You are on page 1of 5

U.S.

DEPARTMENT OF STATE OFFICE OF INSPECTOR GENERAL


INVESTIGATIONS

FRAUD INDICATORS
As an independent office, the Office of Inspector • Benefit Fraud – Claims (e.g. separate
General (OIG) has oversight of the Department of State maintenance allowance; educational allowance;
(Department) and the U.S. Agency for Global Media danger pay etc.) for differentials that are not
(USAGM, formerly known as BBG), as well as U.S. supported, or appear altered or corrected.
International Boundary and Water Commission • Common Employee Fraud – Use of GOVs for
(USIBWC), in order to promote economy, efficiency, and non-official purposes; use/requesting
effectiveness in their respective programs and assistance of Government employees for
operations. All Department, USAGM, and USIBWC personal purposes; misuse of business class
employees; contractors and their subcontractors; and travel.
grantees at all levels are required to cooperate with • Time and Attendance Fraud – Inaccurate,
OIG. They shall report known or suspected fraud, waste, corrected, or missing time cards; excessive
abuse, or other crimes against the integrity of programs overtime or questioned time, such as splitting
and operations to OIG’s Office of Investigations in a overtime between pay periods to avoid bi-
timely manner, and they may not be retaliated against weekly pay limit caps; employees self-certifying
for their assistance. To assist in OIG’s efforts to combat time cards.
fraud, OIG depends upon the vigilance of the people
• Voucher Fraud – Overstated voucher expenses
who conduct the business of the Department, USAGM,
(e.g. mileage, taxis, other transportation
and USIBWC. In that spirit, OIG has put together the
expenses) and consistent submission of
following list of potential “red flags” or indicators to
expenses at or just under the reimbursement
help such individuals detect potential fraud or other
limit for undocumented claim; receipts that do
malfeasance.
not match timeframe; claims for
reimbursement without receipts or for
As a reminder, Department, USAGM, and USIBWC
unauthorized events.
employees are automatically granted confidentiality on
any complaints made to OIG. However, if an individual
chooses to remain anonymous, it may limit our ability Public Corruption
to ensure proper handling and disposition of the
Bribery/Illegal Gratuities/Kickbacks/Conflict of Interest –
matter. We will not disclose the identity of an employee
The use of a Government employee’s public position
without that employee’s consent, unless such disclosure
for personal gain. Frequently involves the acceptance of
is unavoidable during the course of an OIG
something of value in exchange for special treatment.
investigation. Contact information for the OIG Hotline is
provided at the end of this document. Red Flags May Include:
• Sudden and unexplained increase in wealth of
Employee Misconduct Department/USAGM/USIBWC employee.
• Inexplicable favorable treatment of a contractor
Criminal/Serious non-criminal misconduct on the part or grantee.
of any Department, USAGM, or USIBWC employee. • Employee acting beyond the scope of his/her
duties.
Embezzlement/Theft/Misuse of Government Property –
• Costs for services or goods purchased are
The intentional and unauthorized taking, destruction or
inflated above local market rate; unusually high
use of Government money, property or records.
volume of purchases; inadequate contract bid
Red Flags May Include: and negotiation records.

1
• Procurements over $25,000 not competitively • Successful bidder subcontracts to unsuccessful
bid or negotiated; repeated "sole source" bidders.
awards without documentation; numerous • Identical calculations or errors among bidders.
procurements awarded for $24,999. • Repeated awards to same entity or awards to
• Poor performers continue to receive new non-lowest bidder.
contracts. Cost Mischarging – Occurs when contractors charge
• High stock levels and inventory requirements; more than the authorized rates, which results in an
continued purchase of items declared excess; overcharge to the Government.
procurement deviation from best quality/price. Red Flags May Include:
• Stock ownership by Government employees in • Times cards/sheets revised to require less
contractor’s or subcontractor’s company; information from technical staff or contractors;
Government employee’s dependents or destroyed/hidden original time cards.
relatives employed by contractor or • False claims being submitted for payment.
subcontractor.
• “Ghost employees” that no longer or never did
• Standards of Conduct violations, www.oge.gov work on the contract are included in claims.
[5 CFR 2635]
• Actual costs for goods are inflated beyond
what is allowed in the contract.
Contract Fraud • Corporate overhead costs being billed as direct
Contract/Procurement Fraud - Typically occurs when a costs to the Government.
Government employee or contractor knowingly and
Fictitious Vendor Fraud – Typically occurs when a
willfully executes a scheme to defraud the Government,
Government employee with procurement
or when a party obtains information by deception or responsibilities or an outsider submits bills from a non-
misrepresentation to receive inappropriate payment existent vendor to the Government. These types of
from the Government. The more common schemes are schemes may flourish when there is lack of oversight.
as follows:
Red Flags May Include:
Collusive Bidding or Price Fixing – Occurs when bidders • The vendor’s address or phone number is non-
secretly agree to submit high bids in order to let a pre- existent and is not on the approved vendor list.
selected bidder win. Competition is either limited or • The vendor’s address or phone number is the
eliminated while prices are manipulated in favor of a same as that of a Government employee.
few select vendors. Schemes can become very • Payments are provided without invoices.
elaborate and sophisticated. • Multiple vendors have the same address or
Red Flags May Include: contact information.
• Prices on contract services increased by • The invoiced products cannot be located and
identical increments over a period of time. the services cannot be verified.
• Prices not advertised and/or tend to change at
the same time. Unjustified Sole-Source– Occurs when a procurement
• Bid prices from regular competitors drop official in collusion with a vendor improperly awards a
suddenly when a new company enters contract that has not been competed nor supported
competition. with an adequate explanation.
• Qualified bidders do not respond to repeated Red Flags May Include:
requests for quotes, but serve as • Vague justification or documentation
subcontractors to another qualified bidder, supporting a non-competitive award.
particularly if on an apparently rotating basis. • Sole source award is above or just below the
competitive bidding limit.

2
• The request for bids is sent to only one vendor.
U.S Embassy/
• The contract award is made below the
competitive bid limits and is followed by Post-Specific Fraud Schemes
change orders that exceed the bid limits.
Guard Force Contracts
Source Selection Fraud – Occurs when a procurement Red Flags May Include:
official intentionally does not select the proposal that • Missing or falsified training records for guards.
offers the best value to the Government. • Forged or incomplete nomination packages of
Red Flags May Include: prospective guards.
• Improper relationships exist between the • Improper billing by the contractor for unfilled
Government and contract personnel. positions or lack of self-reported deficiencies.
• The Department releases information about Fuel Theft
procurements to one contractor that is not
revealed to another. Red Flags May Include:
• Failure to conduct adequate market research to • Delivery receipts or invoices that do not match
determine the appropriate contracting method fuel usage records.
and factors to ensure the product or services • Delivery receipts or invoices for more fuel than
will meet the Government’s needs. can be stored.
• Lack of fuel usage records or missing
Grant Fraud documentation on fuel deliveries.
• Inoperable fuel delivery or usage meters.
Grant Fraud – Typically occurs when award recipients
• Rebates or credits between contractor and fuel
attempt to deceive the Government about their
vendor/subcontractor.
spending of award money.
• Inability to speak with or locate fuel
Red Flags May Include:
vendor/subcontractor.
• Charging personal expenses as business • Multiple high-volume fuel deliveries in a short
expenses against the grant. period of time.
• Charging for costs which have not been
incurred or are not attributable to the grant. Leased Housing
• Charging for inflated labor costs or hours, or Red Flags May Include:
categories of labor which have not been • Lease agreements are always at or near
incurred (for example, fictitious employees, maximum allowable cost.
contractors or consultants). • Other agencies, governments, or private
• Falsifying information in grant applications or businesses pay less for comparable housing.
contract proposals. • Leases are especially favorable to the
• Billing more than one grant or contract for the landlord/lessor despite local market conditions
same work. and U.S. Government capital improvements.
• Misrepresenting a project's status to continue • Landlords have direct involvement, or close
receiving government funds. family or working- relationships with the
• Influencing Government employees to award a negotiators.
grant or contract to a particular company, Warehouse/Commissary
family member, or friend.
Red Flags May Include:
• Inventory does not reconcile. There are
overages indicating goods received are not
being entered in the system or there are
3
shortages/missing assets indicating • Casual behavior in regard to safeguarding all
incomplete/inaccurate sales, disposals or theft. accountable or sensitive documents, materials,
• Inventory records are incomplete, inaccurate, equipment and machinery.
or out of date. • Records regarding accountability for visas
• Lax warehouse controls (e.g. same person logs and/or passports issued are in disarray, are
items entering or leaving warehouse). incomplete, or contain numerous corrections.
• Excessive purchasing levels; too frequent or • Incomplete or disorganized records regarding
negotiated sale of excess Government visa referral system; excessive waiver of
property. interviews or alien registration; infrequent or
• Same person or persons consistently acquires inadequate reconciliation of visa issuances or
excess property; successful bidders who are consular services with consular receipts.
close friends or relatives of Government • Appearance that American officers have
employees. abdicated their responsibilities, especially in the
• Recovery rate of cost to sale low, especially on area of visa issuance and anti-fraud activities.
hard-to-get items such as air conditioners, • Reliance upon a small number of visa
appliances, automobiles, and spare parts. facilitators, such as travel agents.

Motor Pool (Misuse of GOV) Trafficking in Persons


Red Flags May Include: Trafficking in Persons –defined by the Government as
• Unauthorized/unreimbursed use of modern slavery for forced labor or commercial sexual
exploitation.
Government vehicles; dedicated vehicles
available to unauthorized persons, including Red Flags May Include:
spouses and family members. • Contractor or subcontractor is holding the
• Logs for vehicle mileage and fuel consumption employee’s passport or identity documents
not maintained or inconsistent with approved and they cannot voluntarily leave.
vehicle use. • Contractor or subcontractor is using misleading
or fraudulent practices during the recruitment
Cashier Operations of employees or using recruiters who do not
Red Flags May Include: comply with the local labor laws of that
• Cash level above operational needs. country.
• Cash count does not reconcile. • Contractor or subcontractor is charging a
• Lack of frequent and effective cashier recruitment fee.
reconciliations. • Contractor or subcontractor provides housing
• Lack of frequent and effective unannounced that fails to meet the host country housing and
cash verifications by accountable supervisors. safety standards.
• Unreasonable delays between discovering • Contractor, subcontractor or Government
discrepancies and reporting them. employee engages in a commercial sex act,
where something of value is given in exchange
• Incomplete, disorganized, grossly inaccurate or
for the act, which includes minor victims under
missing records.
the age of 18.
• No segregation of cashiering for cash boxes;
lax security and general disorganization in
regards to cashier areas, safes and cash boxes.

Consular Operations
Red Flags May Include:

4
Should you suspect that fraud is occurring within your In addition, please include information about any other
area of responsibility, you should report it to the OIG potential leads, documents, or evidence that may be
Hotline by one of the following methods: helpful.

Telephone: You may provide information anonymously, but you


(202) 647-3320 or (800) 409-9926 should be aware that if we require further information
to assess your complaint, we may not be able to act on
Internet: your report.
https://www.stateOIG.gov
HELP FIGHT FRAUD, WASTE, AND ABUSE
Mail: 1-800-409-9926
Office of Inspector General Hotline stateOIG.gov/HOTLINE
U.S. Department of State
P.O. Box 9778
If you fear reprisal, contact the OIG Whistleblower
Arlington, VA 22219
Ombudsman to learn more about your rights.
WPEAOmbuds@stateoig.gov
The Hotline may be used for unclassified information
only. To submit classified information, contact the
Hotline at (202) 647-3320 for further instructions.
The following information will be helpful and should be
provided when contacting the OIG Hotline:

• Who committed the wrongdoing (name of


person, company or organization), who may
have been a victim, and who may be a witness?
• What exactly did the person, company or
organization do?
• Where did the wrongdoing take place?
• When did the wrongdoing happen?
• Why did the person, company, or organization
commit the wrongdoing?

You might also like