In January 2020, City University of New York (CUNY), of which Hunter College is part, implemented a new procedure to ensure it reports allegations of violations of law and certain regulations as required to New York’s inspector general (IG).[1]
The state-specific protocol may prove helpful to other institutions juggling similar reporting responsibilities while complying with federal requirements to inform U.S. IGs, awarding agencies and other sponsors of potential wrongdoing.
CUNY’s policy, which replaces one in place since at least 2013, is among the actions it implemented in the last six years in response to misspending by a former psychology professor and lack of oversight by CUNY and Hunter College.[2]
Interestingly, the new policy states that the “reporting employee” should not share concerns with higher-ups. Unlike the earlier version, it assigns specific responsibilities to certain officials and sets deadlines for their actions.
Public Safety Used to Be First Stop
In February, Hunter College, CUNY and the professor, Jeffrey Parsons-Hietikko, entered into separate but related settlements with the U.S. Attorney for the Southern District of New York after both admitted to violating the False Claims Act (FCA). Hunter and CUNY agreed to pay $200,000, while Parsons-Hietikko’s amount is $375,000. The settlement joins others involving universities that ran afoul of the FCA, although the payments are on the low end.[3]
CUNY’s general counsel and senior vice chancellor for legal affairs reissued the old policy to CUNY’s Council of Presidents on July 1, 2013, regarding what was then called the “protocol for reporting and responding to fraud/theft allegations.” He wrote that “a number of instances of fraud or theft by CUNY employees at our campuses have come to the attention of the Office of the General Counsel, Internal Audit and University Public Safety.”
That policy instructed members of the Council of Presidents to “immediately” report suspected “theft of CUNY or Research Foundation funds or property on [their] campus, or falsification of official records, or any other scheme to defraud the College or University, by an employee or student” to the director of public safety, director of internal audit, general counsel and chief compliance officer. The policy updated specific individuals to be contacted by name.