All faculty, staff, Medical Center employees, and other individuals associated with the University (e.g., contractors, vendors, volunteers, student employees, and others while working or acting on behalf of the University or the Medical Center) must immediately report known or suspected Fraudulent Transactions to UVA Audit, regardless of the source of funds.

Any report of a suspected Fraudulent Transaction may be made using one of these options:

• If anonymity is desired, use the UVA Compliance Helpline to submit a report securely and confidentially, either by completing a web intake form or calling (800) 235-8700.
• Fill out an online form with the Office of the State Inspector General Fraud, Waste, and Abuse Hotline or call (800) 723-1615.

The University prohibits retaliation against any individual who makes a good faith report of suspected wrongful conduct pursuant to this policy or related federal or state laws.

Fraudulent activities will be reported to the appropriate local, state, and/or federal authorities as specified in Section 1 below.

1. Responsibilities:

   1. UVA Audit is responsible for:

      • Receiving complaints for investigation.
      • Coordinating with the University Police Division as needed in resolving complaints.
      • Investigating allegations that do not involve the University President, internal audit department or staff, or any other parties stipulated in Code of Virginia Section 2.2-309.B.
      • Establishing whether allegations are substantiated based on the investigation’s procedures, including collaboration with relevant offices and subject matter experts as needed.
      • Determining if there is a “reasonable possibility” that a Fraudulent Transaction has occurred (in consultation with the Office of the University Counsel).
      • Coordinating with UVA Health's Chief Corporate Compliance and Privacy Officer as necessary.
      • Drafting the written notification to other state agencies such as the Auditor of Public Accounts, the State Inspector General, and the Superintendent of State Police, as required by Code of Virginia Section 30-138.A. and submitting it to the University President if UVA Audit concludes that there is a reasonable possibility that a Fraudulent Transaction has occurred.
      • Communicating informally with the Office of the State Inspector General prior to the issuance of a written notification.
      • Providing a written report to the affected area to address any identified misconduct or policy deviations and copying the responsible executive vice president. Copies of such reports may be provided to University Human Resources – Employee Relations, the Office of University Counsel, or other officials to help address the identified issues.
      • Communicating with the Audit, Compliance, and Risk Committee of the University Board of Visitors as needed on matters related to an investigation and results of its investigations of suspected Fraudulent Transactions.
      • Reporting incidents involving students to the Vice President & Chief Student Affairs Officer and the University Judiciary Committee.
      • Reporting incidents involving research or sponsored awards to the Office of Sponsored Programs.
      • Serving as investigative liaison to other state agencies as needed on non-criminal fraud investigations.

   2. The University Police Division is responsible for:

      • Making determinations of fraud in suspected fraud cases and conducting criminal investigations as needed.
      • Communicating informally with the Virginia State Police prior to the issuance of the written notification required by Code of Virginia Section 30-138.
      • Serving as investigative liaison to other state agencies on criminal fraud investigations.

   3. The Office of the University Counsel is responsible for:

      • Assisting UVA Audit in determining whether there is a “reasonable possibility” of fraud in a transaction.
      • Reviewing draft notifications under Code of Virginia Section 30-138 as prepared by UVA Audit.
      • Consulting with the University Police Division and other University officials in the determination of fraudulent activity and advising on the associated legal and administrative actions to be taken.
   4. The University President is responsible for submitting the notifications to other state agencies required under Code of Virginia Section 30-138.A if there is a reasonable possibility that a Fraudulent Transaction has occurred involving funds or property under the control of the University.

   5. All persons - All faculty, staff, Medical Center employees, and other individuals associated with the University (e.g., contractors, vendors, volunteers, student employees, and others while working or acting on behalf of the University or the Medical Center) are responsible for:

      • Reporting known or suspected Fraudulent Transactions.
      • Cooperating fully with individuals performing investigations by providing all requested documentation and answering all questions truthfully and completely.

   6. All managers and executives required to respond to an investigative report are responsible for:

      • Implementing corrective measures and working with UVA Audit to implement such measures.
      • Working with University Human Resources – Employee Relations to take any disciplinary actions necessary to address the findings.
      • Regularly reporting to UVA Audit all corrective measures and disciplinary actions until such actions are completed.

2. Compliance with Policy:       
   Failure to comply with the requirements of this policy may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies. The willful failure to report certain Fraudulent Transactions as required by Code of Virginia Section 30-138 shall constitute a Class 3 misdemeanor.

   Questions about this policy should be directed to UVA Audit.