Fraud and Theft Prevention Policy
To prevent and detect fraud and theft, assign responsibility for implementing appropriate controls to prevent and detect fraud and theft, establish the appropriate reporting mechanisms to be used for notification of known or suspected fraud and theft, and establish the consequences for fraud and theft by employees.
All University of Kansas employees, customers, vendors, contractors, consultants, or other parties related to the University.
Scope of Policy
University of Kansas (KU) employees must comply with applicable state and federal law, Kansas Board of Regents policy, and University policy. Furthermore, a KU employee cannot be compelled by a supervisor or a University official to violate a law, Board of Regents policy, or University policy.
As a publicly supported institution, the University has a fiduciary responsibility to conserve, preserve, and efficiently use all University resources.
This policy applies to any known or suspected fraud or theft involving employees, customers, vendors, contractors, consultants, or other parties related to the University.
Prevention and Detection of Fraud and Theft
University employees shall not perpetrate, engage in, or otherwise facilitate the act of committing fraud and theft.
The Provost/Executive Vice Chancellor, Lawrence Campus, and Executive Vice Chancellor, Medical Center, are responsible for establishing the controls to prevent and detect fraud and theft. University managers are responsible for knowing the types of improprieties that might occur within their areas of responsibility and for identifying and assessing any irregularities. University employees are responsible for the prevention and detection of fraud and theft that might occur within the scope of their work assignments and for reporting any known or suspected fraud and theft.
Reporting Known or Suspected Fraud and Theft
Employees are responsible for immediately reporting known or suspected incidents of fraud, including theft and misappropriation of University Assets, to either the Internal Audit Department or the appropriate campus Public Safety office.
Any employee who has knowledge of fraud or theft of University Assets by any person or organization, including another employee, and does not report it to University officials may be subject to disciplinary action, up to and including termination of employment.
If the initial notification is to the Internal Audit Department, Internal Audit shall notify the appropriate campus Public Safety office and vice versa.
Investigation of Reports of Known or Suspected Fraud and Theft
The campus Public Safety office shall investigate allegations of fraud and theft in accordance with University established policies and procedures.
The Internal Audit Department shall be responsible for ascertaining the extent of loss, and for reviewing and evaluating control and/or process failures related to the loss. Internal Audit will also notify the University Chief Business and Financial Planning Officer, Office of the General Counsel, the Provost/Executive Vice Chancellor, Lawrence Campus, and/or the Executive Vice Chancellor, Medical Center.
Any employee who suspects fraudulent activity should not attempt to personally conduct an investigation related to the activity. If the employee elects to notify department management first, then department management must immediately notify the Internal Audit Department or the appropriate campus Public Safety office before taking any other action. Concerns about work performance and workplace behavior that are unrelated to fraudulent activity should be resolved by department management and Human Resources (Lawrence) or Human Resources (Medical Center): they should not be reported under the fraud and theft policy. If there are any questions about what constitutes fraud and theft, the Internal Audit Department should be contacted.
Reports and investigations of allegations of fraud and theft ordinarily will be kept confidential to the reasonable extent possible under law and consistent with the need to conduct an adequate investigation and take corrective action.
If appropriate University officials conclude that an employee has engaged in fraud or theft, appropriate disciplinary action will be pursued, up to and including termination of employment, in accordance with applicable personnel policies for faculty and staff. In addition, employees engaging in fraud or theft will be required to pay restitution, including the cost of the investigation.
Employees of the University of Kansas who engage in fraudulent activity or theft are not acting within the scope of their employment and should not expect protection for their acts under either the Kansas Tort Claims Act or any applicable University insurance policy.
It is the policy of the University of Kansas to pursue legal action based on the merits of the case in consultation with the Office of the General Counsel.
Ordinarily, the submission of a resignation by an employee accused or suspected of fraud or theft will not preclude later disciplinary action, including restitution and legal action. If restitution is required, payment arrangements will be established with the office of the Provost/Executive Vice Chancellor, Lawrence Campus, or the Executive Vice Chancellor, Medical Center.
Department of Internal Audit
1450 Jayhawk Blvd., Suite 351
Lawrence, KS 66045
Fraud Hotline: 785-864-1300
Office of the General Counsel
1450 Jayhawk Blvd., Suite 245
Lawrence, KS 66045
The University of Kansas, Lawrence campus
Office of the Provost and Executive Vice Chancellor
1450 Jayhawk Blvd., Suite 250
Lawrence, KS 66045
University of Kansas Medical Center
Office of the Executive Vice Chancellor
2032 Murphy Administration Building
Mail Stop 2015
3901 Rainbow Boulevard
Kansas City, KS 66160
Note: The Office of the General Counsel is key contact for policy interpretation, enforcement, and other issues not specifically addressed in this policy.
Organization responsible for appropriate execution of this policy:
- Department of Internal Audit
- Office of the General Counsel
- Office of the Provost/Executive Vice Chancellor, Lawrence Campus
- Office of the Executive Vice Chancellor, Medical Center
University Employee: includes faculty, unclassified academic staff, unclassified professional staff, University Support Staff, classified staff, and student employees, regardless of nature of appointment.
University Assets: include, but are not limited to money, negotiable securities, supplies, equipment, facilities, licenses and rights, and all other property owned by or entrusted to the University for the purpose of carrying out University functions. This includes all assets regardless of where they are located or by whom they are held. This includes services provided by the University.
Misappropriation or Misuse (intentional): the unauthorized use or control over University Assets by an employee with the intent to deprive the University of temporary use of the Assets.
Theft: a taking of University Assets that results in a loss to the University. Examples of theft include:
- Obtaining by fraud, control over University Assets with the intent to permanently deprive the University of ownership;
- Using University assets for personal purposes except for permitted incidental personal use;
- Authorizing or receiving payments for goods not received or services not performed;
- Authorizing or receiving payment for hours not worked;
Fraud: the deliberate misrepresentation of fact for the purpose of depriving the University permanently of property or legal right to property. Examples include, but are not limited to:
- Corruption: conflicts of interest, bribery, illegal gratuities, and economic extortion
- Cash asset misappropriation: larceny; skimming; check tampering; and fraudulent disbursements, including billing, payroll, and expense reimbursement schemes.
- Non-cash asset misappropriation: larceny; false asset requisitions; destruction, removal or inappropriate use of records and equipment; inappropriate disclosure of confidential information; and document forgery or alteration
- Fraudulent statements: financial reporting, employment credentials, and external reporting
- Fraudulent actions by customers, vendors or other parties include bribes or inducements, and fraudulent (rather than erroneous) invoices from a supplier or information from a customer.
07/08/2016: Updated to remove gendered pronouns.
11/17/2014: Policy formatting cleanup (e.g., bolding, spacing).
12/11/2009: Approved by Chancellor Bernadette Gray-Little.