This policy is established to provide increased protection to the assets and financial
interests of Chicago State University, 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 Chicago State administrators.
This policy applies to any situation of fraud or suspected fraud involving University
employees, students, vendors, contractors, consultants, outside agencies, and/or any
other parties with a business relationship with Chicago State University. Any investigative
activity conducted will be done without regard to the suspected wrongdoer’s title/position,
past performance, or length of service to the University.
For purposes of this policy, 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.
Fraud and financial impropriety may include, but are not limited to the following
- Embezzlement or other financial irregularities;
- Forgery, alteration, or falsification of documents (including checks, time sheets,
travel expense reports, contractor agreements, purchase orders, other financial documents,
student academic or financial records, electronic files);
- Misappropriation, misuse, theft, removal, or destruction of University 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 University facilities (including telephones, computers and e-mail system);
- False claims by student, employees, vendors, or other associated with Chicago State
- Receiving or offering bribes, rebates, or kickbacks;
- Personal use of University 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 University (Except as permitted
by the Illinois Gift Ban, 5 ILCS 430/10);
- Conflict of interest;
- Misrepresentation of facts;
- Any similar or related irregularity
Chicago State administrators at all levels of management are accountable for setting
the appropriate tone of intolerance for fraudulent acts by displaying the proper attitude
toward complying with laws, rules, regulations, and policies. Managing administrators
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,
managing administrators shall establish and maintain proper internal controls which
will provide for the security and accountability of the resources within his or her
department. All University employees are responsible for safeguarding University resources
and ensuring that they are used only for authorized purposes, in accordance with University
rules, policies, and applicable law.
The following, though non-exclusive, may indicate fraudulent financial activities:
- 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
Employees, students, and other individuals associated with Chicago State (collectively,
members of the University community) who become aware of, or have a reasonable basis
for believing that fraud, defalcation, misappropriation or other fiscal irregularities
has occurred shall promptly report the suspected activity to the Office of Internal
Audit, University Police, or General Counsel/Ethics Officer. If the suspected fraudulent
activity involves a member of the Internal Audit, University Police or General Counsel/Ethics
Officer, the activity should be reported to the Chicago State University President.
Great care must be taken in dealing with suspected fraudulent activities so as to
avoid any incorrect accusations, alerting suspected individuals that an investigation
is under way, violating a person’s right to due process, or making statements that
could lead to claims of false accusations or other civil rights violations. Any employee
who suspects fraudulent activity shall report it to the Office of Internal Audit,
University Police, or General Counsel/Ethics Officer and shall not attempt to personally
conduct an investigation or interview individuals suspected of being involved in the
suspected fraudulent activity.
The Office of Internal Audit has the primary University office responsible for conducting
investigations of fraud and suspected fraudulent activity reported to its office.
Additionally, the Office of Internal Audit may identify and investigate any suspected
dishonest or fraudulent activity, which in its opinion, may represent risk of significant
loss of assets or reputation to the University. The Internal Auditor may work with
internal or external departments, such as the University General Counsel’s office,
Human Resources, Police and other law enforcement agencies, as circumstances may require.
In the event that the Office of Internal Audit determines that an investigation of
suspected fraudulent activity is warranted, the Office will conduct the following
- Notify the President and General Legal Counsel.
- Advise management to meet with Human Resources Director to determine if any immediate
disciplinary personnel actions should be taken.
- Coordinate the notification of insures and filing of claims with the Risk Management
Office. This office is responsible for notifying bonding companies and filing bonding
- If federal funds are involved, determine the required federal reporting in cooperation
with the grantee department and University General Legal Counsel.
- If illegal activity is indicated, notify the University Police to coordinate an investigation.
- If illegal activity appears to have occurred, the findings will be reported to the
appropriate agency for review such as the Illinois Attorney General. This will be
coordinated with the University General Legal Counsel.
- Notify the Office of the State of Auditor as required by FCIAA guidelines.
The Office of Internal Audit will review and communicate the results of any investigation
with responsible management administrators. It will make recommendations for improvement
to the systems of internal control, as needed. The results of investigation will also
be communicated to the President and Board of Trustees.
Office of Executive Inspector General
The Office of Executive Inspector General is an agency of the State of Illinois that
has authority to receive and investigate allegations of fraud, waste, abuse, mismanagement,
misconduct or other violations of the State Officials and Employees Ethics Act.
Chicago State University will take appropriate disciplinary and legal action against
any individual or entity who commits fraud against the University. Any employee or
student who engages in fraudulent activity relative to Chicago State University will
be subject to discipline, which may include, but is not limited to, discharge from
employment, expulsion from the University and or criminal prosecution under appropriate
State and federal laws.
In accordance with the Whistle Blower Protection Act (5 ILCS 395 et seq.), any Chicago
State employee who reasonably believes that fraudulent activity has been conducted
by another employee and reasonably reports the activity will not be subjected to an
adverse employment action as a result of reporting the activity.
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