Reporting Fraudulent Financial Aid Activity

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Policy Number:
UW-1037
Old Policy Number:
OSFA 204
Responsible Office:
Office of Student Financial Aid

University Policy

Rationale/​Purpose:

Federal financial aid regulations require an institution administering Title IV financial aid to report credible fraudulent financial aid activity committed against federal student aid programs to the U.S. Department of Education.

Definitions:
Legal Counsel
An attorney representing the University of Wisconsin-Madison.
Office of Inspector General (OIG)
An independent entity within the U.S. Department of Education (ED) responsible for identifying fraud, waste, abuse, and criminal activity involving ED funds, programs, and operations.
Student
For purposes of this policy, a student is an individual who is enrolled or intends to enroll at the University of Wisconsin-Madison.
Title IV
Federal financial aid programs for post-secondary students authorized under Title IV of the Higher Education Act (HEA) of 1965, as amended.
Scope:

All federal Title IV financial aid or other Higher Education Act (HEA) programs administered by UW–Madison, third-party servicers or other agents of the institution.

Policy:

  1. Student Fraud

    1. Applicants for Title IV financial aid who are suspected of fraud or other criminal misconduct in relation to Title IV funding must be reported to the Office of Inspector General (OIG), should legal counsel deem the activity fraudulent.
    2. Examples of fraud or other criminal misconduct include, but are not be limited to:
      1. submitting false claims of independent student status;
      2. submitting false claims of citizenship;
      3. use of false identities;
      4. forgery of signatures or certifications; and,
      5. false statements of income.

  2. Employee and Third-Party Fraud

    1. Any credible information indicating an employee of UW–Madison, third-party servicer or other agent of the institution involved in the administration of Title IV or HEA programs may have engaged in fraud, misrepresentation, conversion or breach of fiduciary responsibility, or other illegal conduct involving Title IV or HEA programs must be reported to the OIG, should legal counsel deem the activity fraudulent.

  3. Financial Aid Reporting Requirement

    1. Any employee or third-party responsible for the administration of financial aid is obligated to report suspected fraudulent activities to the Associate Director of Federal Awards and/or the Director of Financial Aid.
External References:

Policy Administration

Approval Authority:
Executive Director of Student Financial Aid
Policy Manager:
Associate Director for Federal Awards
Contact:
Associate Director for Federal Awards -- Shane Maloney, SHANE.MALONEY@WISC.EDU, (608) 262-3384
Revised Dates:

01-01-2020, 11-15-2022

Reviewed Dates:

01/01/2020, 11/15/2022

Retrieved:
07-27-2025 21:22:17