Fraudulent Billing and Fraud Prevention Policy

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Fraudulent Billing and Fraud Prevention Policy Powered By Docstoc
					This is a company’s policy on how to prevent fraudulent billing and related fraudulent
activity. This policy indicates that the company is committed to the highest legal, ethical
and moral standards and will fully comply with all federal and state laws and expects its
employees, contractors, and agents to uphold this standard. Additionally, this policy
provides that any billing suspected of fraudulent activity should immediately be reported
to the human resources department for further investigation. This policy can be used by
small businesses to minimize fraudulent activity by its employees, contractors, and
agents.
                        Fraudulent Billing and Fraud Prevention Policy

1. Policy
The _______________ [Instructions: insert name of entity setting forth policy] (“Entity”) is
committed to protecting its revenue, property, proprietary information and other assets. The
Entity will not tolerate any misuse or misappropriation of those assets. The Fraudulent Billing
and Fraud Prevention Policy is established to provide guidance to employees when misuse or
misappropriation of Entity assets is suspected. It is the Entity’s intent to fully investigate any
suspected acts of fraud, as it is defined in this Policy, in an impartial manner regardless of the
suspected wrongdoer’s length of service, position, title or relationship to the Entity. Any act of
fraud that is detected or suspected must be reported immediately and investigated in accordance
with this Policy. The Entity will make every reasonable effort, including court ordered
restitution, to recover or receive compensation from any appropriate source for Entity assets
obtained by fraud.



2. Scope of Policy
This Policy applies to _______________ [Instructions: insert persons to whom the Policy will
apply] of the Entity.



3. Definition of Fraud
Fraud is the act of using dishonesty as a tool for personal gain. For the purposes of this Policy,
fraud includes any misuse or attempt misuse of an Entity asset for personal gain or purposes
unrelated to Entity business. Examples of fraud include, but are not limited to:



         A. Stealing or removing Entity assets
         B. Using Entity equipment, facilities, supplies or funds for purposes unrelated to Entity
            business
         C. Obtaining Entity funds or compensation through dishonesty
         D. _______________ [Instructions: insert any additional examples]


4. Related Policies
This is a policy whish is designed to augment other policies of Entity, and it is not intended to
replace or preclude them. Should an overlap arise between the application of this Policy and any
other policy, the policy most specific to the situation will apply. [Comment: user may edit this
section establish the policy that user wishes to govern]
5. Responsibilities
_______________ [Instructions: insert names or positions of responsible parties]
(“Administrators”) are responsible for establishing and maintaining a system of internal controls
to ensure the detection and prevention of fraudulent billing, fraud, waste, abuse and other
irregularities. Administrators should be reasonably familiar with the types of fraud that might
occur within their area of responsibility, and be alert for any indication of fraud. Administrators
will support and co-operate with the auditor and law enforcement, if necessary, in the detection,
reporting and investigation of all fraudulent acts, including the prosecution of the offenders. Any
employee of the Entity, who knows or has reason to believe that fraud has occurred, is
responsible for immediately notifying his immediate manager. If the employee has reason to
believe that the employee’s immediate manager may be involved, the employee shall
immediately notify a senior manager. It is expected that all employees will fully co-operate with
Administrators, the auditor and law enforcement agencies during the course of an investigation
and will make all reasonable efforts to be available to assist in the investigation.



6. Confidentiality
All participants in a fraud investigation shall treat all information received confidentially.
Investigation results will not be disclosed or discussed with anyone other than those who have a
legitimate need to know. Any staff person or elected official contacted by the media with respect
to a fraud investigation shall refer the media person to _______________ [Instructions: insert
specific name or position].



7. Whistle-Blower Protection
No person covered by this policy shall:

         A. Dismiss or threaten to dismiss an employee;
         B. Discipline or suspend or threaten to discipline or suspend an employee;
         C. Impose any penalty on an employee; or
         D. Intimidate or coerce and employee, because the employee has acted in accordance
             with the requirements of the Policy.
         E. _______________ [Instructions: insert any additional protections]


8. Disciplinary Action
Administrators are responsible for discipline of employees in consultation with Human
Resources and the _______________ [Instructions: insert name or position party, if
applicable]. Employees who have committed fraud will be subject to disciplinary action up to
and including dismissal. Where fraud is suspected of any Entity employee, the individual will be
given notice of the essential particulars of the allegations following the conclusion of the



© Copyright 2012 Docstoc Inc.                                                                     3
investigation and prior to final disciplinary action. The individual against whom allegations are
being made will be given opportunity to respond.




© Copyright 2012 Docstoc Inc.                                                                       4
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Description: This is a company’s policy on how to prevent fraudulent billing and related fraudulent activity. This policy indicates that the company is committed to the highest legal, ethical and moral standards and will fully comply with all federal and state laws and expects its employees, contractors, and agents to uphold this standard. Additionally, this policy provides that any billing suspected of fraudulent activity should immediately be reported to the human resources department for further investigation. This policy can be used by small businesses to minimize fraudulent activity by its employees, contractors, and agents.