Navex (the vendor/provider for the Hotline) emails all reports to the Internal Audit Department. All information provided through the Hotline report will go through a screening process to determine whether the report is complete and includes sufficient information to determine if there is a violation of EPISD policy or state/federal law, should the allegation(s) be true. In addition, Internal Audit or administration may conduct a preliminary analysis to determine whether an investigation is needed and what steps, if any, are required to respond in an appropriate manner.
Not every Hotline report will result in an investigation. If the preliminary analysis fails to confirm that an incident may have occurred or that there is no reasonable basis for the conduct alleged in the report, there may be no basis for an investigation. An investigation may not be initiated if:
- Sufficient information was not provided
- The Hotline report allegation is a misunderstanding of EPISD policy
- The report relates to a lack of communication between the reporter and another person
- The substance of the report can be resolved informally, such as a request for assistance rather than an allegation of misconduct
When appropriate, reports will be forwarded to principals or other administrators for resolution. However, the Internal Audit Department tracks all Hotline reports from receipt through resolution.
If an investigation is undertaken and if the allegation is substantiated, corrective action will be required to rectify the cause or control weaknesses that allowed the situation to occur. All employees involved in an investigation shall be advised to keep information about the investigation confidential. In most cases, the person initiating the report may not be provided with the details, but rather only the outcome of the investigation (whether the alleged fraud, waste, or abuse was substantiated or not substantiated).
If an investigation substantiates that fraud has occurred, the Board can be notified as required by Board Policy CAA (Local). When circumstances warrant, the Superintendent and/or his/her designee, in conjunction with legal counsel, determine whether to refer the investigation results to the appropriate law enforcement agency and/or regulatory agency.