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National Science Foundation Office of Inspector General

2006 Big 12 Internal Auditors Conference May 21-24, 2006
Hosted by: University of Colorado Department of Internal Audit

NSF at a Glance:
•The National Science Foundation (NSF) is an independent federal agency created by Congress in 1950 •To promote the progress of science; to advance the national health, prosperity,and welfare; to secure the national defense… •With an annual budget of about $6 billion, NSF is the funding source for approximately 20 percent of all federally supported basic research conducted by America's colleges and universities. In many fields such as mathematics, computer science and the social sciences, NSF is the major source of federal backing.

NSB at a Glance:
•The National Science Board is an independent policy body established by Congress in 1950; with dual responsibilities to oversee and guide the activities of, and establish policies for, the National Science Foundation; and •Serves as an independent national science policy body that provides advice to the President and the Congress on policy issues related to science and engineering that have been identified by the President, Congress or the Board itself. •The Board has 24 members appointed by the President and confirmed by the Senate, plus the NSF Director as an ex officio member.

 Provide leadership; coordinate and recommend policies necessary to:
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NSF’s Office of Inspector General

Prevent and detect fraud, waste, abuse Promote economy, efficiency, effectiveness

Features:
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Independent of agency management Jurisdiction (NSF activities, programs, operations) Staff of experts: administrators, attorneys, auditors, criminal investigators, and scientists

Responsible for ensuring the integrity in NSF’s programs and operations

NSF-OIG’s Mission and Vision Statement

MISSION We conduct independent and objective audits, investigations, and other reviews to support NSF in its mission by promoting the economy, efficiency, and effectiveness and safeguarding the integrity of NSF programs and operations.

VISION We will use our diverse and talented staff and cutting-edge technology to have a beneficial effect on NSF and the communities it supports. We will help prevent problems, address existing issues in a timely and proportionate manner, and keep abreast of emerging challenges and opportunities.

Definition of independent – Free from the influence, control., or determination of another or others; specif., e) free from the rule of another; controlling or governing oneself; self-governing g) free from influence, persuasion, or bias; objective i) relying only on oneself or one’s own abilities, judgment, etc.; self-confident; self-reliant… Webster’s New World Dictionary

Key Focus Areas
Administration Finance Research

Administrative Spotlight

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Conflicts of Interest Research Misconduct Lobbying Patent Disclosure (Bayh-Dole Act) Training Requirements Original Work Current and Pending Support Information • time and effort (% to each project not > 100%) • 2/9th rule limiting summer salary Records Retention (financial, research, other) Equipment Tracking and Use Debarment, Drugfree workplace, EEO

Financial Management Spotlight

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Internal Systems Management • Comply with NSF Grant Conditions • Comply with OMB Circulars Contracts and Subcontracts Cost Sharing Program Income (research and conference grants) Rebudgeting FCTRs/Annual and Final Reports Equipment Purchase and Sale Subcontract Payments

Research Management Spotlight

Human Subjects Review (IRB) Animal Welfare (IACUC) Radiation Safety Biosafety (Recombinant DNA and other issues) Collection Permits Variety of Environmental Permits Data or Sample Sharing Change of Scope

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Research Management (cont’d)
● Change or Absence of PI ● Current and Pending Support Information
● Duplicate Proposal Submissions ● Annual and Final Reports ● Bioterrorism Preparedness and Response Act of 2002

(human, animal, or plant agents or toxins) ● Enhanced Border Security Act (student registration)

When should you contact us?

Allegations of wrongdoing
 Research

misconduct  Financial fraud, theft  Violation of research related regulations, directives or policy
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Significant administrative or financial problems Financial fraud or theft that involves NSF activities Participate in or arrange an Outreach seminar or training session

Institutional Compliance
7 elements of an effective compliance program
2) Reasonable Compliance Standards and Procedures 4) Specific High-level Personnel Responsible 6) Due Care in Assignments with Substantial Discretionary Authority 8) Effective Communication of Standards and Procedures

Institutional Compliance (cont’d)
Establish Monitoring and Auditing Systems and Reporting System (Whistleblowing without fear of Retaliation) Consistent Enforcement of Standards through Appropriate Mechanisms (including failure to detect) Respond Appropriately to the Offense (reporting to law enforcement, modify program, prevention)

I have a feeling some bad stuff is about to go down!

Lessons Learned

1st e-mail
From: XXX To: Staff Sent: Tuesday, February 28, 8:38 AM Subject: Task reports Good Morning Again, XXX will tell you how many hours you worked on each project BEFORE you do your task report. We hope this will make it easier for everyone. XXX

AM

From: XXX

2ndFebruary 28, 8:52 AM e-mail Sent: Tuesday,
To: Staff Subject: caution re: task reports In case you are not aware, OIG auditors are here this week. you say out loud as you never know what they may over hear. For example, we don't want them to hear you ask XXX "when are you going to tell me how many hours I worked on XXXXX or anything like that. Please be careful what

3rd e-mail
From: XXX Sent: Friday, March 03, 3:22 PM To: OIG Subject: FW: caution re: task reports Hello OIG I thought that you would be interested in these emails.

Best Practices
Report significant transgressions, early and consistently.  All fraud related matters should also be timely reported to the respective OIG.  Provide complete disclosure.  Anticipate and prepare for the worst and hope for the best.

Best Practices (cont’d)

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Establish critical relationships that will enhance your reputation and credibility in the community; i.e. University Internal Audit peers, cognizant OIG Office (both OI and OA), local State and Federal prosecutors Office. Review OIG semi-annual reports to Congress. Review the on-line archived press releases of your local prosecutors’ office.

How can I contact OIG?
 Internet:  E-mail: Hotline  Phone:  Hotline:  Write: 703-292-7100 1-800-428-2189
National Science Foundation Office of Inspector General Suite II-705 4201 Wilson Blvd. Arlington, VA 22230

www.oig.nsf.gov oig@nsf.gov

On behalf of NSF-OIG, I would like to thank the Offices of Internal Audit of the Big 12 Conference for inviting me to participate in this year’s conference. Thank You! Matthew M. Quinn
Office of Investigations Special Agent in Charge 703-292-4989 mquinn@nsf.gov That’s it, I’m outta here…