WFA Hotline Policies Manual

State Employee
Fraud, Waste, and Abuse Hotline
Policies and Procedures Manual
Issued by the
Division of State Internal Audit (DSIA)
January 2012

Foreword
The State Employee Fraud, Waste, and Abuse Hotline began operation in October 1992.
Since that time State agencies have worked with the DSIA to investigate over 10,000 cases.
Until December 2000, there were no policies and procedures promulgated to assist investigators
in carrying out their responsibilities. In December 2000 the first policies and procedures manual
was published to respond to this need. In 2008, the manual underwent a major revision. Now, in
2012, minor revisions have been made to reflect changes in the current Executive Order and in
other information provided.
The purpose of the manual is to assist internal auditors, Hotline coordinators, agency heads, and
anyone involved in Hotline investigations to better meet their responsibilities. It is also intended
to foster consistency among agencies in the management and conduct of Hotline investigations.
It is our hope that the manual accomplishes these purposes. We intend this to be a living
document, that is, subject to change when appropriate. We ask that readers of this manual
provide the DSIA with feedback on areas that need coverage and suggestions for improvement.
We further ask that readers provide us with effective techniques or approaches that have been
used in the conduct of investigations so that they can be shared with others.
Please direct your suggestions and feedback to—
Tim Sadler
Division of State Internal Audit
(804) 225-3106 Ext. 23
tim.sadler@doa.virginia.gov.
Dedication
This policy and procedures manual is dedicated
to the memory of
Sherry Mason
whose efforts in developing the original manual and in administering the hotline program from
its inception until her passing stand as a legacy to her work on behalf of the Commonwealth.

Table of Contents
Topic Page No.
1000-OVERVIEW
Introduction...................................................................................................................................1
Governor’s Executive Order # 15.................................................................................................3
Hotline Terms and Definitions......................................................................................................6
DSIA Responsibilities...................................................................................................................7
Process for Receiving a Hotline Call............................................................................................9
Other Information .......................................................................................................................10
Hotline Poster..............................................................................................................................11
DSIA Hotline Contact.................................................................................................................12
1001-SECURITY
Hotline Reports, Work Papers, and Other Documents ................................................................ 1
Requests for Hotline Information ................................................................................................ 3
Handling Freedom of Information Act (FOIA) Requests............................................................ 5
Hotline Investigative/Complaint Report...................................................................................... 6
1002-ACCEPTING CALLS
Introduction.................................................................................................................................. 1
Answering the Hotline................................................................................................................. 2
How to Interview the Caller......................................................................................................... 4
How to Write Up Hotline Calls ................................................................................................. 13
Calls Requiring Special Handling.............................................................................................. 14
Handling Hotline Allegations Received by Mail, Fax, or Email............................................... 16
1003-SCREENING
Background.................................................................................................................................. 1
Level 1 Call Screening................................................................................................................. 2
Illustration of Level 1 Screening Sheet........................................................................................ 4
Level 2 Call Screening................................................................................................................. 6
Illustration of Level 2 Screening Sheet...................................................................................... 10
1004-CASE ASSIGNMENT
Background...................................................................................................................................1
Methodology Used to Assign Cases for Investigation..................................................................1
Cases Assigned to Agency Internal Audit Directors ....................................................................4
Investigators’ Responsibilities......................................................................................................5
Hotline Investigative/Complaint Report.......................................................................................6
Hotline Transmittal Letters...........................................................................................................7
Reporting.......................................................................................................................................9

Table of Contents
Topic Page No.
1005-“CALL-BACK” HOTLINE CALLS
Introduction.................................................................................................................................. 1
Hotline After-Hours Telephone Recording ................................................................................. 3
How a “Call back” Hotline Call Is Answered ............................................................................. 4
DSIA Procedure for Responding to Caller’s Questions .............................................................. 5
1006-INVESTIGATIONS
Overview/Background................................................................................................................. 1
Security over Hotline Investigations............................................................................................ 2
Assignment of Hotline Case Investigations................................................................................. 5
Target of the Allegation............................................................................................................... 7
Structure of a Hotline Investigation............................................................................................. 8
Gathering Evidence.................................................................................................................... 12
Examples of Types of Evidence ................................................................................................ 13
Additional Information about Gathering Testimonial and Documentary Evidence.................. 14
How to Plan an Interview .......................................................................................................... 15
Hotline Interview Techniques.................................................................................................... 21
Reaching a Conclusion Based on the Evidence......................................................................... 23
Guide to State Policies, Laws, and Regulations ........................................................................ 25
1007-REPORTING
Guidelines.................................................................................................................................... 1
Documentation and Confidentiality............................................................................................. 6
Confidentiality Stamp Use........................................................................................................... 6
DSIA Contact............................................................................................................................... 6

DIVISION OF STATE INTERNAL AUDIT
TOPIC NO.
1000
Topic: State Employee Hotline – Overview Date: January 2012
Division of State Internal Audit 1000 - 1 Commonwealth of Virginia
Overview of the Hotline Program
Introduction
History In 1990, the Commission of Efficiency in State Government recommended
the establishment of a Commonwealth Fraud and Abuse Hotline. The 1992
General Assembly introduced a House Bill to establish a statewide, toll-free
hotline for state employees to report instances of fraud, waste, or abuse in
state government. This bill did not pass. However, the Governor decided to
implement the hotline by issuing an Executive Order to authorize the hotline
under administrative law under the Governor's authority.
DSIA’s Role The Executive Branch directed the Department of the State Internal Auditor,
which became a division of the Department of Accounts (Division of State
Internal Audit or DSIA) in 2002, to administer the Hotline program. The
DSIA carries out this responsibility with the assistance of the statewide
network of agency and institutional internal audit departments (programs).
Implementation
of the Hotline
The DSIA implemented the Hotline on October 1, 1992, using a non-
traceable, toll-free number (1-800-723-1615) to protect the confidentiality of
the caller.
Objectives The major objectives of the hotline are to provide state employees with a
confidential vehicle to report suspected occurrences of fraud, waste, and
abuse in state agencies and institutions, to investigate such occurrences to
determine their validity and, if valid, to make appropriate recommendations to
eliminate these occurrences.
Structure The State Employee Fraud, Waste, and Abuse Hotline is completely
anonymous. Under no circumstances should anyone attempt to identify any
person who may call the Hotline. If the caller should somehow be identified
or even suspected, there shall be no retribution or adverse action taken against
that person.

TOPIC NO.
1000
Who are our
Customers?
Individuals within the Executive Branch of state government who are aware
of situations where fraud, waste, or abuse are occurring are expected to report
these instances. One way of doing this is to anonymously call the hotline to
report the allegation without fear of retaliation.

TOPIC NO.
1000
Authority
COMMONWEALTH OF VIRGINIA
OFFICE OF THE GOVERNOR
Executive Order 15 (2010)
State Employee Fraud, Waste, and Abuse Hotline
Importance of the Initiative
Efficiency and economy in government and wise stewardship of taxpayer dollars demands
constant vigilance to prevent fraud, waste, and abuse in the operation of state government. The
State Employee Fraud, Waste and Abuse Hotline has been an invaluable tool for helping ensure
economy and efficiency. It is incumbent on the leadership of state government to make the best
possible use of this tool for ensuring integrity in government and wise use of taxpayer money.
By virtue of the authority vested in me as Governor under Article V of the Constitution of
Virginia and under the laws of the Commonwealth, including but not limited to Chapter 1 of
Title 2.2 of the Code of Virginia, and subject to my continuing and ultimate authority and
responsibility to act in such matters, I hereby direct the State Internal Auditor to continue the
anonymous State Employee Fraud, Waste, and Abuse Hotline (hereinafter known as the
"Hotline") to encourage state employees to report situations where fraud, waste, or abuse may be
occurring in Virginia's Executive Branch agencies and institutions, including institutions of
higher education.
State employees should continue to have the opportunity to report possible instances of fraud,
waste, or abuse anonymously and without fear of retribution by using the Hotline. The State
Internal Auditor shall be responsible for administering the Hotline. Through the Hotline, the
State Internal Auditor shall:
Provide assistance to Executive Branch agency heads in fulfilling their responsibilities
for maintaining appropriate internal controls to protect against fraud, waste, and abuse.
Make available to state employees a variety of means to report fraud, waste, and abuse in
the Commonwealth's government business, one of which will be an anonymous toll-free
telephone number, and also including, but not limited to, any other communications
through the Governor's office, Cabinet Secretaries, agency heads, U.S. Mail, e-mail, fax,
and the Internet.

TOPIC NO.
1000
Make appropriate efforts to publicize the availability of the hotline and ways of accessing
it. The Auditor shall e-mail all State employees at least annually to advise them of the
Hotline and other means of reporting such problems.
Implement a process for handling allegations of fraud, waste, and abuse received via the
Hotline.
Deliver ongoing training to state agency heads and managers on prevention of waste,
fraud, and abuse.
Ensure that instances of potential criminal conduct are referred forthwith to the
appropriate law enforcement agency.
The State Internal Auditor, through the Executive Branch's network of internal auditing
programs and agency fraud, waste, and abuse coordinators, shall ensure that investigation and
resolution activities are undertaken in response to allegations received through the Hotline. The
State Internal Auditor may allow an internal auditing program at an executive branch agency to
contract with a private firm in order to perform the investigations in a timely manner. Any such
private firm shall comply with the applicable policies and procedures and the work must be
supervised and approved by the contracting internal auditing program.
The State Internal Auditor shall undertake investigation and resolution activities in the most cost-
effective manner possible. Responsibility for investigation or resolution activities shall be
assigned to other investigative staffs when appropriate to avoid unnecessary duplication.
Executive Branch agencies responsible for promulgating central administrative (e.g., personnel)
policies will provide input on the interpretation of the policies applicable to investigations in
order to ensure consistent and proper application of those policies so that appropriate conclusions
are reached and recommendations made.
The State Internal Auditor shall review the reported corrective actions taken to rectify an actual
fraud, waste, or abuse identified. If corrective actions are deemed insufficient, then the State
Internal Auditor will conduct such follow-up as may be necessary to ensure that acceptable
corrective actions are developed.
The State Internal Auditor shall conduct follow-up reviews to ensure that corrective action has
been implemented. The results of such reviews shall be reported to the Governor's Chief of Staff
and to the relevant cabinet secretary.
All executive branch agencies of the Commonwealth shall cooperate with, and assist, the State
Internal Auditor and all investigators to the fullest extent. During the course of a Hotline
investigation, investigators will have access to electronic and paper files, records, and
documents, as well as personnel, facilities, property, and any other things necessary to conduct
an investigation. This includes access to electronic and paper files maintained by the Virginia
Information Technologies Agency (VITA) for other Executive Branch agencies as well as access
to administrative investigative reports generated by an agency’s in-house investigative unit that
are germane to the hotline investigations.
Under no circumstances shall anyone directly or indirectly interfere with a Hotline investigation,
or induce or coerce others not to cooperate with investigators. Any attempt to directly or
indirectly interfere with a Hotline investigation is also prohibited and is subject to appropriate

TOPIC NO.
1000
disciplinary action under the Standards of Conduct promulgated by the Department of Human
Resource Management.
Under no circumstances shall anyone, directly or indirectly, attempt to identify or retaliate
against someone suspected of calling or cooperating with the Hotline. This includes threatening
to effect any reprisal; or taking, or directing others to take, or recommending, processing, or
approving, any personnel action, or any other retaliatory actions, or attempts to do the same. Any
such actions will be subject to appropriate disciplinary actions under the Standards of Conduct.
The Governor's Chief of Staff shall be responsible for addressing any instances of alleged
interference with an investigation or retaliation against employees using the Hotline.
This Executive Order rescinds Executive Order Number Twelve (2006), State Employee Fraud,
Waste, and Abuse Hotline, issued by Governor Timothy M. Kaine.
Effective Date of the Executive Order
This Executive Order shall be effective upon its signing and shall remain in full force and effect
unless sooner amended or rescinded by further executive order.
Given under my hand and under the Seal of the Commonwealth of Virginia this 29th day of June
2010.
/s/ Robert F. McDonnell, Governor
Attest:
/s/ Secretary of the Commonwealth

TOPIC NO.
1000
Hotline Terms and Definitions
Fraud
Definition
The intentional deception perpetrated by an individual or individuals, or an
organization or organizations, either internal or external to state government,
which could result in a tangible or intangible benefit to themselves, others, or
the Commonwealth or could cause detriment to others or the Commonwealth.
Fraud includes a false representation of a matter of fact, whether by words or
by conduct, by false or misleading statements, or by concealment of that
which should have been disclosed, which deceives and is intended to deceive.
Fraud Example Falsifying financial records to cover up the theft of money or state property is
an example of fraud.
Waste
Definition
The intentional or unintentional, thoughtless or careless expenditure,
consumption, mismanagement, use, or squandering of Commonwealth
resources to the detriment or potential detriment of the Commonwealth.
Waste also includes incurring unnecessary costs because of inefficient or
ineffective practices, systems, or controls.
Waste Example The unnecessary spending of state funds to purchase items that have no
business purpose is an example of waste.
Abuse
Definition
Excessive or improper use of a thing, or to employ something in a manner
contrary to the natural or legal rules for its use. Intentional destruction,
diversion, manipulation, misapplication, mistreatment, or misuse of
Commonwealth resources. Extravagant or excessive use as to abuse one’s
position or authority. Abuse can occur in financial or non-financial settings.
Abuse Example
The use of a state vehicle for non-state business and failure to complete a
leaves slip when absent from work are examples of abuse occurring in a non-
financial setting.

TOPIC NO.
1000
DSIA Responsibilities
Policy Hotline cases are assigned by the DSIA to the respective agency Internal
Audit Director if the agency has an internal audit program.
Heads of agencies that do not have an internal audit program have designated
a high-level individual (called a Hotline Coordinator) within the agency to
coordinate the DSIA’s investigation and resolution of complaints directed at
the respective agency.
The DSIA investigates hotline cases under certain circumstances as outlined
in the section below titled “What Does the DSIA Investigate?”
Authority Under the Executive Order, Agency Internal Audit Directors and Agency
Hotline Coordinators are responsible to the DSIA for the conduct of Hotline
investigations, and may not be restricted, limited, or interfered with in the
conduct of investigations.
DSIA Determines the authenticity of allegations.
Ensures that appropriate recommendations are made to rectify any
situations where fraud, waste, or abuse have been identified.
Ensures that timely investigative and resolution activities are undertaken
in response to allegations received through the hotline.
Works with agency internal audit programs to investigate and resolve
reported allegations in the most cost efficient manner.
Reviews investigative work to determine that it is of an acceptable level
of quality and appropriateness and to provide suggestions for
improvement in future investigations.
Provides training to investigators upon request.

TOPIC NO.
1000
What Does the
DSIA
Investigate?
The DSIA conducts all investigations involving alleged improprieties
committed by agency heads, other appointed officials, and internal auditors.
In situations where an agency has only a Hotline Coordinator, the DSIA may
assist the Hotline Coordinator or conduct the investigation itself.
The DSIA conducts all hotline investigations involving agencies that do not
have an internal audit program or an Agency Hotline Coordinator.
The DSIA may participate in the agency’s hotline investigation if warranted
by the nature of the allegation, or if the agency head or Internal Audit
Director requests the DSIA’s participation.
The DSIA may conduct any investigation it deems necessary.

TOPIC NO.
1000
Process for Receiving a Hotline Call
Step Description
1 The DSIA receives hotline telephone calls through a non-traceable, toll-free line.
2 All callers are told not to disclose their identity.
3 A DSIA investigator records the facts about the allegations and attempts to solicit
sufficient information to facilitate an effective investigation.
4 The DSIA investigator provides a case number to each caller to provide the caller with
a means to contact the investigator when it is necessary to clarify or obtain additional
information regarding the allegations.
5 The DSIA investigator refers callers with complaints pertaining to subject matter
outside of the Executive Branch of State government to the appropriate investigative
authority.
6 The DSIA investigator records all cases by date, time, agency, and case number for
control purposes.
7 An Investigative Complaint Report is mailed or sent via encrypted e-mail to the
respective agency Internal Audit Director or Hotline Coordinator within 2 business
days of being received by the DSIA.
8 There is a 60-day reporting requirement.
9 An investigation is undertaken to determine the authenticity of the allegations. If the
alleged fraud, waste or abuse is substantiated, then appropriate corrective action must
be taken by the agency/institution head to rectify the situation.
If there is a reasonable possibility of a fraud, the fraud should be referred to both the
Auditor of Public Accounts and the Department of State Police in accordance with
§30-138 of the Code of Virginia.

TOPIC NO.
1000
Other Information
Calls Not
Involving
Fraud, Waste,
Or Abuse
Hotline callers with issues involving retaliation for calling the hotline are
referred to the Chief of Staff in the Governor’s Office. Hotline callers with
issues involving employee grievances or discrimination complaints are
referred to the Department of Employee Dispute Resolution or the Office of
Equal Employment Services of the Department of Human Resource
Management. Additional examples of complaints not within the purview of
the DSIA where the caller is directed to other entities include, but are not
limited to, allegations against Legislative or Judicial Branch employees
(except as provided through informal agreements), employees of localities,
and private citizens or entities.
Subject Cross
References
Executive Order Fifteen (2010)
Code of Virginia, §30-138, State agencies, courts, and local constitutional
officers to report certain fraudulent transactions to the Superintendent of State
Police and the Auditor of Public Accounts.
Code of Virginia, § 2.2-3705.3, Virginia Freedom of Information Act;
exemptions.
Code of Virginia, §2.2-1600, The Department of the State Internal Auditor.
Advertising State employees are informed of the hotline through announcements in the
state personnel newsletter; hotline posters on employee bulletin boards,
newspaper articles, and periodic messages on Payline or employee payroll
check stubs, and other marketing efforts.

TOPIC NO.
1000
The hotline poster is displayed at all state agencies.

TOPIC NO.
1000
DSIA Hotline
Contact
Tim Sadler, Audit Manager
(804) 225-3106, Ext. 23 or
tim.sadler@doa.virginia.gov or
DSIA@doa.virginia.gov

TOPIC NO.
1001
Topic: State Employee Hotline – Security Date: January 2012
Security
Hotline Reports, Work Papers, and Other Documents
Policy Confidentiality shall be maintained over hotline documents at all times.
Hotline cases should not be discussed with anyone, except for the Hotline
Coordinator and the State Internal Auditor or others on a need-to-know
basis who are involved in the investigation.
No copies are to be made of any hotline documents.
Hotline case write-up sheets shall not be shown to others, except for
individuals who are responsible for conducting the hotline investigation.
All hotline documents, notes, etc. should be secured at all times.
Case numbers will not be shared with anyone except investigators.
Only the State Internal Auditor is authorized to distribute or release
hotline reports.
Confidentiality over the interview process is addressed within Topic No.
1006, Investigations, “How to Plan an Interview.”
Security over
Documents
All Hotline documents are to be secured in a safe place at all times.
Confidentiality All documents, work papers, notes, and reports dealing with the
investigation shall be marked Confidential State Employee Hotline
Documents.
Investigations, interviews, and information relating to investigations
should not be shared, discussed, or given to anyone without an absolute
need to know.
Strict confidentiality must be maintained over the entire hotline
investigation.

TOPIC NO.
1001
Written
Communication
With the DSIA
Written communications with this Division about Hotline cases are to be sent
primarily through the U.S. mail or delivered in person. This is to ensure that
if any tampering occurs, the violator can be prosecuted to the maximum
extent under the law. All envelopes concerning the hotline should be marked
"Confidential" when sent to the DSIA. Interagency mail should never be
used. Email and fax communications are permitted under certain
circumstances after discussion with the DSIA.
Custodian of
Hotline
Documents
State Internal Audit Directors and the DSIA shall maintain all information
supporting investigations performed by them in a secure location. All such
information, documentation, etc. are the property of the DSIA and shall be so
identified. The DSIA may request that supporting information accompany
formal reports.

TOPIC NO.
1001
Requests for Hotline Information
Calls Asking
About Cases
The following process is followed by the DSIA in responding to telephone
calls requesting information on hotline cases.
Step Description
1 Telephone call is answered by a DSIA investigator.
2 The caller asks the DSIA investigator about a hotline case.
3 The DSIA investigator asks the caller to provide some information
about the case for identification purposes. This should be
information that would only be known to the complainant, such as
the subject, the date of the call, etc.
4 If the DSIA investigator is certain that the caller knows sufficient
information about the case, then the caller is advised only of the
status of the case, either completed or in process.
5 No further information can be provided by telephone.
6 If the requestor desires further information on a closed case, they
will be told how to make a request to the DSIA for the case
information under the Freedom of Information Act.
7 If the caller continues to ask about the case, refer them to the
DSIA Hotline Coordinator or to the State Internal Auditor.
Requests For
Hotline
Information
Only the DSIA provides requestors information about hotline cases. All such
requests should be referred to the DSIA and should not be processed by other
agencies.
The DSIA shall respond to such requests as permissible under the Code of
Virginia, § 2.2-3700 which pertains to the Freedom of Information Act
(FOIA). All requests for information about hotline cases will be processed in
compliance with the FOIA, which requires a written response within five
business days.
What Is
Provided To
the FOIA
Requestor?
Under the Code of Virginia § 2.2-3700 and 2.2-3705.3, this Division is
required to disclose the following information under FOIA requests for
information on completed cases:

TOPIC NO.
1001
If … Then DSIA must disclose… Therefore the report to DSIA must
include:
Allegation
Substantiated
(Corrective Action
taken)
Name of agency
Identity of the person(s) who
is/are the subject(s) of the
complaint
Nature of complaint
Corrective actions taken
All relevant information in hotline
responses. Refer to reporting
section
Any litigation or other legal actions
planned, or taken, involving a case,
such as grievances, etc.
Allegation
Unsubstantiated or
Allegation
Unsubstantiated
but
Recommendations
Made
(No corrective
action taken
against the subject)
If no corrective action is
taken, the identity of the
person who is the subject of
the complaint may be
released only with the
subject's consent.
Name, address, and telephone
number of the target of the
complaint for cases where no
corrective action was taken.

TOPIC NO.
1001
Handling Freedom of Information Act (FOIA) Requests
How Does the
DSIA Handle
FOIA
Requests?
The DSIA handles FOIA requests received by phone, mail, fax, or email
using the following steps.
Step Responsible
Party
Actions Taken
1 DSIA Hotline
Coordinator
Receives the FOIA request by phone. Informs the caller whether or not the
case is closed. Informs the caller that:
The request requires the name of an individual and a Virginia address
of the individual to whom the FOIA response will be sent. If the caller
provides the information, write it down and skip to Step 3.
The request may be made verbally by phone or in writing via the U.S.
mail, by fax, or by email.
2 DSIA Hotline
Coordinator
Receives the FOIA request by U.S. mail, fax, or email
3 DSIA Hotline
Coordinator
Reviews and redacts the case report based on whether or not the allegation
was substantiated. The subject’s name is redacted in cases where the
allegations were not substantiated. Witnesses’ names are also redacted.
4 DSIA Hotline
Coordinator
Prepares and mails, e-mails, or faxes the FOIA response within 5 business
days. FOIA requests and responses are retained for three years as required
by the Library of Virginia’s Record Retention Policy.
Agency
Responsibilities
Agencies should not provide any information to requestors concerning
hotline calls and investigations under any circumstances. Doing so could
seriously jeopardize the integrity of the Hotline and the investigative
techniques used.
If an agency should receive a request for information regarding a Hotline
investigation, either through the Freedom of Information Act or other
means, the requestor should be referred to the DSIA.
However, Hotline reports and supporting work papers may be shared with
the Auditor of Public Accounts (APA) upon its request.

TOPIC NO.
1001
Hotline Investigative/Complaint Report
Introduction A DSIA investigator records hotline calls on an Investigative/Complaint
Report, also informally referred to as a “Case Write-up Sheet.”
.
Step Description
1 Each DSIA Investigator is assigned a sequential list of 100 case numbers to use
when completing the Investigative/Complaint Reports (yellow case-write up
sheets).
2 A DSIA investigator answers a hotline call and interviews the caller, listening to
his/her allegation.
3 A DSIA investigator records the allegation and supporting information on the
Hotline Investigative/Complaint Report.
4 The Hotline Coordinator screens each case by reviewing the case and
determining whether it should be assigned for investigation or screened out and
provided to the agency Internal Audit Director or Hotline Coordinator for
informational purposes. The State Internal Auditor also reviews the screened-out
cases and, on rare occasions, reassigns a screened out case to be investigated.
5 The DSIA sends the Hotline Investigative/Complaint Report to the applicable
agency Internal Audit Director or agency hotline coordinator for investigation
via the U.S. mail system or via encrypted e-mail.
6 The Agency Internal Audit Director or agency hotline coordinator conducts the
investigation of the allegation(s) based on the Hotline Investigative/Complaint
Report.

TOPIC NO.
1001
Concern Do not provide a copy of the Hotline Investigative/Complaint Report (the
hotline case write-up sheet) to the target of the investigation.
The DSIA believes the information contained on the Hotline Investigative/
Complaint Report may compromise the caller’s identity because:
The DSIA investigators prepare the Hotline Investigative/Complaint
Report verbatim from the caller’s description of the situation.
Confidential information is contained in the Hotline
Investigative/Complaint Report, such as individuals who witnessed the
alleged fraud, waste, or abuse.
Other information such as the time and date of the call can provide clues
to the caller’s identity.
Confidentiality The DSIA takes precautions to ensure that the identity of State employees
who report alleged fraud, waste, or abuse to the hotline is totally anonymous.
The Hotline Investigative/Complaint Reports are handled by the DSIA under
the strictest level of confidentiality and are marked as “Confidential State
Employee Hotline Documents.” The agency internal audit programs must
provide the same level of confidentiality over hotline documents in order to
maintain the integrity of the hotline program.
Reminders from
the DSIA
State Internal Audit Directors and others involved in hotline investigations
should not share the Investigative/Complaint Report with anyone except those
individuals who are directly involved in conducting the investigation. Those
provided this information must also understand the confidentiality
requirements.
If it is deemed necessary for investigative purposes to disclose the nature of
the allegation(s) to the target, the disclosure should be done by providing the
target with a summary of the allegation(s). However, be careful not to
provide the target with any information that would compromise the caller’s or
any witness’s identity.

TOPIC NO.
1002
Topic: State Employee Hotline – Accepting Calls Date: January 2012
Accepting Calls
Introduction
Background The conversation with the caller is the most important part of the hotline
process, since this is usually the only opportunity to fully understand and
document the caller's concern(s) and gather relevant details.
Hotline
Parameters
The DSIA operates the hotline program within the following parameters:
The Hotline’s toll free number is 800-723-1615.
Hours are from 8:15 am to 5:00 pm, Monday through Friday, except on
state holidays when the phones are unattended.
After-hours, a recorded message announces the hotline hours and advises
callers to call back during normal working hours.
The after-hours message is used to announce case numbers for which
additional information is needed and to ask the callers to call back.
The DSIA Hotline Coordinator answers the hotline and forwards the calls
to DSIA investigators who interview the callers about their allegations.
The Hotline does not offer callers the option of leaving a recorded
message since there would be no mechanism for the DSIA to interview
them or to contact them later if further information is needed.
Hotline allegations are primarily accepted by telephone. In addition, the
DSIA receives complaints through the mail (P.O. Box 1971, Richmond,
VA 23218), by fax (804-371-0165), or by email (dsia@doa.virginia.gov).

TOPIC NO.
1002
Answering the Hotline
How Does The
DSIA Answer
Hotline Calls?
The DSIA answers and processes a hotline call by following the steps shown
below.
Step Responsible
Party
Actions Taken
1 DSIA Hotline
Coordinator
Answers call and reads the following script:
“You have reached the State Employee Fraud, Waste and Abuse
Hotline. You should not disclose your identity. Are you calling back
about a case you previously reported? Please hold and I will connect
you with an investigator.”
2 Investigator Listens to the particulars of the allegations and records the following:
Time and date
Name of the State Agency
Subject of the allegation.
3 Investigator While discussing the situation with the caller, the investigator makes a
preliminary determination of whether the allegation falls under the
hotline’s authority and whether it involves fraud, waste, or abuse of state
resources.
If yes, go to step 4.
If no, re-direct the caller to the appropriate agency or investigative
authority using the Level 1 Call Screening Criteria Sheet.
4 Investigator Continues to interview the caller, obtaining relevant information about
the allegation.

TOPIC NO.
1002
Step Responsible
Party
Actions Taken
5 Investigator Is the write-up complete?
If yes, go to step 6.
If no, inform the caller that additional relevant information is needed
and to call back.
6 Investigator Assigns the caller a sequential case number. The investigator then states,
“Please call the hotline number again, no sooner than three weeks from
today after 5 PM. When you hear our after-hours message, please listen
to the recording. A listing of case numbers will follow the after-hours
hotline message. If you hear your case number you should call back
during the day so that we can speak to you about your concern.”
What If Caller
Makes More
Than One
Allegation?
Issue a case number and prepare an Investigative/ Complaint Report with
each allegation listed separately on the report.

TOPIC NO.
1002
How to Interview the Caller
What Questions
Does the DSIA
Ask Callers?
Investigators who take calls try to obtain the facts surrounding an allegation.
As a rule of thumb they should ask the who, what, when, where, why, and
how of the allegation. In addition, investigators should ask:
How the complainant knows of the situation,
Whether the allegation has been reported elsewhere or if it has been
previously investigated,
Whether the complainant tried to resolve the matter internally by
reporting the situation through the chain of command,
The names of any witnesses that are aware of the situation who would
be willing to speak with investigators,
Whether the subject’s supervisor or others in authority are aware of
the allegation,
The policy that applies, that is, why does the caller think the situation
is fraud, waste, or abuse, (Note: Institutions of higher education may
have separate policies governing their instructional, administrative,
and professional faculty.)
Whether the caller has documentation that supports the allegation,
The estimated loss, and
The frequency of the occurrence.
Below is a list of some frequent allegations made to the hotline and the
appropriate interview questions used by the DSIA.
This list does not include all the different types of allegations made to the
hotline, only those that are received most frequently.

TOPIC NO.
1002
If the allegation is ... Then ask the following questions, as considered necessary
Leave Abuse
Examples:
Takes long
lunches or other
excessive breaks
Arrives late or
leaves early
Fails to turn in
leave slips for
absences
Not working an 8-
hour day.
Agency, Division, Unit involved?
Name of subject(s) and his/her position (classified employee)?
Subject’s scheduled work hours, lunch break, and other breaks?
Date and time of the occurrence?
Frequency of the occurrence?
Location of the occurrence?
Names of any witnesses?
Is there electronic access to the parking area?
Is there a sign-in or sign-out sheet?
Is there electronic access to the work location?
Is there a time clock?
Do you know where the target went?
Did the target depart in a vehicle? What was the license number and
description of the vehicle?
Did anyone else go with them?
Were leave slips turned in? How do you know this?
Is the supervisor aware of this situation?
Was this situation reported to anyone else?
Are there any documents to support this allegation?
Does the agency have written policies and procedures that address this
issue?
Does the agency allow alternative work schedules?

TOPIC NO.
1002
State Vehicle Abuse
Examples:
Commuting
between office
and home
Improper or
unnecessary use
Personal use
Agency, Division, Unit, etc. involved?
Name of subject(s) and his/her position?
Subject(s) supervisor?
Location of the occurrence?
License plate number of the vehicle or any other numbers or emblems?
Description of the vehicle (color/make/model)?
Exact location of the vehicle – county, city, route number, street address
If the car was in a parking lot, exact location within the lot.
Description of the driver?
Description and the number of any passengers?
Where was the vehicle driven from and to? Approximate distance?
Are there agency policies and procedures?
Is the individual in travel status or on call?
Misuse or Waste of
Funds/Resources
Examples:
Unnecessary
purchases
Excessive
spending
Wasteful use of
state property or
equipment
Malfeasance, such
as failure to
properly manage
departmental
budget
Subject(s) supervisor?
Nature of the fraud/waste/abuse?
Why is it considered wasteful?
Amount and account name/numbers of funds involved?
Description and value of the property?
Location of the funds or property?
How did you find out this information?
Was this situation previously investigated by anyone else?
Are there any documents or other evidence to support this allegation?
issue?
Are there any other circumstances that contributed to this situation?

TOPIC NO.
1002
If the allegations are… Then ask the following questions, as considered necessary
Violations of State
Personnel Policy
Examples
Unfair hiring
Pre-selection
Unqualified
employee
(If the caller is the
aggrieved employee, the
caller should be
referred to the Dept. of
Employment Dispute
Resolution (EDR) or the
Dept. of Human
Resource Management
Office of Equal
Employment Services
(EES))
Is the person a classified employee?
Job title and position number and classification (full time)?
Name of individual hired?
Position’s supervisor?
When did the situation occur?
Are there any documents or other evidence to support this allegation?
issue?
Other questions regarding specific allegations:
Unfair hiring
How was the hiring unfair?
Qualifications that the successful applicant lacks?
Names of other applicants who are better qualified?
Who were the interview panel members?
Who screened the applications?
Who is the hiring authority for the position?
Date job posted/closed or date successful applicant started in the
position?
How can we verify this?
Pre-selection
Why was the person pre-selected?
Who was the person pre-selected by and was that person on the
interview panel?
How did you know this person pre-selected the individual? Does
anyone else know this?
How can we verify this?
Is this person qualified for the position?
Unqualified employee
Why is the person unqualified?
What duties and responsibilities assigned to this position cannot be
performed due to the person’s lack of qualifications and have they
been assigned to someone else?
Has there been a documented incident to verify this?
What qualification is the employee lacking?

TOPIC NO.
1002
State Telephone
Abuse
Examples:
Personal calls on
state telephones,
including cellular
phones
Using state fax
machine for
personal
documents
Charging personal
long distance
telephone calls to
the state.
Agency, Division, Unit, etc. involved
Name of subject(s) and his/her position
Subject(s) supervisor
What is the telephone number from which the calls are made?
What account name/numbers are the calls being charged to?
Date and time of calls?
Frequency and duration of calls?
How do you know the calls are not state business-related?
Do you know the name of the party called?
Their phone number?
Where is the party located (local vs. long distance call)?
If long distance, do you know the area code?
How do you know the employee is not charging the calls to his/her
personal calling card?
Does the agency permit employees to make long distance calls and
reimburse the agency for them later?
Does the agency monitor employee phone calls?
(If fax misuse) Where is the fax machine located?
What is the fax number?
What type of documents is the target sending and/or receiving?
Do you have a copy of those documents? If so, please provide.
Name of cellular phone vendor.
Can you provide the names of any witnesses?
Has this situation been reported to anyone?
Are there any documents to support this allegation?
Does the agency have a written telephone policy?

TOPIC NO.
1002
If the allegations
are ...
Then ask the following questions, as considered necessary
Procurement
Violations
Examples
Unnecessary or
excessive
purchases/
construction
Over-priced
purchases/
construction
Conflict of interest
Non-competitive
procurement
Name of the subject(s) and his/her position?
What goods or services were purchased; the name of the vendor and the
agency account name/number charged?
How many times has this occurred?
Where did this happen?
When were the goods/services purchased?
What was the dollar amount of the purchase?
(If goods) Where are the goods currently located?
(If services) Were the services performed? If not, what is the status?
Who authorized the purchase?
Was this within the authorizer’s purchasing authority?
How did this purchase violate procurement laws?
Has the agency paid the vendor for the goods or services?
Why do you consider this purchase to be unnecessary?
Why do you consider this purchase to be excessive?
Is the employee’s supervisor aware of this situation?
How did you find out about this situation?
What documents or other evidence can we use to prove that this
happened?
Other questions regarding specific allegations:
Special treatment and/or the acceptance of bribes, gifts, or kickbacks.
How was one vendor given special treatment over other vendors?
How was this special treatment able to occur?
Explain why this purchase was a conflict of interest?
Did the employee have a special interest in the transaction?
Did the employee accept a gift, bribe or kickback from a vendor?
What was the nature of the gift, bribe or kickback?
Do you know the value of the gift, bribe or kickback?
Why did the employee act in this manner?

TOPIC NO.
1002
Conducting
Outside Business
in a State Office
and/or
Using State
Resources for
Other Than State
Business
Purposes
Examples:
Private/Personal
Business – Using
state resources in
an outside
business
Conducting
outside business
from a state office
Selling products,
preparing tax
returns, selling
real estate
Date and time the situation occurred?
Does the subject(s) come in early, work late, have approved telework
arrangements, or come in on weekends to make up for time spent on
personal business?
Where did this occur?
Describe the nature of the outside or personal business that is conducted
from the state office?
What is the name of the outside business?
Do you have a business card, brochure, etc?
How much time is involved?
How often does this occur?
How long has this been going on?
How do you know that the subject(s) is not making up the time?
What State resources is the subject using for outside business purposes
(Computer, copier, telephone, paper, fax machine, Internet)?
Is the subject receiving and/or making telephone calls?
How do you know the calls are not related to state business?
Is the target conducting outside business during his/her state work
hours, during lunch, or after work hours?
Do you have any evidence, such as copies of documents?
Is the target’s supervisor aware of this situation?
Has this situation been reported to others?

TOPIC NO.
1002
Travel Abuse
Examples
Inflated
reimbursement
expenditures
Unnecessary
attendance at
conference/class
Excessive travel
What type of abuse occurred?
When were the dates and times of travel?
Travel destination or location of the occurrence?
What was the purpose of the travel?
Did anyone else travel with this individual? If so, please identify.
Is the target’s supervisor aware of this situation?
Was this situation reported to others?
Is there evidence or other documents to support this allegation?
What account name/number was the travel charged to?
issue?
What types of expenditures were inflated (mileage, lodging)?
How was this done?
What was the amount of the inflated expenditures?
Was travel by air, auto, state vehicle, etc.?
Why do you consider attendance of the seminar, conference, etc.
unnecessary?
What was the cost of the travel?
Who approved attendance at the conference?
What was the frequency of the travel?
Does the individual’s position require travel?
For what purposes does this position require travel?

TOPIC NO.
1002
Abuse Of State
Computers
Examples
Unauthorized use
of a state
computer
Unnecessary or
idle computer
Unnecessary
software
Misuse of the
Internet
Personal use of the
e-mail system
Does the subject(s) come in early, work late, have approved telework
arrangements, or come in on weekends to make up for time spent on
personal use?
How do you know that the subject(s) are/are not making up the time?
How did you obtain this information?
Does the Agency have written policies and procedures addressing this
issue?
Was this situation reported to others?
Is it a desktop or a laptop computer?
What type of computer is it? (Gateway, Dell, etc.)
Where is the computer located?
Was this done on state time, after hours, or during lunch?
What type of software was used? (Word, WordPerfect, Excel, Internet,
etc.)
Describe the documents that were used or prepared.
How much time was spent using or preparing the personal documents?
If personal e-mail: frequency, sent to/received from, if sent outside of
the agency, where?
What are the documents about (subject)? Any specific organization?
Do you have a copy of the documents? (If so, please provide them to
us)
Is there any other evidence such as documents to support this
allegation?
Where are the documents saved? (Hard drive, CD, DVD, diskette,
network)
What was the computer supposed to be used for?
What was the cost of the computer? When was the computer
purchased?
Who authorized the purchase of the computer?
What Internet sites are accessed?
Does the agency monitor computer usage?

TOPIC NO.
1002
How to Write Up Hotline Calls
What happens
after the call?
Once the DSIA investigator ends the call, the following tasks are performed.
Step Responsible
Party
Actions Taken
1 Investigator Research PMIS, internet, state employee directory, etc. to verify the
applicable information in the allegations.
Write up the case on an Investigative/Complaint Report.
Attach interview notes to the Investigative/Complaint Report.
Provide all Hotline documents to the Hotline Coordinator.
2 DSIA Hotline
Coordinator
Perform a Level 2 screening of hotline cases.
Determine what level of investigation is warranted, including whether
or not the DSIA should conduct the investigation.
Provide all screened out cases to the State Internal Auditor for review
and concurrence.
3 Investigator Prepare hotline letters for distribution to the appropriate Internal Audit
Directors. Hotline documents may be e-mailed if done so using encrypted
e-mail.

TOPIC NO.
1002
Calls Requiring Special Handling
Exceptions Special Handing is required for the following types of calls.
If Then Process
Allegation involves an
internal audit director or staff,
state agency head, or other
gubernatorial appointee.
Immediately notify the DSIA
Hotline Coordinator or State
Internal Auditor.
Investigation is
assigned to the DSIA.
Inform the State
Comptroller and
provide an explanation
as to why the DSIA is
conducting the
investigation.
Allegation involves a time
sensitive issue or some other
urgent matter.
Internal Auditor.
The DSIA Hotline
Coordinator will
expedite the handling of
the case as considered
appropriate.
Alleged wrongdoing involves
criminal activity or the
immediate threat to life or to
state property.
Internal Auditor.
The DSIA Hotline
Coordinator will
expedite the handling of
the case as considered
appropriate, including
forwarding the
allegation to the State
Police.

TOPIC NO.
1002
If Then Process
Caller desires to mail
information to the hotline.
Provide the following directions:
Mail the information via U S
mail to:
FWA Hotline
P. O. Box 1971
Richmond, VA 23218
Mark the envelope
"Confidential."
Write the case number on the
documents.
Advise the caller that any
documents provided become the
property of the Hotline.
Request that the caller follow-
up with the hotline investigator
to ensure that the documents
were received.
For Hotline mail
opened by the DSIA
Hotline Coordinator:
Date stamp the
document(s)
Verify the case
number or assign a
new case number
Summarize the
information in the
case write-up
File the original
document(s) in the
case file and
provide a copy to
the investigator.
Complaint concerns the
manner in which a hotline
case was investigated.
Immediately refer the caller to the
DSIA Hotline Coordinator or the
State Internal Auditor.
The DSIA Hotline
Coordinator or the State
Internal Auditor
resolves this situation
as deemed appropriate.
Caller thinks he/she is the
victim of retaliation because
he/she reported allegations of
fraud, waste, or abuse to the
hotline.
Immediately refer the caller to the
Governor’s Chief of Staff.
No further action is
required.

TOPIC NO.
1002
Handling Hotline Allegations Received by Mail, Fax, or Email
How Does the
DSIA Handle
Hotline
Allegations
Received by Mail,
Fax, or Email?
The DSIA handles hotline allegations received by mail, fax, or email by
performing the following steps:
Step Responsible
Party
Actions Taken
1 DSIA Hotline
Coordinator
Receives the hotline allegation by mail, fax, or email.
2 DSIA Hotline
Coordinator
Reviews the content of the mail, fax, or email and performs Level 1 and
Level 2 screenings.
3 DSIA Hotline
Coordinator
Assigns a sequential case number to the allegation.
4 DSIA Hotline
Coordinator
Summarizes the allegation on an Investigative/Complaint Report.
5 DSIA Hotline
Coordinator
Prepares a hotline letter for distribution to the appropriate Internal Audit
Director, provided the allegation is not screened out.

TOPIC NO.
1003
Topic: State Employee Hotline – Screening Date: January 2012
Hotline Call Screening
Background
Policy The DSIA shall undertake its investigation and resolution activities in the
most cost-effective manner available.
Overview The DSIA developed screening criteria based on information gathered by
contacting other states with similar hotline programs and by researching other
relevant sources. This screening process helps to:
Reduce the time and expense of investigating complaints.
Ensure that a subject outside of the hotline’s authority is not accepted as a
case.
Minimize the amount of time and effort spent on less significant
allegations.
.
Investigative
Authority
The DSIA administers the hotline program under the authority of an
Executive Order, which only covers Executive Branch State Agencies and
Institutions.
Certain other independent and Judicial and Legislative Branch agencies
of the State government voluntarily participate in the hotline program.
Call Screening The DSIA screens hotline calls at two different levels:
1. Level 1 screening is performed by the DSIA investigator while talking to
the caller to identify calls outside of the hotline’s authority.
2. The DSIA Hotline Coordinator performs level 2 screening after the case
is taken to ascertain the seriousness of the allegation.

TOPIC NO.
1003
Level 1 Call Screening
What Is Level 1
Screening?
The DSIA investigator conducts an interview to identify the nature of the
complaint and to determine:
If the nature of the allegation falls within the hotline program’s authority.
If the nature of the allegation involves fraud, waste, or abuse of state
resources.
Methodology Level 1 Screening uses the following methodology
If the subject of the allegation … Then . . .
Falls under the Executive Branch of State
Government or other voluntarily
participating non-executive branch
agencies and involves alleged fraud, waste,
or abuse of state resources
Accept the case by issuing a case number.
Falls outside of the Executive Branch
or other voluntarily participating non-
executive branch agency
Does not involve a state agency or
institution and/or does not involve state
business
Involves a subject unfamiliar to the
investigator
Do not accept the case. Refer the caller to the
Auditor of Public Accounts or other appropriate
authority.
Refer caller to the appropriate authority by
referring to the following:
Level 1 Screening Sheet (below).
State Agency Telephone Directory.
Consult with the DSIA Hotline Coordinator or
the State Internal Auditor.
If additional time is needed to research this issue,
explain this to the caller and ask them to call back
later (within a reasonable time period).
Involves a criminal matter Do not accept the case.
Refer caller to their local police or appropriate
law enforcement authority.

TOPIC NO.
1003
When Is A Case
Number
Issued?
The DSIA investigator issues a case number when the caller’s allegation
passes the Level I screening.

TOPIC NO.
1003
Illustration of Level 1 Screening Sheet
Non-Hotline Topics Refer Caller Directly Phone #
Alcoholic Beverage Control Violations (non-
State employee violations)
Dept. of Alcoholic Beverage Control (866) 437-3155
APA Staff Record allegation and send case write-up to
Roland Turner, APA
(804) 225-3350
Citizen reports a driver in a state vehicle Department of General Services 367-6526
Citizen reports other issues Refer to applicable agency Varies
City/County/Town Employee/ Function (Ex:
local police officers, school teacher, etc.)
As applicable: City/County Mgr, Internal Audit,
School Board, City/Town Council, Board of
Supervisors
Varies
Constitutional Officers
(Ex: Commonwealth Attorney, Commissioner of
Revenue, Sheriff) & Legislative Branch
Employees except the Auditor of Public
Accounts
Auditor of Public Accounts (804) 225-3350
Driver's License or ID card fraud DMV Hotline (877) 937-6372
Employee Relations Advice Line (workplace
mediation and/or grievance) Includes the following
common conflicts: communication difficulties,
discrimination, termination, harassment,
discipline, management/work styles.
Agency Human Resources
Agency Workplace Mediation Coordinator.
Dept. of Employment Dispute Resolution
Varies
See attached list
(888) 232-3842
Federal Tax Fraud Internal Revenue Service (800) 829-0433
General Assembly Member Clerk of the House: G. Paul Nardo
Clerk of the Senate: Susan Clark Schaar
(804) 698-1619 (House)
(804) 698-7400 (Senate)
Healthcare Providers complaints Dept. of Health Professions (800) 533-1560
Health Plans:
Medical
Drug
Dental
Behavioral Health/EAP
Anthem
Blue Card
Medco
Delta Dental
Value Option
(800) 552-2682
(800) 810-2583
(800) 355-8279
(888) 335-8296
(866) 725-0602
Identify a state government license tag to
determine agency
Department of General Services 367-6525
Identity Theft Federal Trade Commission (877) 438-4357
Inclement Weather Policy Complaints (Hotline
accepts calls alleging violation of policy; refer only
disagreements with policy) DHRM prefers they
write to:
Director, DHRM Employee HR rue.white@dhrm.virginia.gov
Insurance Fraud (including Worker's
Compensation)
Virginia State Police (877) 623-7283
Judges (Code of VA Section 17.1-902) and staff Judicial Inquiry & Review Commissioner (804) 786-6636

TOPIC NO.
1003
Illustration of Level 1 Screening Sheet (continued)
Non-Hotline Topics Refer Caller Directly Phone #
Legislative Branch - The Auditor of Public
Accounts (APA)
Director of JLARC (804) 786-1258
Lottery Hotline State Lottery Hotline
Internal Audit
(804) 692-7699
(804) 692-7123
Medicaid Fraud (can report fraud by providers or
recipients) DMAS Fraud Unit (provider)
Recipient
(800) 371-0824
(804) 786-0156
(866) 486-1971
Occupational License (issues) Dept. of Professional & Occupational Regulation (804) 367-8500
Payroll Errors/Questions Agency Payroll Office
Department of Accounts
Varies
(804) 225-2245
Personnel Matters {Refer callers alleging
employment discrimination based on any of the
following: race, color, gender (including sexual
harassment), age, veteran status, national origin,
religion, political affiliation, or disability}
Department of Human Resource
Management-Office of Equal Employment
Services
Varies
(800) 533-1414
Private Sector Business/Charity VDACS Consumer Protection 786-2042 (Richmond)
(800) 552-9963
Public Defenders Virginia Public Defender’s Office
9th
and Franklin
(804 225-4330
Retirement Benefits Misuse (State) and
complaints regarding UNUM (Virginia Sickness
and Disability Program) including alleged misuse
of state disability benefits (short-term and long-
term).
Virginia Retirement System
For UNUM complaints only, refer caller to
Margaret Corwin, VRS Product Administrator. For
Disability Fraud, refer caller to the VRS IA
Director or VRS Director
(888) 827-3847 or
649-8059 (Richmond)
(804) 775-3225
(804) 344-3120
Road Problems/Conditions (road and traffic
conditions, report unsafe road conditions, request
state maintained work)
Virginia Department of Transportation 511
(800) 367-7623
Social Security Number Fraud US Social Security Administration (800) 269-0271
State Employee Fraud, Waste, and Abuse
Hotline
DOA Division of State Internal Audit (800) 723-1615
(804) 371-0165 (fax)
State-owned vehicle road-side assistance Department of General Services (866) 857-6866
Supreme Court Record allegation and send case write-up to John
Rickman, Supreme Court
(804) 786-6455
Terrorist-related Threats and Activities
Including health-related threats, suspicious
symptoms, outbreaks and other actions (including
those involving labs, private hospitals, and
physicians); technology incidents or threats; and
transportation events or threats.
VA Dept. of Emergency Management
VSP Terrorist Tip Hotline
(804) 897-6510
(877) 4VATIPS
(877) 482-8477
Unemployment Insurance Abuse Record allegation and send case write-up to
Joseph Young, VEC Internal Audit Director
(804) 786-4445
Virginia Tax Fraud (if state employee, take call
and forward information to Tax IA)
Department of Taxation (804) 367-8031
tax-
taxpayercomplaintreferral@tax.
virginia.gov
VITA Customer Care Center Virginia Information Technologies Agency (866) 637-8482
WIC Fraud Department of Health (877) 835-5942
tellwic@vdh.virginia.gov
Workers' Compensation (if employee is victim)
Also see Insurance Fraud Section above.
Workers' Compensation Commission
Varies
(877) 664-2566

TOPIC NO.
1003
Level 2 Call Screening
What Is Level 2
Screening?
The DSIA’s Hotline Coordinator and the State Internal Auditor’s judgments,
along with structured guidelines, are used to determine the seriousness of an
allegation and to classify it as either:
Serious or significant, to be investigated within 60 days.
Less significant, to be screened-out.
When Is Level
2 Screening
Performed?
The DSIA performs level 2 Screening within two business days after the call
is received.
Purpose To ensure sufficient information is gathered in order to minimize
investigative efforts and associated costs of investigations for allegations that
appear to be less significant based on established screening criteria.
Process The DSIA Hotline Coordinator screens the hotline case based on
established criteria and completes the Screening Sheet, which indicates
whether the case met the criteria for further investigation, following the
steps listed below:
Step Description
1 The DSIA investigators give all new cases to the Hotline Coordinator.
2 The DSIA Hotline Coordinator prepares the screening sheet and decides
whether an investigation is justified based on the screening criteria.
3 The DSIA Hotline Coordinator denotes on the screening sheet the
results of the screening and provides the screened out cases and the
screening sheet to the State Internal Auditor.
4 The State Internal Auditor reviews and approves/disapproves the DSIA
Hotline Coordinator’s decision regarding the screened out case, and
documents his decision on the screening sheet. He initials and dates the
sheet.

TOPIC NO.
1003
Step Description
5 Screened out cases are distributed to the Internal Audit Directors on a
monthly basis and may be investigated at the directors’ discretion. If a
screened out case is investigated, the director is required to follow
established hotline case investigative procedures. The original
Investigative/Complaint Sheet and Screening Sheet are filed by case
number in the hotline file.
6 Cases meeting the screening criteria are assigned to the respective
agency’s Internal Audit Director/Hotline Coordinator within two
business days.
Screening
Methodology
The following methodology is used for performing the Level 2 screening and
deciding if a case warrants an investigation.
Criteria Methodology Action
Scope A case should not be normally referred
for investigation unless the DSIA is
certain that the allegation is within the
scope of the Hotline.
Determine if the subject or target of the
allegation is identified. If not, the case will
probably be screened out.
If the subject of the complaint is not clearly
identified, it is generally not practical to
conduct an investigation
Seriousness If there is an alleged immediate threat to
life or state property or an alleged
violation of federal or state law, the
case will usually be referred for
investigation.
An alleged violation of statewide policy
will be considered for referral,
depending on the other criteria.
Consider the seriousness of the allegation.
Does the complainant allege a violation of
law, policy, or procedure?
The violation of a law would rank as a
more serious issue than the deviation from
an agency procedure.

TOPIC NO.
1003
Materiality Allegations of explicit loss of state
funds or property, abuse of state time or
property, or loss of productivity or
inefficiency may be referred for
investigation depending on the other
criteria.
Generally, those allegations with an
estimated loss of $2,000 or more will be
referred for investigation if a sufficient
level of detail is provided.
Normally, estimated losses of less than
$200 will not be referred for investigation
unless other criteria warrant an
investigation.
Those cases with estimated losses between
$200 and $2,000 or those cases whose
losses are not estimated will be referred
based on a case-by-case review.
Timing Generally, if the time elapsed since the
alleged wrongdoing occurred has been 2
years or more, the case will not be
referred for investigation.
The frequency of the alleged
wrongdoing will be considered with
other criteria to determine if an
investigation is necessary.
Consider the timing and frequency along
with other criteria.

TOPIC NO.
1003
Level of
Detail
If the subject of the allegation is not
identified and detailed information is
not provided and documentation is not
provided or identified, the case usually
will not be referred for investigation.
Determine the amount of tangible evidence
submitted or identified by the complainant.
For example, copies of an official document
such as a timesheet, payroll check,
purchase order, vendor invoice, computer
listing, memo on letterhead, or journal
entries that show wrong doing greatly
support the credibility of the allegations.
Determine the degree of detail and
specificity contained in the allegation.
Did the complainant provide the date,
nature, timing, description, name,
location, method of concealment, or
dollar amount of wrongdoing?
The more details provided the more
credible the allegation.
Related
Issues
If the caller states that the allegation has
been previously investigated and found
to be unsubstantiated, the case will not
normally be referred for investigation
unless the caller is able to provide
additional information or a significant
amount of time has elapsed since the
initial investigation.
If the allegation concerns a function that
has a strong probability of adverse
publicity, the case may be referred for
investigation.
Compare the complaint to any other hotline
complaints made of a similar nature in the
past 6 months.
If these cases were found to be
unsubstantiated, determine whether any
new information is contained in the new
complaint. If not, the case should be
considered for screening out.
Try to determine the quality of previous
investigations and the credibility of the
caller.

TOPIC NO.
1003
Illustration of Level 2 Screening Sheet
Division of State Internal Audit
State Employee Fraud, Waste, and Abuse Hotline
Level 2 Call Screening Criteria
Case #: _______________ Initials: __________________ Date: ____________
I Scope:
Does the allegation fall within the Hotline parameters? No -Stop Uncertain Yes
II Seriousness:
Is there an immediate threat to life or state property?
Is there an alleged violation of Federal or State Law?
Is there an alleged violation of State or Agency Policy?
No
No
No
Uncertain
Uncertain
Uncertain
Yes
Yes
Yes
III Materiality:
Is there an allegation of explicit loss of State funds or property?
Is there an allegation of abuse of State time or property?
Is there an allegation of loss of productivity or efficiency?
Total estimated amount of alleged loss, if quantifiable. If none,
check here: __ NQ
No
No
No
<$200
Uncertain
Uncertain
Uncertain
$200 - $2,000
Yes
Yes
Yes
>$2,000
IV Timing:
How frequently has the alleged wrongdoing occurred?
Time elapsed since the wrongdoing occurred?
Once
> 2 Yrs
Several times
1 month - < 2 Yrs
Continuously
On-going
V Level of Detail:
Is the subject/agency/function identified?
Did the caller provide dates, times, witnesses, description,
location, method of concealment?
Was any documentation provided or identified?
No
No
No
Some id provided
Some data provided
Some identified
Name/Title
Very detailed
Evidence provided
VI Related Issues:
Did the caller report this elsewhere?
Any other complaints of a similar nature reported within past
12 months?
Is the allegation a topic with a risk of adverse publicity?
No
No
No
Reviewed by
objective parties
Yes, unsubstantiated
Low
Reviewed by
involved parties
Yes, in progress or
substantiated
High
Case Reviewer Recommendation: ____ No Investigation ____Investigate 60-Days
Review Comments:
_____________________________________________________________________________________________________________________
_____________________________________________________________________________________________________________________
____________________________________________________________________________________________________________
State Internal Auditor Approval: Yes ____ No ____ Initials: _______ Date: _______
Comments: ________________________________________________________________________________________________________
__________________________________________________________________________________________________________________

TOPIC NO.
1004
Topic: State Employee Hotline – Case Assignment Date: January 2012
Assignment of Hotline Cases
Background
Policy The DSIA uses the statewide network of internal auditing programs and
agency hotline coordinators to investigate the validity of hotline allegations
(except for allegations investigated by the DSIA) and to ensure that
appropriate corrective actions are taken to rectify those situations where
fraud, waste, or abuse were identified.
Methodology Used to Assign Cases for Investigation
Process The DSIA assigns cases as follows:
Step Description
1 Within 2 business days of receipt of the hotline call, the DSIA reviews and
evaluates the seriousness of the allegation using a structured screening process.
2 The DSIA decides who shall conduct the investigation.
3 The DSIA assigns the case to either:
an Agency Internal Audit Program,
an Agency Hotline Coordinator, or to
the DSIA.
4 For cases assigned to the DSIA, the DSIA Hotline Coordinator assigns the case
to a DSIA Investigator and notifies the State Comptroller as to why the case has
been assigned to the DSIA.
5 For cases assigned to others, the DSIA prepares a transmittal letter to the
respective Agency’s Internal Audit Director (or Hotline Coordinator) and
attaches a copy of the Hotline Investigative/Complaint Sheet.
6 The DSIA makes a copy of the transmittal letter and attachment.
7 The DSIA states in the transmittal letter that there is a 60-day (calendar)
reporting requirement. (Note: This reporting requirement also applies to
investigations conducted by the DSIA.)
8 The DSIA mails the hotline transmittal letter and any attachments to the agency
via U. S. mail and marks the envelope “Confidential.” Hotline documentation
may be e-mailed provided the e-mail is encrypted.

TOPIC NO.
1004
Step Description
9 A copy of the Transmittal Letter is provided to the DSIA Hotline Coordinator,
who secures it along with the Hotline Investigative/Complaint Sheet in a locked
filing cabinet.
Who Conducts
The
Investigation?
The DSIA decides who shall conduct a hotline investigation based on the
following:
.
If … Then the Hotline
investigation is
assigned to the…
Comment
The subject of the
allegation involves an
agency head or the agency
Internal Audit Department.
DSIA The DSIA also investigates:
Other officials as the
circumstances warrant.
Note: The DSIA can also
investigate any case at its
discretion.
Agency does not have an
Internal Audit Program or
an Agency Hotline
Coordinator.
DSIA
The agency has only a
designated Hotline
Coordinator.
Agency Hotline
Coordinator
Heads of agencies that
do not have an internal
auditing program have
designated a high-level
individual within the
agency to coordinate
the DSIA’s
investigation and
resolution of
complaints directed at
the respective agency.
Depending on the complexity
of the allegation, DSIA may
assist and/or supervise the
Agency Hotline Coordinator in
the investigation.
Depending on past
performance of the Hotline
Coordinator, DSIA may
choose to conduct the
investigation.

TOPIC NO.
1004
If … Then the Hotline
investigation is
assigned to the…
Comment
All other cases Agency Internal Audit
Program
Exception, the DSIA may
conduct the investigation if:
The allegation is very
serious and/or time
sensitive.
Requested to do so by the
Internal Audit Director or
Agency Head.
It involves more than one
state agency.
Note: The DSIA may
investigate any case at its
discretion.

TOPIC NO.
1004
Cases Assigned to Agency Internal Audit Directors
Large State
Agencies
The DSIA recognizes that in some large agencies with locations throughout
the Commonwealth, the Internal Audit Director may delegate hotline
investigations to other responsible members of the management team or
through contracts with private firms.
Investigations
Delegated To
Others
For cases delegated by the Internal Audit Director to other responsible
members of the management team or through contract to a private firm, the
Internal Audit Director shall:
Ensure that others conduct hotline investigations in the same confidential
manner as those conducted by the internal auditors.
Ensure that the person is in a position to be objective and unbiased.
Remain ultimately responsible to the DSIA for the proper conduct of the
investigations.
Review the work performed by others and provide a conclusion as to
whether or not the allegation(s) was/were substantiated.
Approve the objectives and questions that need to be answered or develop
them and provide that information to the investigator.
Ensure that the person conducting the investigation is properly trained in
how to conduct a hotline investigation.
An important consideration in conducting an investigation is determining
how much information to provide to those outside the investigative
process. Those involved in the investigative process must be familiar
with investigative techniques, confidentiality requirements, and hotline
policies. If sufficient investigative personnel are not available, the
Internal Audit Director may consider delegating tasks without providing
the sensitive information such as the allegation, investigative methods,
and so on.
The IA Director will ensure that the person conducting the investigation is
familiar with the hotline policies and procedures.

TOPIC NO.
1004
Investigators’ Responsibilities
Agency
Responsibility
Agency Internal Audit Directors and Agency Hotline Coordinators are
responsible for conducting Hotline investigations. They shall not be
restricted, limited, or interfered with by anyone in the conduct of hotline
investigations.
The DSIA’s
Role
The DSIA may participate in the agency’s hotline investigation, if warranted
by the nature of the allegation, or if the agency head or Internal Audit
Director requests the DSIA’s participation.
Agency
Internal Audit
Directors’
Responsibility
Agency Internal Audit Directors shall maintain confidentiality over hotline
documents in order to preserve the integrity of the hotline program.
Confidentiality Hotline investigations will be undertaken in a confidential manner and related
reports and correspondence will not be distributed to anyone other than the
investigator or the agency head without the consent of the DSIA.
Copies of memorandums, reports, etc. pertaining to hotline investigations will
only be provided to the individual assigned to conduct the hotline
investigation and all documents must be marked as Confidential State
Employee Hotline Documents.
Agency Audit Programs shall not share the Hotline Investigative/ Complaint
Report with anyone except the individual who is conducting the investigation.

TOPIC NO.
1004
Hotline Investigative/Complaint Report
Security and
Concerns Over
the Hotline
Investigative/
Complaint
Report
The DSIA believes the information contained on the Investigative/Complaint
Report will compromise the caller’s identity because:
The DSIA investigators prepare the Hotline Investigative/Complaint
Report verbatim from the caller’s description of the situation.
Confidential information is contained in the Hotline
Investigative/Complaint Report such as individuals who witnessed the
alleged fraud, waste, or abuse.
Other information such as the time and date of the call can provide clues
to the caller’s identity.
Confidentiality The DSIA assures callers that they will be anonymous and steps are taken to
protect their identity. The DSIA takes precautions to ensure that the identities
of State employees who report alleged fraud, waste, or abuse to the hotline
are not found out.
The Hotline Investigative/Complaint Report is handled by the DSIA under the
strictest level of confidentiality and is marked “Confidential State Employee
Hotline Documents”. Agency internal audit programs must provide the same
level of confidentiality over hotline documents in order to maintain the
integrity of the Hotline program.
Instructions That
the DSIA
Provides to
Investigators
Agency Internal Audit Directors and others involved in hotline Investigations
will not share the Investigative/Complaint Report with anyone except those
individuals who are conducting the investigation.
If an investigator deems that it is necessary for investigative purposes to
disclose the nature of the allegation(s) to the target, they may do so by
providing them with a summary of the allegation(s). However, they should
be careful not to provide any information that would compromise the caller’s
identity. The allegation should only be disclosed to the target when sufficient
evidence has been gathered so as to be confident that the allegation is
substantiated.

TOPIC NO.
1004
Hotline Transmittal Letters
How are cases
assigned to the
investigator?
The DSIA uses the following types of transmittal letters to assign cases for
investigation. A copy of the Hotline Investigative/Complaint Report is
attached to the transmittal letter.
Type of Case Example of a Transmittal Letter
Assigned Case DATE: Current
TO: Agency Internal Audit Director
FROM: Tim Sadler
Audit Manager
SUBJECT: State Employee Fraud, Waste, and Abuse Hotline
The attached complaint regarding Case No. XXXX was received by this
Division and needs to be investigated by your unit.
In connection with the previous instructions provided to you and your agency
head about the hotline, a report should be sent to this Division within 60 days.
Also, if you need additional information to investigate these cases, you should
notify this Division within 10 days of the date this Division took the allegation
so that we can make further contact with the complainant. You should contact
me at (804) 225-3106 if you need more information. Hotline Procedures and
Policies can be found at the following website:
http://www.doa.virginia.gov/DSIA/HotlinePoliciesManual.pdf. Please ensure
that all required reporting elements are included in your report.
Since strict confidentiality must be maintained over the entire investigation,
you should make sure that all documents, working papers, notes, and reports
dealing with this investigation are marked "Confidential State Employee
Hotline Documents." In addition, all written communication with this
Division about this or any other hotline case should be similarly marked and
sent through the U.S. mail. This is to ensure that if any tampering occurs, the
violator can be prosecuted to the maximum extent. All envelopes related to
hotline cases should be marked "Confidential" when sent to this Division. If
there are any questions regarding this matter, please contact me.
Attachment

TOPIC NO.
1004
Type of Case Example of a Transmittal Letter
Screened-Out
Case DATE: Current
TO: Agency Internal Audit Director
FROM Tim Sadler
Audit Manager
SUBJECT: State Employee Fraud, Waste, and Abuse Hotline
As you are aware, we established a structured call screening process to reduce
time and expenses associated with hotline calls that appear to have little or no
substance. During the past month, this Division received the attached
complaint(s), Case No. XXXX. While these allegations meet the hotline's
definition of fraud, waste or abuse, they do not meet the criteria used by this
Division to determine which calls warrant investigation through the hotline
program. We have classified these cases as "SCREENED-OUT" and no
investigation by your unit is required.
All screened-out cases involving your agency are provided to you for
informational purposes on a monthly basis. You do not need to provide a
response regarding this/these case(s). However, if you decide to investigate
this matter/these matters, you should follow the procedures established by this
Division for conducting hotline investigations.
If there are any questions regarding this matter, please contact me at (804)
225-3106, ext 23.
Attachment

TOPIC NO.
1004
Reporting
Reporting
Requirements
The DSIA requires a written report within 60 calendar days. The report may
be submitted to the DSIA using encrypted e-mail.
Extensions to
Reporting
Deadlines
The DSIA generally will grant extensions to reporting deadlines at the
Internal Audit Director’s or Hotline Coordinator’s request.

TOPIC NO.
1005
Topic: State Employee Hotline – “Call-Back” Calls Date: January 2012
“Call-Back” Hotline Calls
Introduction
Background Hotline callers sometimes call back regarding cases that they previously
reported. They usually call back for one of four reasons:
Caller’s case number was on the after hours call-back tape.
Caller wants to know the results of the investigation.
Caller wants to add some additional information to the case.
Caller is calling back after three weeks, per our instructions, from the date
he/she made the initial call.
The remainder of the call-backs usually ask one of the following questions:
How was the investigation undertaken?
Who conducted the investigation?
How long did/does the investigation take?
Was the case assigned for investigation? If not, why not?
Was the allegation substantiated?
What disciplinary action was taken against the subject of the allegation?
It appears that nothing happened as a result of the call. Why not?
Has the investigation been completed?
Caller wants to mail in some additional information to the DSIA.
How much longer will the investigation take?
The allegation continues to occur.
The DSIA procedures for responding to the above questions are
presented in this section.

TOPIC NO.
1005
Policy If the caller can provide sufficient information about the case to enable the
DSIA investigator to identify the caller as the complainant, the DSIA Hotline
Investigators may disclose that the investigation is either in progress or is
completed.
The DSIA Hotline Investigators shall not disclose any further information
about hotline cases by telephone. If a caller makes any further inquiries
about a hotline investigation, the caller shall be directed to submit a written
request to the State Internal Auditor to obtain answers.

TOPIC NO.
1005
Hotline After-Hours Telephone Recording
Introduction The after-hours, recorded message left by the DSIA staff on the hotline
telephone line provides a mechanism for hotline investigators to ask hotline
callers additional questions about their allegations.
Call-Back
Process
The following process is currently in place for obtaining additional
information from hotline callers.
Step Description
1 On the initial call, the DSIA instructs the hotline caller to call back no sooner than
three weeks after the initial call, and when calling back to check the after-hours
messages.
2 The DSIA informs the applicable agency internal audit director of the initial call within
2 business days. At this time, the DSIA instructs him/her to let the DSIA know within
10 business days, if he/she has additional questions to ask the caller.
3 When hotline investigators have additional questions, the DSIA places the case number
on the after-hours message.
4 The caller calls back after three weeks from the initial call date and responds to the
investigator’s questions.
5 The DSIA relays the information to the investigator.

TOPIC NO.
1005
How a “Call-back” Hotline Call Is Answered
How To
Answer Call-
Backs
The following process is used by the DSIA:
Step Who Does it … Description
1 DSIA Investigator Investigator answers the hotline and asks caller if they are
calling back about a case they previously reported.
2 DSIA Investigator If no, see Accepting a Hotline Call. If yes, go to Step 3.
3 DSIA Investigator Ask for the case number and then check the hotline database
and “Call-back” file to see if the case has additional questions
to be answered.
4 DSIA Investigator If the case number is listed on the call-back tape, refer to the
first example under DSIA Procedure for Responding to
Caller’s Questions (Page 1005-5)
If the case number is not on the call-back tape, then ask the
caller how you can help him/her.
5 Caller Caller explains why s/he is calling back about a specific case.
See examples provided earlier.
6 DSIA Investigator The DSIA provides assistance in response to the caller’s
questions. Refer to the specific questions listed in the
following sections.

TOPIC NO.
1005
DSIA Procedure for Responding to Caller’s Questions
Confidentiality Prior to disclosing any information about a hotline case, the DSIA
Investigator shall ask the caller to provide some details about the case which
would only be known by the original caller, such as:
When was the case reported?
What is the subject of the investigation?
What state agency was involved?
Process for
Handling
Various Types
of Call-Backs
Depending on the reason the caller is calling back, the DSIA Investigator
shall handle the call as follows.
If… Then... Process . . .
The purpose of
the call is
because the
caller’s case
number was on
the call back
tape
Retrieve the questions.
Cases on the Call-Back Tape are
filed in the hotline case files
marked "Cases on Overnight
Tape". A note will be attached to
the case containing the specific
questions to be asked.
Contact the investigator to let
them know that the additional
information was received.
Delete the hotline case number
from the call-back tape.
Document the caller's response
on the Investigative/Complaint
Sheet, below the questions.
Provide the form to the
Hotline Coordinator.
Send the form to the IA
Director which provides
additional information to help
in the investigation.

TOPIC NO.
1005
The caller wants
to know the
status of the
investigation of
the case.
Review the case write-up in the
hotline database.
Once you are satisfied that the caller
is the bona fide complainant, disclose
that the case is either “in progress” or
“completed”.
No other information shall be
provided to the caller.
No action is required.
Caller wants to
add information
to the existing
case.
Review the case write-up in the
hotline database.
Once the investigator is satisfied that
the caller is the bona fide
complainant, take the new
information.
Write the additional information
on an Investigative/Complaint
Sheet.
Provide the
Investigative/Complaint Sheet to
the Hotline Coordinator.
Caller is calling
three weeks after
the initial call
was made, per
our instructions.
Review the hotline database and
“Cases on Overnight Tape” file to
determine if the caller’s number is
included. If so, then follow the call-
back process.
If not, advise the caller that we do
not have any further questions for
him/her.
Refer to the first type of call-back
process documented in this
section.
Caller wants to
know about the
manner in which
the case was
investigated.
Advise the caller that hotline
investigations are conducted in a
confidential manner and that
investigative methods are not generally
disclosed.
Refer the caller to the Hotline
Coordinator or the State Internal
Auditor, if the caller is not
satisfied with the handling of the
case.
Caller asks who
conducted the
hotline
investigation?
Advise the caller that investigations are
conducted in a confidential manner
under the statewide network of internal
audit programs under the direction of the
DSIA. We do not disclose the name of
the investigator.
satisfied.

TOPIC NO.
1005
Caller asks if
his/her case was
assigned for
investigation?
If not, why not?
Review the hotline database.
Respond that the case was either
assigned for investigation or
screened out.
If the case was screened out, explain
the reason why it was not
investigated to the caller. Advise the
caller that if s/he wishes to provide
more details about the allegation, we
will re-consider investigating the
case.
If not investigated and the caller
wants to add information,
complete a case continuation
sheet.
Provide the new information to
the Hotline Coordinator. (The
new information will be re-
evaluated to determine if an
investigation is warranted. Refer
to the Screened Out Section.)
Caller asks if the
allegation was
substantiated?
Once you are satisfied that the call is
the bona fide complainant, you may
disclose that the case is either in
progress or completed.
No other information shall be
provided to the caller unless
authorized by the Hotline
Auditor
.
satisfied.
Caller asks what
disciplinary
action was taken
against the
subject of the
allegation?
Advise the caller that investigations are
conducted in a confidential manner and
that the results of the investigation are
not generally disclosed. However, s/he
may request the information under the
Freedom of Information Act.
satisfied.

TOPIC NO.
1005
Caller states that
nothing
happened as a
result of their
call. Why not?
Review the case write-up in the hotline
database.
If the case is still under
investigation, advise the caller that
any necessary corrective action will
be recommended once the case is
completed.
If the allegation was
unsubstantiated, document the
caller’s concerns that the alleged
fraud, waste, or abuse is still
occurring and refer the information
to the Hotline Coordinator or the
State Internal Auditor so s/he can
determine if a new case should be
opened.
If the case was substantiated,
consider whether or not the caller’s
new allegation should be issued a
new case number. Explain that it
may take time for corrective action
to be noticeable.
Document the conversation on an
Investigative/Complaint Sheet.
Provide the
Investigative/Complaint Sheet to
the Hotline Coordinator.
Either a new case number is
assigned or no action is taken.
Advise the caller to call back
again in two weeks if corrective
action has not been observed.

TOPIC NO.
1005
Caller wants to
mail some
additional
information to
the hotline.
Provide the following directions:
Mail via U S mail to:
FWA Hotline
P. O. Box 1971
Richmond, VA 23218-1971
Mark the envelope "Confidential."
Write the case number on the
documents.
Advise the caller that any documents
provided become the property of the
DSIA.
Request the caller to follow up via
the Hotline to ensure that the DSIA
received the documents.
No further action is required.
Caller wants to
know how much
longer will the
investigation
take?
Advise the caller that hotline cases may
take up to 60 days to investigate.
Specific information about the length of
time involved in the investigation cannot
be disclosed.
.
No further action is required.
Caller wants to
add a new
allegation.
Take the allegation, but issue a new case
number.
Follow the new case procedures.

TOPIC NO.
1006
Topic: State Employee Hotline – Investigations Date: January 2012
Conducting a Hotline Investigation
Overview/Background
Purpose To provide guidance and suggestions to internal auditors and others,
including the DSIA, who conduct hotline investigations.
Policy All investigations will be conducted thoroughly and with due diligence using
investigative and interview techniques appropriate to the situation. The DSIA
is available to assist in the development of appropriate investigative steps and
interview questions and techniques. All investigative procedures will be
documented and maintained as indicated below. The DSIA may, from time to
time, review the investigative work to determine the quality and
appropriateness of investigative work, and to provide suggestions for
improvement in future investigations.
Objectives of a
Hotline
Investigation
An investigation should be undertaken to:
Determine if there is any validity to the allegation, and whether fraud,
waste, or abuse occurred prior to reporting to, or alerting management of
the potential fraud, waste, or abuse. Internal auditors may want to make
the agency head or applicable management aware that they are conducting
a hotline investigation but not provide the specifics of what is being
investigated.
Determine how the fraud, waste, or abuse took place and the conditions
and circumstances that contributed to the fraud, waste, or abuse.
Determine that corrective actions are taken to prevent future instances of
the fraud, waste, or abuse from occurring and/or to remediate the
condition, such as recovering the loss.

TOPIC NO.
1006
Security over Hotline Investigations
Confidential
Stamp
Strict confidentiality must be maintained over the entire hotline
investigation. All documents, work papers, notes, and reports associated
with this investigation shall be marked Confidential State Employee
Hotline Documents.

TOPIC NO.
1006
Confidentiality Investigative notes, interview notes, and other information relating to
investigations will not be shared, discussed, or given to anyone without
an absolute need to know.
Strict confidentiality will be maintained over all hotline documents,
notes, etc, at all times.
All hotline documents will be secured at all times, when not in use.
As a general rule, hotline cases should not be discussed with anyone,
except for the DSIA Hotline Coordinator, the State Internal Auditor, or
others involved in the investigation. However, some discussions about
hotline cases are necessary. It may be necessary to notify the agency
head, or their designee, that an internal auditor will be conducting a
hotline investigation or to discuss aspects of a case with agency
management to effect corrective actions. In such instances, investigators
should disclose no more information than is absolutely necessary to those
outside of the investigative process.
Hotline investigations should be undertaken in a confidential manner and
related reports and correspondence will not be circulated to individuals
who are not directly involved in the conduct of the investigation.
Copies of memorandums, reports, etc. pertaining to hotline investigations
will only be provided to individuals who are conducting the hotline
investigation and will be marked as Confidential State Employee Hotline
Documents.
Agency Internal Audit Directors shall not share the Hotline Investigative/
Complaint Report with anyone except the individual(s) who are
conducting the investigation. These reports must never be shared with
witnesses or the target of the investigation.
Summary reports and support documents may be issued to agency
management and/or grievance hearing officers to effect and uphold
corrective and/or disciplinary actions. Contact the DSIA for guidance on
what specific information may be released.
To ensure confidentiality, under no circumstances should the
investigative case number be disclosed to anyone other than the caller,
head of internal audit, investigators, or hotline coordinator. Case
numbers may appear in electronic work papers and menus that may only
be accessed by the assigned investigator and/or supervisor.

TOPIC NO.
1006
Written
Communication
with DSIA
Written communications with the DSIA about hotline cases are to be sent
primarily through the U.S. mail unless using encrypted e-mail. This is to
ensure that if any tampering occurs, the violator can be prosecuted to the
maximum extent.
All envelopes containing hotline information should be marked
"Confidential" when sent to the DSIA.
Under certain circumstances communications may be sent over
electronic media or by fax. Contact the DSIA prior to using these
methods of communication.
Custodian of
Hotline
Documents
State Internal Audit Directors shall maintain all information supporting
investigations performed by them in a secure location, including
encrypted electronic work paper databases.
All such information, documentation, etc., is the property of the DSIA and
shall be so identified.
The DSIA may request that supporting information accompany
investigative reports.

TOPIC NO.
1006
Assignment of Hotline Case Investigations
Policy Hotline cases are assigned by the DSIA to the respective agency Internal
Audit Director in cases where the agency has an internal audit program.
Heads of agencies that do not have an internal audit program have designated
a high-level individual within the agency to coordinate the DSIA’s
investigation and resolution of complaints directed at the respective agency.
Exception Cases where the agency head or a member of the internal audit staff may be
the subject of the investigation are investigated by the DSIA.
Hotline
Coordinators
Heads of agencies that do not have an internal auditing program should
designate a high-level individual within the agency to conduct investigations
or to coordinate the DSIA investigation and the resolution of complaints
involving the respective agency. This individual should have some
background or training in conducting administrative investigations. The
individual’s name, position within the agency, address, and telephone number
should be provided to the DSIA each year.
Large State
Agencies
The DSIA recognizes that in some large agencies with locations throughout
the Commonwealth, the Internal Audit Director may delegate hotline
investigations to other responsible members of the management team or may
contract them out to a private firm.

TOPIC NO.
1006
Investigations
Delegated to
Others
For cases delegated by the Internal Audit Director to other responsible
members of the management team or to a private firm, the Internal Audit
Director shall:
Ensure that others conduct the hotline investigations in the same
confidential manner as those conducted by the internal auditors.
Ensure that the person is in a position to be objective and unbiased.
Remain ultimately responsible to the DSIA for the proper conduct of the
investigations.
Review the work performed by others and provide a conclusion as to
whether or not the allegation(s) was/were substantiated.
Develop the objectives of the investigation and the questions that need to
be answered and provide that information to the investigator.
Ensure that the person conducting the investigation is properly trained in
conducting a hotline investigation.
Carefully consider how much information to provide to those outside the
investigative process. Those involved in the investigative process must be
familiar with investigative techniques, confidentiality, and hotline
policies. If sufficient investigative personnel are not available, the
Internal Audit Director may consider delegating tasks without providing
sensitive information such as the allegation, the investigative methods to
use, and so on to the non-investigative personnel.
Ensure that the person conducting the investigation is familiar with these
policies and procedures.

TOPIC NO.
1006
Target of the Allegation
When Should
the Target Be
Advised of the
Allegation?
Investigators should avoid alerting the target of the allegation until they have
sufficient evidence to corroborate the allegation. If the allegation is
corroborated by reasonable evidence, the investigator shall interview the
target of the allegation.
What Are the
Rights of the
Target of the
Allegation?
Remember that an anonymous tipster initiated the investigation and it could be
false. Therefore, the investigator should conduct a certain amount of
investigative work to determine whether or not the allegation appears to be
substantiated prior to interviewing the target. You should maintain strict
confidentiality to protect the reputation of the target, especially for unfounded
allegations. Be cognizant of the rights of the target, however, bear in mind
these are administrative and not legal proceedings. For example, there have
been instances where the target of an investigation retained legal counsel
following an interview and requested legal representation in subsequent
interviews. The DSIA permitted counsel to observe the interview on the
condition that the counsel remained silent during the interview. Legal counsel
was thus constrained from advising the client during the interview. Therefore,
the target of the investigation may have legal counsel present, if desired, as an
observer only. The investigator, in conjunction with advice from the Office of
the Attorney General, should determine when or if agency legal counsel is
necessary under such circumstances.

TOPIC NO.
1006
Structure of a Hotline Investigation
Overview of a
Hotline
Investigation
The following is the structure of a hotline investigation:
Objective: Did fraud, waste, or abuse (of state resources) occur?
Step Action Comments/Suggestions
1 Review the Hotline Investigative/
Complaint Sheet to ascertain what
alleged fraud, waste, or abuse
occurred and who was the target of
the investigation.
Highlight the allegation (s) within the
Investigative/Complaint Sheet.
Some examples of hotline allegations are:
theft of cash, diverting cash receipts, financial
fraud, lapping of accounts receivable payments,
stealing or forging checks, theft of inventory or
equipment, overstated work hours, leave abuse,
misappropriation, falsified travel
reimbursement vouchers, unnecessary
purchase/spending, unnecessary or excessive
travel, embezzlement, waste, mismanagement,
conflicts of interest, manipulation of financial
records, contract and procurement fraud,
malfeasance, misappropriation of assets,
misuse of funds, bribes, kickbacks,
misstatement, forgery, and other irregularities.
2 Determine if any further information
is needed to conduct the
investigation. If so, contact the
DSIA Hotline Coordinator.
The DSIA will place the hotline case number
on the call-back tape. Once the complainant
calls back, the DSIA will gather the additional
information and provide it to the Internal Audit
Director.
3 Research what law, regulation, state
and/or internal agency policy
governs the allegation.
State references should include a review of the
CAPP manual, the PMIS, and the DHRM
policy manual at a minimum.
4 Set the scope of the investigation,
considering the evidence identified
or provided by the complainant such
as: documentation, witnesses,
method of concealment, date of
occurrence, etc.
Develop investigative strategies to gather
sufficient information about the details
provided in the complaint to
substantiate/refute material allegations.
Decide what investigative techniques shall
be used to corroborate or refute the
allegations. Some examples of how to
investigate allegations are provided below.

TOPIC NO.
1006
5 Prepare a work plan. An effective work plan will:
Guard against omitting important steps.
Help the auditor perform an efficient
investigation.
Keep the investigation organized and
focused.
6 Conduct a discrete and thorough on-
site investigation to obtain evidence
and other documents to establish a
reasonable basis for any opinion
rendered.
Avoid tipping off the suspect (target) during
the early stages of the investigation. You
may accomplish this by reminding those
you interview that they should keep the
information discussed confidential. When
requesting information consider requesting
additional information to conceal the
identity of the target, (for example request
travel vouchers for W, X, Y and Z instead
of just X.) Never divulge the name of the
target of the investigation. That is, while it
may be necessary to ask about X’s
activities, never tell a witness that X is the
target of a hotline investigation.
Be wary of receiving misleading
information.
Be careful that outsiders do not find out the
nature of the hotline investigation.
Remember that an anonymous tipster
initiated the investigation and it could be
false. You should maintain strict
confidentiality to protect the reputation of
the target, especially for unfounded
allegations.
Be cognizant of the rights of the target.

TOPIC NO.
1006
6
cont.
Gather evidence. Trace accounting entries,
recognize patterns in documents, search
electronic databases, identify documents
that appear forged or reconstructed, conduct
interviews of witnesses and suspects, and
maintain a high level of professional
skepticism.
7 Evaluate evidence obtained to date
and decide whether additional
information is needed to meet the
investigation objective. If necessary,
search for and accumulate additional
evidence.
If the information gathered does not support the
hotline allegations, discontinue the
investigation.
(Remember the Hotline Executive Order states
that investigations be undertaken in the most
cost efficient manner.)
8 Evaluate the evidence and determine
what it means in relation to the
suspected fraud, waste, or abuse
activity. Carefully assess the
relevance of all gathered evidence.
Gathered evidence should enable the
investigator to answer the following questions:
Did fraud, waste, or abuse occur?
When did it occur?
What assets or accounts were involved?
How was it committed?
What is the amount?
9 Reach a conclusion based on the
evidence gathered on whether fraud,
waste, or abuse occurred and, if
necessary, make recommendations to
prevent improper incidents from
recurring.
Be alert to opportunities such as internal control
weaknesses that could allow fraud to occur. If
significant internal control weaknesses are
detected, consider performing additional tests
to detect other fraudulent transactions.

TOPIC NO.
1006
10 If fraud, waste, or abuse occurred:
Make recommendations to
agency management to rectify the
fraud, waste, or abuse identified
in the hotline allegation.
As considered necessary,
Make recommendations to
prevent future similar
occurrences of fraud, waste, or
abuse from occurring.
While recommendations that
appropriate disciplinary actions
be taken may be included, it is
within management’s authority to
determine final disciplinary
action.
Make recommendations for
recovery of any monies due to
the Commonwealth.
If there is a reasonable suspicion that
a fraudulent transaction occurred,
refer to the Code of Virginia Section
30-138 for reporting requirements.
Report information to the DSIA following
established reporting guidelines. (Refer to
Reporting section/Topic No. 1007).
The DSIA does not prescribe any specific
reporting guidelines for the Internal Auditor
to follow when reporting hotline results and
recommendation(s) to agency management.
The Internal Audit Division should provide
hotline recommendations to Senior Agency
Management in the same manner that it
reports other strictly confidential matters.
All reports resulting from hotline
investigations are to be marked as
“Confidential State Employee Hotline
Documents.”
A copy of all reports issued by management
that address hotline recommendations shall
be provided to the DSIA.
The Internal Audit program is the custodian
of all work papers and any other documents
relating to the hotline investigation. (These
documents are to be maintained until the
DSIA informs Internal Audit that the
documents may be destroyed in accordance
with the State Library record retention
guidelines. To maintain confidentiality of
the documents, Internal Audit staff should
perform the destruction of the documents.)
All hotline documents, reports, and other
information relating to a hotline
investigation are the property of the DSIA.
11 Report results of the investigation to
the DSIA, rendering your opinion on
whether or not the allegation was
substantiated.
See reporting section for more details.

TOPIC NO.
1006
Gathering Evidence
How Do I
Determine If
the Allegation
Is Valid?
Various types of investigative techniques are used to gather evidence needed
to substantiate or refute the hotline allegation. Examples follow.
What Evidence
Is Needed?
Sufficient evidence to either confirm or refute the allegation.
What
Investigative
Techniques Are
Used?
Investigators should select the type of investigative techniques based on the
following:
Effectiveness of the method selected; will it likely uncover fraud, waste,
or abuse?
Investigator’s knowledge and comfort in using the method.
Costs of using the method. The selected method may be too expensive
given the potential dollar amount of the allegation.
Ability to gather the evidence without arousing suspicions.

TOPIC NO.
1006
Examples of Types of Evidence
Evidence Definition Examples of Investigative
Technique(s)
Documentary Written evidence on paper or
computer medium.
Examination of records and computer
databases to obtain the documents.
Examinations, recompilations, and
financial analysis of records. Sample
transactions and documents. Extraction
of data from databases.
Testimonial Evidence obtained from the
testimony of individuals
Interviews of witnesses and/or suspects.
Observational Evidence of actions or
behavior seen or heard by
the investigator.
Observing a scene where alleged fraud,
waste, or abuse is expected to occur and
recording observations of physical facts,
acts, movement on paper, tape, or film.
Physical examination and confirmations
with third parties.
Covert surveillance Gathering evidence by
tailing, through electronic
surveillance, and through
undercover operations.
Generally not used for hotline
investigations. Consult with the DSIA
before using this technique.
Other physical
forensic evidence
Gather evidence by using
scientific techniques such as
collecting fingerprints or
analyzing handwriting
samples.
Generally not used for hotline
investigations. Consult with the DSIA
before using this technique.

TOPIC NO.
1006
Additional Information about Gathering Testimonial and
Documentary Evidence
Discovery
Sampling to
Gather
Documentary
Evidence
Use when it is too time consuming or expensive to manually investigate all
documents in an area unless there is evidence that fraud exists. Discovery
sampling allows the auditor to examine fewer than all items in a population
and quantify the risk of error/fraud in the entire population.
Personal
Observations to
Gather
Evidence
Use to observe a location where the allegation occurred. The investigator
makes a log of the date, day, time, and location of observation; the name of
the observer and any witnesses; all movements and activities observed; the
identity of the persons observed; and the time of the occurrence. An example
is watching activity within a warehouse.
Interview to
Gather
Testimonial
Evidence
An interview is a major investigative technique. It is generally a non-
accusatory structured question and answer session held for a specific purpose.
An interview is usually held to obtain new or corroborating information from
neutral or other witnesses who are not suspected of involvement in the alleged
fraud, waste, or abuse. The questions are usually about agency policies,
procedures, and controls and any deviations that they witnessed, and other
details such as who deviated from the policies and procedures, leads or tips
about possible suspects, information about other possible witnesses, the
interviewee’s connection with the target, and any documents received from
the target.
Interrogation to
Gather
Testimonial
Evidence
Interrogation is a carefully controlled and confrontational interview with a
suspect. The purpose is to obtain information from the suspect that is not
obtainable elsewhere, to obtain a confession from a guilty suspect, or to
obtain evidence that the suspect is not involved in the allegation. It is
recommended that two investigators be present so that one can serve as a
witness to the session.

TOPIC NO.
1006
How to Plan an Interview
It is important to remember that your objective is to obtain truthful and complete disclosure with
as little inconvenience to the interviewee as possible. The following steps should be taken:
Step Action
1 Timing: Hold as soon as possible but not before the investigator has gathered
sufficient evidence and information on which to base the interview questions.
2 Advance Notice: The amount of notice given to the interviewee should be
carefully determined. Some investigators like to give the interviewee advance
notice so they can be better prepared to give informed answers and/or gather
any supporting documents. Other investigators do not like to give advance
notice for various reasons, such as the target might find out and coerce or
supply answers to the interviewee. Hostile interviews should be held on a
surprise basis so that the interviewee will have no time to prepare answers.
3 Preparation: The investigator should gather as much information as possible
before the interview, about the allegation, and the person being interviewed.
This will help the interviewer to structure questions.
Physical Location: The interview should be conducted in a confidential,
controlled setting. The room should offer privacy and be away from
interrupting co-workers and other distractions.
Room Arrangement: The investigator should be seated in the place that gives
the best eye contact and proximity to the interviewee. Also, the investigator
should not block the interviewee’s ability to exit the room.
Other Considerations: The investigator should only interview one person at a
time, both for privacy purposes and because one person may influence another.
4 Conducting the Interview:
1. Opening – Perform introductions and state the purpose of the interview.
Do not divulge information that may identify the caller or other witnesses.
2. Middle – Obtain information about the allegation by asking questions.
These types of questions are usually non-threatening and non-
confrontational and are asked to obtain factual and unbiased information.
The questions may be open-ended, closed, or leading.
3. Closing- Ask closing questions to summarize key facts and statements
made during the interview to be sure they are correct. Usually start
with…”Let me summarize what we have discussed…” Give the
interviewee a business card or number to call if they have questions or
follow-up information.
5 Summarize the results of the interview as soon as possible after concluding the
interview.

TOPIC NO.
1006
Interviews –
Other Hints
You should consider the following:
If interviewee is: Then consider:
Friendly (helpful, volunteering
information)
That the interviewee may:
Sincerely want to help.
Be seeking revenge against the
suspect for some other reason
Be trying to deflect the
investigator’s attention.
Offer biased, false, or irrelevant
information.
Neutral That the interviewee provides the
most unbiased information.
Interview the neutral witness
first.
Hostile That the interviewee may:
Be associated with or friends
with the suspect
Need to be persuaded to be
interviewed.
Need to be reminded that they are
not suspected of involvement.
Need to be reminded that the
interview is an important use of
their time.
The interviewer should:
Display a sympathetic and
nonjudgmental attitude.
Minimize facts that can make
someone reluctant to be
interviewed or that can inhibit an
interview.

TOPIC NO.
1006
How Do I
Document the
Interview?
Interview forms are used that contain the name of the interviewee, date, time
and location of the interview and the opening statement that follows.
Questions are asked of the interviewee and their responses are recorded on the
interview form. It is important to take good notes and to record as closely as
possible the interviewee’s responses verbatim. This is one reason for having
two investigators conduct interviews – one can take notes. In some cases,
where the case is sensitive and you want to avoid repudiation by the
interviewee or you believe the responses may be complex, you may want to
tape record their responses. In such instances, request the interviewee’s
consent before recording and have them acknowledge their consent on the
recording before beginning.
Investigators may want to get the interviewee’s signature or initials on the
interview sheets.
Opening
Interview
Statement
The following statement should be read to all interviewees to clarify the level
of confidentiality expected from the interviewee:
We are conducting a confidential review on behalf of the State Employee
Fraud, Waste, and Abuse Hotline in accordance with Executive Order #15.
We will ask you to respond to some questions pertaining to this review and to
provide any other information that you consider relevant. We request that
you not discuss with anyone what we talk about during this interview. If you
do so, you could jeopardize the confidential nature of this investigation. We
ask for this confidentiality in order to protect you, other witnesses, and the
subject(s). The information that you provide to us will be treated in the same
way as any other information gathered during this review. We appreciate
your cooperation and taking the time to meet with us and respond to our
questions.
What Questions
Do I Ask
Witnesses?
Generally, witnesses are asked questions that provide factual information
related to the allegation. The following are interview questions that are
typically asked for different types of allegations.

TOPIC NO.
1006
Type of
Allegation
Typical Questions to Ask Witnesses
Leave Abuse Are alternate work schedules allowed?
Based on your observations, what is the subject’s set work hours?
When does the subject take lunch and breaks?
Physically, are you in a position to observe the subject(s) when they enter or
leave their office? Is anyone else in a position to observe this?
Does the employee arrive late/leave early? If so, how often does this occur
and how long has it been going on? Are there other individuals who may have
observed this?
Can you provide specific dates of leave abuse?
Are there sign-in/sign-out sheets, time clocks, electronic building access
records, or computer log on/off records? Are there any other records available
to determine when the subject arrives or leaves?
If the subject leaves early, do you know where the subject goes?
If surveillance will be conducted, then also ask:
What type of vehicle does the subject drive? Ask for the make, model, color,
and license plate #.
Are there assigned parking spaces? Where does the subject normally park?
Describe the subject. Ask for the approximate height, weight, hair color, etc.
Ask for any available photos of the individual such as from an office party or a
website.
Where does the subject live? Do you know the route they go to/from work?
How do you know whether leave forms are turned in?
Does the subject work extended hours, nights, or weekends?
Is there a compensatory time policy?
Does the agency have a telework policy?
State Vehicle
Abuse
Is the subject permanently assigned a vehicle? If not, how does s/he obtain
access to a state vehicle?
Describe the state vehicle (make, model, color, license plate #).
For what business purpose would the subject need to use a state vehicle?
Does the subject drive the vehicle to and from work? If so, estimate the
approximate distance of roundtrip travel.
If the vehicle is used for personal purposes, how is it used? (Subject drives to
lunch, shops at the mall, etc.) Obtain specific details.
Provide specific dates of when the vehicle abuse occurred and frequency.
If necessary, interview the Fleet Manager.
What is the agency policy regarding vehicle use?

TOPIC NO.
1006
Type of
Allegation
Telephone/
Cell
Phone/Fax
Abuse
Telephone/Cell Phone Calls
What is the process for monitoring telephone calls?
How do you know the telephone calls are not related to state business?
Do you know who the subject is calling and the telephone number called?
Are the phone calls long distance or local calls?
What evidence exists?
Faxes
What fax machine is the subject using (fax number and location)?
What type of documents is the subject sending and/or receiving?
Do you know the fax number the subject is sending/receiving documents
to/from?
Do you have a copy of those documents? If so, please provide.
Purchases Procurement Violations
What was purchased and what was the cost?
Who authorized the purchase?
Have the goods/services been received?
Has the agency paid the vendor for the goods or services?
What account name/number was the purchase charged to?
Private/
Personal
Business on
State Time or
Uses State
Resources
Does the subject have an outside business or part-time job that s/he is working
on while at work?
Describe the nature of the outside or personal business that is being conducted
while at work.
What is the name of the business? Do you have a business card, pamphlet or
any other materials? If so, please provide.
How much time does the subject spend on this business each day? How long
has this been going on?
Is the subject conducting the outside business during state work hours, during
lunch, or after work hours?
Does the subject come in early, work late, have an approved telework
agreement, or work on weekends to make up the time?
What state resources is the subject using for outside business purposes
(computer, copier, paper, fax machine, Internet, etc.)?
Is the subject receiving and/or making telephone calls? If so, to whom? How
do you know the calls are not related to state business?
Do you have any evidence that supports this allegation, such as copies of
documents prepared or faxes?
Does the subject use other staff to assist in the work?

TOPIC NO.
1006
Type of
Allegation
Travel General Questions
What was the date and time of the travel?
What was the travel destination or location of the occurrence?
What was the purpose of the travel?
Did anyone else travel with this individual? If so, please identify.
Was a travel claim filed and reimbursement made?
Computers Unauthorized use of a state computer
Does the subject prepare personal documents on his/her computer?
Is this done on state time, after hours, or during lunch?
Describe the documents that were used or prepared. How much time was
spent using or preparing the documents?
What is the subject of the documents?
Do you have copies of the documents? If so, please provide them to us.
Where are the documents saved (hard drive, diskette, CD, DVD, network)?
Were any other state resources used in preparing these documents, such as a
copy machine or printer?
Internet
Abuse
Does the subject have a separate log-on to access the Internet?
What types of sites does the subject access? Do you know of any specific site
addresses?
Is the Internet access through the agency network or a private service
provider?

TOPIC NO.
1006
Hotline Interview Techniques
The following are some examples of interview techniques used by hotline
investigators to address specific allegations.
Type of
Allegation
Symptoms Detection
Leave Abuse Late arrivals, early departures,
extended lunch breaks
Failure to turn in annual or sick leave
request forms.
Unable to keep up with work load.
Poor performance
Official records indicate little or no use
of annual or sick leave.
No set work hours
Personal Observation
Interview witnesses
Search time and attendance
records for patterns
Monitor time of day of
computer log on/off.
Monitor building access or
parking lot access
Review building access or
parking lot access records.
Abuse of
telephone
Increased volume and duration of
telephone calls
Out of state calls
Poor system of reviewing and
monitoring employee telephone calls
No internal telephone policy
Search telephone records
Interview witnesses
Search telephone message
pads, if applicable
Obtain records from the
VITA/contracted vendor as
needed
Identify parties called as
provided by the
VITA/contracted vendor
Theft of Cash Cash receipts differ from normal or
expected patterns.
Unusual amounts or patterns of cash
overages/shortages.
Increased use of the petty cash fund or
the inappropriate use of petty cash.
Conduct surprise cash counts
Make observations
Interview witnesses
Review supporting
documentation, etc.

TOPIC NO.
1006
Type of
Allegation
Symptoms Detection
Unfair Hiring Poor or insufficient documentation of
the stages of the hiring process, such as
the screening of applications.
Qualified applications are screened out
so that the favored applicant scores
high enough for an interview.
Documents are missing, such as
interview notes.
Screening criteria are not related to the
position description.
Examination of personnel and
recruiting records.
Redo the initial scoring of
applications.
Interview all panel members.
Interview witnesses.
Review the qualifications of
selected individuals.
Do staff believe that the
individual is adequately
performing the job duties?
Theft of
Inventory
Inventory discrepancies
Inventory is lower than expected
Inventory records are missing
Poor internal controls over the
inventory
Inventory is not in the state’s fixed
assets system
Make inventory comparisons
Observe the inventory
Perform surprise physical
inventory counts
Compare the most recent
inventory listing to the
procurement and usage
records, and then compare it
to the physical inventory.
Theft of
computer
Missing computer inventory records
Poor internal controls over the
computer inventory
Computers are not in the state’s fixed
assets system
No internal system
No sign-out sheets are completed when
taking the computer home
Compare purchase records to
the physical inventory
Interview witnesses
Perform surprise physical
inventory counts
Review inventory control
records

TOPIC NO.
1006
Type of
Allegation
Symptoms Detection
Inflated hours
on time
sheets
Sloppy, altered, or forged records
No records
Unable to keep up with workload
Review the records
Interview witnesses
Search time and attendance
records for patterns
Monitor the time of day of the
computer log on and log off
Monitor the time of day of
outgoing telephone calls
Monitor the building access
or the parking lot access
Procurement
kickbacks
Improper segregation of duties
Poor internal controls over purchasing
No code of ethics or internal policy
prohibiting certain types of gifts, etc.
Interview witnesses
Review employee’s statement
of economic interest form
Reaching a Conclusion Based on the Evidence
Once the appropriate documentation has been gathered and reviewed and all
necessary interviews have been conducted, a conclusion should be reached
regarding whether or not the allegation is substantiated. When there is more
than one allegation, it may be necessary to conclude that some of the allegations
are substantiated while others are not. It is important to look at each allegation
individually when drawing the final conclusion.
To conclude that there was waste or abuse does not require that it be
intentional. Therefore, this should not be considered when determining whether
or not the allegation was substantiated. However, mitigating circumstances may
be considered when determining corrective action.
The standard of proof for substantiating allegations is a preponderance of the
evidence; that is, there is more evidence than not that substantiates the
allegation. It is not necessary to have proof beyond a reasonable doubt. Clear
and convincing evidence is enough to cause a reasonable person to believe that
the subject committed the offense or was responsible for the outcome.
When determining whether an allegation has merit, all evidence gathered should
be weighed, including witnesses’ statements. Without supporting
documentation to prove the allegation is true, relying on witnesses’ statements

TOPIC NO.
1006
alone is risky. Normally witnesses’ statements should lead to other evidence
that can be proven such as records or documents. While witnesses’ statements
alone will not make the case, they do provide additional corroborating evidence
that the allegation is true, provided there is documentary evidence to back it up.
In the case where the investigator has the word of one witness against another, it
will be difficult to conclusively deem that an allegation is substantiated.
However, this does not prevent the investigator from stating in the report what
each witness said. The investigator should refrain, though, from giving an
opinion as to which witness is to be believed.
You may also find that the allegation is not substantiated, but that policy
changes or improvements in internal control may avoid future problems. In
such cases, you may find the allegation unsubstantiated, but make these
recommendations as a part of your hotline report.

TOPIC NO.
1006
Guide to State Policies, Laws, and Regulations
Reference
Matrix
Some frequently used state policies, laws, and regulations are listed below.
This matrix is provided for use only as a quick reference. This matrix does
not include all applicable state codes, policies, and regulations. You should
refer to the regulation for additional information and you must also consider
internal policies and procedures:
Topic Reference Summary
Hours of Work DHRM policy 1.25 Work schedules, alternate work schedules,
overtime hours, lunch periods, and breaks.
Compensatory
Leave - Exempt
Employees
DHRM policy 3.10 Additional work hours for an exempt
employee must be specifically authorized in
advance by the agency head, or his/her
designee.
Additional work hours are intended only to
relieve specific peak workload needs and
shall not be authorized to provide for
continuous workload requirements.
Additional work hours do not include extra
hours that an exempt employee independently
determines are necessary to carry out his/her
job responsibilities.
Outside
Employment
State personnel policy
under the DHRM’s
Policies and Procedures
Manual, Standards of
Conduct, 1.60, requires
that:
Employees obtain approval from supervisor
prior to accepting outside employment.
Employees complete a telework agreement that
is kept on file in the agency.

TOPIC NO.
1006
Telephone Policy Department of
Accounts, the CAPP
Manual, Section
20310, Expenditures
VITA/Contracting
vendor
The agency head or designee must
authorize the acquisition and use of
cellular phones.
Recurring monthly billings must be
received in the agency fiscal office.
The VITA’s general telephone procedures
state that Commonwealth-provided
telephone services are to be used for
conducting official business only, and
should not be used for personal or private
purposes.
State Vehicle DGS Fleet Management
http://www.dgs.virginia.
gov/ofmshome/tabid/17
3/Default.aspx
Fleet Vehicle Use
Commuting with Fleet Vehicles
Enterprise contract vehicles
State Travel
Policy
Department of
Accounts, the CAPP
Manual, Topic No.
20335, State Travel
Regulations
Business Meals
Commuting Mileage
Conference Procurement
Disallowed Expenses
Lodging Reimbursement Rates
Meals and Incidental Travel Expenses
Mileage Rates
Overtime Meals
Rental Car
Travel Charge Cards
Travel in Personal Vehicle
Travel Reimbursement Requirements
Petty Cash Department of
Accounts, the CAPP
Manual, Topic No.
20330, Petty Cash
Policy
Restrictions

TOPIC NO.
1006
Small Purchase
Charge Card
Department of
Accounts, the CAPP
Manual, Topic No.
20355, Purchasing
Charge Card
Purchasing Card Security
General Requirements
Small Purchases APSPM Chapter 5 DGS - Small Purchases
Competitive
Procurements
APSPM Chapter 6
APSPM Chapter 7
DGS -Competitive Procurements
Sole Source
Procurements
APSPM Chapter 8 DGS - Sole Source Procurements
Emergency
Procurements
APSPM Chapter 9 DGS – Emergency Procurements
Standards of
Conduct
DHRM Policy 1.60 Standards for Professional Conduct
Procurement –
Ethics
Code of Virginia
Ethics in Public
Contracting
§2.2-4300, …All procurement procedures be
conducted in a fair and impartial manner
with avoidance of any impropriety or
appearance of impropriety….
§2.2-4368,… A procurement transaction
means all functions that pertain to the
obtaining of any goods, services or
construction, including description of
requirements, selection and solicitation of
sources, preparation and award of contract
and all phases of contract administration.
§2.2-4371,… No public employee having
official responsibility for a procurement
transaction shall solicit, demand, accept, or
agree to accept from a bidder, offeror,
contractor or subcontractor any payment,
loan, subscription, advance, deposit of
money, services or anything of more than
nominal or minimal value…

TOPIC NO.
1006
Procurement APSPM Section 3.22 State procurement policy requires that … all
state employees having official responsibility for
procurement transactions shall conduct business
with vendors in a manner above reproach in
every respect…
State and Local
Government
Conflict of
Interests Act.
Code of Virginia §2.2-
3106 A, the State and
Local Government
Conflict of Interests
Act.
No officer or employee of any governmental
agency shall have a personal interest in a
contract with the governmental agency of which
he is an officer or employee, other than his own
contract of employment.
Hiring DHRM 2.10 Includes recruitment, screening, and selection.
Compensation DHRM 3.05 Encompasses all pay practices to include starting
pay, temporary pay, role changes, and in-band
adjustments.
Expenditures Department of
Accounts, the CAPP
Manual, Topic No.
20310, Expenditures
Expenditures that are not considered to be proper
charges against state funds.
References The Institute of Internal Auditors, International Standards for the
Professional Practice of Internal Auditing, Code of Ethics.
Guide to Fraud Investigations, Practitioners Publishing Company, Fort
Worth, Texas.
Governor’s Executive Order Number Fifteen (2010), The State Employee
Fraud, Waste, and Abuse Hotline.
Department of Accounts, CAPP Manual.
Department of General Services, Agency Procurement and Surplus Property
Manual (APSPM).
DGS, Division of Fleet Management, Rules & Regulations governing the use,
operation and maintenance of state-owned fleet vehicles.
Department of Human Resource Management, Human Resource Policies and
Procedures Manual.

TOPIC NO.
1006
Subject Cross
References
Code of Virginia, §30-138, State agencies, courts, and local constitutional
officers to report certain fraudulent transactions to the Department of the State
Police and the Auditor of Public Accounts.
Code of Virginia, § 2.2-3705.3, Virginia Freedom of Information Act;
exemptions.
Code of Virginia, §2.2-1600, The Department of the State Internal Auditor.
Records
Retention
Copies of hotline documentation are to be maintained on file in each agency’s
internal audit department for 3 years after the case is closed. DSIA annually
informs the internal audit departments of case files that may be disposed of.
See the Library of Virginia Records Retention and Disposition Schedule No.
101, “Investigative Files, Records, or Reports.”

`DIVISION OF STATE INTERNAL AUDIT
TOPIC NO.
1007
Topic: State Employee Hotline – Reporting Date: January 2012
Reporting
Guidelines
Subject This Chapter addresses the State Internal Audit Directors’ responsibilities for
submitting hotline reports to the DSIA and appropriate management, including
Boards of Visitors.
Hotline
Reports
As a general rule, hotline reports should not be released to anyone, except to the
DSIA. However, it may be necessary in some cases to issue summary reports
for hotline cases. For example, it may be necessary to supply such a report to
the agency’s governing board in order to keep them notified of significant
events, or it may be necessary to issue such a report to agency management in
order to effect corrective and/or disciplinary actions. In such instances,
summary reports should disclose no more information than is absolutely
necessary. It is imperative that the callers and witnesses’ identities are protected
and that such reports do not disclose information that may compromise their
identities.
Summary
Reports
As a general rule, summary reports should follow these guidelines:
The summary report should be limited to a statement that an investigation
took place. The summary report should also state the finding(s) and the
recommended corrective action(s).
The summary report should not disclose that the investigation was conducted
in connection with the hotline, and should not be stamped “Confidential State
Employee Hotline Document”.
It is permissible, though not required, to make recommendations for
disciplinary actions in the summary report.
Summary reports and support documents may be issued to agency
management and/or grievance hearing officers to effect and uphold
corrective and/or disciplinary actions.
The summary report should be carefully prepared to exclude information in
the scope of the investigation that may reveal any witnesses to the
investigation. Moreover, the summary report should not include the hotline
allegation or other information that may compromise the identity of the
caller. The summary report should not include the case number, date of call,
or other information that might identify the caller or witnesses.

TOPIC NO.
1007
Due Date of
the Report
All cases that are assigned have a report due date sixty days from the assignment
of the case.
Report
Format
While there is no particular format for the report that is due to the DSIA, the
content of all reports should be similar. Agency Internal Audit Directors or
Hotline Coordinators will provide a report to the DSIA which includes the
information contained in this section. Below are the required report elements.
Report
Elements –
Report to
DSIA
Case number;
Amount of funds involved in the fraud, waste, or abuse;
Nature of the complaint;
Results of the investigation, including savings identified and recoveries
and/or restitution expected to be received;
Auditor’s conclusion;
Any corrective actions planned or taken;
The name of the target of the complaint;
Any internal control weaknesses identified and corrected;
Cost of the investigation
Case
Number
This is a five digit number that is included on the case referral form that is sent
to the investigators.
Nature of
Complaint
Hotline referrals are written in a narrative form that closely corresponds to the
actual conversation that was held during the original call, and as such include
allegations, and other information needed by the investigators. In order for the
report to be clear, investigators should include the allegations that they are
investigating. These allegations can be stated in a narrative form or in a list.
Often cases have more than one related allegation, and the investigator should
include all of those that they investigate.
Investigative
Techniques
or Scope
The investigator should include a statement of the investigative techniques used
to investigate the allegation. These statements may be broken down by
allegation, or included in a separate section. If there are more than three related
allegations in one case, it is generally clearer to separate the investigative
techniques by allegation. This section may be either in narrative form or
completed as a list; however, it should be specific. It should include all of the
steps taken to investigate the case.

TOPIC NO.
1007
Results of
Investigation
The results of the investigation section should include the auditor’s findings and
observations made during the course of the investigation. At a minimum, there
should be observations that address the allegations and issues identified.
Generally, there should be observations for each of the investigative techniques
outlined in the section preceding this one.
If during the course of the investigation other internal control or compliance
issues not specifically related to the allegations are identified, they also should
be included in the report along with the appropriate recommendations that
address these issues.
Auditor’s
Conclusion
Cases must be concluded as to being substantiated, unsubstantiated, or
inconclusive. A substantiated case indicates that fraud, waste, or abuse
occurred. The auditor’s conclusion must go beyond merely confirming whether
information contained in the allegations is factual. It is possible to have
substantiated cases result from information that is not factual in the allegations
and cases that are unsubstantiated when all of the facts in the allegations are
accurate. If the case contains more than one allegation, there should be a
conclusion for each of the allegations investigated. If the investigator is unable
to reach a conclusion regarding an allegation yet internal control weaknesses or
compliance issues are identified, then the investigator is required to state this in
the report and to provide recommendations to address these issues.
Any
Corrective
Actions
Planned or
Taken
Unless there is a compelling reason not to do so, reports should be submitted
after corrective action has been recommended and agreed to by management.
Corrective action need not be necessarily taken as of the report date since some
corrective actions are implemented over a period of time. Investigators should
therefore obtain a commitment as to when corrective action will be taken.
Type of
Disciplinary
Action
It is not the investigator’s responsibility to recommend any specific disciplinary
action or to follow-up to determine the type of disciplinary action taken. Any
disciplinary action taken should not be included in the report. If disciplinary
action is to be taken, the report can include a statement that appropriate
disciplinary action was or will be taken, but should not contain the specific
outcomes. This policy is to protect the target of the investigation.
Any Internal
Control
Weaknesses
Identified
and
Corrected
The report should address the conditions that gave rise to any substantiated
fraud, waste, or abuse. The report should address any weaknesses in the system
of internal controls and the recommendations to correct those weaknesses.
Unlike the disclosures concerning disciplinary actions referred to above, the
disclosures about internal control weaknesses and recommended corrective
actions should be specific.

TOPIC NO.
1007
Cost of the
Investigation
The report should contain a summary of the cost of the investigation. This
summary should include all investigative costs for all phases of the investigation
as practical. The reported cost does not need to be broken down or include any
detail, but the investigator should have a documented basis for the reported costs
included with the investigative notes. Fringe benefits and/or administrative costs
should not exceed 35% of the direct labor cost to conduct the investigation.
Reasonable estimates are acceptable.
Funds
Identified
The report should contain the amount of funds identified as a result of
substantiating the allegation and taking corrective action, that is, the amount
directly attributed to the fraud, waste, or abuse. The amount of funds involved
should be broken down and identified to include three components:
Finding - Amount of fraud, waste, or abuse identified. For example, this may be
the value of leave abused.
Recovery – The funds that were recovered as a result of the investigation. For
example, this may be as a result of restitution. Restitution may include leave
slips processed for back leave owed and payment made by the subject for state
resources taken or a state vehicle driven for personal use,
Savings – The amount of savings to the Commonwealth as a result of
implementing recommended corrective actions. This amount may be estimated.
The basis for these estimates should be documented in the investigative notes.
There should also be an estimate of the time frame for any reported future
savings, that is, over what period will the savings be realized.
Case Closed A case investigated by an agency Internal Audit Department or Hotline
Coordinator is considered closed when the DSIA has received, reviewed, and
accepted the investigative report. A case investigated by the DSIA is considered
closed when a response to the investigative report has been received and
accepted by the DSIA. However, in investigations where recommendations for
corrective action were made, the Internal Audit Director, the Hotline
Coordinator, or the DSIA has an obligation to follow-up, preferably within 6 to 9
months, to determine that the recommended corrective actions have been taken
by management.
Quarterly
Report
Once a quarter, the DSIA will send internal audit departments a list of open
cases that are over 60 days old. Internal audit departments are asked to review
that list and identify inconsistencies between their records and the DSIA’s. Such
discrepancies may include open cases the agency did not receive or cases for
which a report was submitted but has not been closed by the DSIA.

TOPIC NO.
1007
When Fraud
Has Occurred,
Agency Head’s
Responsibility
In those instances where there is a reasonable possibility that fraud has
occurred as defined above or as described in Code of Virginia, Section 30-138,
the agency head or his designee is required to notify the Auditor of Public
Accounts and the Department of State Police. The DSIA should also be
notified if an investigation is referred to either entity.

TOPIC NO.
1007
Documentation and Confidentiality
Information
Maintenance
and
Ownership
All information supporting investigations and any remedial action taken shall
be maintained at the agency. All such information, documentation, etc. is the
property of the DSIA and shall be so identified. The DSIA may request that
supporting information accompany formal reports. All supporting
documentation and information must be stamped or identified as “Confidential
State Employee Hotline Documents.”
Investigations, interviews, and information relating to investigations should
not be shared, discussed, or given to anyone without an absolute need to know.
Information
Requests
If an agency should receive a request for information regarding a Hotline
investigation, either through the Freedom of Information Act or other means,
the requestor should be referred to the DSIA. Under no circumstances should
the agency provide any information to the requestor. Doing so could seriously
jeopardize the integrity of the Hotline and the investigative techniques used.
Confidentiality Stamp Use
Policy Strict confidentiality must be maintained over the entire Hotline investigation.
You should ensure that all documents, work papers, notes, and reports
associated with the investigation are marked Confidential State Employee
Hotline Documents. Electronic records should include a header or footer
with this statement. The only exceptions to this policy are the Summary
reports provided to the governing board or agency management. They should
not be marked as shown above.
DSIA Contact
Questions? Tim Sadler, Audit Manager
(804) 225-3106, Ext. 23 or
tim.sadler@doa.virginia.gov

WFA Hotline Policies Manual

More Related Content

What's hot (19)

Viewers also liked (14)

Similar to WFA Hotline Policies Manual (18)

More from Chuck Thompson (20)

Recently uploaded (20)

WFA Hotline Policies Manual