4:080 AP2 Fraud, Waste and Abuse Awareness Program

The Grant Accountability and Transparency Act (GATA) (30 ILCS 708/) and federal regulations (2 CFR 200.113) require grant fund recipients to timely disclose, in writing, all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal awarding agency or pass-through entity, e.g., Ill. State Board of Education (ISBE).

In alignment with best practices contained in ISBE’s Fiscal Procedures Handbook, the District has a Fraud, Waste, and Abuse Awareness Program, which includes employee reporting procedures for suspected fraud, waste, or abuse. The District will take all appropriate measures to deter fraud, waste, and abuse.

Reporting

The District encourages all District employees to be vigilant and report suspicions of fraud, waste, or abuse. Employees who make good faith reports of suspected violations of law, public corruption or wrongdoing are protected from retaliation by the provisions of the Ill. Whistleblower Act (740 ILCS 174/). See the chart below for details on how to make a report.

Enforcement

Staff members found to have engaged in fraud, waste, or abuse will be disciplined, up to and including discharge. The District will also seek to recover any wrongfully obtained assets from the employee.

Definitions

Fraud is defined as: (1) fraudulent financial reporting, (2) misappropriation of assets, and/or (3) corruption (bribery and other illegal acts). Examples of fraud include:

• Embezzlement, e.g., theft of cash, use of entity credit card or accounts payable systems to purchase personal items
• Collusion with others to circumvent internal controls
• Forgery or alteration of documents, e.g., checks, time cards, receipts, contracts, purchase orders, expense reimbursement paperwork, student bills, electronic files, bids, or other financial documents
• Fraudulent reporting of expenditures or other District financial information
• Misappropriation or misuse of resources, e.g., cash, securities, inventory, facilities, equipment, services, supplies, or other assets
• Impropriety in the handling or reporting of cash or financial transactions
• Unless properly authorized, accepting or seeking anything of material value from contractors, vendors, or persons providing services or materials.
• Authorization or receipt of payment for goods not received or services not performed, e.g., payments to fictitious employees or vendors
• Submitting multiple vouchers for the same expense reimbursement
• Using the District’s tax exempt status for purchase of personal items
• Authorization or receipt of unearned wages or benefits
• Personal use of District property in commercial business activities
• Identity theft
• Conflict of interest or other ethics violations
• Destruction, removal, or inappropriate use of records, buildings, furniture, fixtures, or equipment
• Any similar or related irregularity to those listed

Waste is the act of using or expending resources carelessly, extravagantly, or to no purpose.

Abuse is behavior that is deficient or improper compared to the behavior that a prudent person would consider reasonable and necessary operational practice given the facts and circumstances.

The terms fraud, waste, and abuse are not mutually exclusive; certain conduct may constitute fraud, waste, and/or abuse.

Roles, Responsibilities, and Reporting Procedures

Date Adopted:  August 21, 2018