The purpose of this policy is to establish the overall roles and responsibilities of university employees for preventing, identifying, and reporting fraudulent transactions at the university. Code of Virginia § 30-138 requires agency heads to promptly report circumstances suggesting a reasonable possibility that a fraudulent transaction has occurred to the Auditor of Public Accounts, Office of the State Inspector General, and Virginia State Police. The president of the university has assigned this reporting responsibility to Audit and Compliance Services, in conjunction with VCU Police.
University employees are responsible for safeguarding university resources under their control and for ensuring that those resources are used only for authorized purposes and in accordance with university rules, policies, and applicable federal and state laws. Administrators and all levels of management have additional responsibility for the design and implementation of effective internal controls to protect university resources from misuse or abuse. Administrators and managers should be familiar with the potential risks and exposures in their areas of responsibility and be alert to any indicators of fraud and financial misconduct, including abusive or dishonest activities. Fraud and financial misconduct create negative impacts beyond the initial monetary loss; damaging morale, halting or slowing operations, reducing departmental budgets by any reimbursement to outside parties or specialty investigatory costs. By establishing sound internal controls department management can greatly reduce the potential occurrence of fraud, waste, or abuse.
In accordance with the VCU’s Duty to Report and Protection from Retaliation policy, all members of the university community will timely report actual or suspected violations of laws, regulations, and policies to include instances of fraud, waste, or abuse involving funds or property under the control of the university. The “Procedures Section” provides guidance for reporting suspected or known fraud and financial misconduct activities. All good faith reports will be investigated and results reported to the appropriate levels of management. Individuals who report actual or suspected violations of fraud, waste, or abuse involving funds or property under the control of the university in good faith, are also subject to the anti-retaliation protections of the Duty to Report policy. The reporter may not be privileged to the results of the report submitted.
Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
All departments of the university and all members of the university community.
Abuse involves behavior that is deficient or improper when compared with behavior that a prudent person would consider reasonable and necessary business practice given the facts and circumstances. Abuse also includes misuse of authority or position for personal financial interests or those of an immediate or close family member or business associate. Abuse does not necessarily involve fraud, violation of laws, regulations, or provisions of a contract or grant agreement. Examples may include excessive charges, improper billing practices, or payment for unnecessary services.
Fraud is the intentional deception perpetrated by an individual or individuals, or an organization, either internal or external to the university, 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. Fraud and financial misconduct includes a false representation of a matter of fact, whether by word or conduct, by false or misleading statements, or by concealment of that which should have been disclosed, which deceives and is intended to deceive.
A Good Faith Report is a report that is made with reasonable belief or suspicion and without ill-will.
Policies, practices, and procedures that are designed to provide reasonable assurance that objectives are achieved in the following categories:
Internal controls are used to monitor and control the use of university assets and, thereby, reduce the potential for fraud and financial misconduct.
Waste is the intentional or unintentional, thoughtless or careless expenditure, consumption, mismanagement, use, or squandering of resources, to the detriment or potential detriment of the university. Waste also includes incurring unnecessary costs as a result of inefficient or ineffective practices, systems, or controls.
Audit and Compliance Services and VCU Police officially interpret this policy and are responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures.
By establishing sound internal controls, administrators and managers can greatly reduce the potential occurrence of fraud, waste, or abuse.
There are no forms associated with this policy and procedures.</>
Office of the State Inspector General, State Fraud, Waste, and Abuse Hotline, Policies and Procedures Manual, https://www.osig.virginia.gov/media/governorvirginiagov/office-of-the-state-inspector-general/pdf/Hotline-Policies-and-Procedures-Manual-2018-Edition.pdf
VCU Policy: Duty to Report and Protection from Retaliation
12/03/2005 New Policy
5/26/2021 Minor Revisions
1. What are some examples of Fraud including Financial Misconduct?
Fraud and financial misconduct may include, but is not limited to, the following actions:
2. What are characteristics of internal controls?
Internal controls include such characteristics as:
3. I noticed a co-worker using their P-card to purchase items that do not seem to be work related. What should I do?
The concern should be reported following the procedures described above.
4. I supervise an excellently performing staff member who took a check payable to the university and did not deposit it appropriately. Do I have to report that conduct?
Yes, this action should be reported following the procedures described above.
5. My supervisor turns in personal receipts from a home improvement store, but none of the materials seem to be used at work. What should I do?
You may report any suspected fraud, waste, or abuse to any entity listed above. If your supervisor is involved, you may prefer to report your suspicion to a higher level of management.
6. Employees in my department are taking leave but not reporting i What should I do?
You should report it to your supervisor, Audit and Compliance Services or Human Resources.