The National Defense Authorization Act, P.L. 112-239 (PDF) (NDAA) established a pilot program for the enhancement of contractor and subcontractor employee protections from reprisal for whistleblowing.
What is Whistleblowing?
Whistleblowing is the disclosure by a person, usually an employee in a government agency or private enterprise, to the public or to those in authority, of mismanagement, corruption, illegality, or some other wrongdoing. Specifically:
- Gross mismanagement of a Federal contract or grant;
- The gross waste of Federal funds;
- An abuse of authority relating to a Federal contract or grant;
- A substantial and specific danger to public health or safety; or,
- A violation of law or regulation related to a Federal contract or grant (including the competition for, or negotiation of, a contract or grant).
Section 828(a) of the NDAA, Pilot Program for Enhancement of Contractor Employee Whistleblower Protections, provides that, “An employee of a contractor, subcontractor, or grantee may not be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing the aforementioned types of information to:
- A Member of Congress, or a representative of a Congressional committee,
- An Inspector General,
- The Government Accountability Office,
- A federal employee responsible for contract or grant oversight or management at the relevant agency,
- An official from the Department of Justice, or other law enforcement agency,
- A court or grand jury, or,
- A management official or other employee of the contractor, subcontractor, grantee, or sub-grantee who has the responsibility to investigate, discover or address misconduct
The pilot program also establishes a new process for review of whistleblower reprisal complaints alleged by employees of contractors, subcontractors, and grantees, “A person who believes that the person has been subjected to a reprisal prohibited by subsection (a) may submit a complaint to the Inspector General of the executive agency involved.”
Procedures for submitting fraud, waste, abuse, and whistleblower complaints are generally accessible on the Office of Inspector General (OIG) website, via phone (800) 409-9926, or Whistleblower Internet sites, such as these:
- Department of Agriculture : http://www.usda.gov/oig/contractorform.htm
- Department of Health and Human Services: https://forms.oig.hhs.gov/hotlineoperations/
- National Institutes of Health: http://oma.od.nih.gov/public/DPI/Pages/default.aspx
- National Science Foundation: http://www.nsf.gov/oig/
Concerns related to alleged fraud, waste, and/or abuse may be reported anonymously to the Wayne State University Office of Internal Audit as follows:
- Online Tips Form – www.internalaudit.wayne.edu
- Hotline – (313) 577-5138
All allegations will be investigated and reported to the appropriate University officials and the sponsor. Please provide sufficient information to enable a thorough investigation.
“It’s been written that if you travel far enough, you meet yourself. That is frightening! And confusing!”
Dear Dr. Llama,
SPA finance team is questioning my travel expense to Africa, charged to my federally funded grant, for a possible dis-allowance due to the timing factor. The travel took place after the end date, but was completed within a week’s time after that. I traveled to participate in the conference that focused on the Geology project on which I worked, to present my work supported by this grant. What can I do to include this cost on my grant?
Kenya Dig It
It is imperative that no expense, travel or any other type that take place after the end date, can be charged to a grant. However, once it is determined that the travel was related to the accomplishment of the goals of this particular grant;, the following can help you present your case for the allowability of the travel expense in question:
- If such a travel is specifically mentioned in the proposal and is approved by the sponsor.
- There is a specific approval from the sponsor for this travel during the life time of this grant.
- If it can be justified, that without that particular travel expense, the required work on the grant would be deemed incomplete.
In case there is still a lack of clarity, the sponsor should immediately be contacted, via your SPA Grant and Contract Officer, for their comments and assistance in basing decisions on allowability.
“I’m not a real llama! That’s just my name!”
How? What? Who? When? All questions answered!
In the spirit of the cost principle example published in a past SPA Newsletter, SPA Blah Blah introduces the expert on all things sponsored project related, Dr. Llama. A regular feature, Ask Dr. Llama will provide examples and answers regarding proposal development and grant management and, well, everything you need to know about sponsored projects at WSU. Contributing questions are welcomed and encouraged! Contact firstname.lastname@example.org.
With personnel changes over the last few months, it has become necessary to re-assign department assignments among the SPA GCOs. This change ensures that all needs of Principal Investigators and department administrators are met with expedience and thoroughness. Affected departments have been notified of these changes