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Financial Irregularities

Section: Auditing Number: 10.100
Title: Financial Irregularities

 

Index

POLICY

APPENDIX

POLICY

.100  POLICY STATEMENT 

This policy summarizes the Board policy on Financial Irregularities, adopted by the Oregon State Board of Higher Education on November 7, 2008, Meeting #818. No substantive changes have been made to the content of this policy.

This policy sets forth guidelines for reporting known or suspected fraudulent acts or financial irregularities (see Section .150, Definitions) within any Oregon University System (OUS) institution or the Chancellor’s Office.

The Campus Procedural Checklist, available by contacting the Internal Audit Division, sets forth the investigative procedures for known or suspected frauds.

.110 POLICY RATIONALE

The OUS has a stewardship responsibility over all resources entrusted to it. The OUS is committed to compliance with laws and regulations to which it is subject and expects the highest standards of moral and ethical behavior from all of its employees. OUS internal controls are designed to prevent and detect inappropriate activity; however, in the event these controls are circumvented, this policy is designed to encourage all employees and others to report fraudulent acts or irregularities in a timely manner.

.120  AUTHORITY

.130  APPROVAL AND EFFECTIVE DATE OF POLICY

Summarization and addition of this policy to the Fiscal Policy Manual was approved by the Vice Chancellor for Finance & Administration on March 23, 2009. (See Financial Irregularities Policy, adopted by the Oregon State board of Higher Education on November 7, 2008, Meeting #818.)

.140  KNOWLEDGE OF THIS POLICY

All Oregon University System employees should be knowledgeable of this policy.

.150  DEFINITIONS

Fraudulent activity or financial irregularities: An act, misstatement, or omission of information that is intentional and detrimental to the financial interests of the institution or System. These may include but are not limited to the following:

Accounting and financial reporting irregularities

Deliberate misstatement of revenues, expenses, assets, liabilities, and net assets.

Financial reporting assumptions in violations of generally accepted governmental accounting standards.

Purposely misreporting transactions to conceal the true accounting picture of the unit.

Accounting and financial reporting errors known to management that they have failed to correct.
Conflict of interest and purchasing ethics

Using an OUS position for personal financial gain. The Oregon State Ethics Law (ORS 244) outlines guidelines for public officials.

Examples may include an employee contracting with a vendor who is a family member or giving, receiving, or soliciting gifts or items of value from a vendor.
Misuse of university assets

Using OUS resources for personal use.

Examples may include using a state-owned car for personal travel, making routine personal long distance calls on university phones, and using university-owned copy machines for personal business operation.
Payroll and time abuse

Inappropriate reporting of hours and wages.

Examples include not recording time away from work (leave) and reporting hours that were not worked – including overtime.
Theft or conversion of university property Act of unlawfully taking OUS assets such as cash or equipment and converting them for personal use or selling them for personal gain.
Purchasing and expenditures

Purposeful, unauthorized, or falsified purchases or expenditures for personal gain or in violation of funding restrictions.

Examples may include purchases of computers for personal use, falsified travel reimbursements, abuse of procurement card for the use of personal expenses, purchasing of alcohol with state or federal funds.
Falsification of contracts, reports, or records Altering, fabricating, destroying, misrepresenting, or forging contracts or documents for personal gain or unfair advantage. One example may include forging the signature of an OUS official on a legal document.
Improper disclosure of confidential records Disclosure of confidential personal data which may lead to identity theft. One example includes the loss of computers containing social security numbers obtained from OUS databases.
Other financial matters Improper accounting or financial practices, not categorized above, which lead to a financial detriment to OUS.

 

Suspected fraudulent act or financial irregularity is a reasonable belief or actual knowledge that a financial irregularity is occurring or has occurred.

Campus management and the Chancellor’s Office includes the chancellor, vice chancellors, presidents, vice presidents, provosts, vice provosts, deans, directors, and division/department heads, as well as other managers authorized to determine and assign duties to university employees.

.160   RESPONSIBILITIES

All employees of the Oregon University System shall report known or suspected fraudulent acts or financial irregularities. Matters can be reported to campus management, the OUS Internal Audit Division (IAD), or through the OUS hotline. Campus management who receive notice of suspected or known fraudulent acts and financial irregularities are required by this policy to report such matters to the IAD. When employees do not feel comfortable discussing these matters directly with the IAD or campus management, reporting can be made through the OUS hotline:

OUS Hotline: 1.888.304.7810 or www.ous.edu/dept/intaudit/fc

The reporting service is contracted with an outside hotline vendor, who reports notices received to IAD. IAD will coordinate investigation efforts in conjunction with necessary campus and external parties as deemed appropriate.

Employees who identify themselves and make a good faith report of a known or suspected financial irregularity are protected from retaliation, in accordance with the law. The OUS shall take steps to maintain confidentiality for employees reporting suspected financial irregularities to the extent possible under the law. The Oregon State Whistleblowers Protection Law defined in Oregon Revised Statute (ORS) 659 protects employees disclosing fraud in good faith.

In accordance with ORS 297, the Secretary of State Audits Division http://www.sos.state.or.us/audits/ is notified of all complaints and confirmed losses that are in excess of $100.

.690  CONTACT INFORMATION

Direct questions about this policy to the following office:

Oregon University System Internal Audit Division
Phone: (541) 737-2193
http://www.ous.edu/dept/intaudit/

.695  HISTORY

11/07/08 - Financial Irregularities Policy adopted by the Oregon State Board of Higher Education, Meeting #818
03/23/09 - Approved for Fiscal Policy Manual

Policy Last Updated: 03/23/09

APPENDIX

.700  OUS HOTLINE

OUS Hotline: 1.888.304.7810 or www.ous.edu/dept/intaudit/fc

.995  HISTORY

Posted Wed, 01/12/2011 - 11:48am