Whistleblower Program Update Fiscal Year 2014 15 Review of - - PowerPoint PPT Presentation

Whistleblower Program Update

Fiscal Year 2014‐15 Review of Activities and Initiatives

Presentation to Citizens’ General Obligation Bond Oversight Committee May 28, 2015 City & County of San Francisco Office of the Controller

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Whistleblower Program Authority

The authority for Whistleblower Program investigations is derived from statute and regulation:

– California Government Code 53087.6 – San Francisco Charter Appendix F – Campaign and Governmental Conduct Code Article IV

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Matters Appropriate For Investigation

The Whistleblower Program shall investigate or

• therwise attempt to resolve complaints

concerning:

– The misuse of city funds. – Improper activities by city officers and employees. – Deficiencies in the quality and delivery of government services. – Wasteful and inefficient government practices.

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Referral of Certain Complaints

The Whistleblower Program shall refer the following complaints:

– Those which another city department is required by federal, state, or local law to adjudicate. – Those which may be resolved through a grievance mechanism established by bargaining unit or contract. – Those involving violations of criminal law. – Those subject to an existing investigation. – Those which allege violations of governmental ethics laws.

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Whistleblower Program Importance and Benefits

• A fraud hotline is a critical internal control that is often

noted as an operating and credit rating strength when well implemented by a municipality.

• The Whistleblower Program allows complaints to be

submitted anonymously and confidentially.

• Whistleblower Program investigations:

– Stop improper conduct and prevent further violations. – Reveal all of the relevant facts so that management can make a fully informed decision as to how best to proceed.

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Complaints Received By Quarter

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80 73 68 73 51 79 79 63 72 10 20 30 40 50 60 70 80 90

Q1 Q2 Q3

FY 14‐15 FY 13‐14 FY 12‐13

Fiscal Year 2014‐15 Complaint Activity

Quarter 3 Quarter 2 Quarter 1 Open Complaints at Beginning of Quarter 55 56 64 New Complaints Received 68 73 80 (Complaints Closed) 55 74 88 Open Complaints at End of Quarter 68 55 56

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Fiscal Year 2014‐15 Overview – Age of 55 Complaints Closed in Quarter 3

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19 25 10 1 5 10 15 20 25 30 Less than 30 Days 31‐90 Days 91‐180 Days 181‐270 Days

Fiscal Year 2014‐15 Overview – Age of 68 Complaints Open at the End of Quarter 3

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25 19 18 4 2 5 10 15 20 25 30 Less than 30 Days 31‐90 Days 91‐180 Days 181‐270 Days 271‐360 Days

Fiscal Year 2014‐15 Overview – Complaints Investigated and Closed

Total Quarter 3 Quarter 2 Quarter 1 Complaints Investigated and Closed 155 38 55 62 Complaints Resulting in Corrective/Preventive Action 45 11 21 13 29% 29% 38% 21%

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Closed Complaints

• Investigated and Closed

– Substantiated complaints

• Evidence is sufficient to support that a violation occurred.

– Unsubstantiated complaints:

• Evidence does not support that the allegation occurred.
• Incident occurred but it does not violate any rule or regulation.
• Can sometimes result in preventive action taken.
• Complaints Referred to Department With Charter Jurisdiction

– Complaint was referred to the city department with charter‐granted jurisdiction over the issue (for example, the Ethics Commission, City Attorney, or District Attorney).

• Not Enough Information

– Insufficient information to investigate. For example, no indication of department, employee(s) involved, or vehicle number.

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Closed Complaints

• Outside of Jurisdiction

– Issue falls within the jurisdiction of federal, state,

• r other noncity government agency or is a

suggestion or general complaint about decisions that are within management’s discretion.

• Merged With Previous Complaint

– Complainant provided information for a complaint that is already under investigation or was previously investigated by the Whistleblower Program.

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Fiscal Year 2014‐15 ‐ Initiatives

Employee Outreach

• Continued outreach and education to city employees

through employee presentations.

• Citywide employee outreach occurred Quarter 3.

– Departments were required to distribute Whistleblower Program contact information to all city employees. – Departments were also required to post a notice of whistleblower protections in locations that are conspicuous and accessible to all employees. – Issued investigative guidelines for department liaisons.

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Fiscal Year 2014‐15 ‐ Initiatives

Fraud Hotline Webinar Series

• Purpose: To create a forum that encourages

dialogue and collaboration on best practices for fraud hotlines.

• Next webinar ‐ How to “Steer” Your Hotline Calls
• Scheduled for June 11, 2015
• Topics covered in FY 2014‐15:
• Fraud Hotlines in a Social Housing Environment
• Proactive Fraud Detection Through Data Analysis
• Leveraging IT to Support a Hotline Program

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Fiscal Year 2014‐15 ‐ Initiatives

Complainant Survey

• Survey went live on October 1, 2014.
• Two responses received.
• Survey promoted in the following venues:
• Website
• Quarterly reports
• Complaint receipt and closure correspondence
• Employee outreach communications

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