility over resources are responsible for maintaining compliance with this policy.

6.2    All affected persons are responsible for being aware of fraud and for reporting misuse through proper channels.

7.0    Procedures

7.1    All affected persons should be familiar with the risk of fraud in their areas of responsibility and be alert to any fraudulent activity. Administrators and employees who have management responsibility should educate their employees under their supervision of potential areas of fraud risk and must implement proper internal controls to safeguard the use and control of college resources.

7.2    Any affected persons must promptly report actual, potential, or suspected fraud to their supervisor or the president. In the case of fraud involving federal regulations or funds, a report may be made to the Office of the Inspector General Complaints Analysis Office (Hotline) at 200 Constitution Avenue, NW Room S-5506 Washington, DC 20210 Telephone: (202) 693-6999 or 800-347-3756. The college forbids retaliation against anyone who reports suspected fraud.

7.3    Supervisors who receive a fraud-related report must promptly make a report to the President’s Office, unless the report involves the president. In that case, a report must be made to one of the officers of the Board of Trustees or the federal hotline.

7.4    The President’s Office is responsible for managing the investigation of suspected fraud and should engage other college units as necessary. All investigatory decisions must be made in writing and all investigatory documentation must be kept for five years after the close of the investigation. All information gathered is confidential. Information may not be discussed or disclosed to anyone without a legitimate need to know.