Crown Management Capital Reviews: Fraud, Waste, and Abuse

7/29/2019 Crown Management Capital Reviews: Fraud, Waste, and Abuse

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United StateS environmental Protection agency

of isp g

Fraud, Waste, and abuse

Prevention, Detection, and Reporting

for Federal, State, Local, and Tribal Administrators


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United StateS environmental Protection agency

of isp g

Catalyst for Improving the Environment

who we are

The Ofce o Inspector General is an independent ofce within EPA that helps the

Agency protect the environment in a more efcient and cost eective manner.

We consist o auditors, program analysts, investigators, and others with extensive

expertise.

what we do

We perorm audits, evaluations, and investigations o EPA and its contractors,

grantees, and recipients o other Federal unds to promote economy and efciency,

and to prevent and detect raud, waste, and abuse. We also maintain the OIG

Hotline.

why we do it

We strive to serve as a catalyst or improving the environment. By helping the

Agency operate more economically, eectively, and efciently, we contribute to

improved environmental quality and human health. We strive to provide solutions to

problems that ultimately result in making America a cleaner and healthier place.

oUr miSSion

Add value by promoting economy, efciency, and eectiveness within EPA and the

delivery o environmental programs. Inspire public confdence by preventing and

detecting raud, waste, and abuse in Agency operations and protecting the integrity

o EPA programs.

There is no kind of dishonesty into which otherwise good people more

easily and frequently fall than that of defrauding the government.

Bj Fk

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Fraud, Waste, and abusePrevention, Detection, and Reporting

for Federal, State, Local, and Tribal Administrators

F, W, aWh i i?

Wh i FSimply raud is a alse representation about a material act.

It is any intentional deception designed to deprive the United States, or EPA,unlawully o something o value or to secure rom the United States, or EPA, oran individual, a benet, privilege, allowance, or consideration to which he or sheis not entitled.

Wh i WIt is the extravagant, careless, or needless expenditure o Government unds, orthe consumption o Government property, that results rom decient practices,systems, controls, or decisions. Te term also includes improper practices notinvolving prosecutable raud.

Wh i aIt is the intentional or improper use o Government resources. Examplesinclude misuse o rank, position, or authority or misuse o resources such astools, vehicles, or copying machines.

Strive for Accountability and Integrity 2


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How C I tll i F, W, a Occig?

You can tell i raud, waste, and abuse are occurring by looking or raudindicators.

Fraud indicators are clues that may warrant urther review o a specic area oractivity.

Some o the indicators o raud include:

No separation of duties.

Lack of internal controls. High turnover of personnel.

Unexplained entries or altered records.

Unusually large amounts of payments for cash.

Inadequate or missing documentation.

Non-serial number transactions.

Unauthorized transactions.

While the above occurrences are indicators o raud, they could also be indicatorso weak or poor business practices without actual raud occurring; suchindicators can oen lead to opportunities to commit raud.

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Remember, Act Like Its Your Money It Is!

a Fl, s, Locl, o til amiio,Wh C I do o avoi tol ?

If you suspect any irregularities, or criminal acts, contact theEPA OIG immediately.

Establish regular, open and clear lines of communication with yourcontractors, awardees, or recipients. Know who they are and whatthey do.

Follow established agency policies, procedures, rules andregulations.

Keep current on training and applicable regulations.

Correct any audit or program evaluation ndings promptly.

Ensure contractor, awardee, or recipient accountability.

Conduct site visits, examine work performed and ensure recipientcompliance with terms o contract or grant.

Ensure that all work is being performed as originally outlined andplanned.

Protect Government information, resources, and equipment underyour control.

Above all else, if you have any questions or concerns, ask your EPA contact.We are here to assist you. We want you to succeed.

I you are a ederal employee, you are duty bound to report Fraud, Waste, Abuse,and Corruption under the Code of Federal Regulations (CFR):

Employees Shall Disclose Waste, Fraud, Abuse, and Corruption to AppropriateAuthorities. 5 CFR 2635.101(b)(11)

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Commo F schm...Wh o Look o Fom Yo sppli, Vo, Coco,

o scoco

Pohii Pcic bo h aw o Coc o G

biy, Gii, KickckGiving or receiving a thing o value or the purpose o inuencing an ofcial actor an award.

Acceptance of inappropriate, high-value gis or services fromsuppliers, contractors, or awardees.

Overly friendly interaction between government employee andcontractor or awardee.

Sudden unexplained increase in wealth.

Coic o I ehic ViolioGovernment personnel using their ofcial duties to garner personal or nancialgain.

Acceptance of gis from a vendor or contractor.

Government personnel providing proprietary information to one,or a ew competitors.

Government personnel negotiating for employment with a companythat they have an ofcial interest in or with.

ulc biigContracting personnel providing a favored bidder with information in the bidprocess.

Particular line item bids appear to be unreasonably low.

Change orders issued soon aer contract award deleting ormodiying line items.

Bidder is close to a government procurement ocial, or directlyparticipated in draing the contract specications.

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Pohii Pcic a h aw o Coc o G

dciv Picig

Contractors failure to disclose all facts that aect its cost for pricing productsor services. Not disclosing signicant cost issues that will reduce contractors

proposed costs.

Indications of falsication or alteration of supporting data.

Denial of the existence of historical records.

Co MichgigImproper allocation o costs to a cost contract or charging at higher than allowedrates.

Labor time and charges inconsistent with project progress.

Time cards completed by management and not individualemployees.

Inability to produce time cards immediately when requested.

Lower level work being done by high level wage earners.

Poc siioContractors deliver goods which do not conform to contract requirementswithout making proper notications.

Falsication of test results, or delivery of counterfeit products.

Providing foreign made products where domestic products arerequired.

Using one coat of paint instead of two, or using watered loadso concrete.

Fl sm Fl ClimKnowingly and willully alsiying or concealing a material act, knowing thesame contains any materially alse statement or entry.

Discrepancies between reported facts and supportingdocumentation.

Inability or refusal to provide supporting documentation.

Site inspection reveals less progress on the site than reported.

Protecting our Environment for Our Childrens Future 6


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s o Coc ViolioAll EPA employees are expected to adhere to certain standards o conduct which,i violated, could adversely reect on the Agency. Such prohibited conduct in-cludes, but is not limited to:

Ocial or moral misconduct (on or o duty).

Soliciting or accepting gis from outside sources.

Abuse of authority or position.

Misuse of government time, equipment, IT resources, andinormation.

(Other Federal, State, and Local employees should know and adhereto their applicable Standards of Conduct).

Comp CimComputer fraud includes anyone who knowingly accesses a computer withoutauthorization; exceeds authorized access; obtains information from any depart-ment or agency o the US Government to urther an intended raud; or to accessprohibited sites.

Wh shol Yo o i Yo spc Flaciviy, W, o a

Do contact the OIG Hotline.

Do discuss your concerns with the OIG.

Do seek answers to your questions in the normal course ofbusiness.

Do cooperate with the OIG and expect to be contacted andinvolved.

Dont eel compelled to prove a case or intent.

Dont tip o subjects of actual or pending investigation.

Dont stop your normal course o business unless otherwisedirected.

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Whillow Pocio

A whistleblower is an individual that believes his or her organization is engagedin or willully permits unethical, or unlawul activities and reports it.

e Whistleblower Protection Act (WPA) provides protection rights to Federalemployees. Under WPA, Federal employees may seek protection rom the Ofceof Special Counsel and the Merit Systems Protection Board.

Section 1553 of the American Recovery and Reinvestment Act (ARRA) extendsthe whistleblower protection to non-federal employees, whose employer is re-ceiving ARRA funds.

Any employee of any non-Federal employer receiving funds under ARRA, may notbe discharged, demoted, or otherwise discriminated against as a reprisal for disclos-ing; Mismanagement, Waste, A danger to public Health or Safety, or any Violationof law, rule, or regulation.

(Non-federal employers include a State or Local employing agency, as well as,private companies).

Additional inormation about Whistleblower Protection may be ound at theOce of Special Counsel website, www.osc.gov.

We All Have a Choice, Choose to do the Right Thing 8


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rpo spc F aciviy o O Ofc

Yu ca Place a telephe Call our 24-hur Hlie

(888) 546-8740

Yu Ca Mail Us

U.S. Environmental Protection AgencyOfce o Inspector General Hotline (2443)

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Yu Ca E-mail Us

[email protected]

or Yu Ca Cac our ofces Direcly

Northeastern Resource CenterArlington, VA(703) 347-8740

Eastern Resource CenterAtlanta, GA

(404) 562-9857

Central Resource CenterChicago, IL

(312) 353-2507

Western Resource CenterSan Francisco, CA

(415) 947-4507

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Protecting our Environment for Our Childrens Future

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Crown Management Capital Reviews: Fraud, Waste, and Abuse

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