Cornell University Policy Library -- Policy 3.6.1

FINANCIAL IRREGULARITIES (WEILL MEDICAL COLLEGE)

Volume 3, Financial Management
Chapter 6, Financial Irregularities
Responsible Executive: Dean of the Weill Medical College
Responsible Office: University Audit
Originally Issued October 1983
Revised October 2002
Errors or changes? Email us.

POLICY STATEMENT

REASON FOR POLICY

ENTITIES AFFECTED BY THIS POLICY

WHO SHOULD READ THIS POLICY

RELATED DOCUMENTS

CONTACTS

DEFINITIONS

PROCEDURES

Reporting and Investigating a Financial Irregularity

Internal Disciplinary Action
External Referral
Final Reporting and Notification RESPONSIBILITIES

POLICY STATEMENT

All members of the Cornell Univeristy Weill Medical College community have a responsibility to report known or suspected financial irregularities. Reporting must be handled by all parties in a confidential manner. Decisions on disciplinary action should be made with due regard for appropriateness and consistency.

REASON FOR POLICY

Financial irregularities may be criminal acts and subject to prosecution under the law. The university must safeguard its assets and protect its funds from theft and misappropriation. This policy provides information on the proper procedures that should be followed to report known or suspected irregularities. These procedures have been developed to achieve confidentiality and consistency.

ENTITIES AFFECTED BY THIS POLICY

Joan and Sanford I.Weill Medical College

WHO SHOULD READ THIS POLICY

All Joan and Sanford I. Weill Medical College employees, including student employees

CONTACTS

Direct any general questions about University Policy 3.6.1, Financial Irregularities (Weill Medical College), to your department's administrative office. If you have questions about specific issues, call the following offices:

Subject	Contact	Telephone
Faculty Issues	Dean and Provost for Medical Affairs	(212) 746-6005
Policy Clarification	University Audit Office (Ithaca Campus) University Audit Office (Weill Medical College Division)	(607) 255-9300 (212) 746-1897
Reporting Irregularities	University Audit Office (Ithaca Campus) University Audit Office (Weill Medical College Division)	(607) 255-9300 (212) 746-1897
Reporting Other Criminal Acts	New York Presbyterian Hospital Security	(212) 746-0911
Student Issues	Associate Dean for Student Affairs and Equal Opportunity Programs	(212) 746-1058

DEFINITIONS

These definitions apply to these terms as they are used in this policy.

Advisory Committee	An ad hoc committee consisting of the head of the unit in question, the University Auditor, the Senior Director of Human Resources, the Senior Director of Financial Management, and the Dean's designee. It also includes the Chief Administrative Officer of the Physician Organization (when individuals with faculty appointments who are members of the Physician Organization are involved), and the Associate Dean for Student Affairs and Equal Opportunity Programs (when students are involved). This committee seeks to resolve a disagreement between the University Auditor and the unit head regarding internal discipline.
Financial Irregularity	An intentional misstatement or omission of information related to financial transactions that is detrimental to the interests of the university. Includes embezzlement, fraud, or falsification of records to misappropriate assets.
Financial Irregularities Committee	A standing committee consisting of University Counsel (Chair), the University Auditor, the Senior Director of Financial Management, the Senior Director for Human Resources, the Associate University Counsel, and the unit head. It also includes a Dean's designee (when individuals with a faculty appointment are involved), the Chief Administrative Officer of the Physician Organization (when individuals with faculty appointments who are members of the Physician Organization are involved), and the Associate Dean for Student Affairs and Equal Opportunity Programs (when students are involved). This committee determines whether to refer the matter to the District Attorney or other outside law enforcement agency.
Unit Head	Individual with administrative responsibility for the unit where the alleged perpetrator is employed. For cases where the subject of the inquiry is a faculty member, the unit head is the Department Chair.

PROCEDURES

Reporting and Investigating a Financial Irregularity

"Definitions"

Caution: Reporting and investigating must be handled in a confidential manner by all involved parties until determination of the final university action. After this determination, the university reserves the right to make disclosures as necessary.

2. The unit head should take no action to resolve the irregularity before consulting the University Audit Office.

3. The University Audit Office will conduct an investigation to determine the validity of the charges.

4. Once the investigation is completed, the University Audit Office will report its findings to the unit head.

5. If there is sufficient evidence of wrong-doing, the University Audit Office may communicate the findings internally to the Senior Director of Financial Management, the Senior Director for Human Resources, the Associate University Counsel, the Dean's designee (in cases where an individual with a faculty appointment is involved), or the Chief Administrative Officer of the Physician Organization (in cases where a member of the Physician Organization is involved).

Internal Disciplinary Action

The unit head is responsible for recommending to the University Auditor disciplinary action, if such action is warranted.

Caution: When termination or suspension is proposed, the unit head must receive the approval of the Senior Director for Human Resources and, in cases involving an individual with a faculty appointment, the Dean's designee, prior to recommending the action to the Dean.

Case 1
When the University Audit Office agrees with the unit's recommendation:

The unit head carries out the discipline subject to either Weill Medical College of Cornell University Human Resource procedures or academic appointment procedures.

Case 2
When the University Audit Office disagrees with the unit's recommendation:

2. When agreement cannot be reached on internal discipline, the matter is referred by the University Audit Office to the Dean of the Weill Medical College for final disposition.

External Referral

"Definitions"

Note: New York Presbyterian Hospital Security or other outside security services may be asked by the University Audit Office to undertake further investigation prior to a decision to refer the matter to local law enforcement offices.

2. University Counsel convenes that committee, which then determines whether an external referral of the matter should be made.

3. When a decision is made to refer a matter to the District Attorney or other outside law enforcement agency, this must be done by University Counsel.

4. University Counsel will communicate to the District Attorney's Office any further views the university may have regarding the matter, both at the time of referral and subsequently; and determine the need for confidentiality on a case-by-case basis.

Final Reporting and Notification

2. The University Audit Office is responsible for notifying the Office of Risk Management and Insurance, the Office of Research and Sponsored Programs, New York Presbyterian Hospital Security, and/or the Audit Committee of the Board of Trustees to meet their specific reporting requirements.

RESPONSIBILITIES

The major responsibilities each party has in connection with the University Policy 6.2.1, Financial Irregularities (Weill Medical College) are as follows:

You	Read and understand University Policy 6.2.1, Financial Irregularities (Weill Medical College). Report instances of suspected or proven financial irregularities to the unit head or directly to the University Audit Office.
Unit Head	Communicate the provisions of University Policy 6.2.1, Financial Irregularities (Weill Medical College), to all staff members. Take no action to resolve the irregularity without consulting the University Audit Office. Recommend appropriate internal disciplinary measures when there is sufficient evidence of wrong-doing.
University Audit Office	Investigate all suspected or documented financial irregularities. Notify the Office of Risk Management, the Office of Research and Sponsored Programs, and New York Presbyterian Hospital Security when appropriate.
Human Resources	Consult with the unit head when internal discipline involves suspension or termination.
Advisory Committee	Determine if a disagreement between the University Audit Office and the unit head over internal discipline can be resolved.
Dean of the Weill Medical College	Determine final internal disciplinary action when agreement cannot be reached between the unit head and the University Audit Office.
Office of University Counsel	Convene and conduct the meeting of the Financial Irregularities Committee. Refer the matter to the District Attorney's Office or other outside law enforcement agency. Determine the need for confidentiality after final action, on a case by case basis.
Financial Irregularities Committee	Decide whether or not to refer the matter to the District Attorney's Office or other outside law enforcement agency for criminal prosecution.

Date last modified 08/18/00