(Bowers is the inspector general of the internal audit department at the University of West Florida in Pensacola. Coffey is the University’s chief of police.)

One fundamental concept behind the Certified Fraud Examiner designation is to combine the skills of a law enforcement officer with those of an auditor or accountant thereby achieving the perfect balance of expertise to investigate white-collar crime. A few years ago when the University of West Florida (UWF) in Pensacola experienced budget and personnel restraints, we decided to create a partnership between our campus police and internal audit departments to alleviate some of the work load in the internal audit department. Once the partnership was in place, not only did we experience improved efficiency among personnel, but we also inadvertently created a more comprehensive environment to detect and deter fraud – all without additional expenses being incurred. The University now plans to continue this partnership as long as the need arises; we highly recommend other organizations to follow suit and reap the same benefits we have experienced here at UWF.

Why Partner Between Campus Police and Internal Auditors?

Who wants to work with police or internal auditors anyway, except other police and internal auditors, right? However, these two departments play similar roles in any organization. Both ensure compliance to laws, rules, policies, and procedures. Police have the ability to enforce legal compliance, while internal auditors can only recommend appropriate courses of action to managers.

Often a case begins as an administrative audit and then evidence shows it to be criminal (or vice-versa). What are you to do then? Under whose jurisdiction would the case fall – the police or the internal auditor?

This blurring of the lines of responsibility between the police and internal audit departments can be beneficial and even appealing to management. If these two entities work closely together on investigations, the resulting case – whether administrative or criminal – will have thorough expertise from two perspectives. That sounds like a good deal, especially if it does not cost the organization any more money.

How Did the Partnership Materialize?

During the academic year of 1996-97, the Office of Inspector General at UWF (a staff of three internal auditors) handled 10 investigations, assisted the Board of Regents on two additional investigations, and performed seven audits and 25 management consulting activities. Each auditor worked the equivalent of a 13-month year at 40 hours/week. Like most higher-education institutions, budget constraints had been experienced on campus; therefore, additional help was not hired. The work load became unbearable on the internal audit staff and investigations continued to rise.

Meanwhile, we, the campus police chief and the inspector general (director of internal audit), had established a procedure of informing each other about current cases. We would meet weekly and discuss operational issues. During one of these meetings, we discussed alleviating the work load of the internal auditing staff by providing some job enhancement and enrichment opportunities to one of the campus police officers.

In March 1997, we began an innovative partnership between campus police and internal audit. We placed a police investigator on full-time assignment in the internal auditing office to assist in the growing number of administrative investigations.

Was it culture shock for the officer? Absolutely! Foremost, he did not have the security of being able to clearly distinguish whether or not a law had been broken. The cases he worked in the internal audit department dealt with procedural and performance issues, rather than violations of law. Secondly, this police investigator had to learn how to approach cases from a completely different angle: develop a fraud theory, and then examine evidence to ascertain if it fits the theory. This was quite contrary from normal police investigations, which focus on examining all the evidence, then developing a hypothesis (or hypotheses).

Occasionally, the police investigator would follow a paper trail that did not lead to evidence of wrongdoing or a crime. However, sometimes he would find issues requiring a closer look and would get enthused about the project. He said it was almost as exciting as making an arrest, but not quite!

What were the Advantages?

Many positive advantages resulted from this partnership, such as the following:

• The internal audit department had an experienced investigator to do the leg work on cases.
• The partnership led to increased knowledge of the other department’s duties and operations.
• The internal audit staff, in essence, was increased without incurring additional payroll costs.
• The investigator assigned to internal audit experienced job enrichment and enhancement.
• The work load of the internal audit office was distributed more evenly.
• The investigator readily knew when allegations had merit and whether or not those actions were of a criminal nature.

Any Drawbacks?

Drawbacks were minimal in this partnership; however, we did encounter some complications. Both police and internal audit investigations involve tremendous amounts of paperwork, but the process of documentation differs. Teaching an investigator the intricacies of audit documentation and referencing was challenging. However, the investigator was able to share some of his learned techniques with other police officers, which resulted in clearer and more organized case documentation within the police department.

Another challenge in this partnership dealt with the personnel evaluation of the police investigator. In essence, both of us supervised the police investigator, but he was only being evaluated by one of us – the police chief. We overcame this hurdle by meeting to discuss the officer’s duties within the internal auditing department. When the personnel evaluation was conducted, it reflected both of our perspectives.

Another challenge for the police investigator was the daily timekeeping of internal audit activities. This was a change for the officer; however, the readily accessible information regarding how long it took to investigate a case was valuable to the officer.

Parallel Investigations: Administrative and Criminal

Prior to our partnership, when allegations arose regarding misconduct, mismanagement, or other possible criminal activities, department managers were faced with the dilemma of reporting the allegations to the police or the internal auditors. Once our partnership began, we contacted each other when one of us learned of an allegation. We then evaluated the allegation together and determined a course of action. For allegations in which it was not clear whether the case would remain administrative or turn criminal, it usually was necessary to conduct a parallel investigation. Such investigations encompassed the steps of an administrative investigation as well as a criminal investigation, and they were performed simultaneously.

We found certain activities that were universal to any investigation (reviewing documents, reviewing procedures, and interviewing). However, these steps took different focuses depending upon the circumstances or the investigative body in charge.

Both police investigators and auditors review documents. A police investigator will look at the documents for probable cause or elements (corpus delicti) of a crime (authenticity, content, and tampering/alteration). An auditor will look at the documents to analyze the propriety and content of the document, but he also will analyze the flow of the document (who has viewed it, when, and what processes were followed).

Both police investigators and auditors review policies and procedures. The officer will review the procedures to see what steps should or should not have been performed and if there were any violations to the policy or procedure. The auditor, on the other hand, will look not only at the compliance to the policy or procedure but also will assess the efficiency and effectiveness of the policy or procedure itself. If the particular policy or procedure appears to be outdated, the auditor will recommend updating or repealing the policy or procedure to management.

Both departments also conduct interviews. This is where we found a marked difference. Police interviews are performed primarily to obtain information about a possible crime. Police interrogations are demands of information from the suspect(s) about their involvement in the crime. Auditor interviews primarily are conducted to gather information about policy and procedural issues. Rarely does an auditor interrogate.

Separate Procedures

We found similar, yet distinct, procedures employed within each department. For example, when employees were interviewed by the auditors and the questions were related to the person’s work (narrow, specific, and directly related to the work duties), then Garrity could be invoked. If a police interrogation was conducted, the subject of the interview would be advised of his Miranda rights.

During criminal investigations, law enforcement officers brief other law enforcement agencies and prosecutors. In administrative investigations, auditors brief management and the external auditors. In either type of investigation, records will be requested for review, but in criminal investigations a subpoena may be required to legally obtain these records. Likewise, a review of the workplace may be conducted by an auditor without a search warrant; however, if the auditor is working as an agent of the police, a search warrant would be necessary.

Administrative investigations are documented with working papers, usually prepared in an audit-type format. Criminal investigations primarily are documented through offense reports, and then supporting documents are attached as needed. The final reports for administrative investigations usually are formal reports or memoranda to management. The conclusion of a criminal investigation is the collection and preservation of evidence, reports, and other documentation the prosecution will need for court presentation, and the warrant for an arrest.

Example of an Administrative Case Turned Criminal

In June 1997, we received allegations regarding mismanagement of the campus housing department. We met and decided to investigate the allegations as an administrative case with Bowers directing the investigation. The police investigator assigned to the internal audit department, an internal auditor, and a few external auditors began gathering evidence. By August 1997, the evidence indicated criminal activity.

Due to our partnership, the transition of the case from an administrative investigation to a criminal investigation went quite smoothly. We met one afternoon, analyzed all the evidence, and agreed the case was criminal. Next, we met with the respective vice presidents, general counsel, and the University’s president to relay our decision to move the case to the criminal arena. At this time, Bowers relinquished the lead as the primary investigative body and Coffey assumed the lead role. We also met with the external auditors and the state attorney’s office to advise them of the potential ramifications of the current case.

The internal audit staff assisted the police investigator in the completion of the case. By doing this, the auditors learned techniques of criminal investigations (how to prepare requests for subpoenas and affidavits, and presentation techniques to the state attorney and other law enforcement agencies, etc.). Auditors also learned about the rules of evidence and how to apply them readily during the investigation.

The remaining investigation took eight months. From the state controller’s office, we obtained microfiche copies of student payroll checks issued for this department during the past year. From the local bank, we obtained bank statements for a campus organization and several individuals. Analysis of these documents showed how monies had been diverted from the state into a campus organization account and then taken from the account as cash or payment of personal expenses. Interviews, subsequently, were conducted on and off campus by campus police.

Both of our departments maintained various types of referencing tools, such as subpoena logs, document logs (showing chain of custody of documents), and time lines of activity by each audit/police employee working on the case. This facilitated our presenting the case to the state attorney for placing charges.

At the conclusion of the criminal case, a total of 85 charges – ranging from grand theft, petit theft, and unlawful financial transactions – were placed against the former housing director. These charges dated from 1994 to 1997. Twenty-seven individuals were affected by the inappropriate payroll transactions (totaling in excess of $31,000), inappropriate travel expenses, and abuse of long distance. Another individual was charged with grand theft (approximately $26,000) related to his involvement in the scheme.

Tips and Suggestions for Partnering 

We feel our partnering endeavor has been successful and we plan to continue working together as the need arises. Upon reflection, we offer several suggestions to make a police/auditor investigative partnership successful:

• Meet periodically (at least weekly) and keep detailed notes;
• Coordinate tasks to be performed;
• Determine the interview settings: friendly, neutral, or hostile;
• Establish files for each witness and store pertinent document(s) in these files (for example, personnel history, copies of intercepted checks, affidavits of forgery, interview notes/summaries, etc.);
• Make duplicate files for the prosecutors (Ensure they mirror the witness files you have established for your own records); and
• Cross-reference between the files and schedules, so the prosecutors or other reviewers may readily find the information.

Would We Recommend Partnering?

Absolutely! The partnership we have established is a testimony to intrinsic motivation. Each department has gained new insight and learned about the other’s operations. No longer do we view each other’s departments as separate “turfs” but as similar operations with the common goal of making our school the best it can be. As Daniel Seymour wrote, “Transformation, or re-creation of the institution, begins by challenging the sanity of doing things the same way they have always been done....The goal is not change; the goal is renewal.” We feel our partnership has been just that, a renewal of our commitment to the university and its success.

J. Betsy Bowers, CFE, CIA, CGFM, is the inspector general at the University of West Florida. She has a bachelor’s degree in accounting and a master’s degree in business administration from East Tennessee State University. 

Richard C. Coffey is the chief of police at the University of West Florida and the current chairman of Florida’s Criminal Justice Standards and Training Commission. He has a bachelor’s degree in public safety from the University of West Florida and a master of science degree in criminal justice from Troy State University 

1. See Joseph T. Wells, CFE, CPA, “Fraud Examination Units,” The White Paper, February/March 1993. This article expounds on the concept of creating a department specifically to detect, investigate, and prevent fraud.
2. Supreme Court Case: Edward J. Garrity et al., Appellants v. State of New Jersey. (1967) 87 S. Ct. 616 17 L. Ed.2d562, (Cite 385 U.S. 493, 87 S. Ct. 616). Garrity establishes the rights of employers to compel employees to answer questions as to possible violations of set rules, regulations, and policies. Further, this case ruled that any statements made during a “Garrity”-invoked interview could not be used for any subsequent criminal investigation or proceeding.
3. Supreme Court Case: Miranda v. Arizona, 384 U.S. 436 (1996).
4. Daniel Seymour, Once Upon a Campus, American Council on Education and The Onyx Press, Phoenix, Ariz.: 1995, p. 102.