15. Title IV Fraund

KCTCS will refer applicants who are suspected of having engaged in fraud or other criminal misconduct in connection with Title IV programs to the DOE Office of Inspector General (OIG). The regulations require only that KCTCS refer the suspected case for investigation, not that it should reach a firm conclusion about the propriety of the applicant’s conduct. The local KCTCS College Financial Aid Office should resolve discrepancies in the information received from different sources with respect to a student’s application for Title IV aid.

Areas include but are not limited to:

• All student aid applications (e.g. federal, state, institutional, etc.)
• Need analysis documents (e.g. ISIRs and SARs)
• Copies of federal and state income tax returns
• Information regarding a student’s citizenship
• Previous educational experience (e.g. school credentials such as a high school diploma)
• Documentation of the student’s Social Security Number (SSN), if needed
• Other factors relating to the student’s eligibility for funds under Title IV aid programs(e.g. compliance with the Selective Service registration requirement)

Examples of financial aid fraud include but are not limited to:

• Falsified documents or forged signatures on an application, verification documents, orloan promissory notes
• False statements of income
• False statements of citizenship
• Use of false or fictitious names or aliases, addresses, or social security numbers,including the deliberate use of multiple social security numbers
• False claims of independent status
• Patterns of misreported information from one year to the next

If the local Financial Aid office suspects any type of fraud, the Financial Aid Director should contact the System Office Financial Aid Office and provide documentation as to why they suspect the student may be involved in fraud. This information will be submitted to the KCTCS Office of Legal Services for review. If deemed appropriate, a referral will be made to the DOE OIG of Inspector General (OIG) along with any credible Information indicating that an applicant for Federal Student aid may have engaged in fraud or other criminal misconduct in connection with his or her application.

KCTCS has a Whistleblower Policy (KCTCS Administrative Policy and Procedures 2.20 and related Business Procedures 1.20) that provides a means for reporting any type of suspected fraud, waste and abuse. All reports are investigated through the KCTCS Office of Legal Services, and appropriate action taken internally or reported to law enforcement authorities as necessary.

All departments of a KCTCS college that suspects a student, employee, or other individual has misreported information and/or altered documentation to increase student aid eligibility or to fraudulently obtain federal funds, shall report those suspicions and provide any evidence to the local college financial aid office. The local financial aid office will contact the KCTCS System Office Financial Aid Office. This information will be submitted to the KCTCS Office of Legal Services for review. If deemed appropriate, a referral will be made to the Department’s OIG. The OIG website at contains information on the various methods by which an institution can report suspected fraud.

Under the American Recovery and Reinvestment Act of 2009 (ARRA), nonfederal employees who report waste, fraud or abuse connected to the use of ARRA funds may not be discharged, demoted or otherwise discriminated against because of his or her disclosure.