Q: What is fraud?
Fraud is the use of your occupation for personal enrichment through the deliberate misuse or misapplication of the employing organization's resources or assets. Fraud is normally considered to be a criminal act, and employees who commit fraud may be terminated, fined, and/or imprisoned depending on the severity of the fraudulent act. For additional information, see
System Administrative Memorandum 01.C.04 - Reporting/Investigating Fraudulent Acts
Q: What are some examples of fraud?
Examples of fraud include:
Stealing cash or checks
Falsifying timesheets or workers comp claims
Falsifying expense reimbursements
Personal use of university credit cards or long distance codes
Stealing property or supplies
Personal use of university assets (occasional local phone calls are okay)
Outside employment that conflicts with university employment
Awarding contracts to friends or relatives
Awarding scholarships/grants based on personal or financial relationships as opposed to merit
Seeking or accepting gifts or favors from vendors or contractors in exchange for placing orders or awarding contracts
Purposefully falsifying financial statements
Q: Am I protected against retaliation if I report suspected fraud or compliance violations?
What types of issues should NOT be reported through the Fraud & Non-Compliance Hotline, and what are the other avenues for reporting these issues?
Examples of issues that should not be reported through Fraud & Non-Compliance Hotline include:
Q: What is the Institutional Compliance Program?
The Institutional Compliance Program was established to develop standards and procedures to help ensure UH Systems' compliance with federal and state laws and regulations. Many of the policies and procedures of UH System and UHD are based upon these legal requirements.
Development of the University of Houston System Institutional Compliance Program began in 2002 with an Institutional Compliance Action Plan. Under this plan, each component university in the UH System was required to:
Designate both an Institutional Compliance Officer
Appoint an Institutional Compliance Committee that meets at least quarterly
Identify and assess the risk to the University
Develop a High-Risk Management Program that meets the criteria for the U.S. Sentencing Guidelines
Establish a Confidential Hotline to allow individuals to report suspected fraud outside of the normal chain of command
Ensure specialized compliance training for employees in high risk areas and general compliance training for all employees
Submit a quarterly component University reports on compliance activities to the UH System Compliance Officer for quarterly Board of Regent reports
What are the elements of a good Compliance Program?
The elements of an effective Compliance Program are based upon the requirements of the
United States Sentencing Guidelines, revised in November 2007. They include:
Existence of written standards
Due care in delegation of authority
Periodic assessment of risks
The Compliance Program at UHD is structured upon the following components:
|Executive Officer|| David Bradley|
|Compliance Officer|| Stefany Records|
Membership varies periodically to accommodate identified high level risk |
|Risk Assessment||Initial/Periodic Risk Assessment and Identification of Institutional Level Risk|
|Assurance Strategies||Confidential Reporting Mechanism in Place (Fraud and Non-Compliance Hotline)|
|Risk Management||Risk Management Program for identified Institutional level risks are developed by Responsible Party and Subject Matter Expert in conjunction with Compliance Officer|
|General Compliance Training ||Employee training specifically applied to work responsibilities,
Employee Compliance and Ethics Guide|
|Assessment of the Compliance Program||Includes self-assessment and internal audit to assess the ongoing effectiveness of the compliance program|
Q: What are the consequences of non-compliance?
The consequences of non-compliance can negatively impact UHD as well as the individual(s) involved.
The University could suffer:
Fines, penalties and legal fees
Negative media coverage
Imposed compliance "settlement" requirements
Loss of funding sources
Increased regulatory and audit agency scrutiny
Reduced faculty and staff morale
Management, faculty and staff turnover
The lingering effect of a tarnished reputation in higher education
Involved individuals could suffer:
- Disciplinary action up to and including termination
- Tax proceedings
- Imprisonment (depending on the severity of non-compliance)
Q: What if I see something that is wrong? What should I do?
You have several options for reporting another employee's conduct that you suspect may not be in compliance with applicable laws, rules, regulations, and policies.
- Notify your Supervisor or UHD Management
- Notify the Compliance Officer (Stefany Records
- Notify the
UHS Internal Auditing Department (713-743-8000)
- Use the Fraud & Non-Compliance Hotline
Q: With all of the concerns about risk, who is responsible for resolving the risks?
Compliance with applicable laws, rules, regulations, and policies is the personal responsibility of every employee at UHD. Each one of us is a risk manager because we are all presented with risk each day in the workplace. We all have resources at our discretion, such as staff, finances, property, and information. What we do or do not do with those resources can either cause risk or mitigate risk.
The UH System Internal Auditing Department identifies risks in the course of doing audits and brings those concerns to our attention.
The Compliance Officer and members of the Institutional Compliance Committee at UHD coordinate the oversight of the identified high level "A" risks via a Risk Management Program that includes the monitoring of controls, training of policies and procedures, implementing predefined consequences for non-compliance and taking appropriate action to mitigate the risks.