Prevention and Reporting of Fraud and Fiscal Irregularities

Title: Prevention and Reporting of Fraud and Fiscal Irregularities
Policy Owner: Executive VP for Administration and Chief Financial Officer
Applies to: Faculty, Staff, and Others
Campus Applicability: All
Effective Date: March 23, 2016
For More Information, Contact: OACE: (860) 486-4526 (Storrs & Regionals) / (860) 679-4180 (UConn Health)
EVP for Administration and CFO: (860) 486-3455
UConn Health CFO: (860) 679-3162
Official Website: http://evpacfo.uconn.edu/ 

Purpose

The University of Connecticut is committed to upholding the highest standards of honest behavior, ethical conduct, and fiduciary responsibility with respect to all assets of the University and assets entrusted to the University, including all funds, resources, and property. The purpose of this policy is both to inform the University community of each member’s responsibility to safeguard University resources and to establish standards for the reporting of suspected or known fraud or fiscal irregularities to the appropriate officials.

This policy applies to all units of the University including Storrs and the Regional Campuses, Professional Schools and UConn Health.  It applies to members of the University community including faculty, staff, contractors, business associates, and others involved in the activities of the University.

Definitions

Fraud and fiscal irregularities generally involve an intentional or deliberate act, omission or concealment with the intent of obtaining an unauthorized benefit, such as money, property or other personal or business advantage, by deception or other unethical means.  Examples include, but are not limited to:

  • Misappropriation, misapplication, removal, or concealment of University property
  • Forgery, falsification, or alteration of documents and/or information (e.g., checks, bank drafts, deposit tickets, promissory notes, time cards, travel expense reports, contractor agreements, purchase orders, etc.)
  • Theft or misappropriation of funds, securities, supplies, inventory, or any other University assets including furniture, fixtures, equipment, data, and intellectual property
  • Billing customers, patients and third party payers for services when it is known that the services were not provided
  • Authorizing payment to vendors when it is known that the goods were not received or services were not performed
  • Misuse of University facilities, such as vehicles, telephones, mail systems, or computer-related equipment
  • Engaging in bribery, accepting kickbacks, or seeking unauthorized rebates
  • Actions related to concealing or perpetuating any fraud or fiscal irregularity

Policy Statement

All members of the University community are responsible for safeguarding University resources in their units and for ensuring that those resources are used for authorized purposes and in accordance with University rules and policies, and as required by applicable laws. In addition, all members of the University community should promptly report any known or suspected fraudulent activity or fiscal irregularities involving University and affiliated entity funds resources, property, or employees. Each unit manager should be familiar with the types of improprieties that might occur in the manager’s area of responsibility and ensure that all reasonable internal controls are in place and operating effectively to prevent and detect the occurrence of fraudulent activity or fiscal irregularities.

Nothing in this policy relieves faculty and staff from reporting responsibilities under professional codes of conduct, licensing, or other requirements applicable to them individually or to their function.

Process for Reporting Detected or Suspected Fraud and Irregularities

Individual Reporting Obligations

All members of the University community are obligated to report any known or suspected fraudulent activity or fiscal irregularities. Generally, an individual may discuss the concern directly with a supervisor. However, in the event that the individual is not comfortable speaking with the supervisor or is dissatisfied with the supervisor’s response, the individual should report the concern directly to the Office of Audit, Compliance and Ethics (OACE) and/or Campus Police.  Individuals should not investigate suspected fraudulent activity independently.

Individuals who wish to report suspected fraudulent activity or fiscal irregularities anonymously may utilize the University’s REPORTLINE using the contact information below. The REPORTLINE is operated by a private (non-University) company. No effort is made to identify the person reporting and no trace of the call is performed. Information received is provided to the OACE for review and appropriate action. This service is available 24 hours a day, 7 days a week and is staffed by independent specialists trained to obtain complete and accurate information in a confidential manner. To contact the REPORTLINE:

Phone:  All University campus including UConn Health: Phone: 1-888-685-2637
Web reporting address:
(Storrs, Regional Campuses and Professional Schools only): https://www.compliance-helpline.com/uconncares.jsp

At a minimum, individuals should provide key information such as a description of the incident, the time frame in which the incident occurred, and names of individual(s) involved. OACE will make every effort to handle all information received in a confidential manner, to the extent permitted by law.

University policy prohibits retaliation when an individual reports, in good faith, suspected fraudulent activity or fiscal irregularities to any supervisor, faculty, administrator, OACE, University Police, the REPORTLINE, or any appropriate agency outside of the University. An individual who believes he or she has been subjected to retaliation, should contact OACE immediately.  This policy is not intended to preclude the reporting of suspected fraudulent activity or fiscal irregularities to appropriate external authorities[1].

Institutional Obligations:

Departments are obligated to notify OACE of suspected or known fraudulent activity or fiscal irregularities as soon as they become known.   OACE will evaluate the information provided and determine an appropriate strategy for investigating and resolving the allegation.   Additional University officials may be asked to conduct or participate in an investigation as appropriate. When sufficient facts and circumstances exist to establish a reasonable suspicion that fraudulent activity or fiscal irregularity has occurred, OACE will consult with the Office of the General Counsel (Storrs, Regional Campuses and the Professional schools), Senior Counsel (UConn Health) and other University officials regarding federal, state and other external reporting requirements.

Enforcement

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.

[1]Other Reporting Options:

  • State Auditors of Public Accounts

The Whistle Blower Act, Section 4-61dd of the Connecticut General Statutes, authorizes the Auditors of Public Accounts to receive information concerning matters involving corruption, unethical practices, violation of State laws or regulations, mismanagement, gross waste of funds, abuse of authority or danger to the public safety occurring in any State department or agency. Upon receiving such information the Auditors are required to review such matter and report their findings and any recommendations to the Attorney General. The Auditors shall not, after receipt of any information from a person under the provisions of this section, disclose the identity of such person without his/her consent unless the Auditors determine that such disclosure is unavoidable during the course of the review. You can file a complaint with the Auditors of Public Accounts by calling (860) 240-5369 or toll free at (800) 797-1702. Website:https://www.cga.ct.gov/apa/

  • Federal False Claims Act (31 U.S.C. § 3729-3733)

This act permits a person with knowledge of fraud against the federal government to file a lawsuit on behalf of the government against those that committed the fraud. The person filing the lawsuit is also known as the “whistleblower” or “qui tam” plaintiff. The “qui tam” plaintiff must notify the United States Department of Justice (DOJ) of all information regarding the fraud. If the DOJ takes the case and fraud is proven the “qui tam” plaintiff is entitled to a portion of the money recovered by the federal government. Under the False Claims Act the “qui tam” plaintiff is protected from retaliation that may result from his or her involvement in the case. This is known as Whistleblower Protection.