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Violations, Fraud, Waste and Abuse

    • Last Updated: 06/17/2016
    • Effective Date:

    Policy Statement
    The University of Georgia establishes and maintains sound business practices in order to ensure the institution’s assets are safeguarded from fraud, waste and abuse.  
    Reason for policy
    State Purchasing Division and Board of Regents (BOR) regulations require the University to monitor p-card transactions to prevent violations which may result in fraud, waste or abuse.
    Procedures

    Section 14.0 thru 14.2 of the UGA P-Card Manual  (see link in “Related Information” below) provide the procedures regarding violations, fraud, waste, abuse, written violation notices as well as detection and prevention of fraud.   Additionally, Appendix C of the manual outlines descriptions of misuse and non-compliance and provides examples of non-compliance. Among the avenues for reporting apparent incidents of wrongdoing is the University Hotline which can be accessed by calling 1-877-516-3467 or via the link provided below in ”Related Information”.  Other avenues are identified in Section 14.2 of the UGA P-Card Manual. 

    When a cardholder intentionally commits fraud with a p-card, the University is protected from the loss by Visa®’s Liability Protection Coverage under certain conditions. The principal conditions are that the employee who committed the fraud must have been terminated and Bank of America must be notified of the termination within TWO (2) DAYS of its occurrence. 

    Additional contacts

    Jill Haag, Lynn Stephens 

    Phone Number: 706-542-2361

    Policy definitions

    Violations are defined as and include non-compliance with policy or procedure or actions as severe as misuse.

    As defined by BOR Business Procedures Manual Section 16.4.1, fraud can be defined as a false representation of a matter of fact that is intended to deceive another. A fraudulent act may be illegal, unethical, improper, or dishonest and may include, but is not necessarily limited to:

    • Embezzlement

    • Misappropriation

    • Alteration or falsification of documents

    • False claims

    • Theft of any asset

    • Inappropriate use of computer systems, including hacking and software piracy

    • Bribery or kickback

    • Conflict of interest

    • Misrepresentation of facts

     

    A fraudulent act may have criminal and/or civil law consequences. The Internal Audit department is not required to use a determination by a criminal justice authority to criminally prosecute as the basis for determining whether an act is fraudulent. It is the internal determination of the above criteria that defines an act as fraudulent under this policy. 

    Waste is the expenditure or allocation of resources in excess of need that is often extravagant or careless. 

    Abuse is the intentional, wrongful, or improper use of resources. Abuse can be a form of wastefulness as it entails the exploitation of “loopholes” to the limits of the law, primarily for personal advantage.

    Responsibilities

    Responsible University Senior Administrator: Vice President for Finance & Administration 

    Responsible University Administrator: Procurement Officer 

    Policy Owner: Procurement 

    Policy Contact: Jill Haag, Lynn Stephens 

    Phone Number: 706-542-2361 

    Responsibilities: The Department Head or Approving Official must contact Business and Accounting Services and the Procurement P-Card Administrators immediately when an employee has been terminated as a result of fraudulent p-card activities.

    Responsibilities: Per the BOR Business Procedure Manual, any USG employee who has a reasonable basis for believing a fraudulent act has occurred has a responsibility to promptly notify one of the following:

    • His or her supervisor
    • Internal Audit department at the institution or at the BOR
    • Institution police department
    • Institutional or BOR Ethics and Compliance Hotline
    Record Retention

    Series documents administration of credit cards and P-Cards issued to institutional staff and units. Records may include: applications; master monthly billing statements; individual card holders' statements; billing summaries; printouts including vendor analysis by code; number of charges and stores; use summaries; related correspondence.

    Retention:  7 years, BOR 0472-03-013

    For expenditures processed with grant funding, all documentation should be retained for the life of the grant plus seven (7) years.  0472-09-006