Preventing Evaluation Fraud in Federally Funded Programs

Introduction: How the Agency Created This Problem

The program staff in this case are deeply confused and anxious about the routine collection of demographic information required by the federal government — a requirement that almost certainly has nothing to do with the actual content of their training manual. It appears they were simply unaware that the collection of such information was one of the conditions of their funding, or they were so focused on their core work that they neglected this administrative requirement entirely. They were therefore negligent in their duties by failing to ensure they were adequately informed about the need to collect basic demographic information from all participants at the start of the project.

Even worse, they are now about to compound the problem significantly by committing an act of academic fraud — supplying false information about participants' ages, incomes, and other demographic factors. The head of the project is particularly at fault for failing to notice that the new evaluation form requested this data, given that the form used in the previous year did not include such a requirement. This oversight set the stage for a much more serious ethical and legal crisis.

Part of the evaluation concerns what the agency accomplished in its workshops, which is not a problem for the staff since they have records of all interventions that took place. However, the federal evaluators also want demographic data so they can compare this program's participants with those from all other federally funded projects. By law, federal agencies are required to report to Congress and to the executives of their own agencies how many people participated in a given program during any particular fiscal year.

Scope and Purpose of the Federal Evaluation

For this reason, evaluators request data on the ages, sex, employment status, and income of trainees — in short, all standard demographic information. Many federal agencies collect and share such data, including the Bureau of the Census, the Social Security Administration, the Department of Health and Human Services, the National Health Interview Survey, and the National Center for Health Statistics. This includes data on ages, incomes, disabilities, illnesses, and health services utilization, which is then shared with various administrative agencies (Siegel, 2002, p. 131).

Understanding the scope and purpose of an evaluation at the design stage is critical. Had the agency known from the outset that demographic reporting was required, staff could have built data collection into the very first workshop session. Evaluators must align data collection instruments with reporting mandates before a program begins, not after it ends.

The staff is very concerned that the federal evaluator will judge the quality of what they did in the workshops. In fact, they need not worry about that dimension, since they have complete records of the interventions that took place. They could not reasonably have been expected to know how many people watched their programming on television or what those viewers' demographic characteristics were — and they are not being asked to provide such information. They are only being asked to supply demographic data for people who physically attended their training workshops, which they simply failed to collect at the outset.

The head of the program appears to have been confused and did not realize that the federal government had changed its requirements from the previous year, now mandating the collection of demographic information across a variety of program types, including continuing education. While the program director seems to understand that the demographic requirement has little to do with the substantive content of the workshops, it was likely mandated by Congress or introduced through a regulatory change. Rather than responding to this oversight with transparency, the staff are now considering providing bogus and fraudulent information to a federal evaluator — data that will be completely useless regardless of whether the falsification is ever discovered.

Challenges Facing Staff and Evaluators

The only appropriate response in this situation is for the agency to admit that it failed to collect the required data. This admission may reflect poorly on the program director, but it is the only ethical and legally defensible course of action. As Speight and Foote (2011, p. 282) note, intentional falsification and fabrication constitute the most serious type of research fraud, and even being aware that such fraud has occurred without reporting it is itself unethical.

The employees in this situation would be far better served by simply admitting to the federal evaluators that they failed to collect the required demographic data. The rank-and-file staff were not directly responsible for this oversight, since it was the program director who failed to notice the requirement. However, they will become responsible — and legally complicit — if they agree to go along with the director's plan to falsify the information.

For whatever reason, the staff were not aware that this demographic information needed to be collected, and the appropriate response is to acknowledge the lapse and commit to collecting the data properly in future funding cycles. This is a straightforward and honest resolution that, while potentially embarrassing, carries no legal risk.

It is also worth emphasizing the role that employees play in the broader evaluation process. Program evaluation depends on the integrity of the data provided by program staff. When staff falsify or fabricate that data, they do not merely mislead one evaluator — they corrupt the larger dataset that federal agencies use to report to Congress and make policy decisions. Each individual employee has a professional and ethical duty to protect the integrity of that process.

Conclusion: What Should Have Been Done Differently

Speight, J. G., & Foote, R. (2011). Ethics in Science and Engineering. Scrivener Publishing.