Newly approved Fraud, Waste, and Abuse Policy

By now, you should have already been made aware of a new Fraud, Waste and Abuse Policy that the board of trustees approved at the June 18, 2024 board meeting that went into effect on July 1, 2024. The impetus of this new policy was due to the Higher Learning Commission ensuring all member institutions are complying with the expectations of specific federal regulations. 

As such, this new policy has been created and is a codification of existing expectations for all college employees, providing a mechanism for reporting and handling of such concerns. If you have not already signed off on this policy, which was emailed out to you on June 21 by Janet Fager using Adobe Acrobat Sign, please do so now. Your signature simply means you have received and have read the new policy, which has been cut and pasted below: 

9.25 Fraud, Waste, and Abuse Policy

Fraud, Waste, and Abuse is defined as the following: 

1. Fraud is an intentional act to deceive, steal, or cheat, ordinarily for the purpose or result of causing a detriment to another and/or bringing about some benefit to oneself or others.

2. Waste is an act resulting in the expenditure, consumption, mismanagement and use or squandering of institutional assets or resources to the detriment or potential detriment of the institution. Waste may also result from incurring unnecessary expenses due to inefficient or ineffective practices, systems, or controls.

3. Abuse involves behavior that is deficient or improper when compared with behavior that a prudent person would consider a reasonable and necessary business practice given the facts and circumstances. Abuse includes misuse of authority or position for personal financial interest or those of an immediate or close family member or business associate.

All employees have a responsibility to be knowledgeable of the Fraud, Waste, and Abuse procedure. This will be accomplished by having the Human Resources Department post this new policy on the portal, as well as email out this policy to all KCC employees using Adobe, which will require employees' signatures indicating they have received and read the new policy.

If an employee feels that this policy has been violated, they should submit their concerns in writing to the Director of Human Resources, who will forward to the Vice President for Business Affairs. In the event concerns involve the Director or Human Resources, submissions should be sent directly to the Vice President for Business Affairs. In the event concerns involve the Vice President for Business Affairs, submissions should be sent directly to the President. In the event concerns involve the President, submissions should be sent directly to the Chair of the Board of Trustees.

Supervisors have an additional responsibility to be aware of the types of fraudulent activities, waste, and/or abuse that may occur within their department and to establish and maintain controls to prevent them.

If fraud is suspected within a department, all supervisors shall cooperate fully with college administration and any other agencies investigating the activity. If fraud is discovered, all supervisors shall take appropriate action and implement appropriate systems to prevent recurrence.

An employee who violates this policy may be subject to disciplinary action up to, and including, termination. The discipline imposed will depend on the severity of the violation and the circumstances of the situation. If appropriate, the College will report any activity that appears to violate any local, state, or federal law to the appropriate authorities.

If the fraud, waste, or abuse involves a financial loss to the College, KCC may seek restitution from any individuals involved in the activity.

KCC strictly prohibits retaliation for reporting suspected fraud. Any employee who believes they have been retaliated against should report their concern to the Director or Human Resources. Any employee who directly or indirectly retaliates against another employee for reporting suspected fraud may be subject to disciplinary action.