Topic: Waste, Fraud, and Abuse
This Lubbock ISD procedure is based on Board Policies CAA, BBFB, CDA, DH and BJA.
To ensure the public receives the most value, the district shall strive to ensure its administrative management of public funds is as effective and efficient as possible, with a high standard of accountability to prevent waste, fraud, and abuse.
All trustees, employees, vendors, contractors, consultants, volunteers, and any other parties who are involved in the district’s financial transactions shall act with integrity and diligence in duties involving the district’s financial resources.
Conflict of Interest
No district employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal, state, or other award if he or she has a real or apparent conflict of interest. If required by the terms and agreements of a Grant Award Notice and/or the awarding agency, the district will disclose in writing any potential conflict of interest to the awarding agency in accordance with the awarding agency’s policies.
See Conflict of Interest procedure for further information.
Fraud and Financial Impropriety
The district prohibits fraud and financial impropriety, as defined below, in the actions of its trustees, employees, vendors, contractors, consultants, volunteers and others seeking or maintaining a business relationship with the district. These persons shall not seek a financial or other advantage, either personally or for the district, through bribery, fraud, kickbacks, misapplication of funds, malfeasance, gross mismanagement, or other criminal activities. These persons shall not offer, promise, give, request, agree to receive or accept a bribe for any purpose. Excessive or lavish gifts or hospitality in relation to business transactions or arrangements with granting agencies, contractors, vendors or other parties to contracts might constitute bribery.
Fraud and financial impropriety includes, but is not limited to:
- Forgery or unauthorized alteration of any document or account belonging to the district
- Forgery or unauthorized alteration of a check, bank draft, or any other financial document
- Misappropriation of funds, securities, supplies, or other district assets, including employee time
- Impropriety in the handling of money or reporting of district financial transactions;
- Profiteering as a result of insider knowledge of district information or activities;
- Unauthorized disclosure of confidential or proprietary information to outside parties;
- Unauthorized disclosure of investment activities engaged in or contemplated by the district;
- Accepting or seeking anything of material value from contractors, vendors, or other persons providing services or materials to the district;
- Destroying, removing, or inappropriately using records, furniture, fixtures, or equipment;
- Failure to provide financial records required by state and local entities;
- Failure to disclose conflicts of interest as required by policy; and
- Any other dishonest act regarding the finances of the district.
Lubbock ISD will take appropriate action to prevent incidents of fraud, malfeasance, misapplication of funds, gross mismanagement, or other criminal activities in all forms, which may be prosecutable. Lubbock ISD will disclose in writing to the awarding agency any violation of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting a federal award.
Reporting Fraud or Financial Impropriety
Any person who suspects fraud or financial impropriety, or suspects an illegal or unethical act has occurred, shall report the suspicions immediately to any supervisor, the Superintendent or designee, the Board President, or district law enforcement. Lubbock ISD will not retaliate against any person who, in good faith, has reported what they believe to be illegal acts by Lubbock ISD employees, officers, agents, or of other individuals or entities with whom the district has a business relationship, on the basis of a reasonable belief that the practice is in violation of law or clear mandate of public policy.
Investigating Reports of Fraud or Financial Impropriety
The Finance Office and/or Human Resources Department will appropriately investigate and record all suspected instances of fraud or financial impropriety to the Superintendent or designee. If necessary, the appropriate investigative agency or law enforcement will be notified. Depending on the results of the investigation, the district will take appropriate action, including disciplinary actions for violations of the district's code of conduct as addressed in Board Policy DH and the Employee Handbook. Appeals related to the conclusion of an investigation or disciplinary action resulting from an investigation should be made in writing to the Superintendent or designee.