ORIGINATOR: Associate Vice President, Finance

SUBJECT: Reporting Suspected or Known Fiscal Irregularities

I. Introduction

In accordance with the University System of Maryland (USM) Policy on Reporting Suspected or Known Fiscal Irregularities (VIII - 7.10), approved by the Board of Regents on June 21, 1990, the University of Maryland University College is establishing this internal control structure in order to ensure financial accountability. Every employee is responsible for safeguarding the assets of the institution and preventing and/or reporting the misuse of these assets.

II. Procedures

1. Every Department/Unit Head is responsible for creating a comprehensive internal control plan that ensures financial accountability within the University.

2. Reporting

1. Suspected or known fiscal irregularities such as embezzlement, theft, falsification of documents, and financial conflicts of interest must be reported to the Associate Vice President of Finance, who will notify the Sr. Vice President and CFO, and Security. Security will investigate and/or notify Campus Police of serious crimes and prepare a written report for the SVP & CFO. The SVP & CFO or his designee will notify the Chancellor, the System Administration Internal Audit Office, the manager of financial operations where the fiscal irregularity allegedly occurred, and the Office of Attorney General.

2. Irregularities involving the loss of assets with a monetary or fair market value of $100 or less will not be reported to the Chancellor and Internal Audit Office unless they occur in departments that routinely handle cash or cash equivalents. Irregularities in departments that routinely handle other valuable assets such as inventories, accounts receivable, and marketable securities, or involve personnel responsible for major fiscal functions such as payroll, procurement, accounts payable, or bookkeeping will be reported to the Chancellor and Internal Audit Office.

3. The Sr. Vice President and CFO shall immediately investigate the report of alleged misconduct. When a preliminary investigation has been completed, the responsible official will report the findings to the President who, in consultation with the Office of Attorney General, shall determine a course of action, e.g., discipline, restitution, or discharge. The determination of the President shall be reported to the System Administration Internal Audit Office and the Chancellor. The Office of Attorney General will independently make a determination concerning criminal prosecution.

4. A person who suspects financial misconduct may initially report the suspicion to the Internal Audit Office of System Administration for investigation. Preliminary findings will be reported by the Internal Audit Office to the Chancellor and to the President for further action.

5. In no case may University System officials promise known or suspected offenders that the University System will forego criminal prosecution and in no case may the officials enter into written agreements that preclude criminal prosecution.

6. Federal requirements shall be followed if the financial misconduct involves federal grant funds.

7. Every effort shall be made to ensure the confidentiality of any person reporting suspected financial misconduct, and every effort shall be made to ensure that no retaliation of any kind will be tolerated against any individual who, in good faith, furnishes information about known or suspected fiscal irregularities.