1 NATIONAL SCIENCE FOUNDATION 4201 WILSON BOULEVARD ARLINGTON, VIRGINIA 22230 OFFICE OF INSPECTORGENERAL I MEMORANDUM arch ....... 31, 1997 ......... . ..... .A- - - ....... ..................... .- - ,- .... .-.... To : Case File No. I9 Through: s-pe vestigations Section From: w Forensic Scientist, Investigations Sectio ecial Agent, Investigations Sectio Investigative Attorney, Investigatl Re: Case Resolution - we investigated to determine whether Dr. the same travel expenses he incurred in August 1 I. Background has been employed a m a s a full-time professor since August 1992. At one point, e was simultaneously employed b University. He remained on a leave of absence fro during the academic and 1993-94. Dr active NSF grants. has 11. The Double Reimbursement the trip to the mathematics department accountant in order for the accountant to prepare a -ravel expense report for him ses totaled $2,401 and included airfare of $459 and hotel ned and submitted the travel expense repor el expense report listed many trips, including his trip did not include any information regarding a reimbur id include information about a reimbursement related to a trip to Santander, Spain (one of the other trips he had claimed on this same travel expense report). ...... . . ... .. ........-..-...... Approximately nine months prior to the trip, however, Dr. -. ... was informed by-.& ... .e.-.., ... at it would fund a portion of his trip to th ately September 13, drafted, signed and subm Expense Voucher requesting , , for his airfare exDenses. B ive reimbursement t h m n d l f o r the airfare expenses on, because these expenses were grant-related, from his NSF grant funds. The es incurred during the i n P a k and deposited the chec into is personal bank account. At that time, he did not use t h e m f u n d s to pay back the NSF grant, which had already fully reimbursed him. Dr. has acknowledged that he received duplicate reimbursements. He said that he sub vouchers because he was unsure as to when and how much reimburse him for his expenses. He claimed that he intended to reimburse - grant with the funds fro 'S actually received th when he received them, but that he forgot to do so when he check. He said that when he realized that he had neglected to reimburse the NSF grant in August 1996), he went to his department chairman the very next day, discussed the matter with him, and wrote a personal check t o f o r $1,700. The $1,700 was subsequently credited to the NSF grant. w s said that he paid back more than the amount of the double reimbursement for t ree r sons. First, he realized that t h t r a v e l expense report was filled out incorrectly, and charged the NSF grant $215.71 for previously paid hotel charges for the trip to Zurich. Second, h~ remembered that he received a larger amount in reimbursement funds from his visit to Sahtander, Spain than he originally reported on the travel expense report. Finally, Souganidis said that he thought he might be liable for financial penalties for his failure to reimburse the grant. 111. Other Payments In an interview with NSF OIG ' special agents, stated that he had received payments from other universities/organizations in the form of honoraria payments. He said that he received honoraria during some of the same.trips wherein he claimed reimbursement for travel expenses from his NSF grants, but that he used these honoraria during his travel to defray expenses such as lodging and meals. Despite receiving over twenty honoraria payments since 1993,-aimed to be unfamiliar with any o f r NSF's policies regarding crediting honoraria to the program that supported travel to and from a host organization. After the i n t e r ~ i e w -- , ~ r o v i d ae list d of all the honoraria that he has received over the past four years. In analyzing the list, we found six instances geh cw ra'ehre to his NSF grants for I travel expenses plus the honoraria he received while on that travel exceeded the actual travel expenses by $200 or more. This analysis, however, actually supports -ontention that he used his honoraria to defray part of his travel expenses because, for the six trips, , I l - -- --- w - -- i d not charge his __ NSF grants for expenses such as lodging and/or meals. In fact, on one of these trips, he used ~ e r s o n a funds l to make up-the differenceb-etWeEnnliiG5%pEiKes -- and what he claimed. IV. Conclusions NSFOIG reviewed account summaries, consultant and participant support payments, salaries, and all travel expenditures for -_rants. This review did not detect additional misuse of grant funds. The doublep$ment appears to have been an isolated incident. appears to have violated 18 U.S.C. $ 1001, False Statements, by submitting the expense report certifying that he did not and would not receive any other reimbursement for the expenses,listed. This certification stated: stated in his affidavit that: Intent is not required, however, to violate 18 U.S.C. $ 1001. His intentional submission of a false statement, i.e. the certification, is sufficient to violate the statute. However, the fact that this was an isolated incident, as opposed to part of a pattern of abuse, suggests that it is unsuitable for prosecution. submission of duplicative documents may have violated 3 1 U.S.C. $3 3729-3733, aims Act. He claimed that he intended to reimburse his NSF grant. We have found no evidence which illustrates a pattern of submitting duplicate travel vouchers, and therefore the intent to defraud the government cannot be established. In addition, we believe that can claim that the six trips described above were related to his NSF research, these trips were for collaborations not mentioned in proposals. The NSF Grant Policy Manual's regulation on travel costs is We have concluded that ay- be able to legitimately claim that these expenses were "relatedn to his NSF grants and therefore are allowable costs against his NSF grants. These facts appear to support assertion that he was using the honoraria to offset -- - - .- .. . . . .. .. - ~ anddid his.tr.a~l.-ex.~e-~se_s_.,- profit from his travel charged to his NSF _- grants. ---_- .- -. - _. The U.S. Attornev's Office for the Eastern District of Virginia has declined this case for prosecution. Due ro the lack of evidence to support tha-has formed a pattern of fraudulent behavior and activity, this case is closed.
Published by the National Science Foundation, Office of Inspector General on 1997-03-31.
Below is a raw (and likely hideous) rendition of the original report. (PDF)