2020 Anti-Fraud Policy Training
Joint Committee on Government and Finance
Why Anti-Fraud Training?
The Joint Committee receives funding from a federal grant to administer its Crime Victim’s Compensation Fund. As a requirement of that fund, formal fraud awareness and reporting training is mandated.
In addition, the Joint Committee has an obligation to protect its assets and financial interests and believes that fraud awareness training is beneficial for all Joint Committee employees.
Why does the Joint Committee have an Anti-Fraud policy?
- To provide a coordinated approach to the identification, investigation, and resolution of fraudulent activities, and
- To increase the overall awareness of the responsibility to report fraud and reasonably suspected fraudulent activity to the appropriate persons.
What does the policy apply to?
The Anti-Fraud policy applies to any situation of fraud or suspected fraud involving Joint Committee employees, claimants for Crime Victim’s benefits, vendors, contractors, consultants, outside agencies, and/or any other parties with a business relationship with the Joint Committee.
What is Fraud?
- Fraud includes any willful or deliberate act committed with the intention of obtaining an unauthorized benefit, such as money or property, by misrepresentation, deception, or other unethical means.
- Acts do not need to be elaborate, or solely criminal in nature, for deceit to constitute fraud.
Common Examples of Fraud and Financial Impropriety
- Forgery, alteration, or falsification of documents (including checks, time sheets, electronic time records, travel expense reports, contractor agreements, purchase orders, financial documents, or electronic files).
- Misappropriation, misuse, theft, removal, or destruction of Legislative resources (including funds, securities, supplies, inventory, furniture, fixtures, equipment, intellectual property or any other asset).
- Improprieties in the handling or reporting of money or financial transactions.
- Misuse of facilities (including telephones, computers and e-mail system).
- Receiving or offering bribes, rebates, or kickbacks.
- Personal use of Legislative property in commercial business activities.
- Accepting or seeking anything of material value from contractors, vendors, or persons providing or seeking to provide services/materials to the Legislature.
How do I recognize Fraud?
To recognize fraud, one must be aware of where it can originate:
- Internal Fraud is committed by employees
Examples: “Skimming” from cash distributions, awarding funds with a real or perceived conflict of interest, or falsifying time sheets.
- External Fraud is committed by claimants.
Examples: Submitting false claims, false or misleading statements related to reimbursement funds, or other false documents.
Indications of Fraud
The following are indicators fraudulent activity may have occurred:
- Excessive number of missing or voided documents
- Alterations of documents
- Questionable handwriting or approval
- Documents not numerically controlled
- Duplicate payments
- Unusual billing addresses or arrangements
- Vendor’s billing address is the same as employee’s
- Duplicate or photocopied invoices
What are the consequences of fraud to the Crime Victim’s Compensation Fund?
From the DOJ Office of Inspector General, grant fraud can result in:
- Inability to receive future funds
- Civil law suits
- Criminal prosecution
- Expensive administrative recovery of the funds, and
- The inability to receive future funds affects the state’s ability to assist legitimate victims of crime.
What is the Joint Committee’s Responsibility for Fraud?
The Joint Committee’s management is accountable for setting the appropriate tone of intolerance for fraudulent acts by complying with laws, rules, regulations, and policies.
Division Directors are responsible for identifying and assessing the level of the risks and exposures to fraudulent activity inherent in his or her area of responsibility. Additionally, Directors shall establish and maintain proper internal controls which will provide for the security and accountability of the resources within his or her division.
All Joint Committee employees are responsible for safeguarding public resources and ensuring that they are used only for authorized purposes, in accordance with state rules, policies, and applicable law.
Reporting Requirements
Joint Committee employees who suspect fraud has occurred should promptly report such activity to the Fiscal Officer, Legislative Manager, or Director of Legislative Services. Fraud may also be reported to the Commission on Special Investigations if the employee suspects Joint Committee management of fraudulent activity.