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Policy No.: 6055
Effective Date: 08/21/00
Revised Date: 08/17/15
Reviewed Date: 07/29/15

Fraud Policy

Basis for Policy

This policy is established to protect the assets and interests of the University of Nebraska Medical Center (UNMC), to increase overall fraud awareness, and to ensure a coordinated approach toward resolution of fraud.

Policy

Fraud in any form will not be tolerated.

This policy applies to all UNMC employees and will be enforced without regard to past performance, position held or length of service. All persons found to have committed fraud relevant to UNMC assets shall be subject to punitive action by UNMC and investigation by external law enforcement agencies when warranted.

It shall also be a violation of this policy for any UNMC employee to make a baseless allegation of fraudulent conduct that is made with reckless disregard for truth and that is intended to be disruptive or to cause harm to another individual or individuals or to UNMC.

Definitions

Fraud and related misconduct prohibited by this policy generally involves a willful or deliberate act or failure to act with the intention of obtaining an unauthorized benefit, such as money or property, by deception or other unethical means. All fraudulent acts are included under this policy and include, but are not limited to, such things as:

• Embezzlement, misappropriation or other financial irregularities
• Forgery or alteration of documents (checks, time sheets, contractor agreements, purchase orders, other financial documents) or computer files
• Purposely inaccurate financial reporting
• Misappropriation or misuse of UNMC resources, such as funds, supplies, or other assets such as inventory, furniture, fixtures, or equipment
• Improper handling or reporting of money or financial transactions
• Authorization or receipt of compensation for goods not received or services not performed
• Authorization or receipt of compensation for hours not worked
• Unauthorized use of UNMC logos or trademarks

Responsibilities

UNMC administrators and all levels of management are responsible for preventing and detecting instances of fraud and related misconduct and for establishing and maintaining proper internal controls that provide security and accountability for the resources entrusted to them. Administrators are also expected to recognize risks and exposures inherent in their area of responsibility, and be aware of indications of fraud and related misconduct. Responses to such allegations or indicators should be consistent. Management should contact the Director of Internal Audit or the Compliance Officer as soon as a fraud is detected or suspected.

Employees who know or suspect that other UNMC employees are engaged in theft, fraud, embezzlement, fiscal misconduct or violation of UNMC financial policies, have a responsibility to report it to their supervisor, appropriate administrator, the Director of Internal Audit, or the Compliance Officer. Employees should not confront the individual under suspicion or initiate investigations on their own, as such actions could compromise any ensuing investigation by the Director of Internal Audit or the Compliance Officer. All employees are to cooperate fully with those performing an investigation pursuant to this policy.

The Director of Internal Audit or the Compliance Officer will coordinate the investigation and resolution of reported fraudulent activities with appropriate UNMC management and departments (e.g., Campus Security, Human Resources, Risk Management) and external law enforcement officials/agencies as appropriate in accordance with the following guidelines:

• During all aspects of any investigation, the Constitutional rights of all persons are to be observed.
• All investigations will be conducted in the strictest of confidence. The name or names of those communicating information about fraudulent activity and the name or names of those suspected of fraudulent activity will be revealed only if required in conjunction with legal action.
• If an investigation reveals theft/fraud, appropriate legal action may be pursued.
• If investigation results indicate restitution is appropriate, then restitution of the funds, including costs associated with the investigation, will be required.
• Human Resources will determine the extent to which disciplinary action, in accordance with personnel policies and procedures, will be imposed.
• Risk Management will initiate appropriate action if the loss exceeds the deductible limits established for insurance coverage.

Additional Information

• Contact the Director, Internal Audit, 402-559-5824
• Contact the Chief Compliance Officer, 402-559-9576

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