COST EFFECTIVE DETERRANCE OF VENDOR & CONTRACTOR FRAUD

1. COST EFFECTIVE DETERRANCE OF VENDOR & CONTRACTOR FRAUD Special Agent Jamila Davis/Region 4 | July 2017

2. SECTION I HUDOIG - Mission and Purpose

3. HUDOIG Mission As the Office of Inspector General (OIG) for the U.S. Department of Housing and Urban Development (HUD), we remain an independent and objective organization, conducting and supervising audits, evaluations, and investigations relating to the Department’s programs and operations.  We promote economy, efficiency, and effectiveness in these programs and operations as we also prevent and detect fraud, abuse, and mismanagement.  We are committed to keeping the HUD Secretary, Congress, and our stakeholders fully and currently informed about problems and deficiencies and the necessity for and progress of corrective action.

4. HUDOIG Values • Collaboration: The commitment to work jointly with HUD, Congress, and our stakeholders for the benefit of all citizens. • Accountability: The obligation and willingness to accept responsibility and account for our actions. • Integrity: The firm adherence to high moral and professional standards, honesty, and fairness in all that we do. Acting with integrity is a core job responsibility for every employee. • Stewardship: The careful and responsible management of that which has been entrusted to our care. • Diversity: The promotion of high standards of equal employment opportunity for employees and job applicants at all levels so that our workforce is reflective of our Country’s citizens

5. HUDOIG Vision • To promote fiscal responsibility and financial accountability in HUD programs and operations, • improve the execution of and accountability for grant funds, • strengthen the soundness of public and Indian housing programs, • protect the integrity of housing insurance and guarantee programs, • assist HUD in determining whether it is successful in achieving its goals, • look ahead for emerging trends or weaknesses that create risk and program inefficiencies, • produce innovative work products that are timely and of high quality, • benchmark best practices as a means to guide HUD, and • have a significant impact on improving the way HUD does business.

6. Our Five Main Offices Plans and conducts investigations that vary in purpose and scope and may involve alleged violations of criminal or civil laws, as well as administrative requirements. The focus of an investigation may include the integrity of programs, operations, and personnel in agencies at Federal, State, and local levels of government; program, procurement, and grant fraud schemes; mortgage fraud, financial fraud, and whistleblower retaliation; and other matters involving alleged violations of law, rules, regulations, and policies. Office of Investigation

7. Our Locations

8. Fraud in Small Organizations • Fraud in large organizations is identified more quickly than in small organizations • Fraud in small organizations is more likely to result in higher losses than in large organizations • The mission of the agency is more of a priority than fraud awareness/prevention • Employees are trusted and dedicated so employers feel safe against fraud and abuse from within the organization • Employees can educate client/vendors about loopholes or how to circumvent lie detection R - 58 G - 161 B - 55

9. Size of Victim Organizations

10. Employees are always vastly outnumbered by clients & vendors Sources of Fraud Employees are the biggest fraud-related threat to any organization

11. SECTION II Deterring Fraud On a Budget

13. Strengthen Your Forms

14. Strengthen Your Forms • The look of your forms create an impression about the culture of your agency • Make sure the forms are professional-looking; avoid using poorly copied documents (blurry, too light, too dark, improperly aligned); • 18.USC.1001 • Reiterates that federal funds are/may be awarded • Reinforces that the HAP Contract/Consulting Agreement/Vendor Relationship has standards, formality and consequences if abused. 18 USC 100 Except as otherwise provided in this section, whoever, in any matter within the jurisdiction of the executive, legislative, or judicial branch of the Government of the United States, knowingly and willfully- (1) falsifies, conceals, or covers up by any trick, scheme, or device a material fact; (2) makes any materially false, fictitious, or fraudulent statement or representation; or (3) makes or uses any false writing or document knowing the same to contain any materially false, fictitious, or fraudulent statement or entry; shall be fined under this title, imprisoned not more than 5 years or, if the offense involves international or domestic terrorism (as defined in section 2331), imprisoned not more than 8 years, or both.

15. Strengthen Your Forms By signing this application below I certify that the information within this document is true and complete and to the best of my knowledge. I understand that this application may result in my receipt of state and/or federal funds. Further, the submission of false or misleading information to influence a decision regarding the receipt of such funds may be punishable under 18 USC 1001. X_________________________________________________________ By submitting this application I certify that the information I have entered is true and complete and to the best of my knowledge. I understand that this application may result in my receipt of state and/or federal funds. Further, the submission of false or misleading information to influence a decision regarding the receipt of such funds may be punishable under 18 USC 1001. You Must Agree to Continue Disagree and Exit Application

16. Excluded Parties List • www.sam.gov

17. Excluded Parties List

18. Ask the Right Questions • Asking the right questions will help make decisions now…and later • “Have you ever worked for an agency that administers or oversees funding from the government? Please list all:” • “List of all states in which you have lived. Include time periods” • “Have you ever been subject to a suspension or debarment imposed by a state or local government?” • “Have you been convicted of a violent or drug related crime?” • “Are you subject to lifetime registration as a sexual offender?”

19. A doctor’s request for you to complete a medical history form at least annually protects the physician just as much as the patient.

20. Ask…..Again • Most agencies rely on the original application during the entire life of the relationship • The original application only represents the circumstances at the time • Do not expect people to volunteer unflattering information • If you want to know if something has changed, you need to ask • Employee Annual Reviews -Have you been arrested or charged with a felony or economic crime? -Are you related to any participant, landlord or vendor? Related means “mother, father, husband…..”, Please list all:” • Vendor Application Update Annually or Bi-annually • HAP Contract Renewal

21. Anti-Fraud Policy • Develop a written policy for employees, clients and vendors • A good fraud policy will: • Define fraud • List examples of offenses that are prohibited • You may not receive gifts or tips from clients/vendors • You may not offer gifts or tips to employees • You must report a relationship to a vendor/employee within XX days • A familial relationship to a subcontractor must be reported & approved • Out of town landlords (excess of XXX miles) must provide a local contact for repair/maintenance/lease enforcement issues • You may not seek reimbursement for exaggerated expenses or expenses you have not incurred or for expenses reimbursed by another government agency • Require employees and contractors to report suspected fraud • State your commitment to investigate • State your commitment to report instances of fraud, waste and abuse to law • enforcement

22. It’s Their Paperwork….Not Yours • Don’t accept incomplete paperwork • Never “write-in” information based on a verbal conversation • Require the personal update of the information (email or written statement) • Make sure people get a copy of what they sign or make it available on-line for their reference • Require a signature to verify that Code of Conduct/Anti-Fraud Policy was given • Landlord/Contractor orientation attendance should be noted

23. Make Sure Everyone Knows Where YOUStand • Require your vendors to have an Anti-Fraud Policy • Ask to see and review their Code of Conduct • Ask how the Code Conduct and Anti-Fraud Policy are communicated to subcontractors • Place fraud reporting information on client, employee and vendor orientation materials, invoices, check stubs, website, email signatures etc. • Make sure your fraud reporting information is issued to your subcontractors • Remind people annually about your position on fraud, waste and abuse. Re-issue or require yearly review of policies: • Employee Annual Reviews • HAP Contract Renewal

24. Make Sure Everyone Knows How to Reach YOU • Email Account • Example: Reportfraud@anywherefl.org • Cost Effective • More anonymous, people are more comfortable • A fraud hotline advertises to clients, vendors and employees that your are sincere about detecting & preventing fraud • Make sure that information from the hotline is actually addressed and that the emails are handled by the appropriate individual • Conduct surveys upon move out/contract end among tenants and subcontractors • Don’t make your surveying a secret • *Agencies with a Code of Conduct visible to the public are more likely to receive information about fraud within or against the organization

25. CONTACT INFORMATION HUDOIG HOTLINE: 1-800-347-3735 (Toll-Free) and/or HOTLINE@hudoig.gov SPECIAL AGENT JAMILA DAVIS: 813-228-2160and/orjdavis@hudoig.gov AGENCY WEBISTE: www.hudoig.gov