DoD FWA Compliance Checklist: Policies, Training, Monitoring, and Hotline Reporting

DoD FWA Compliance Policies

Purpose and scope

This checklist helps you build and maintain a robust Fraud, Waste, and Abuse (FWA) program aligned to DoD expectations. It anchors day-to-day controls to program integrity enforcement while ensuring clear reporting pathways and protection from retaliation.

Core policy elements to include

• Definitions of fraud, waste, and abuse with mission-relevant examples.
• Code of ethics, conflicts-of-interest disclosures, and gift/benefit restrictions.
• Reporting channels: your chain of command, local IG, and the DoD Inspector General Hotline.
• Non-retaliation commitments and confidential reporting options.
• Recordkeeping and evidence-handling procedures for allegations and investigations.
• Risk assessment cadence tied to budget, acquisition, healthcare, travel, and payroll risks.
• Escalation rules, including thresholds for immediate IG referral and law enforcement coordination.

Governance and maintenance

• Appoint an accountable compliance owner with cross-functional authority.
• Review policies at least annually and after major organizational or regulatory changes.
• Map controls to key risks and document ownership, frequency, and testing methods.
• Track policy attestations and maintain signed acknowledgments.

DoD FWA Compliance Training

Compliance Training Requirements

Training should cover who must report, what to report, and how to report—reinforcing responsibilities for military members, civilian employees, and contractors. Require initial training at onboarding and periodic refreshers to keep standards current.

Curriculum essentials

• FWA definitions, red flags, and real-world scenarios from your functional areas.
• Reporting Chain of Command and DoD Inspector General Hotline options, including confidentiality.
• Documentation basics: what information to capture, preserve, and share.
• Anti-retaliation protections and witness responsibilities.
• Role-specific modules for acquisition, finance, healthcare, and travel card holders.

Delivery and verification

• Blend e-learning with live workshops, tabletop exercises, and case studies.
• Use knowledge checks, scenario walk-throughs, and attestation prompts to verify comprehension.
• Track completions, overdue training, and remediation in a central dashboard.

DoD FWA Compliance Monitoring

Continuous monitoring framework

Monitoring validates that controls work in practice. Use risk-based sampling, automated analytics, and targeted reviews to detect anomalies before they escalate.

Key monitoring activities

• Claims Payment Audits to identify improper payments, upcoding, or duplicate claims.
• Service Pattern Reviews to flag unusual volumes, frequencies, or provider outliers.
• Vendor and contract surveillance, including change-order trends and sole-source justifications.
• Timekeeping, travel card, and purchase card analytics to spot misuse and split purchases.
• Access and segregation-of-duties reviews across financial and procurement systems.

Issue management

• Route findings to owners, set due dates, and verify corrective action effectiveness.
• Aggregate themes quarterly to drive program integrity enforcement and policy updates.

DoD FWA Compliance Hotline Reporting

Purpose and protections

The DoD Inspector General Hotline provides confidential channels to report FWA when normal supervision is ineffective or inappropriate. Policies must affirm anti-retaliation protections and encourage early reporting.

What to include in a report

• Who, what, when, where, and how—include dates, amounts, and contract or claim identifiers.
• Any documents, emails, or screenshots that support the allegation.
• Whether the matter has been reported to your supervisor or local IG.

Intake and triage

Establish procedures to log, triage, and route allegations promptly. Define criteria for immediate escalation to the IG or law enforcement and maintain chain-of-custody for evidence.

Reporting Procedures and Channels

Reporting Chain of Command

Encourage reporting through the immediate supervisor when appropriate. If the chain is implicated or unresponsive, report directly to your IG office or the DoD Inspector General Hotline without delay.

Approved channels

• Supervisor or higher commander for operational issues.
• Local Inspector General and Component hotlines for investigative intake.
• Compliance, legal, security, and HR for specialized concerns (e.g., safety, harassment, or security violations).

Documentation and timelines

• Assign case numbers, capture key facts, and timestamp all actions.
• Set service-level targets for acknowledgment, triage, investigation, and closure.
• Provide periodic status updates to reporters when permissible.

FWA Detection Techniques

Data-driven methods

• Outlier analytics on payments, vendor master data, and approval patterns.
• Duplicate detection and text mining of invoices, justifications, and emails.
• Network analysis to uncover collusion among vendors or employees.

Targeted reviews

• Claims Payment Audits for improper payments and coding anomalies.
• Service Pattern Reviews to compare utilization against expected baselines.
• Surprise cash counts, inventory spot checks, and site visits.
• Conflict-of-interest screening and gift log examinations.

Proactive and reactive balance

Blend continuous controls with responsive investigations. Use detection results to refine training, tighten approvals, and reinforce program integrity enforcement.

Roles and Responsibilities in Compliance

Leadership

Commanders and senior leaders set tone, allocate resources, and hold teams accountable for results. They approve risk appetites and ensure independence for compliance and IG functions.

Compliance and program owners

Compliance officers design the control framework, perform monitoring, and coordinate with auditors and investigators. Program owners implement controls and remediate findings quickly.

Supervisors and employees

Supervisors model ethical behavior, reinforce reporting expectations, and escalate suspected misconduct. Every employee and contractor must recognize red flags and report concerns promptly.

Auditors and investigators

Auditors test controls and quantify risk; investigators gather facts, protect evidence, and recommend corrective actions. Coordination ensures fair, timely outcomes and durable fixes.

Key takeaways

• Clear policies, role-based training, and continuous monitoring reduce FWA risk.
• Multiple reporting channels—especially the DoD Inspector General Hotline—enable safe, timely disclosures.
• Program integrity enforcement depends on swift remediation and leadership oversight.

FAQs.

What is the DoD IG Hotline phone number for reporting FWA?

You can report suspected Fraud, Waste, or Abuse to the DoD Inspector General Hotline by calling 1-800-424-9098. You may also report through your local IG or your chain of command if appropriate.

How often is FWA compliance training required?

At a minimum, require initial training at onboarding and refresher training on a recurring basis, typically annually. Components may mandate more frequent or role-specific refreshers based on risk.

What monitoring methods does DoD use to detect FWA?

Common methods include claims payment audits, service pattern reviews, data analytics for outliers and duplicates, vendor surveillance, timekeeping and purchase card reviews, and surprise inspections with targeted sampling.

Who must report suspected fraud within the DoD?

All DoD personnel—military members, civilian employees, and contractors—have a duty to report suspected FWA. If your chain of command is unsuitable or unresponsive, contact your IG or the DoD Inspector General Hotline.