Fraud Detection in Public Schools

Goal: To learn how to prevent and detect fraud from actual evidence uncovered during fraud investigations

Format: We will discuss three of the largest fraud cases over the past ten years in Kentucky Schools. We will look at actual evidence from each case and discuss how the auditors pieced it together. We will discuss some simple techniques to minimize the risk of the same frauds happening at your district.

Scope: These are just three cases which resulted in a large dollar loss to the schools and the district. Any fraud is too much fraud, and every dollar is significant. Hopefully, you can prevent a problem before it starts.

Cases: All three cases were successfully prosecuted and all the evidence presented herein is subject to the open records law; however, since school personnel has changed, I have redacted school names so the current school personnel may focus on student achievement.

School “D”: How it was discovered: Anonymous letter mailed to Internal Audit & Superintendent with concerns of consultants being paid for work not being done at the school. Other concerns surfaced after the initial investigation including conflict of interest and fraudulent use of a school’s credit card.

How it was perpetrated: • Kickback scheme between Principal and “educational consultants.” • One or more of the consultants were friends or a relative. • EC’s got paid for services not rendered & split pay with Principal • Bookkeeper believed to have been hand-picked and worked in conjunction with the principal to deceive. • Bookkeeper created on line purchase orders for fictitious vendors and did receiving for false invoices.

How it could have been prevented: • Check credentials of educational consultants. • Criminal background checks of consultants. • Fraud hotline or other reporting mechanism. • Ensure credit card use is only for school’s purposes. • Do not allow vendors to pick-up checks from Accounts Payable.

School “S”: How it was discovered: During the routine audit of the school’s activity funds it was discovered that a number of checks were made payable to the bookkeeper totaling hundreds of dollars. After this initial finding it was necessary to aggressively pursue additional financial concerns at this school.

How it was perpetrated: • Bookkeeper wrote and cashed checks payable to cash and bookkeeper with no backup available for review. She verbally claimed she was reimbursing student fees that were paid to the school. • She stole cash from one deposit & made deposit whole by substituting checks from another deposit. • She used checks out of order & not aligned with software, so bank statement couldn’t be reconciled. • Bookkeeper kept records so sloppy and in disarray that auditing became an adventure in itself. How it could have been prevented: • Don’t allow excessive disorganization! • Mandate that teachers/sponsors receive and review monthly activity account statements. • If refunds are allowed they should be made by check not cash and documentation signed by payee (similar to multiple receipt form). • Staff told Auditor that bookkeeper was trying to obtain personal loans from coworkers; this is an indication that the bookkeeper was hurting financially. This should have been a warning sign!

School “L”: How it was discovered: During the routine school activity audit it was discovered that a check, made payable to the bookkeeper, lacked supporting documentation and that the authoritative signature on the face of the check was not that of the principal. After this fraud was discovered, it was determined a more in-depth investigation was warranted, including reviewing previous years records.

Others fraudulent discoveries included. • Deception by fraud and forgery of School Activity and PTA documents. • Checks written to the bookkeeper lacking sufficient supporting documentation. • Use of school’s Kroger charge card accounts for personal use. • Use of a fictitious vendor. • Theft of fund-raising proceeds and the creation of fraudulent invoices. • The co-mingling of School Activity, PTA and FRC funds allowing the school’s bookkeeper to manipulate and falsify the financial records at her school for personal gain. • Made payments to bookkeepers Mortgage Company (KHC) and replaced the backup with fictitious documentation.

How it was perpetrated: • Bookkeeper maintained the PTA records, she convinced the PTA president that she should maintain the PTA records allowing her to manipulate the funds; she never reconciled and no one ever saw the records. Donations to the school and the FRC were deposited into the PTA account then the bookkeeper wrote checks from PTA account to herself with no documentation. • Ordered from Allegra Printing Company a set of duplicated checks to keep on file replacing fraudulent checks written to vendors and bookkeeper for cash. Duplicate checks on file in the school files had altered check numbers, forged signatures and endorsements. • Wrote checks payable to the bookkeeper out of the activity account and used forged and fictitious receipts as supporting documents. • Used Kroger charge card purchasing food and personal items. • Bookkeeper created a fictitious vendor Aurora!, wrote check to this vendor, and deposited the check in her bank account endorsing it “Aurora” with her name signed below. • Boldly stole fund raising money generated from parking at special events. Bookkeeper had complete control over fund-raising activities.

How it could have been prevented • Principal should open bank statement and examines each cancelled check. • Closely examine supporting documentations for all expenditures. • Periodically visit bookkeeper’s office with questions and general observations of records not necessarily available for review. • Express a genuine interest in the overall duties and responsibilities of the bookkeeper. • Observe and review receipting of funds run through the activity account. Understand, analyze and scrutinize all financial statements within reason. • Review check register and question payments to certain vendors, large dollar amounts and checks made payable to bookkeeper.

TO PRICNIPALS FROM: JESSICA ANNIS, DIRECTOR OF FINANCE

RE: FRAUD PREVENTION STEPS

1. Always sign financial forms. Never use a signature stamp. Spend a few seconds reviewing every financial form you sign. By inspecting what you sign, and making sure your staff knows it, you are reducing the perceived opportunity to steal.

2. Segregation of Duties is key in preventing fraud. Make sure no one has the ability initiate, approve, and complete any one transaction.

3. Always receive the bank statement unopened, review the balance, and scan through the canceled checks and deposits. You should always have at least four deposits per months per Redbook. When you do this, look for unfamiliar vendors (acronyms), suspicious signatures, or suspicious endorsements.

4. Randomly ask questions. When reviewing the bank statement, ask to see documentation for a couple of canceled checks. Ask questions about items you sign. Your financial operations should mirror your school.

5. Keep your ears open. The most common method of finding a case of fraud is by tip. Make sure your staff knows you are available if they have any suspicions.

6. Do not pre-sign any checks or forms.

7. Involve numerous people when cash is involved and always require receipts.

8. Look for trends. Are you using a particular vendor more than in the past? Are you signing more checks? Is your bank balance going down? Do the profits from bookstore sales or fundraisers seem smaller than in the past?

9. The culture of an organization comes from the top. If you demonstrate ethical behavior and place importance on financial matters, those who report to you will reflect your attitude.

10. All events that take cash, such as athletic events where a fee is charged, dances, or parking fundraisers, should have two HCS employees with the cash at all times. Pre- numbered tickets should be used whenever possible. Ticket stubs should be reconciled to cash received (beginning cash drawer $100 + $5 per ticket x 100 tickets should equal $600 in the ending cash drawer).

11. Sponsors should review receipts, disbursements and understand transfers in their activity accounts. Principals should have bookkeepers print out and provide activity fund sponsors copies of YTD reports monthly. If sponsors notice any discrepancies between the report and their receipts, they should immediately notify the Principal.

12. When signing payroll, review for indication of overtime and excessive hours of extra service.

13. Whenever you feel uncomfortable, call Director of Finance 769-8816, Associate Supt of Finance 769-8814 or Anonymous Fraud Hotline 769-7929.

What to do if fraud is suspected:

 Contact Director of Finance 270-769-8816 or Associate Superintendent of Finance and Support 270-769-8814.

 Contact the fraud hotline if you would like to remain anonymous. Please report the problem on the hotline and the Director of Finance will then proceed to investigate the claim.

 Do not accuse the person or persons of any fraud as they will have time to cover their tracks if fraud exists.

Key Statistic’s to Remember:  ANYONE can commit fraud. In fact, 87% of people who commit have never been charged or convicted of a fraud-related expense.

 The longer a person has worked for an organization, the higher fraud losses tend to be.

 The person committing fraud typically has been doing this for 18 month before they are detected.

 Fraud is more likely to be detected by a tip than any other method. Almost half of all fraud is reported by a tip from an employee or hotline.

 Only 3.3% of fraud is found in an external audit.

 In 80% of all cases the fraudster displayed one or more behavioral red flags that are often associated with fraudulent conduct.

. Living Beyond Their Means . Financial Difficulties . Unusually Close Relationships with Vendors or Customers . Excessive Control Issues

People who commit fraud go through the three phases of the Fraud Triangle:

No one watching Too much control Opportunity Cash Management Override

Incentive Rationalization

Medical Issues Just Borrowing Spouse Unemployed They Owe Me Gambling I volunteer all the Time Debt They will never miss it

HARDIN COUNTY SCHOOLS 65 W.A. Jenkins Road Elizabethtown, KY 42701 Office: (270) 769-8800 Fax: (270) 769-8889

24 Hour Anonymous Reporting Hotline (270) 769-7929

No Personal Contact

Hardin County Schools provides a reporting hotline to anyone who wishes to report any of the following incidents anonymously:

Fraud Ethical Violations

Conflict of Interest Internal Controls

Bribery and Kickbacks Violation of School Policy

All calls are confidential and the anonymity of the caller will remain confidential.