Supervisor Compliance Check List

State Whistleblower Protection

Employees are encouraged to disclose improper governmental action and have their rights protected.

Reporting Improper Action

• Must be within 1 year of occurrence.
• Whistleblower (employee reporting allegation) remains confidential.

Retaliatory Action Defined

• Denied adequate staff or staff changes.
• Undesirable office location.
• Refusal to assign meaningful work.
• Unwarranted/unsubstantiated letter of reprimand.
• Demotion, suspension, dismissal.
• Encourage coworkers' hostility.

Examples of Recent Whistleblowers

• Agency paid employee while they were on unpaid leave.
• Employee claimed hours worked when they were not at their designated workstation.

Key Ethical Concepts and the Use of State Resources

Responsibility for ethical violation rests with the state employee or the supervisor who authorized the employee action. State officers and employees never lose their identity as a state employee, even when they are not working.

Student employees are state employees and are subject to restrictions while employed. University visitors and employee family members (including children) are not authorized to use university information technology resources.

Substantive Rule

• State employees are obligated to conserve and protect state resources for the benefit of the public interest.
• State employees may not use state resources for private gain.

Use of Email

• Personal outside business use of email is NOT permitted.
• Occasional and limited personal (non-business) use is acceptable, if it does not interfere with the performance of state duties.

Use of the Internet

• Use of the Internet is subject to the de minimis rule.
• Personal or personal outside business use of the Internet is a violation of the Ethics Law.

Phone Calls/Fax/Voice Mail/Cell Phones/Copy Machine

• Personal or personal business use of phones and copy machines is a violation of the Ethics Law, even if reimbursed.

Consumable Supplies

• Personal use of paper, envelopes, tablets, and other office, shop, maintenance, custodial, and motor vehicle supplies is a violation of the Ethics Law.

Internal Control

Internal control is a process, affected by Central Washington University Board of Trustees, administration, and especially line management. It is designed to provide reasonable assurance regarding the effectiveness and efficiency of operations, the reliability of financial reporting, and compliance with applicable laws and regulations.

Internal controls are the practices performed by departments to provide management with reasonable assurance that assets are safeguarded and transactions are authorized, valid, complete and accurate.

Line management, more than any other function, is directly responsible for all Central Washington University activities, including its internal control system. The responsibilities of the control system are to safeguard assets and use resources wisely.

Benefits of Internal Controls

• Prevents errors and irregularities from occurring. If errors or irregularities do occur, they will be detected in a timely manner.
• Encourages adherence to prescribed policies and procedures.
• Protects employees:
  1. By clearly outlining tasks and responsibilities:
  2. By providing checks and balances: and,
  3. From being accused of misappropriations, errors or irregularities

Separation of Duties

No person should have control over a transaction from beginning to end. Ideally, no person should be able to record, authorize and reconcile a transaction.

Authorization

Transactions should be authorized and executed by persons acting within the range of their authority.

• Individuals should understand what they are approving. Supervisors should have first hand knowledge of transactions being approved, or they should review supporting information to verify the propriety and validity of transactions.
• Adjustment documents including leave and payroll documents should proceed directly for processing after approval by a supervisor and not return to the employee where they can be falsified. Many frauds (i.e. unauthorized overtime adjustments) occur after approval.
• Supervisors should not sign blank forms, including timesheets, leave request forms, or journal vouchers.
• Authorization for leave, overtime, and change of work schedule should be obtained in advance and in writing.

Documentation

Transactions should be clearly and thoroughly documented and available for review.

Reconciliation

Reconciliation is the process of comparing the entries in the general ledger to supporting documentation and resolving any discrepancies or differences. The time and leave records should be reconciled to the payroll system reports.

Risk Assessment

The State Administrative and Accounting Manual, issued by the Office of Financial Management, defines internal control, basic internal control requirements, and agency responsibilities for assessing and minimizing risk through internal control assessment. The requirements include participation by all levels of the organization in an annual risk assessment. The process of assessing risk is an opportunity for review of operations, determination of the areas of significant risk, and evaluation of what actions can be taken to minimize the risk and enhance internal controls.

The annual risk assessment questionnaire provide by the Office of Internal Audit is a tool for documenting and quantifying risk. Determination of an effective means of managing the risks, determining the likelihood of occurrence, minimizing the risks, and providing compensating controls is management's responsibility.

Fraud and Asset Misappropriation Awareness

Vulnerable Areas

• Payroll
• Petty Cash
• Cash Receipts
• Long Distance Phone Calls
• Travel Vouchers

Consistent Patterns

• "Blind Trust"
• Lack of Separation of Duties
• Progressive
• Simple Methods
• Repeat Offenders
• Seldom takes leave
• No one performs duties when absent
• Works evenings and weekends

Payroll Fraud and Misappropriation Methods

• Overtime abused
• Leave inaccurately reported
• Supervisor knowingly allowed employee to backlog hours to avoid excessive overtime
• Supervisor pre-signed blank timesheets
• Accepted duplicated faxed timesheets and did not follow up by getting the original

Prevention of Payroll Irregularities

• Properly approved documents are reconciled to FMS and budget records
• Overtime should be pre-approved in writing with reason and estimated hours documented
• Approved documents should be controlled
• Line through or cross out blank lines on timesheet
• Supervisor approval should be timely
• Process only original documents
• Do not pre-sign blank or incomplete documents
• Do not supervise or control a relative's employment

Grants

The following are real life incidents in which grant recipients did not work within the boundaries established by the grant provisions, rules from the granting agency, or institutional policies. Generally speaking, any institution determined by the granting organization to be out of compliance with any requirements can be assessed double the amount of the grant money involved.

Several administrators colluded to double bill various grants under which they received funding. The auditors never went back to the beginning of the frauds, but the amounts they calculated exceeded $6 million. They were convicted and served time in state prison.

A Principle Investigator (PI) submitted airline tickets for reimbursement by grant funds for travel that auditors determined was for his son. This audit was triggered by an employee complaint. The PI was convicted and served time for this fraud.

Other Concerns

• Volunteers should sign an agreement and hours should be reported to payroll for Labor and Industries reporting purposes.
• Scan Authorization Numbers and long distance access on phones should be protected.
• Surplus property belongs to the state and has disposal guidelines.
• Child Care in the Workplace is not appropriate.
• Banking 15-Minute Breaks (to extend lunch hours, adjust arrival or departure times) is not appropriate. Rest periods not taken at appropriate times are lost.
• Skipping Lunches (to adjust arrival or departure time) is not appropriate. The Fair Labor Standards Act requires a lunch break.
• Supervisor approved flexible work schedules are appropriate for wellness hour and one-half.

Managing an Audit

These are suggestions when interacting with auditors, both internal and external, to expedite the audit process while minimizing disruptions to day-to-day departmental operations. It is important to both the auditors and the departments to have accurate and objective audit results.

• Designate an audit liaison person. (Department manager)
• Clarify the audit objective and scope (areas to be tested and period covered by the audit).
• Determine auditor needs (records, workspace, and resources).
• Consider giving the auditor a general tour of your facilities.

Access to Records by Auditor

• Ensure original documents do not leave department premises without prior approval.
• If a request is ambiguous, ask the auditor for the purpose of reviewing the document. Be prepared to recommend alternate documents that would achieve the auditor's purpose.
• Unless absolutely necessary, do not allow full access to your file drawers, storerooms, etc. Auditors are expected to obtain permission and state their objective for accessing these areas.
• Have documents available upon their arrival. Maintain a list of records provided to the auditor.
• Review records you are providing to anticipate questions. If records will hurt University's interest, notify department management and the University Director of Internal Audit (for external audits) of the issue.

Responding to Audit Findings

• Keep informed of issues throughout the audit.
• Ensure an exit interview is held. Use it to verify facts and respond to the audit. Ask a representative from Internal Audit and/or Financial Services Office to attend if there are questioned or disputed findings.
• Ask for time to review findings, and then re-verify calculations and source data.
• Concede valid findings, but do not speculate on whether they apply to other areas on campus.
  1. Discuss with the auditor the dispositions of audit issues, i.e. verbal comment, exit item, management summary or report item.
  2. If necessary, appeal the auditor's conclusion with their supervisors. For external audits, this action should be coordinated with Internal Audit and the Office of Financial Services.

Criteria and References

RCW 42.52 Ethics in Public Service
WAC 292-110 Agency Substantive Rules
WAC 292-120 Executive Ethics Board
CWU Policies Part 2, 2-2.7 Code of Ethics
CWU Policies, Part 7, 7-2.2.1.2 Entertainment and Hosting
RCW 42.40 State Employee Whistleblower Protection
CWU Policies 3-2.8.1 Whistleblower