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 George Mason University employees, students, contractors, employees of contractors, and agents.

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

A. 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.  Intentional deception may be inferred from the totality of the circumstances, including statements and conduct, and does not need to be proven with direct evidence.

B. 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;
• misrepresentation or falsification of documents;
• misrepresentation or falsification of entries to payroll, travel, or other financial or non-financial (including academic and administrative) records;
• misrepresentation or falsification of conflict of interest or other related disclosures;
• misrepresentation or falsification of procurement-related information; including level of delegated authority;
• charging personal purchases to the university; and
• misstatement or omission of financial, accounting, or financial reporting information.

C. Person means a George Mason University employee, student, contractor, employee of contractor, or agent.

D. Reporting Person means a 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 the Office of University Audit.

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

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. The Office of University Audit shall 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 the Office of University Audit or those individuals working under the direction of the Office of University Audit.

4. The Office of University Audit may consult with various university offices in making its determination as to whether there is a reasonable possibility that a Fraudulent Transaction has occurred.  Such offices may include Ethics Office, Department of Police and Public Safety, Human Resources Employee Relations, University Controller, University Counsel, senior University officials, or others as considered necessary.

5. The Office of University Audit may be required to investigate reports of suspected Fraudulent Transactions received by the Office of the State Inspector General Fraud, Waste, and Abuse Hotline.

6. The Office of University Audit shall report incidents involving students to the Office of Student Conduct and, if student organizations are involved, to the Vice President of University Life.

C. Communications Procedures:

1. The Office of University Audit shall assist the President in reporting all reports of suspected Fraudulent Transactions where the Office of University Audit 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.

2. The Office of University Audit shall communicate the results of its investigations of all reports of suspected Fraudulent Transactions to the Audit Committee of the University’s Board of Visitors.

3. The Office of University Audit shall communicate 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.

4. The Office of University Audit shall communicate the results of its investigations of all reports of suspected Fraudulent Transactions where the Office of University Audit concludes there is a reasonable possibility that a Fraudulent Transaction has occurred as follows:

a. to the Department of Police and Public Safety and to the University Counsel for their evaluation, liaison, and coordination related to the potential for any criminal or civil actions.

b. to the Vice President of Human Resources and Payroll related to the involvement of any University employee.

c. to the University Controller and to the Office of Risk Management related to potential impacts on the University’s financial accounting and reporting processes and the potential for insurance recovery.

D. Remediation and Discipline Procedures:

1. Based on the report from University Audit, the following individuals are responsible for implementing appropriate actions to remediate identified control weaknesses, employee disciplinary action in coordination with Human Resources Employee Relations, and any other appropriate actions:

  • the Provost and Executive Vice President related to any Person who reports to them.
  • the Senior Vice President related to any Person who reports to them.
  • the Chief of Staff related to (i) any Person who reports to them, (ii) any Person who reports directly to the President, or (iii) any Person who reports to a Person who reports directly to the President other than to the Provost and Executive Vice President or the Senior Vice President.

2. The Provost and Executive Vice President, the Senior Vice President, and the Chief of Staff are responsible for regularly reporting to the Office of University Audit the status of (i) actions to remediate identified control weaknesses, (ii) employee disciplinary actions, and (iii) any other appropriate actions, until all such actions are completed.

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:

3/21/2019

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

Revision Approved: 3/26/2019