PURPOSE
The purpose of this procedure is to establish the reporting and investigation process for suspected fraud, waste or abuse reported by City employees, vendors or the public.
PROCEDURE
Filing a Report
1. Employees who report suspected fraud are protected by the Utah Protection of Public Employees Act (Utah Code Annotated, Title 67 Chapter 21).
2. Employees are responsible to report fraud, misappropriations, theft, forgery, waste, abuse and other irregularities.
3. Suspected fraud, waste or abuse should be reported immediately, providing as much information as possible to aid in the investigation including: names of individuals involved, details about the issue and the date, time and place of the occurrence.
Employees may file a report directly through one of the following means:
- Their immediate supervisor.
- Their division or department director.
- The City Human Resources Department.
- An auditor/investigator in the Finance Department.
If the employee prefers to remain anonymous, a report can be placed through the City’s third party fraud, waste and abuse hotline using one of the following methods:
- On line: reports@lighthouse-services.com
- Telephone: 844-405-0007 (toll free)
- Email: reports@lighthouse-services.com (must include company name with
report)
- Fax: 215-689-3885
4. Employees should not file false, frivolous or malicious reports.
5. Employees should not alert suspected individuals that they are the subject of or part of a fraud, waste or abuse report. If a supervisor is suspected of being involved in the activity being reported, the employee should choose a reporting avenue that does not involve that supervisor.
6. Employees should not attempt to personally conduct investigations or interviews/interrogations related to any suspected inappropriate activity. The employee making the report should not contact the suspected individual in an effort to determine facts or demand restitution.
Intake and Assessment (for System Administrators only)
1. All reports, regardless of the method used to report, will be submitted into the Lighthouse software package. These will be forwarded to the Fraud, Waste and Abuse Committee (the “Committee”) for review. The Committee is made up of a diverse group with representation from the following departments: Finance, Human Resources, Attorney’s Office, Mayor’s Office and Council Staff. Their role is to review each report, determine who should conduct the investigation. The Committee will also make recommendations of appropriate action at the conclusion of an investigation.
2. If an employee reports a suspected irregularity through a supervisor, director, department director, the Human Resources Department, the Finance Department, or an investigator, the individual receiving the report will contact the Fraud, Waste and Abuse System administrators immediately and relay the report.
3. Confidentiality is critical in every case. Members of the Committee, reporting system administrators, investigators and any managers involved in investigating a report should not discuss the case, facts, suspicions, or allegations with anyone not key to the investigation unless specifically authorized by the Committee.
4. All case files will be maintained by the system administrators under the direction of the Committee. A record of each case will be kept in the case management system.
Investigation and Reporting
1. In the event a report is made against a department director or any Finance division director the case may be outsourced by the Committee.
2. Any person or group to which a case is referred or outsourced will report the progress of the investigation back to the Committee on a regular basis. Investigators will regularly update the status in the case management system of the hotline for the cases they are assigned. The system administrators will then regularly update the Committee on the status of each case.
3. The system administrators will manage the assignment of cases to investigators under the direction of the Committee. Cases may be assigned to specific investigators, department directors or external investigators at the discretion of the Committee or the system administrator upon delegation from the Committee.
4. The system administrators will have access to all cases through the case management system of the fraud, waste and abuse hotline provided by a third party contractor. Investigators will only have access to information regarding the cases they are assigned.
5. If the Committee deems it necessary, an investigator may be asked to attend a meeting with the Committee.
6. With necessary approval from the Committee, investigators will have access to all City records and premises, whether owned or rented. They will also have the authority to examine, copy, and remove all or any portion of the contents of files, desks, cabinets, computers and other storage facilities on City premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.
7. Upon conclusion of the investigation, a draft report will be made to the Committee. This report may include any recommendations relating to the case. A final report will include changes made by the Committee and any responses from the department involved. The report will be given to the Committee for distribution.
8. If an investigation substantiates that a violation has occurred, the Committee will distribute reports to appropriate designated member of City management.
Training
1. The Finance Department will conduct regular training on fraud, waste and abuse in each department and as part of the City’s new hire orientation in an effort to ensure that each City employee is familiar with the policy and procedure on fraud, waste and abuse.
2. This procedure and the City’s policy on Fraud, Waste and Abuse Detection and Prevention will be made available to all employees as part of their new hire orientation.
Administration
1. The Chief Financial Officer is responsible for the administration, revision, interpretation, and application of this policy. The policy will be reviewed and revised as needed.