SUNY System Fraud Policy

The SUNY Board of Trustees adopted a Fraud Policy at its March 2013 Board Meeting.  The Fraud policy helps to set the tone of the organization and communicate to all employees the requirement for honest behavior, ethical conduct, and fiduciary oversight with SUNY funds, resources, and property. At this meeting, the Board of Trustee's also amended the existing Fraud Procedure. The impact of this new Fraud and Irregularities Policy and the Fraud Procedure changes are outlined below.

SUNY already maintains a System-wide Fraud Hotline to Report Suspected Fraud. Through the revised procedure, campuses will be required to report all frauds to the Office of University Audit so they may be tracked and monitored by the Fraud Committee using a standard form, and report to the Office of the University Auditor any contact from the New York State Attorney General, the Inspector General, or any other outside agency regarding any investigation. In addition, each campus is required to establish a mechanism (fraud hotline) such as a toll free number, e-mail address, or facsimile number that individuals can use to report suspected and detected fraud and irregularities.

SUNY Fraud Resources (including methods of reporting)

SUNY Fraud Policy and Procedure

• SUNY Policy on Fraud and Irregularities.
• SUNY Procedure on Reporting and Reviewing Fraud and Irregularities.

Notable Features of the Fraud & Irregularities Policy and Procedure

• NOTICE ON CONFIDENTIALITY
  Reports made to the hotline will be treated as confidential. However, this confidentiality is not absolute because of legal or other requirements (e.g., discovery in litigation, government investigations, etc.) and situations where the University would need to use the information to protect the University's interests. SUNY will do everything it can to protect a reporter's identity during the investigation and handling of a matter, but in some limited situations the person being investigated may be able to ascertain who the reporter is just by the nature of the facts or the contextual situation that gave rise to the report.
• FRAUD PROCEDURE SIGNIFICANT CHANGES
  SUNY has had a fraud procedure in place since since November 1993, and also maintains a system-wide fraud hotline, where all frauds are tracked and investigated in accordance with the Fraud Procedure by the Fraud Committee. Significant changes to SUNY’s fraud procedure, adopted in March of 2013 include:
  1. Title change to clarify that the procedure includes reporting and reviewing.
  2. Requirement for campuses to establish a fraud hotline.
  3. Definition of the “types of activities covered.”
  4. Clarification of the types of activities that are covered under other policies/procedures such as complaints of sexual harassment.
  5. Clarification on where and how to file a complaint or allegation.
  6. The Office of University Controller is added as a member of the Fraud Committee.
  7. Clarification of the steps related to reviewing complaints and allegations.
• CAMPUS MUST HAVE REPORTING MECHANISM AND MUST REPORT FRAUDS TO SYSTEM:
  As part of the revised fraud procedure, System Administration and each campus is required to identify an individual to whom suspected or detected fraud and irregularities must be reported. In addition, System Administration and each campus is required to establish an easily accessible mechanism (fraud hotline) such as a toll free number, e-mail address, or facsimile number that individuals can use to report suspected or detected fraud and irregularities. Furthermore, campuses are required to report any suspected or detected fraud to the Office of the University Auditor at System Administration.  “Campuses and System Administration are further required to report any suspected or detected fraud to the Office of the University Auditor at System Administration using Form A”
• FRAUD IS DEFINED BROADLY:
  The procedure addresses that “for the purpose of these procedures, fraud and irregularities includes activities that are:
  1. a misappropriation of assets;
  2. in violation of or non-compliant with any SUNY, New York State, or federal law, regulation, policy or procedure;
  3. economically wasteful;
  4. an indication of gross misconduct or incompetency; or
  5. an unethical, improper, or dishonest act."

SUNY Fraud Resources

SUNY Compliance Webpage on the SUNY Systemwide Fraud Hotline, which includes information on how to report fraud

SUNY Compliance Webpage with the Campus Fraud Hotlines - the campus-specific fraud hotlines are listed on this website in one place.  Campus-specific fraud reports can also be reported to the SUNY Systen-wide Fraud hotline.

Methods of Reporting

If you suspect fraud, waste, abuse, or irregular activities within the University, you may report these allegations anonymously to the University Auditor in the methods listed below.