Original Issuance Date: May 1, 2017
Last Revision Date: May 1, 2017

1. Purpose of Procedures

This procedure outlines the process through which acts of fiscal misconduct within the UW System are to be reported, investigated, and resolved.

2. Responsible UW System Officer

Vice President for Finance

3. Definitions

Fiscal Misconduct: A deliberate act or failure to act that is contrary to established laws, regulations or policies and which results or was intended to result in either loss or other damage to the State or the UW System or improper personal gain. Instances of fiscal misconduct to be reported and reviewed include:

  • Theft of any State or UW System funds
  • Bribery, kickbacks, and bid rigging
  • Misappropriation, misapplication, destruction, removal, or concealment of State or UW System funds
  • Authorizing or receiving compensation for hours not worked or covered by appropriate and available leave
  • Improper handling or reporting of financial transactions
  • Credit card and travel expense fraud
  • Forgery, falsification, or unauthorized alteration of financial documents or records

4. Procedures

As soon as there is any indication of an actual or suspected act of fiscal misconduct the process outlined below shall be followed. Where the suspected fiscal misconduct occurs at UW System Administration or involves a chancellor, the term ‘UW System President’ shall be substituted for ‘chancellor’ in the following process.

  1. The discovering party should generally notify their immediate supervisor of the situation. The supervisor, in turn, should immediately notify the institution’s chief business officer or the UW System Vice President for Finance.
    1. If the individual is uncomfortable speaking with the supervisor, is not satisfied with the supervisor’s response, or does not have a supervisor, the individual may report the concern directly to:
      • the institution’s chief business officer;
      • the UW System Vice President for Finance;
      • the UW System Office of Internal Audit; or
      • the UW System Waste, Fraud and Abuse Hotline.

The relevant UW System institution shall conduct a preliminary review into the suspected instance of fiscal misconduct.

If the institution determines that the suspected fiscal misconduct has not caused or is unlikely to cause significant financial, legal, and/or reputational risk to the UW System or the institution, the institution may resolve and conclude the matter through appropriate institutional processes.

If the preliminary review finds that the suspected fiscal misconduct has caused or is likely to cause significant financial, legal, and/or reputational risk to the UW System or the institution, the chancellor or other appropriate institutional representative shall report the suspected misconduct to the Chief Audit Executive and the UW System Vice President for Finance. The remainder of this procedure shall then be followed.

  1. The Chief Audit Executive, or designee, shall convene a working group to coordinate a more comprehensive review. Representation will vary from instance to instance, depending on the nature of the suspected fiscal misconduct and the individual(s) involved. However, individuals from the following areas shall be considered when convening a working group:
    • University police or campus safety;
    • appropriate institutional officials, as designated by the chancellor;
    • UW System Office of Internal Audit (convener);
    • UW System Office of Finance; and
    • UW System Office of Human Resources and Workforce Diversity.

A working group may consult with the UW System Office of General Counsel, or in the case of UW-Madison or UW-Milwaukee the campus legal affairs office, for advice and counsel where needed.

If uncertain whether an instance of suspected fiscal misconduct rises to the threshold where a working group is to be convened under this procedure, the chancellor or other appropriate institutional representative should consult with the Vice President for Finance and the Chief Audit Executive.

  1. The working group shall thoroughly review the suspected fiscal misconduct to determine if a violation has occurred. Every effort will be made to maintain confidentiality throughout the review process to the extent allowable by law. However, confidentiality is not guaranteed.
  2. If a violation is found to have occurred, the chancellor shall:
    • determine whether referral of the matter to the Department of Justice and/or local law enforcement agencies is necessary for purposes of potential criminal prosecution or other legal action;
    • notify federal authorities if federal funds or resources are involved;
    • determine whether any disciplinary action may be appropriate. Any disciplinary action the chancellor may wish to initiate must follow applicable UW System and/or institutional policies and procedures.

In addition, the Chief Audit Executive shall notify the UW System President and the Chair of the Board of Regents Audit Committee of any material instances of fiscal misconduct. The UW System Office of Internal Audit may prepare a report for the Audit Committee of the Board of Regents based on a determination of a violation by the working group.

The working group may offer recommendations for improvement of policies, processes, or controls to institutional personnel based on its review.

5. Related Documents

UW System Administrative Policy 304, Fiscal Misconduct

6. History

First approved: May 1, 2017*

*Prior to this date, UW System Administrative Policy 304, Fiscal Misconduct, contained certain procedures now revised and found in this document.

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