Chapter 2: Fraudulent or Dishonest Activities
The University of Texas System Policy 118 Dishonest or Fraudulent Activities (UTS 118) dictates that all suspected fraudulent or dishonest activities, including but not limited to embezzlement, misappropriation, or other fiscal irregularity, should be reported immediately and investigated by the appropriate University departments. University Administration is responsible for establishing and maintaining internal controls to provide reasonable assurance that improprieties are prevented and detected. Each department should be familiar with the types of improprieties that might occur in their areas and be alert for any indication that such an act has occurred.
2.1 Dishonest or Fraudulent Activities
Dishonest or fraudulent activities concern any illegal, dishonest, or fraudulent acts involving University property or resources. Examples of such activities include but are not limited to: embezzlement, misappropriation, or fiscal irregularities; forgery or alteration of checks, drafts, or securities; forgery or alteration of employee benefit or salary-related items such as time cards, billings, claims, or changes in beneficiary; forgery or alteration of medical-related items such as reports, charts, prescriptions, x-rays, billings, or claims; forgery or alteration of student-related items such as grades, transcripts, loans, fees, or tuition documents; misappropriation of funds, securities, supplies or any other University asset for private gain (e.g., equipment used for private consulting work, personal long-distance calls made on University telephones); illegal or fraudulent handling or reporting of money transactions; acceptance or solicitation of any gift, favor, or service that might reasonably tend to influence the employee in the discharge of his or her official duties; destruction or disappearance of records, furniture, fixtures, or equipment where theft is suspected.
2.2 Coordination of Investigations
The Office of Auditing and Consulting Services (OACS) will supervise all investigations of allegations of dishonest or fraudulent activities. When an investigation reveals suspected criminal activity or is initiated due to an allegation of criminal activity, the University Police are to be notified immediately.
If an investigation reveals activity that may constitute a felony offense, the Chief Audit Executive shall immediately notify the Executive Vice President and Chief of Staff and the Vice President for Business Affairs. If related to faculty, the Provost and Vice President for Academic Affairs shall also be notified immediately. In any circumstance involving a potential felony offense, timely notification will be given to the U.T. System Chief Audit Executive.
All reasonable assistance will be provided to law enforcement agencies when requested. OACS, the University Police, the Vice President for Business Affairs, and the Office of Legal Affairs will coordinate assistance provided to state, federal, and local law enforcement agencies. Where appropriate, the U.T. System Office of General Counsel may also assist.
Employees and students may use UTEP’s Compliance Helpline to report an activity suspected to be dishonest or fraudulent. The Compliance Helpline is a confidential alternative for reporting suspected unethical or inappropriate activity, including financial reporting, internal accounting controls, audit matters, waste, and violations of any federal or state laws or University policy. All reports are investigated and addressed as appropriate. The Office of Institutional Compliance will protect the confidentiality and anonymity of those making a report to the extent provided by law.
The Vice President for Business Affairs may also receive information on a confidential basis, to the extent permitted by law. Individuals who report suspected activity should not attempt to personally conduct investigations, interviews, or interrogations with regard to the reported activity.
2.3 Internal Audit
When an internal audit involves allegations or reveals suspected criminal activity that may constitute a felony offense, the Chief Audit Executive will, when appropriate, immediately notify the President, the University Police, and the U.T. System Chief Audit Executive.
2.4 Investigations by Federal or State Agencies
All requests for information and assistance related to investigations conducted by auditors or investigators of Federal or State agencies that are concerned with potential Dishonest or Fraudulent Activities shall also be forwarded immediately to the Chief Audit Executive, who shall consult with the Office of Legal Affairs and notify the U.T. System Chief Audit Executive. The Office of Legal Affairs shall notify the U.T. System Office of General Counsel.
2.5 Notification of Loss and Approval of Claims
In accordance with Regents' Rule 80601, the Vice President for Business Affairs shall notify the U.T. System Chief Compliance and Risk Officer, or designee, as soon as it is known that a loss has occurred, for approval of all insurance and fidelity bond claims. It is the responsibility of the Vice President for Business Affairs to notify the President, who advises the Executive Vice Chancellor for Business Affairs, of criminal activity, as appropriate.
2.6 Integrity of Investigations
Reviews conducted by OACS as part of their yearly audit plan, or any investigations that reveal violations of the Penal Code for which an investigation report will be issued, should be reduced to final report form only after consultation with the Executive Vice President and Chief of Staff, the Office of Legal Affairs, and where appropriate, the U.T. System Office of General Counsel.
The University Police will coordinate any criminal investigations if probable criminal activity is detected.
Reporting individuals should not discuss the investigation with anyone, unless specifically directed to do so by OACS, the University Police, or the Office of Legal Affairs. All inquiries from the suspected individual or their representative or attorney must be directed to the Vice President for Business Affairs.
When an investigation initiated due to an allegation of criminal activity fails to detect criminal activity, and when advised by the Office of Legal Affairs, the Chief Audit Executive has the discretion to stop the investigation.
2.7 Findings of Investigations
Each investigation of possible dishonest or fraudulent activity has the potential to provide insight into specific activities and may reveal control weaknesses or other issues that require further investigation, audit, or University Administration attention.
Each investigation will be reviewed by OACS to determine whether additional work needs to be done to provide the Internal Audit Committee and University Administration with a basis for taking corrective action, if necessary.
Allegations or issues found to involve research misconduct will be handled in accordance with UTS 118 and HOP Section IV, Chapter 6: Research Integrity Policy.
2.8 Definitions
Dishonest or Fraudulent Activity - these terms include but are not limited to any:
2.9 References
Texas Government Code Chapter 321.022: Coordination of Investigations
Regents’ Rule 80601: Property and Casualty Insurance and Surety Bonds
UTS 118: Dishonest or Fraudulent Activities
UTS 131: Protection from Retaliation for reporting Suspected Wrongdoing
HOP Section V, Chapter 8: Protection from Retaliation from Alleged Wrongdoing
2.10 Dates Approved oR UPDATED
December 11, 2025
May 7, 2021
