85 – Firm routinely certifies the accuracy of audits to senior management or regulatory agency? No = Bad
86 – Firm has tight distribution and accountability system? No = Bad
87 – Firm periodically audits the contractor’s relevant project filing system? No = Bad
88 – Firm only uses approved contractors? No = Bad
89 – Firm certifies that only approved resources are being used? No = Bad
90 – Are oversight managers in their positions for either too long or too short a period of time to maintain effective control? Yes = Bad
91 – Are audits performed by a qualified and recognized review group? No = Bad
92 – Does the vendor get paid even if it does not submit paperwork and receipts as required? Yes = Bad
93 – Are firm’s employees able to bypass protections (e.g., systems/procedures) that are built into the system? Yes = Bad
94 – Are key contract people regularly rotated into different assignments? No = Bad
95 – Does either the vendor/contractor have employees who have the ability to write checks without supervisory authorization? Yes = Bad
96 – Do all vendor/firm’s checks require 2 separate verification signatures? No = Bad
97 – Are cross-checks of location against time done in order to control overtime? No = Bad
98 – Has/retains time & attendance records? No = Bad
99 – Does the firm maintain a list of potential fraud indicators? No = Bad
100 – Does firm require multiple supervisory reviews before approving invoices? No = Bad
101– Does firm have strict rules regarding accepting gifts from contractors? No = Bad
102– Does firm routinely ask contractors and document if any of the firm’s employees have solicited bribes/kick backs? No = Bad
103– Have formal policies for collecting and depositing cash, for purchasing and recording regular work time and attendance? No = Bad
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ANALYSIS:
1 – Skimps/shortchanges on delivering contracted product or services/work performed to cut costs while collecting preset fees from the firm, regardless of the amount actually provided? Yes = Bad
2 – Firm compares contractor’s costs against comparable vendor’s charges? No = Bad
3 – Vendor has convinced (or is trying to convince) firm to buy more equipment or services/work performed than needed. Yes = Bad
4 – Firm has received questionable invoices from the vendor for items that are useless, not needed, not wanted, and don’t know what to do with and cannot maintain? Yes = Bad
5 – Firm has received invoices for products or services/work performed for an excessive amount of money more than the actual cost? Yes = Bad
6 – Are the same project/job invoices being re-cycled for payment again and again over a period of time (duplicate payments/ repetitive descriptions of the work being performed)? Yes = Bad
7 – Are actual conditions being falsified and inflated by the contractor in order to charge the firm for unnecessary charges? Yes = Bad
8 – Does the vendor submit excessive late charges? Yes = Bad
9 – Does either firm or vendor see unauthorized personal expenses being charged to business credit cards? Y = Bad
10 – Are significant changes in invoice filing patterns which may be indicators of fraud, reported to the contractor oversight manager? N = Bad
11 – Does the firm collect detailed information for tracking/ trend analysis? No = Bad
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AUDIT:
1 – Contractor has bribed or attempted to bribe firm’s officials to forgo competitive bids for the project? Yes = Bad
2 – Contractor provides (or is alleged to provide) kick backs for new business referrals? Yes = Bad
3 – Firm does not systematically analyze, looking for overpayments from data it has already collected? No = Bad
4 – Firm has confirmed that the product or service or work being performed actually existed or occurred (needed)? No = Bad
5 – Firm has confirmed that it actually used the full amount of product, service or work performed as being invoiced? If the firm used less, was an adjustment made? No = Bad
6 – Contractor has submitted invoices for more than authorized product, services or work performed? Contractor is/ has submitted payments before her/his contract was officially approved? Yes = Bad
7 – Does quality control review and test a random sample, periodically, for accuracy and completeness to reveal improper payments? No = Bad
8 – Does the contractor bill for higher cost employees when lower cost employees actually did the work (bait and switch)? Yes = Bad
9 – Are background checks done on all levels of the contractor’s personnel? No = Bad
10 – Does the vendor maintain records for an extended period of time? No = Bad
11 – Are the firm’s key contract people required to be polygraphed on a regular basis? No = Bad
12 – Can the firm’s employees calculate and substantiate all of their salary expenses? No = Bad
13 – Are the vendors accurately paid for products, services or work performed as the firm’s books say they were paid? No = Bad
14 – Does the firm have an incentive mechanism (e.g. cash rewards) to encourage the reporting of insider fraud which may exist between the bid requester, approver, and receiver of products, services or work performed? No = Bad
15 – Do bills or other back-up material exist to justify payments? No = Bad
16 – Are checks made out to cash without explanation? Yes = Bad
17 – Does firm have receipts for materials received from the vendor? No = Bad
18 – Does the vendor submitting the invoice actually exist? No = Bad
19 – Do discrepancies/conflicting information occur between any of the following 2 document sources, such as, invoices/the type/relevance of work being performed/purchase orders/amount paid/date paid/start-finish times/account numbers? Yes = Bad
20 – Have any documents been forged by either the firm or the vendor? Yes = Bad
21 – Are confirmed fraud abuses sent to law enforcement? N = Bad
22 – Does the organization that received the contractor’s products/services/work performed get the opportunity to reconcile/review the contractor’s invoice before payment is made? N = Bad
23 – Does a toll-free fraud tip hot line exist? N = Bad
24 – Does firm conduct refresher training in contractor oversight? No = Bad
25 – Contractor has bribed or attempted to bribe firm’s officials to forgo competitive bids for the project? Yes = Bad
26 – Contractor provides (or is alleged to provide) kick backs for new business referrals? Yes = Bad
27 – Firm does not systematically analyze, looking for overpayments from data it has already collected? No = Bad