Tip #8. Compliance and Procurement – Fraud, Abuse and Waste of Federal Programs from our Compliance & Resource Development Director, Vince Franco.
Fraud
- Fraud is theft. The intent is to take something of value from someone of something.
- Fraud is deception. The intent is to give someone or something a consideration to which they are not entitled.
- Fraud is deliberate.
Abuse
- Abuse is the improper use of government resources.
- Abuse is deliberate.
- Waste
- Waste is carelessness.
- Waste is excessive spending of federal funds.
- Waste is unnecessary use of federal funds or property.
Appropriate Questions:
- What can I/we do to reduce the risk of fraud, abuse and waste in our organization/tribe/housing authority/department?
- What are the most common anti-fraud measures for federal funding?
- Where can I find regulations for financial and operational activities?
Potential Solutions:
Documentation
- Require original documents…not copies
- Receipts for all transactions
- Conduct periodic reviews by someone other than the provided of the documentation
- Develop internal controls and provide training
Payments
- Establish who is authorized to sign, when, for what, and how much
- Develop a Conflict of Interest policy
- Develop internal controls and provide training
Reporting
- Conduct periodic reviews
- Develop internal controls and provide training
Misappropriation
- Conduct periodic reviews of allowable and unallowable costs
- Monitor bank accounts
- Develop internal controls and provide training
Unallowable Costs
- Conduct self-monitoring
- Develop internal controls and provide training
Non-Compliance with Grant Regulations
- Conduct self-monitoring
- Develop internal controls and provide training
Common Anti-Fraud Measures:
- Develop a Code of Conduct
- Implement internal and external audits of financial and operational activities
- Conduct management reviews
- Become familiar with 2 CFR Part 200 Uniform Guidance (Super Circular) Develop internal controls and policies/procedures
- Implement self-monitoring
