Reporting and Investigation of Suspected Fraudulent Transactions

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University Policy Number 1139

Categorized:

Responsible Office:

Policy Procedure: N/A

Related Law & Policy:


I. Scope

This policy applies to all Persons, i.e., George Mason University employees, students, and contractors.

II. Policy Statement

George Mason University does not tolerate theft, waste, or abuse of state, university, or university-related funds, property, or other resources through fraudulent means. All Persons must report any suspected Fraudulent Transaction in accordance with this policy. Substantiated fraudulent activities will be reported to the appropriate authorities.

III. Definitions

Fraud means the intentional deception perpetrated by an individual or individuals, which could result in a tangible or intangible benefit to themselves, others, the University, or the Commonwealth or could cause detriment to others, the University, or the Commonwealth. The definition of Fraud includes a false representation of a matter of fact (whether by words or by conduct, by false or misleading statements, or by concealment of that which should have been disclosed) that deceives or is intended to deceive.

Fraudulent Transactions means transactions involving Fraud. The definition of Fraudulent Transactions includes, but is not limited to, the following:
• misappropriation of cash, funds, or property;
• falsification of documents;
• unauthorized use of university property or resources;
• unauthorized access to (or misuse of) computer systems or equipment;
• falsification of entries to payroll or travel records;
• charging personal purchases to the university; and
• unauthorized use of university employees.

Person means George Mason University employees, students, and contractors.

Reporting Person means the Person reporting a suspected Fraudulent Transaction.
IV. Compliance

A. Reporting Procedures:

1. All Persons must report immediately any suspected Fraudulent Transaction. This report must ordinarily be made to the Reporting Person’s supervisor. The supervisor must immediately report the suspected Fraudulent Transaction to Internal Audit and Management Services.

2. Should the Reporting Person feel uncomfortable with reporting a suspected Fraudulent Transaction to their supervisor, the report may be made to:
• Internal Audit and Management Services, or
• Employee Relations, within Human Resources and Payroll. Employee Relations must immediately report the suspected Fraudulent Transaction to Internal Audit and Management Services.

3. In the alternative, Reporting Persons may report suspected Fraudulent Transactions in an anonymous and confidential manner using the following Hotlines:
• George Mason University Hotline: (866-GMU-1706).
• Office of the State Inspector General Fraud, Waste, and Abuse Hotline (800-723-1615).

B. Investigation Procedures:

1. Internal Audit and Management Services will perform or oversee investigative, audit, or other procedures to determine whether there is a reasonable possibility that a Fraudulent Transaction has occurred.

2. All Persons must cooperate fully with persons performing investigations.

3. No Person may conduct investigations of Fraud or suspected Fraudulent Transactions, other than Internal Audit and Management Services or those individuals working under the direction of Internal Audit and Management Services.

4. Internal Audit and Management Services may be required to investigate reports of suspected Fraudulent Transactions received by the Office of the State Inspector General Fraud, Waste, and Abuse Hotline.

5. Internal Audit and Management Services will report incidents involving students to the Office of Student Conduct and, if student organizations are involved, the Vice President of University Life.

C. Communications Procedures:

1. Internal Audit and Management Services communicates the results of its investigations of all reports of suspected Fraudulent Transactions to the Audit Committee of the University’s Board of Visitors.

2. Internal Audit and Management Services communicates the results of its investigations of all reports of suspected Fraudulent Transactions received via the Office of the State Inspector General Fraud, Waste, and Abuse Hotline to the State Inspector General.

3. Internal Audit and Management Services assists the President in reporting all reports of suspected Fraudulent Transactions where Internal Audit and Management Services concludes there is a reasonable possibility that a Fraudulent Transaction has occurred. Such reports by the President are made in accordance with Section 30-138.A of the Code of Virginia to:
• the Auditor of Public Accounts,
• the State Inspector General, and
• the Superintendent of State Police.

4. Internal Audit and Management Services communicates the results of its investigations of all reports of suspected Fraudulent Transactions where Internal Audit and Management Services concludes there is a reasonable possibility that a Fraudulent Transaction has occurred and a University employee was involved to the Vice President of Human Resources and Payroll.

V. Forms

N/A

VI. Dates:

A. Effective Date:
This policy will become effective upon the date of approval by the Senior Vice President for Administration and Finance and the Provost and Executive Vice President.

B. Date of Most Recent Review:

N/A.

VII. Timetable for Review

This policy, and any related procedures, shall be reviewed every three years or more frequently as needed.

VIII. Signatures

Approved:

_____/S/________
Senior Vice President for
Administration and Finance

_____/S/_________
Provost and Executive Vice President

Date Approved: 2/9/2016