Office of the Ohio Inspector General 2024 Annual Report
Summary
This is the Office of the Ohio Inspector General’s 2024 Annual Report, submitted by Inspector General Randall J. Meyer to the governor and members of the 136th Ohio General Assembly under Ohio Revised Code §121.48. It describes the office’s complaint and investigative processes and statistics, and summarizes investigations released from January 1, 2024, through December 31, 2024. Meyer’s message says that between 2021 and 2024 the office opened 23 investigations involving the Ohio Department of Job and Family Services (ODJFS) and the Pandemic Unemployment Assistance (PUA) program, and that five completed in 2024 identified a total loss of $13.3 million to the State of Ohio. To date, it says, 13 PUA reports of investigation have identified over $20.5 million lost and 95 criminal charges issued. Appendices hold statutory references and a table of organization.
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Office of the Ohio Inspector General
Rhodes State Office Tower 30 East Broad Street - Suite 2940 Columbus, Ohio 43215-3414
Office of the
Phone: 614-644-9110 FAX: 614-644-9504 Toll Free: 800-686-1525 Ohio Inspector General
Randall J. Meyer
Email: watchdog@oig.ohio.gov Website: watchdog.ohio.gov
2024
Annual
Report
Office of the Ohio Inspector General / 2024 Annual Report
Inspector General Randall J. Meyer
Randall J. Meyer was appointed as Ohio Inspector General in January 2011, and reappointed
by the governor of Ohio and confirmed by the Ohio Senate in 2015, 2021, and 2025. While
serving as the inspector general, Meyer has released 792 reports of investigation, issued
1,614 recommendations to agencies, and identified over $1/4 billion lost to the State of
Ohio. Meyer has been active on the board of directors of the National White Collar Crime
Center since 2008, and in 2020 was elected as an officer to the board. In addition, from
2013 through 2023, Meyer served on the board of directors of the Association of Inspectors
General.
Inspector General Meyer has dedicated his career to public service for more than 35 years.
After completing four years of honorable military service in the United States Navy, Meyer
began work as a police officer in 1990, serving as a deputy in the San Francisco Bay area. In
1992, Meyer returned to Ohio, working first as a police officer, and then as a detective for the
City of Wilmington Police Department. In 1999, Meyer was recruited to serve as a criminal
investigator for the Ohio Attorney General, and was eventually promoted as director of the
Ohio Attorney General’s Anti-Gang Unit. During this time, Meyer developed and established
G.U.A.R.D., a statewide security threat group database which singularly integrated the
various data collection systems used by different investigative entities. In 2003, Meyer
joined the Ohio Auditor of State’s Public Corruption Unit as senior investigator and, in
2007, was promoted to chief of Special Investigations, managing the unit’s responsibility of
identifying misappropriated or illegally expended public funds, and instituting a statewide
fraud prevention training program.
Meyer earned a bachelor’s degree in Public Safety Management from Franklin University.
He is certified as a fraud examiner with the Association of Certified Fraud Examiners, holds
a certification as an economic crime forensic examiner with the National White Collar Crime
Center, and is a certified inspector general with the Association of Inspectors General.
Office of the Ohio Inspector General / 2024 Annual Report
Message from the Inspector General
I am pleased to present the Office of the Ohio Inspector General’s
2024 Annual Report. This report is submitted to the governor and
members of the 136th Ohio General Assembly in accordance with
Ohio Revised Code §121.48. This report outlines the mission and
responsibilities of the Inspector General’s Office; examines the office’s
complaint and investigative processes and related statistics; and cites
summaries of several investigations the office released from January
1, 2024, through December 31, 2024.
During my tenure, the Office of the Ohio Inspector General (OIG)
has identified issues of particular concern warranting special
attention. For instance, between 2021 and 2024, the office opened Randall J. Meyer
23 investigations involving the fraudulent disbursals of millions Inspector General
of taxpayer dollars involving the Ohio Department of Job and
Family Services (ODJFS) and the Pandemic Unemployment Assistance (PUA) program.
Significant staff resources were assigned to these cases to perform various investigative
actions including issuing subpoenas for records, completing forensic analysis, conducting
interviews, assisting in search warrants, administering prolonged surveillance of targeted
individuals, and collaborating with state and federal partners and local prosecutors. In 2024,
five of these cases were completed and released by the OIG, identifying a total loss of $13.3
million to the State of Ohio. To date, the OIG has completed and released 13 reports of
investigation specifically related to the abuses of the PUA program, identifying over $20.5
million lost and 95 criminal charges issued. In some instances, these cases have resulted in
indictments for multiple offenses including first- and second-degree felonies that carry up to
10 and eight years in prison, respectively.
Since 2011, the first year of my appointment, the OIG has released 792 reports of
investigation, issued 1,614 recommendations to agencies, and identified over $1/4 billion lost
to the State of Ohio.
As Ohio’s Inspector General, my office continues to find new techniques to combat
malfeasance, innovative methods to increase public trust, and meaningful recommendations
to improve and expand current best practices and processes.
Respectfully submitted,
Randall J. Meyer
Office of the Ohio Inspector General / 2024 Annual Report
Table of Contents
Mission and Responsibilities................................................................................................. 1
Conducting an Investigation. ............................................................................................... 2
Filing a Complaint. ................................................................................................................3
Types of Allegations..............................................................................................................4
2024 Statistical Summary. ....................................................................................................6
Report from the Inspector General for the General Area...................................................8
A Focus on Pandemic Unemployment Assistance Investigations...........................9
Summaries of PUA Cases.................................................................................. 11
Summaries of Selected Cases - General..................................................................29
Report from the Inspector General
for the Ohio Department of Transportation..................................................................... 48
Summary of Selected Case......................................................................................49
Report from the Inspector General for the
Ohio Bureau of Workers’ Compensation and Industrial Commission.............................. 52
Summary of Selected Case......................................................................................54
2024 Community Outreach.................................................................................................56
APPENDICES........................................................................................................................ 57
Appendix 1: Statutory References.......................................................................... 57
Appendix 2: Table of Organization.........................................................................67
CONTACT INFORMATION.................................................................................................. 68
Office of the Ohio Inspector General / 2024 Annual Report
Mission and Responsibilities
Safeguarding Integrity in State Government
The Office of the Ohio Inspector General was established
in 1988 by an Executive Order of the Governor.
Through this executive order, the inspector general
was charged with the authority to, “… examine,
investigate, and make recommendations with respect
to the prevention and detection of wrongful acts and
omissions in the Governor’s Office and the agencies of
state government… .” In 1990, the legislature passed
Amended Substitute House Bill 588, which permanently
established the position and the Office of the Ohio
Inspector General.
The jurisdiction of the Inspector General’s Office is limited to the executive branch of
state government and to any person and/or vendors who do business with the state.
The inspector general is authorized by law to investigate alleged wrongful acts or
omissions committed by state officers or employees. It extends to the governor, the
governor’s cabinet and staff, state agencies (as defined in Ohio Revised Code (ORC) §1.60),
departments, authorities, and boards and commissions. The inspector general’s jurisdiction
includes state universities and state medical colleges, but does not include community
colleges. The courts, the General Assembly, and the offices of the Secretary of State, the
Auditor of State, the Treasurer of State, and the Attorney General, and their respective
state officers or employees are statutorily excluded from the jurisdiction of the Inspector
General’s Office. Likewise, the office has no authority to investigate allegations concerning
any federal, county, municipal or other local officials, agencies, or governing bodies.
The inspector general’s authority extends to:
• Addressing complaints received by the office alleging that wrongful acts or omissions
have been committed or are being committed by a state officer or employee; or any
person or vendor who does business with the state.
• Investigating the management and operation of state agencies on the inspector
general’s initiative to determine whether wrongful acts and omissions have been
committed or are being committed by state officers and employees.
The Inspector General’s Office does not become involved in private disputes, labor/
management issues, or litigation. The office does not review or override the decisions of a
court or the findings of any administrative body.
The Inspector General’s Office is not an advocate for either the state agency or the
complainant in any particular case. The office’s obligation is to ensure that the investigative
process is conducted fully, fairly, and impartially. As independent fact finders, wrongdoing
may or may not be found as the result of an investigation.
1
Office of the Ohio Inspector General / 2024 Annual Report
Conducting an Investigation
Complaint Process and Reports of Investigation
Anyone may file a complaint with the Inspector General’s Office. At times, complaints
are forwarded by other agencies or officials. Complaint forms can be downloaded
from the inspector general’s website or are provided upon request. Complaints can be
made anonymously. However, without the ability to follow up and ask questions of the
complainant, anonymous complaints are often more difficult to investigate and verify.
The inspector general may grant complainants or witnesses confidentiality. When
appropriate, information received from complainants and witnesses may also be deemed
“confidential.” Confidentiality is appropriate when it is necessary to protect a witness. It
is also appropriate in cases where the information and documentation provided during the
course of an investigation would, if disclosed, compromise the integrity of the investigation
or when considered confidential by operation of law.
The Inspector General’s Office does not offer legal advice or opinions to complainants.
In instances where it appears that a complainant is seeking legal assistance, or where it
appears that another agency is better suited to address a complainant’s issues, the office will
advise the complainant to consult with private legal counsel or a more appropriate agency,
organization, or resource.
Complaints received are reviewed by the intake committee. This committee consists of
the inspector general, chief legal counsel, and case manager. A complaint offering credible
allegations of wrongful acts or omissions that fall within the inspector general’s jurisdiction is
assigned to a deputy inspector general for investigation. Opened and ongoing investigations
are generally not subject to public disclosure in order to safeguard the integrity of the
investigative process.
At the conclusion of an investigation by the Inspector General’s Office, a report of
investigation is completed and provided to the governor and the agency subject to
investigation. The report may include recommendations for the agency to consider in
addressing and avoiding the recurrence of fraud, waste, abuse, or corruption uncovered by
the investigation. For each report where the inspector general concludes there is reasonable
cause to believe wrongful acts or omissions have occurred, the agency subject to the
investigation is asked to respond back to the inspector general within 60 days of the issuance
of the report, detailing how the report’s recommendations will be implemented. Although
there is no enforcement mechanism to ensure items are addressed, the inspector general
exercises his due diligence and follows up with the agency. When appropriate, a report of
investigation may also be forwarded to a prosecuting authority for review to determine
whether the underlying facts give rise to a criminal prosecution. Selected issued reports
of investigation are posted on the inspector general’s website and all issued reports of
investigation are available to the public upon request, unless otherwise noted by law.
2
Office of the Ohio Inspector General / 2024 Annual Report
Filing a Complaint
OIG
Complaint determines
received if complaint falls No
by OIG within its
jurisdiction
OIG refers complaint
Yes to appropriate
agency or declines
for insufficient cause
OIG determines if
complaint has
sufficient cause for No
further investigation
Yes
Case is initiated
by OIG and
investigator
is assigned
Yes
OIG
Matter is closed
determines
and final report No if case
issued
is founded
Yes
Agency is
Final report issued given 60 days
to respond
3
Office of the Ohio Inspector General / 2024 Annual Report
Types of Allegations
Complaints submitted to the Inspector General’s Office may
include a wide range of wrongdoing and may include allegations
of more than one type of misconduct committed by an entity
or individual. As investigations proceed, new allegations
of wrongdoing may be discovered and other individuals or
entities may become part of the investigation. Five types of
wrongdoing that fall under the inspector general’s jurisdiction
are:
Fraud
An act, intentional or reckless, designed to mislead or deceive.
Examples:
• Fraudulent travel reimbursement
• Falsifying financial records to cover up a theft
• Intentionally misrepresenting the cost of goods or services
• Falsifying payroll information or other government records
Waste
A reckless or grossly negligent act that causes state funds to be spent
in a manner that was not authorized or which represents significant
inefficiency and needless expense.
Examples:
• Purchase of unneeded supplies or equipment
• Purchase of goods at inflated prices
• Failure to reuse major resources or reduce waste generation
4
Office of the Ohio Inspector General / 2024 Annual Report
Abuse
The intentional, wrongful, or improper use or destruction of
state resources, or a seriously improper practice that does not involve
prosecutable fraud.
Examples:
• Failure to report damage to state equipment or property
• Improper hiring practices
• Significant unauthorized time away from work
• Misuse of overtime or compensatory time
• Misuse of state money, equipment, or supplies
Corruption
An intentional act of fraud, waste, or abuse, or the use of public office
for personal, pecuniary gain for oneself or another.
Examples:
• Accepting kickbacks or other gifts or gratuities
• Bid rigging
• Contract steering
Conflict of Interest
A conflict of interest is a situation in which a person is in a position to
exploit his/her professional capacity in some way for personal benefit.
Examples:
• Purchasing state goods from vendors who employ or are
controlled by the purchaser’s relatives
• Outside employment with vendors
• Using confidential information for personal profit or to
assist outside organizations
5
Office of the Ohio Inspector General / 2024 Annual Report
2024 Statistical Summary
The Inspector General’s Office received a total of 396 complaints in 2024. From 2011 through
2024, more than 4,700 complaints have been reviewed.
2024 Complaint Status
GENERAL ODOT1 OBWC/OIC2 ALL
Cases Opened 15 9 4 28
No Jurisdiction 189 0 0 189
Insufficient Cause 78 3 7 88
Referred 83 0 2 85
Pending3 3 2 1 6
Complaint Totals 368 14 14 396
1
ODOT = Ohio Department of Transportation.
2
OBWC/OIC = Ohio Bureau of Workers’ Compensation/Ohio Industrial Commission.
3
“Pending” are those complaints that require additional information before a determination can be made.
The following chart highlights the various methods in which complaints were received by the
Inspector General’s Office:
Methods in which Complaints were Received in 2024
U.S. Mail Fax Phone/Other
14% 2% 1%
Email
83%
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Office of the Ohio Inspector General / 2024 Annual Report
The Inspector General’s Office closed 22 cases in 2024. The number of cases closed may
reflect cases that were opened in previous years. The following chart summarizes the
outcome of the cases closed during the period covered by the 2024 Annual Report:
Results of Cases Closed in 2024
Total Recommendations Made to Agencies 57 in 14 cases
Total Referrals 34 in 17 cases
Total Criminal Charges 64 in 4 cases
Identified Monetary Loss $14,575,258.33 in 8 cases
Of the 22 cases closed in 2024, the following chart illustrates the percentage of allegations in
closed cases that were found to be substantiated versus those allegations that were found
to be unsubstantiated.
Findings of Allegations for Cases Closed in 2024
Unsubstantiated
28%
Substantiated
72%
The following chart shows the types of alleged wrongdoing substantiated in cases closed
in 2024. Cases investigated for criminal conduct (46%) and state contracts (18%) led the
categories in the cases closed for 2024.
Substantiated Allegations by Type in 2024
Abuse of
State Contracts Office/Position
18% 16%
Improper
Rules & Policies Practices
16% 2%
Bribery &
Corruption
2%
Criminal
Conduct
46%
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Office of the Ohio Inspector General / 2024 Annual Report
General Area
2024 Report
In order to efficiently investigate matters delegated to this office by statute, the Inspector
General’s Office divides its investigatory casework between three separate areas. Two of
these areas, the Ohio Bureau of Workers’ Compensation/Ohio Industrial Commission (OBWC/
OIC), and the Ohio Department of Transportation (ODOT), have assigned deputy inspectors
general. These designated positions were created by specific statutes in the Ohio Revised
Code.
The third area, the General Area, is broad in scope and encompasses all the remaining State
of Ohio departments and agencies under the purview of the Governor’s Office. Deputy
inspectors general who are assigned casework in the General Area are responsible for
investigating matters within many entities of Ohio government, including the departments
of Job and Family Services, Natural Resources, Public Safety, and Rehabilitation and
Correction, to name a few. Because of the extensive nature of the casework performed in
the General Area, this area generates and reflects the largest amount of cases completed, or
closed, by the office.
In 2024, there were 15 cases opened and 16 cases closed in the General Area of the Inspector
General’s Office. As part of the lifespan of a case, the number of cases closed may reflect
cases that were opened in previous years.
2024 Cases Closed
ODOT,
OBWC/OIC
27%
General
73%
8
Office of the Ohio Inspector General / 2024 Annual Report
General Area
A Focus on Pandemic Unemployment Assistance
Investigations
In 2020, because of the COVID-19 pandemic and the
increased unemployment of millions of Americans,
Congress passed various programs to address the crisis.
The Coronavirus Aid, Relief and Economic Security
(CARES) Act was a $2.2 trillion economic stimulus bill
passed by the 116th U.S. Congress and was signed
into law on March 27, 2020. The CARES Act included provisions for the Pandemic
Unemployment Assistance (PUA) program. The PUA program provided temporary
benefits and support to self-employed individuals, independent contractors, and others
who did not qualify for traditional unemployment benefits and had lost work due to
COVID-19 related reasons. Additionally, the PUA program provided temporary benefits
and support to workers whose earnings averaged less than $280 per week in their
former jobs and permitted qualified applicants to receive these benefits for up to 39
weeks. During the COVID-19 pandemic, the Ohio Department of Job and Family Services
(ODJFS) Office of Unemployment Insurance Operations (ODJFS OUI) was responsible
for the distribution of PUA benefits to qualified individuals in Ohio.
The CARES Act stipulated that the distribution of PUA benefits to individuals was
to end on December 31, 2020. However, on December 27, 2020, the Consolidated
Appropriations Act was signed into law and extended the expiration date set by the
CARES Act for the payment of PUA benefits to qualified applicants from December 31,
2020, to March 14, 2021. The Act further extended the number of weeks an eligible
applicant could receive these benefits from 39 weeks to 50 weeks. On March 11, 2021,
the American Rescue Plan Act was signed into law and extended the payment of
PUA benefits to qualified individuals from March 14, 2021, to September 6, 2021, and
extended the maximum weeks an eligible applicant could receive these benefits from 50
weeks to 70 weeks. The State of Ohio ended the PUA program on September 4, 2021.
Because the PUA program expanded and loosened eligibility to obtain unemployment
benefits for recipients, the Ohio Department of Job and Family Services (ODJFS)
received an unprecedented number of unemployment compensation claims. This
increase in claims necessitated ODJFS to hire intermittent and temporary contracted
workers to process the claims. In fiscal year 2021, ODJFS disbursed approximately $7.6
billion in pandemic unemployment benefits and later, ODJFS identified millions of dollars
of the disbursals as fraudulent. To address the rampant fraud connected to the PUA
program, an investigative group was established in Ohio that consisted of the Office
of the Ohio Inspector General; Ohio State Highway Patrol; U.S. Department of Labor -
Office of Inspector General; and the Ohio Department of Job and Family Services.
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Office of the Ohio Inspector General / 2024 Annual Report
Overview of PUA Eligibility, Claim Processing, and Benefit Payments
During the period when PUA benefits were available for distribution, ODJFS posted on
their website the requirement for PUA applicants to self-certify their COVID-19 eligibility
to receive benefits. The U.S. Department of Labor issued guidance and defined PUA
eligibility for three groups of people:
• Those previously receiving traditional unemployment benefits who refused to
return to work or refused an offer of work because the workplace was not in
compliance with local, state, or national health and safety standards directly
related to COVID-19.
• Those who provided services to an educational institution or educational service
agency and were fully or partially unemployed due to COVID-19 related reasons.
• Those who were laid-off or had their work hours reduced due to COVID-19
reasons.
Also, to ensure applicants met the criteria of eligibility and to strengthen the integrity of
the PUA program, the Consolidated Appropriations Act amended the CARES Act by:
• Requiring states to verify the identity of applicants.
• Requiring applicants to substantiate employment or self-employment, and
wages earned or paid, to confirm eligibility for pandemic unemployment
assistance no later than 90 days from the date of application.
To determine PUA benefit eligibility and the proper release of payments , ODJFS used
the following process:
1. The Claimant Applied for Benefits: This was the initial step in the PUA claims
process and required the claimant to:
a. Complete a claim application questionnaire;
b. Enter their personal, demographic, and work history information;
c. Adjust the start date of the claim to the last date the claimant worked/
onset of COVID-19 date. This action was referred to as “backdating;”
d. Upload all ODJFS-required documentation into the claims system; and
e. Submit the claim.
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Office of the Ohio Inspector General / 2024 Annual Report
2. ODJFS Adjudication: After the claimant submitted the claim to ODJFS, the
adjudication step was the initial determination made by ODJFS on the claim
based on the accuracy and comprehensiveness of the claimant’s application and
uploaded documents.
3. ODJFS Redetermination (if applicable): This was a claimant appeal process
that occurred when a claim initially adjudicated as “Ineligible” was appealed
by the claimant. The claim was either sent to the appeals team or to the
redetermination team for further review.
4. Processing for Payment: Once the claimant was found to be eligible for benefits,
ODJFS performed steps to release benefit payments to the claimant by either
direct deposit or by “ReliaCard®,” which is Ohio’s unemployment-specific debit
card.
5. Payment Release: The claimant received their benefit payment by direct deposit,
or the funds were loaded onto their ReliaCard® for immediate use.
Once ODJFS contacted US Bank, a ReliaCard® debit card with the approved benefit
amount was mailed to the claimant.
Claimants could make purchases with the US Bank ReliaCard® anywhere Visa® and
Mastercard® debit cards were accepted, or could withdraw their PUA funds in the
form of cash from bank ATMs. The US Bank ReliaCard® does not require a personal
identification number or PIN for signature-based purchases should the claimant choose
credit when making the purchase. However, a PIN is needed for debit card purchases
and cash withdrawals from ATMs. The four-digit PIN is created by the cardholder when
activating the card.
Summaries of PUA Cases
OHIO DEPARTMENT OF JOB AND FAMILY SERVICES
FILE ID NO: 2023-CA00001
In January 2022, the Ohio Department of Job and Family Services (ODJFS) was notified
by the Federal Bureau of Investigation (FBI) of an anonymous report stating that
intermittent Customer Service Representative (CSR) Rashanna Burley was authorizing
previously denied Pandemic Unemployment Assistance (PUA) claims, which released
funds to ineligible claimants. Burley had been hired as an ODJFS intermittent CSR
on December 15, 2020, and was responsible for reviewing assigned PUA claims
to determine if all the required documentation had been properly submitted for
processing. The ODJFS Internal Fraud team conducted an audit of the 413 claims Burley
accessed during her employment. The Internal Fraud team reviewed Burley’s activities
in the ODJFS Unemployment Framework for Automated Claim and Tax Services
(uFACTS). From this audit of Burley’s alleged actions, ODJFS identified 20 claims as
fraudulent for various reasons and determined Burley improperly released payments
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Office of the Ohio Inspector General / 2024 Annual Report
for a total amount of $355,382 in PUA benefit funds to the 20 claim recipients. ODJFS
terminated Burley on January 13, 2021.
While auditing PUA claims accessed by Burley, ODJFS also audited the claims accessed
by Velma Cain who was hired as an intermittent CSR on January 19, 2021. From this
audit, ODJFS suspected Cain was performing fraudulent actions and had her de-
scheduled and her access to the PUA claims system revoked. ODJFS evaluated all 7,466
PUA claims Cain had accessed and identified 123 claims as fraudulent. As a result of
Cain’s fraudulent actions, a total amount of $1,582,251.50 was improperly released for
payment to individuals on the 123 fraudulent claims identified. Cain was terminated
from her employment with ODJFS on January 4, 2022.
ODJFS discovered an unusual crossover of claims accessed by Burley and Cain, and
referred the matter and their reported findings to the Ohio Inspector General and
other members of the PUA Investigative Group on January 13, 2023. The Ohio Inspector
General’s Office opened an investigation to establish what connections/relationships
existed between CSRs Burley and Cain. Investigators discovered that Velma Cain was
Rashanna Burley’s biological mother. In addition, investigators found 12 claimants
whose PUA claims were fraudulently accessed and improperly acted upon by Burley and
Cain, and 12 additional claimants who were friends and relatives of Burley and Cain that
were fraudulently accessed and improperly acted upon by Cain.
From investigators’ review of Burley’s and Cain’s actions, the following are examples of
the unauthorized actions taken by Burley and Cain to approve PUA benefits for ineligible
claimants with whom they had personal connections:
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Office of the Ohio Inspector General / 2024 Annual Report
Claimant #1
Burley accessed Claimant #1’s claim and adjudicated the claim, which she was not
trained or authorized to do, which improperly released $10,824 in PUA funds to
Claimant #1. Investigators discovered that Claimant #1 had been incarcerated in Warren
Correctional Institution since December 29, 2014, and was subsequently ineligible for
PUA benefits.
Claimant #2
Burley accessed Claimant #2’s claim and backdated the claim, which she was not trained
or authorized to do. Burley’s actions improperly released $10,824 in PUA funds to a US
Bank ReliaCard® debit card issued to Claimant #2. Claimant #2 was a Facebook friend of
Burley and had the same home address as Kyson Murphy (Claimant #13).
Claimant #4
Burley accessed Claimant #4’s claim and changed the claimant’s email address,
password, and bank account information, which was identified as an account takeover.
Burley’s action resulted in the improper release of $19,182 in ineligible PUA funds into a
bank account Burley fraudulently set up.
Claimant #7
Investigators discovered several personal connections between Claimant #7 and
Burley. Claimant #7’s name was listed on Burley’s ODJFS employment application as her
emergency contact. Claimant #7 was also mentioned on a post on Burley’s Facebook
account and was listed as a relative of Burley in an obituary for Burley’s grandmother.
Investigators also discovered that Claimant #7 was a close relative of Cain.
Burley accessed and fraudulently backdated Claimant #7’s claim, resulting in the
improper release of $19,371 in retroactive PUA benefit payments. Cain accessed
Claimant #7’s claim and fraudulently erased a $13,281 overpayment and improperly
released $1,323 in new PUA benefit payments. The fraudulent actions taken by both
Burley and Cain in Claimant #7’s PUA benefit claims resulted in the improper release of a
total of $34,164.
Claimant #10
Burley accessed Claimant #10’s claim and adjudicated a fraud issue as eligible. Burley’s
actions resulted in the improper release of $32,463 in PUA benefit payments to Claimant
#10. Burley’s Facebook account revealed a post where Burley identified Claimant #10 as
her aunt and wished her a happy birthday on the claimant’s birthday.
Claimant #11
Burley accessed Claimant #11’s claim and backdated the claim, and adjudicated the
identity verification issues as eligible. Burley’s fraudulent actions resulted in the
improper release of $32,693 in PUA benefit payments to Claimant #11, who had been
incarcerated in the Belmont Correctional Institution since November 29, 2018. Claimant
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Office of the Ohio Inspector General / 2024 Annual Report
#11’s ReliaCard® was mailed to an address that was used on two other fraudulent claims
which were manipulated by Velma Cain.
Claimant #13
Investigators found that Burley and Claimant #13 (Kyson Murphy) had a personal
relationship, had children together, and previously lived together at a former address
listed for Velma Cain. Investigators reviewed Murphy’s PUA claim and found that on
June 8, 2021, Cain had accessed Claimant #13’s claim, which was submitted by Kyson
Murphy, and Cain ruled an employment verification issue as eligible without obtaining
the required documents. Cain’s actions improperly released $7,824 in PUA benefit
payments to Murphy which was mailed to an address also used by claimants #2 and #3.
ODJFS determined that the pay stub Murphy submitted as an employment verification
document on this claim was “fake,” and Ohio Taxation Wage and Earnings records
indicate Murphy had not been employed since the third quarter of 2019. On May 20,
2021, Murphy was involved in a robbery that resulted in a shooting death of one of the
victims. On July 12, 2021, Murphy was arrested for aggravated robbery and murder.
During the homicide investigation, Murphy’s cellphone was searched which revealed
numerous calls and text messages between Murphy and Rashanna Burley.
In addition to the $7,824 Murphy had received from his own fraudulent PUA claim,
investigators also found three fictitious PUA claimants (Claimants #14, #16 and #17) that
Burley and Murphy created, submitting fictitious names and Social Security numbers as
required identity documentation for the processing of PUA claims. Cain then improperly
cleared the claims of those fictitious claimants as eligible, releasing funds to bank
accounts accessed by Burley and Murphy.
Claimant #14
On February 23, 2021, a claim for Claimant #14 was filed. The following day, on February
24, 2021, Cain accessed this claim, backdated the claim and adjudicated the claim as
eligible. Cain’s fraudulent actions resulted in the release of $31,386 in PUA benefit
payments into a Huntington bank account for Claimant #14. Claimant #14’s claim
and bank account were in the name of Kaitlynn Cole, which was a fictitious name.
Investigators found that on February 22, 2021, Rashanna Burley created the identity of
Claimant #14, Kaitlynn Cole. Burley went to the Ohio Bureau of Motor Vehicles office
claiming to have lost her driver’s license. After receiving a paper temporary driver’s
license form, Burley removed her name and operator’s license number from the
document and inserted the fictitious name of Kaitlynn Cole, and a fictitious operator’s
license number. However, Burley failed to remove her photograph, signature, and
address from the document. This fictitious form was then submitted as identification
for the claim, but no other required documents were submitted.
Huntington bank records for Kaitlynn Cole (fictitious Claimant #14), showed ATM
withdrawals, counter check withdrawals, and electronic payments to Rashanna Burley.
An analysis of this Huntington bank account indicated the account was used to receive
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Office of the Ohio Inspector General / 2024 Annual Report
and send payments to many of the claimants on claims upon which Burley and Cain
conducted fraudulent actions.
Claimant #16
On April 23, 2021, Kyson Murphy (Claimant #13) created the fictitious identity of Claimant
#16, Torey Goins, by going to the Ohio Bureau of Motor Vehicles office claiming to have
lost his identification card. After receiving a temporary paper identification card form,
Murphy removed his name and address from the form and inserted the fictitious name
(Torey Goins) and address and removed his signature under his photograph, leaving the
space blank. This fake temporary identification card form was submitted to ODJFS for
identity verification of fictitious Claimant #16, but no other required documents were
submitted.
On April 27, 2021, Murphy filed a claim for PUA benefits for fictitious Claimant #16 (Torey
Goins). On April 28, 2021, Cain accessed the claim and adjudicated the issues as eligible
without uploading to the claim the required identity and employment verification
documents.
According to ODJFS, Cain’s improper actions resulted in the fraudulent release of
$29,808 in PUA benefits funds to fictitious Claimant #16 (Torey Goins), which was direct
deposited into a Huntington bank account. The Huntington bank records revealed large
cash withdrawals and electronic transfers through Zelle® and Cash App to Rashanna
Burley and Claimant #7. The address provided on the Huntington bank account was
Burley’s current and former addresses.
Claimant #17
On April 23, 2021, Kyson Murphy created the fictitious identity of Claimant #17, Corey
Goins, by going to the Ohio Bureau of Motor Vehicles office claiming to have lost his
identification card. After receiving a paper temporary identification card form, Murphy
removed his name and address from the document and inserted the fictitious name
(Corey Goins) and address, and Murphy removed his signature under his photograph
leaving the space blank. This fake temporary paper identification card form was
submitted to ODJFS for identification verification, but no other required documents
were submitted.
On June 24, 2021, Cain falsely reported that the “Claimant provided all requested
information for verification.”
On June 28, 2021, Cain’s fraudulent actions resulted in the release of $18,396 in PUA
benefit payments to a ReliaCard® debit card for fictitious Claimant #17 Corey Goins.
According to ODJFS, once Claimant #17’s claim was falsely determined to be eligible,
PUA benefit payments totaling $30,597 continued to be released to fictitious Claimant
#17 through the end of the PUA program on September 4, 2021.
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Office of the Ohio Inspector General / 2024 Annual Report
As a result of this investigation, the Ohio Inspector General’s Office referred the
completed report of investigation to the Franklin County Prosecuting Attorney. On
August 28, 2024, Rashanna Burley, Velma Cain, and Kyson Murphy were indicted by
a Franklin County grand jury for various offenses including Engaging in a Pattern of
Corrupt Activity, Theft, Telecommunications Fraud, Theft in Office, Tampering with
Records, and Money Laundering. The Ohio Inspector General’s Office also referred the
report of investigation to the Ohio Auditor of State for consideration.
OHIO DEPARTMENT OF JOB AND FAMILY SERVICES
FILE ID NO: 2023-CA00008
On June 29, 2021, ODJFS contractor Deloitte Consulting LLP notified ODJFS that,
“During the verification process that we conducted, it has come to our attention that
the following agent [Intermittent CSR Janelle Thrower-Rivera] accounts seem to merit
further investigation based on possible suspicious activity.” During the COVID-19
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Office of the Ohio Inspector General / 2024 Annual Report
pandemic, Deloitte Consulting was contracted
by ODJFS to hire intermittent customer
service representatives (CSRs) to process the
unprecedented number of PUA unemployment
compensation claims. Deloitte Consulting
subcontracted with Harte Hanks and Harte
Hanks subcontracted with Randstad to provide
intermittent CSRs. Harte Hanks was the company
who provided the supervisors and the training for
the PUA workers provided by Randstad.
Intermittent CSR Janelle Thrower-Rivera was hired
by Randstad on June 8, 2020, and was terminated on August 12, 2020. During a review
of the claims accessed by Thrower-Rivera during her period of employment, Harte
Hanks discovered that Thrower-Rivera had filed on July 3, 2020, an application to receive
PUA unemployment benefits when she was employed by Randstad. A review of her
PUA application showed that Thrower-Rivera attested she was unemployed at the time
she filed the original claim. Thrower-Rivera was terminated from Randstad on August
12, 2020, for poor attendance/job abandonment. On August 19, 2020, Harte Hanks
notified Deloitte of the termination of Thrower-Rivera. According to Deloitte, the final
occasion Thrower-Rivera logged into the PUA claims system was on September 9, 2020.
However, investigators discovered records indicating that Thrower-Rivera’s access to
the PUA system was not terminated by Deloitte until June 7, 2021.
In July 2021, ODJFS received an email notification from Deloitte alleging Thrower-
Rivera improperly accessed PUA claims. After receiving this email, ODJFS conducted
an audit of all 883 PUA claims accessed by Thrower-Rivera and discovered that she had
searched claims without a business reason. ODJFS also discovered Thrower-Rivera had
improperly accessed six claims numerous times, and that one of those six claims was her
own PUA unemployment claim filed during the same time she was employed by ODJFS/
Randstad.
On June 22, 2023, ODJFS notified the Ohio Inspector General of Thrower-Rivera’s
suspected illegal activity. Investigators searched and evaluated the claims improperly
accessed by Thrower-Rivera to determine if there were any connections between her
and the six claims in question. From this evaluation, investigators discovered Thrower-
Rivera was able to release PUA funds for payment for one of the six claims she had
improperly accessed. In four other ineligible claims Thrower-Rivera accessed and
attempted to manipulate, there were additional issues that prevented Thrower-Rivera
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Office of the Ohio Inspector General / 2024 Annual Report
from releasing PUA funds on those claims. The sixth claim Thrower-Rivera accessed
was a claim for PUA funds that she filed for herself during the time she was employed
by ODJFS/Randstad to conduct CSR duties. A review of her PUA application showed
that Thrower-Rivera falsely attested she was unemployed at the time she filed her claim.
Investigators learned that after her termination from ODJFS/Randstad, Thrower-Rivera
was employed by Digital Risk Mortgage Services, LLC (Digital Risk) during the third and
fourth quarters of 2020 and all of 2021. Investigators discovered Thrower-Rivera also
submitted weekly PUA claims during her employment with Digital Risk, falsely attesting
she was unemployed and improperly receiving PUA unemployment benefits. According
to ODJFS, Thrower-Rivera improperly received $32,463 in PUA unemployment funds
during times she was either employed by ODJFS/Randstad or by Digital Risk Mortgage
Services, LLC.
Investigators obtained and reviewed Thrower-Rivera’s bank records. For the period
from June 18, 2020, through September 30, 2021, investigators determined the following
dollar amounts Thrower-Rivera had received from her employers and from her PUA
unemployment claims:
From their evaluation of Facebook, IP addresses, and Venmo® records and the claims
Thrower-Rivera improperly accessed, investigators determined the following:
Claimant #1 filed a PUA claim with ODJFS on June 12, 2020. However, the claim was
denied because it did not meet the program eligibility requirements. Thrower-Rivera
was not authorized to adjudicate a program eligibility issue in this claim. However,
on August 22, 2020, Thrower-Rivera accessed this claim and adjudicated the program
eligibility issue as eligible. According to ODJFS, her actions resulted in the improper
release to a US Bank ReliaCard® debit card of $15,393 to Claimant #1. Thrower-Rivera is
a Facebook friend with a relative of Claimant #1. According to Facebook conversations,
Claimant #1’s relative is the godparent to a relative of Thrower-Rivera.
Claimant #2 filed a PUA claim with ODJFS on August 6, 2020, and is a close relative to
Thrower-Rivera. On six different occasions, Thrower-Rivera accessed Claimant #2’s
claim, and attempted to adjudicate the claim as eligible. However, Thrower-Rivera was
unable to release payment of any PUA funds in these instances, because the claim had
been denied based on other issues of which she was either unaware or incapable of
clearing.
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Office of the Ohio Inspector General / 2024 Annual Report
Claimants #3, #4, and #5 each filed more than one PUA claim with ODJFS. Thrower-
Rivera attempted to adjudicate the claims for these three individuals; however, she was
unable to release payment of any PUA funds in these instances, because the claims had
been denied based on other issues of which she was either unaware or incapable of
clearing.
Investigators reviewed Summary of Thrower-Rivera Actions
Facebook records and
discovered that there were
Facebook connections
between Thrower-Rivera and
PUA fund claimants #1, #2,
#3, and #4. Investigators also
found a Facebook connection
between Thrower-Rivera
and a relative of Claimant
#1, which included Venmo®
transactions. In additional
Facebook posts, the relative
of Claimant #1 is identified as
the godparent of Thrower-
Rivera’s relative. Facebook
identifies the relative of Claimant #1 and Claimant #3 as Facebook friends.
Investigators analyzed ODJFS’ PUA dashboard and captured the IP addresses of the
electronic devices used by Thrower-Rivera and PUA claimants #1, #2, #3, and #4. From
a review of these records, investigators discovered IP address connections linking
Thrower-Rivera to both Claimant #1 and Claimant #2, and an IP address connection
linking Claimant #2 to Claimant # 1 and Claimant #4.
On September 13, 2023, investigators went to Thrower-Rivera’s residence. A male
subject answered the door, said Thrower-Rivera was not there and that he did not
know how to reach her. Investigators left their contact information with the male
subject. Minutes later Thrower-Rivera called investigators wanting to know what their
inquiry was about. When told it was regarding her employment with ODJFS/Randstad,
Thrower-Rivera said she did not want to talk at that time but would call investigators
the following day. Thrower-Rivera did not call investigators the following day, and
when investigators called her, she would hang up.
The Ohio Inspector General referred this report of investigation to the Hamilton County
Prosecutor for consideration. Janelle Thrower-Rivera was indicted on charges of Theft,
Unauthorized Use of a Computer, Tampering with Records, and Telecommunications
Fraud.
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Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF JOB AND FAMILY SERVICES
FILE ID NO: 2023-CA00010
On June 15, 2023, the Ohio Department of Job and Family Services (ODJFS) referred
an allegation of wrongdoing to the Inspector General’s Office, the Ohio State Highway
Patrol (OSHP), and the U.S. Department of Labor - Office of Inspector General
(DOL-OIG). ODJFS alleged that a former Randstad employee, Customer Service
Representative (CSR) Ericka Holland, improperly accessed and authorized payments on
Pandemic Unemployment Assistance (PUA) claims. On June 28, 2020, Ericka Holland
was hired by subcontractor Randstad as a CSR assigned to answer calls for the PUA Call
Center under the supervision of Harte Hanks. Randstad terminated Holland on or about
August 20, 2020, after Harte Hanks discovered that Holland was making outbound
calls from the Call Center, which was prohibited without supervisory permission, and
was working outside her scheduled hours. As a CSR call taker, Holland did not have
authority to “adjudicate” or resolve any issues which could either trigger a payment to
a claimant or prevent a claim from being paid. Additionally, Holland did not have the
authority to “redetermine monetary” status, which involved taking action to increase
the weekly PUA benefit payments on a claim. ODJFS alleged Holland improperly took
actions outside the scope of her training and authority on 393 PUA claims. ODJFS
generated a report of Holland’s activities from the ODJFS Unemployment Framework
for Automated Claim and Tax Services (uFACTS) system and provided the report to the
Inspector General’s Office for its review.
Investigators reviewed the records provided by ODJFS and determined Holland had
improperly released PUA benefit funds on 126 of the 393 claims flagged for fraud,
totaling $3,247,402. Investigators found that Holland “voided fraud” alerts on PUA
claims; cleared identity verification,
program eligibility and other issues on
PUA claims; and increased the reported ... Holland had improperly released PUA
income amounts for claimants – all of benefit funds on 126 of the 393 claims
which were actions Holland was not flagged for fraud, totaling $3,247,402.
permitted to perform in her position.
On March 7, 2024, investigators contacted Holland and she agreed to be interviewed.
Holland admitted that she had voided fraud alerts and cleared issues on PUA claims and
increased the monetary PUA benefits for claimants who contacted the PUA Call Center.
Holland stated that she had been trained to take those actions and was encouraged by
supervisors to do all she could to help claimants. Holland stated that when she found an
issue on a claim that she believed she was not authorized to correct, she would forward
that issue to the appropriate team of workers for resolution. Holland also admitted
that, using the PUA Call Center phone system, she called some claimants back after
speaking with them earlier in the day to provide updated information on the status of
their claims, which she was not authorized to do without a supervisor’s prior approval.
Holland said that she did not receive any payments from claimants in exchange for her
assistance and claimed she did not collect PUA benefits while employed by Randstad.
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Office of the Ohio Inspector General / 2024 Annual Report
Holland said she believed her work was being monitored and evaluated by her Harte
Hanks supervisor and Quality Assurance (QA) team.
Investigators subpoenaed and evaluated Holland’s bank records and personal cell
phone records for any evidence of financial gain, motive, or a personal relationship with
any of the claimants whose claims were accessed by Holland and flagged for fraud.
Investigators found no evidence that Holland knew or had a personal relationship with
any of the callers. Additionally, investigators found no evidence of profit or collusion
with co-conspirators and none of the claimants’ phone numbers appeared on Holland’s
personal phone records.
Holland’s Training and Supervision Provided by Harte Hanks
Though Harte Hanks was responsible for supervising, monitoring and evaluating
Holland’s PUA assignment, investigators found Harte Hanks supervisors reviewed very
little of Holland’s work activity. Investigators learned that a CSR’s calls were monitored
by both the CSR’s supervisor and a Quality Assurance (QA) team. Supervisors were
required to listen to a minimum of two calls per CSR per week and the QA team
was required to listen to five calls per CSR per week – for a total of seven calls to be
monitored for each CSR per week. Supervisors were also required to review the CSR’s
work in the uFACTS system related to these calls. The CSRs were informed that their
calls were recorded and could be monitored and evaluated, but the CSR was not aware
at the time of a call whether someone was listening in on their call.
However, during the approximately seven-week period Holland worked as a
subcontractor for Randstad, Holland’s Harte Hanks supervisor only accessed four claims
to review, and the QA team accessed only two of the 791 claims Holland accessed
(about 3/4 of 1%) in uFACTS at the time of or within two weeks of Holland’s work on
the claims. Quality Assurance evaluations related to Holland’s work emphasized
professionalism and compassion toward callers but did not directly evaluate or address
the quality of Holland’s work activity
on PUA claims. Though Holland told ... Though Harte Hanks was responsible
investigators that she believed her for supervising, monitoring and
phone calls and uFACTS actions on evaluating Holland’s PUA assignment,
PUA claims were being monitored investigators found Harte Hanks
and evaluated, Harte Hanks failed to supervisors reviewed very little of
monitor and evaluate Holland’s actions Holland’s work activity.
in the uFACTS system and took no
action to notify Holland that she was
acting improperly or to re-train her. Despite claims by Harte Hanks that procedures
were in place to identify improper activity by CSRs, Holland’s improper actions on PUA
claims were not noticed by her supervisor or the QA team and was only discovered
by ODJFS long after Holland was terminated by Randstad. Additionally, investigators
determined that 43% of Holland’s accesses to the uFACTS claims system occurred
more than one-half hour after Holland was scheduled to end her workday. It took
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Office of the Ohio Inspector General / 2024 Annual Report
seven weeks for Holland’s
Holland uFACTS Accesses and Actions
Harte Hanks supervisor to
notice that Holland was Number Percentage
improperly working outside
During Work Hours* 1873 57%
of her scheduled work hours.
Investigators concluded that Outside Work Hours 1405 43%
Harte Hanks’ insufficient
Total Accesses and Actions 3278
supervision and a lack of
effective quality control
allowed Holland to routinely release PUA funds to ineligible claimants. Additionally,
investigators concluded that Harte Hanks’ lack of appropriate oversight and evaluation
of Holland’s work activity led Holland to believe that she was acting in accordance with
her training and authority. Investigators determined that adequate supervision and
timely review of Holland’s work activity would have likely led to the discovery of her
improper actions much sooner – preventing or markedly reducing the improper release
of over $3.2 million in PUA funds.
Holland’s Improper Personal PUA Claim
In addition, investigators discovered that Holland had filed a claim for PUA benefits for
which she was not eligible.
Holland’s ineligible PUA claim
and the benefits she received
included the time period
she worked for Randstad as
a PUA CSR. Investigators
also discovered Holland had
fraudulently submitted a false
Form 1099-MISC to inflate
her reported income on her
PUA claim and substantially
increase her PUA benefit
payments. Investigators
determined Holland received
in total, $56,780 in improper
PUA benefits. Investigators
verified that Holland did not
use her PUA credentials while working as a CSR call taker to file or access her own claim
in uFACTS.
The Inspector General’s Office found that wrongful acts and omissions occurred
on the part of Holland and subcontractor Harte Hanks. Investigators issued three
recommendations to the Ohio Department of Job and Family Services, and referred
the report of investigation to the Hamilton County Prosecuting Attorney and the Ohio
Auditor of State for consideration.
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Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF JOB & FAMILY SERVICES
FILE ID NO: 2023-CA00009
On June 29, 2023, the Ohio Department of Job and Family Services (ODJFS) referred
an allegation of wrongdoing by intermittent Customer Service Representative (CSR)
Shontiera Barnes to the Inspector General’s Office. ODJFS hired intermittent employees
and contracted through staffing companies for employees to process PUA claims.
One of these staffing companies, Randstad, hired Barnes from August 14, 2020, to
September 22, 2020. Barnes’ duties at Randstad were to take calls from Ohioans
needing assistance with their PUA claims. She was not authorized to adjudicate, nullify,
or void PUA claim issues (such as Fraud, Identity Verification, and Program Eligibility),
redetermine monetary amounts, or backdate claims. As an intermittent and contract
employee, Barnes worked by computer remotely from her home.
During her job training, Barnes was instructed that she was not permitted to access
claims of relatives or friends. ODJFS reviewed Barnes’ work and found she accessed 223
claims during her employment at ODJFS/Randstad. ODJFS identified 42 of those claims
as potentially fraudulent because the required documents to ensure the claimant’s
eligibility, such as employment and identity verification documents, were not present
within the claims. ODJFS discovered Barnes took improper actions to void the Fraud
holds and eligibility issues on the claims,
which resulted in the fraudulent release
of PUA funds in 34 of the 42 claims, ... Barnes took improper actions to
totaling $1,164,153.50. The remaining void the Fraud holds and eligibility
eight claims Barnes redetermined as issues on the claims, which resulted in
eligible met the requirements for PUA the fraudulent release of PUA funds ...
benefits; however, Barnes was not totaling $1,164,153.50.
authorized in her position to make
those determinations.
After ODJFS notified the Inspector General’s Office of their findings, investigators
selected 20 claims from the 42 claims that were identified by ODJFS as fraudulent
and evaluated the claims for any connections between Barnes and the PUA claimants
in question. Investigators obtained and analyzed applicable ODJFS records and
Barnes’ bank, social media, and wage records to determine whether there were any
relationships between Barnes and the claimants. From this review, investigators
discovered numerous personal connections between Barnes and the claimants and that
she had improperly removed Fraud holds on the claims which she was not authorized
to perform. On April 18, 2024, investigators interviewed Barnes. During her interview,
Barnes identified several of the claimants in question and admitted to investigators that
she knew them. Barnes also admitted that one of the claimants was the father of her
children, and that another claimant was his brother. Barnes also admitted knowing two
other claimants because she had attended school with them.
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Office of the Ohio Inspector General / 2024 Annual Report
Connections Between Barnes and the PUA Claimants in Question
Barnes denied being told that she was prohibited from accessing claims of people she
knew, but later acknowledged that she did not listen during her job training. Barnes
admitted to investigators that she removed Fraud holds on the claims, which she was
not authorized to perform in her position.
Investigators also found that Barnes filed her own personal PUA claim during the same
period she was employed by ODJFS/Randstad and other employers, and improperly
received PUA benefit payments, totaling $49,302. From their analysis of records,
investigators determined the following timeline shows the period she was concurrently
and improperly receiving PUA unemployment benefit payments.
Barnes’ PUA Timeline
Barnes admitted to investigators that she had received PUA benefit payments during
the same period she was employed by ODJFS/Randstad and other employers.
The Inspector General’s Office referred this report of investigation to the Franklin
County Prosecutor’s Office for consideration.
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Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF JOB AND FAMILY SERVICES
FILE ID NO: 2023-CA00011
On August 3, 2023, the Ohio Inspector General’s Office joined an ongoing investigation
conducted by the Ohio State Highway Patrol (OSHP) and the U.S. Department of Labor
Office of Inspector General (DOL-OIG) into the improper
actions alleged by the Ohio Department of Job and Family
Services (ODJFS) concerning Andrew Kerobo, a seasonal
teleservices representative (STR) who worked for the
ODJFS subcontractor Randstad and was supervised by
subcontractor Harte Hanks, Inc. to process Pandemic
Unemployment Assistance (PUA) claims. Referral
documents provided to OSHP and DOL-OIG by ODJFS
specifically alleged that Kerobo appeared to have engaged
in fraudulent activity involving his processing of PUA claims, which resulted in improper
payments to more than 300 individuals totaling approximately $6.8 million.
Subjects of Investigation
Andrew Kerobo
Andrew Kerobo (Kerobo) was a temporary contract employee hired by Randstad
and worked remotely from his family home in Cincinnati, Ohio, taking inbound phone
calls from Ohioans needing assistance with their PUA claims. Kerobo did not have the
authority to “adjudicate” or resolve any issues which could either trigger a payment
or prevent a claim from being paid. Call takers, like Kerobo, were also not permitted
to take action to increase or decrease the weekly PUA payments on a claim. Kerobo’s
employment with Randstad started on June 22, 2020, and he was terminated, effective
September 5, 2020. After Kerobo’s termination, his login credentials in the ODJFS
Unemployment Framework for Automated Claim & Tax Services (uFACTS) database
were not deactivated and Kerobo, for three additional months, continued to log in to
the system and make changes to and adjudicate PUA claims, until December 10, 2020.
From Kerobo’s first login to the ODJFS uFACTS system while employed with Randstad,
up until his last improper and unauthorized login months after his termination with
Randstad, Kerobo improperly accessed 448 claims
and released $6,864,263 in fraudulent funds by
manipulating and fabricating claims.
Deonta Belser AKA “Tay Ocho”
Deonta Belser and Kerobo were teammates in 2018
on the Highland Community College Men’s varsity
football team in Highland, Kansas, and he later
moved back to his hometown of Cincinnati during the
Source: https://scottieathletics.com
COVID-19 pandemic in 2020. Investigators discovered
Kerobo and Belser had conspired in 2020 to release
fraudulent pandemic unemployment funds. Belser was tasked with recruiting, or
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Office of the Ohio Inspector General / 2024 Annual Report
crowd-sourcing claimants, gathering their information and then relaying that claimant
information to Kerobo, who would search for and access the claim in the ODJFS uFACTS
database.
Fraud Breakdown
Fraudulent PUA Claims Attributable to Kerobo Only, Prior to His Termination from
Randstad
According to ODJFS’ initial review of Kerobo’s activities during his employment with
Randstad from June 22, 2020, to his termination date of September 5, 2020, Kerobo
improperly accessed, backdated, and/or redetermined 13 PUA claims by voiding issues
on ineligible claims, which resulted in the release of $36,803 in fraudulent PUA benefits.
Fraudulent PUA Claims Attributable to Kerobo Only, After His Termination from Randstad
During Kerobo’s interview with OSHP, Kerobo admitted that after he was terminated
by Randstad, he performed unauthorized accesses within the uFACTS database and
created and manipulated four counterfeit PUA claims, resulting in the fraudulent release
of $118,983 in PUA monies. Kerobo arranged for the deposit of these fraudulent monies
onto four ReliaCards® which were mailed directly to his apartment in Columbus, OH,
where he had moved after being terminated from Randstad. Once the ReliaCards®
were in his possession, Kerobo used the $118,983 in fraudulent PUA funds for his own
personal use. Kerobo did not attribute this fraudulent activity to anyone but himself;
therefore, investigators concluded he alone was responsible for the fraudulent release
of the $118,983 in PUA funds.
Fraudulent PUA Claims with Direct Evidence to Both Kerobo and Belser
From the findings of their analysis of independently obtained evidence and their review
of evidence provided by OSHP and DOL-OIG, the Ohio Inspector General’s Office (OIG)
determined Belser and Kerobo had worked together to defraud the State of Ohio. OIG
investigators concluded that Belser and claimants and/or recruiters communicated and
coordinated fraudulent activities involving PUA claims. In total, investigators attributed
146 fraudulent PUA claims directly to Kerobo, co-conspirator Belser, and claimants
and/or recruiters, that were accessed and fraudulently manipulated by Kerobo after
he was terminated by Randstad but continued to have improper access to the uFACTS
database, fraudulently releasing a total of $2,857,274 in PUA funds.
OIG investigators examined and evaluated Belser’s PUA claim as well as the claims
Kerobo accessed and manipulated thereafter for any financial connections evident
between Kerobo and other PUA benefit fund recipients. OIG investigators also
reviewed and analyzed Cash App and banking records provided by OSHP, and additional
Cash App and banking records independently obtained via subpoenas. From their
review of these records, OIG investigators discovered many instances of significant cash
transfers from PUA claimants and/or recruiters to Belser, and afterwards, subsequent
significant cash transfers to Kerobo. OIG investigators concluded Kerobo and Belser
had conspired to release fraudulent pandemic unemployment funds starting less than
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Office of the Ohio Inspector General / 2024 Annual Report
a week after Kerobo’s termination from Randstad in 2020. Once Belser obtained a
claimant’s fraudulent PUA information, he then relayed that claimant information
to Kerobo. Kerobo then accessed
the claim in the uFACTS database,
improperly using his login credentials ... OIG investigators concluded Kerobo
that had not been deactivated after and Belser had conspired to release
his termination from Randstad and fraudulent pandemic unemployment
would improperly release PUA benefit funds starting less than a week after
funds for that claimant. Both Belser Kerobo’s termination from Randstad in
and Kerobo then took from these 2020.
claimants a percentage of the funds
that were improperly released as their
kickback. OIG investigators found a direct correlation between the contemporaneous
times of these significant cash transfers to Kerobo’s unauthorized accesses and logged
audit trail activity in the uFACTS database.
For a number of claims that Kerobo improperly accessed and fraudulently redetermined
after he was terminated from Randstad, OIG investigators discovered incidents of
significant cash transfers occurring near the same times when Kerobo accessed those
specific claims. For these incidents, after Kerobo accessed and manipulated the claims,
the claimant and/or recruiter would transfer/pay Belser a monetary kickback using
Cash App and/or Apple Pay®, and Belser would later transfer/ pay Kerobo a monetary
kickback using Cash App and/or Apple Pay®. Additionally, from their review of Kerobo’s
electronic banking records, OIG investigators confirmed that Kerobo had received
money from Belser through both Cash App and Apple Pay®, for participating in the
scheme with Belser to defraud the State of Ohio.
Additional Fraudulent PUA Claims
OIG investigators identified 285 fraudulent claims totaling $3,851,203 that were accessed
and fraudulently manipulated by Kerobo after he was terminated by Randstad.
However, investigators were not able to find evidence that showed Kerobo was paid
and/or directly benefitted from releasing PUA funds on these 285 fraudulent claims.
Investigators did ascertain that the 285 claims, like the 146 aforementioned claims,
contained one or more common data points associated with persons known to be
involved in the scheme to defraud the State of Ohio, such as:
• Cincinnati address
• Bowling Green address
• Evidence of Belser and/or Kerobo’s personal relationships with claimants
through social media, bank accounts, etc.
Summary of Fraudulent Claims
From Kerobo’s first login to the ODJFS uFACTS system while employed with Randstad
up until his last unauthorized access/login months after he was terminated from
Randstad, investigators determined Kerobo manipulated and/or fabricated a total
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Office of the Ohio Inspector General / 2024 Annual Report
of 448 claims,
including claims
with evidence
directly related
to co-conspirator
Belser,
claimants, and/
or recruiter(s)
and claims with
known data
points, resulting
in the improper
release of
$6,864,263 in fraudulent pandemic unemployment assistance payments.
The Ohio Inspector General’s Office referred this report of investigation to the Franklin
County Prosecuting Attorney’s Office. As a result of the referral, the subjects in this
report, Andrew Kerobo, Deonta Belser, and other co-conspirators that were involved
in the scheme to defraud the State of Ohio were indicted on December 18, 2024, by
a Franklin County Grand Jury. Due to the ongoing criminal cases, the Ohio Inspector
General’s Office issued this preliminary report of investigation, which will be superseded
by a comprehensive report to be released at a later date in order to ensure the integrity
of the criminal justice proceedings. The Ohio Inspector General also referred this report
to the Ohio Auditor of State for consideration.
28
Office of the Ohio Inspector General / 2024 Annual Report
Summaries of Selected Cases - General
OHIO DEPARTMENT OF DEVELOPMENT
FILE ID NO: 2023-CA00004
In March 2023, the Ohio Department of Development (ODEV) referred a matter to the
Ohio Inspector General involving BridgePort Digital (BD), a provider of online information
technology (IT) training, and 26 companies whose employees were receiving training
from BridgePort Digital. In their referral, ODEV reported that the matter involved certain
companies who were enrolled in the Ohio TechCred (TC) program and had received
monetary reimbursements from the TC program for employees who had participated in
training classes provided by BridgePort Digital.
The TC program offers employers the opportunity to upskill current and future employees
by having them participate in technology-focused trainings. Employers who submit
applications to the TC program and are approved by ODEV are reimbursed a maximum
of $2,000 per employee after their current or prospective employees have successfully
completed and earned credentials from an eligible technology-focused training. Employers
can receive up to a maximum of $30,000 per funding round of the TC program.
ODEV expressed concerns about the legitimacy of the documents submitted by the 26
companies and BridgePort Digital to the department as proofs of payment and course
completions. Additionally, ODEV alleged that Dana Perkins, owner of Aja, Principled Living,
Good Company, a company enrolled in and who received monetary reimbursements through
the TC program, was also an employee of BridgePort Digital.
Investigators reviewed the Ohio TechCred program (TC) guidelines and learned the
following:
• Employers may be reimbursed [emphasis added] for outlays covering tuition, lab
fees, manuals, textbooks, and certification costs, up to $2,000 per credential. Costs
must be incurred by the employer, not the employee.
• Employers can only be reimbursed for individuals who are W-2 employees of their
companies [emphasis added] and who have successfully completed and obtained a
certification from participating in a training applicable to the TC program.
• Invoices submitted for TC reimbursement for costs incurred by the companies
[emphasis added] must truthfully report the costs of the credential(s) and what was
actually expended by the companies for these trainings.
The ODEV spreadsheet also listed the individuals who had received the IT trainings through
BD and the corresponding companies they worked for. Investigators found that 24 of the 26
companies had received TC reimbursements in at least one grant-funding round from the TC
program, ranging in cumulative amounts from $2,000 to $170,000. Investigators discovered
that several individuals were listed as the same contact for different companies that
received reimbursements from the TC program. Investigators reviewed the invoices and
canceled checks submitted to ODEV as substantiation of costs incurred by the companies
29
Office of the Ohio Inspector General / 2024 Annual Report
for the trainings that were provided to their employees by BD. These documents were
required to be submitted by the companies to ODEV to receive reimbursements from the
TC program. Investigators found that during the period under review, these companies
submitted documents and received TC reimbursements totaling $1,161,500.
Investigators issued subpoenas to obtain the bank accounts of BridgePort Digital (BD) and
20 of the 24 companies who had received TC reimbursements. Investigators also issued
a subpoena to BridgePort Digital (BD) for records related to paid invoices provided to the
companies, payments received (e.g.,
checks, electronic payments, cash
payments), and communications
between BD and the companies.
Investigators reviewed these records
to verify that the amounts specified
on the BD invoices for the trainings
and submitted by the companies
to ODEV for TC reimbursements
were the same amounts that were
paid to these companies by ODEV.
Investigators found that all payments
made to BD by the companies
were made after receiving their
TC reimbursements from ODEV,
and the payments were often less
than the amounts specified on
BD’s invoices to the companies for
trainings. Specifically, investigators
found that for the majority of the
companies, only half of the amounts
reimbursed to them by ODEV was
paid to BD, and the remaining half
of the TC reimbursement amounts
were retained by the companies.
(See chart at right, and note that for
those companies who had received
funds in multiple rounds, the amounts
are shown in aggregate for all funding
rounds).
For example, investigators reviewed the bank account of Lady Stasya LLC and found that
on December 16, 2022, $30,000 was deposited into the Lady Stasya LLC’s bank account
from the TC program. On December 23, 2022, a check from Lady Stasya LLC’s bank account
totaling $15,000 and made payable to BD cleared the bank. Investigators note that the date
the check was written, December 22, 2022, is one month after the date stamp on the invoice
indicated $30,000 had been “paid.”
30
Office of the Ohio Inspector General / 2024 Annual Report
Investigators received from ODEV email addresses the department used to correspond
with businesses who received TC reimbursements, and investigators sent emails to the
20 business owners requesting interviews. Investigators received responses from Dana
Perkins, Solomon Doibo, Reggie Holmes, Jane Doe (name redacted due to the confidentiality
requirements of State of Ohio Unemployment Resource for Claimants and Employers - “The
Source”), and Tommy Alexander, and interviews were arranged and conducted with each of
these individuals.
On November 9, 2023, investigators interviewed Dana Perkins, owner of Aja, Principled
Living, Good Company via Microsoft Teams. Investigators determined Perkins received
$170,000 from the TC program, and paid only $35,000 to BD. Perkins told investigators that
after taking a TC program training course which would provide people the opportunity to
obtain skilled jobs (Scrum), she began to provide referrals to BD about other companies
who were eligible for TC trainings. Perkins confirmed that she was paid commission by
BD for referring other companies to complete the Scrum training course and said her
commission was about 20%. Perkins told investigators that BD would send her an invoice for
the costs related to training individuals and she would submit the BD invoice to ODEV for TC
reimbursement. Perkins said the cost of the training was $2,000 per person. Perkins stated
after she received the TC reimbursement payment from ODEV, she would pay half of the
amount she had received to BD. Perkins was asked if she ever submitted checks to ODEV as
proof of payment that were never sent to BD and never cleared the bank. Perkins replied,
“… yes we did and it was probably bad organization.”
On October 5, 2023, investigators interviewed Solomon Doibo, owner of Greater Heights
Institute (GHI) via Microsoft Teams. Investigators determined Doibo received $26,000 from
the TC program and paid $0.00 to BD for the training. Investigators reviewed the bank
account for GHI and found that $26,000 from the TC reimbursement had been deposited
into the account on January 23, 2023. On March 3, 2023, a check payable to BMW Cleveland
totaling $5,500 with the memo “equipment purchase” cleared the bank and on March 20,
2023, a check payable to John Carroll University totaling $2,000 cleared the bank.
Doibo explained he became aware about the TC program from a networking event he
attended in 2022. Doibo told investigators that after he had participated in the TC training
from BD he refused to send payment to BD because he was not satisfied with the training.
Investigators asked Doibo how he notified ODEV about how much the training cost.
Doibo explained BD sent him an invoice for $26,000, which he submitted to ODEV for TC
reimbursement. Investigators asked Doibo if any of the money had been used to purchase a
car, to which he replied, “Yes.” Investigators
also asked Doibo if he had used any of the ... Investigators asked Doibo if any of
money he had received from ODEV to pay the money had been used to purchase
for his daughter’s tuition at John Carroll
a car, to which he replied, “Yes.”
University and he replied, “Yes.”
On October 5, 2023, investigators interviewed Reggie Holmes, owner of Holmes Potentia
Motus Enterprise D/B/A Covenant Seed via Microsoft Teams. Investigators determined
Holmes received $60,000 from the TC program, and paid $30,000 to BD. Holmes stated
31
Office of the Ohio Inspector General / 2024 Annual Report
that he was approached by Dana Perkins, a representative of BD, who explained to him
the concept of Scrum and the opportunity for small businesses to learn the concept of
Scrum, which would provide people the opportunity to obtain skilled jobs. Holmes told
investigators that Perkins approved everything through Brian Levy, who was the BD trainer
who taught the online Scrum courses.
Holmes told investigators that when he was approached by Perkins about the opportunities
available for small businesses, she explained that it was necessary for him to bring people
aboard who were interested in Scrum and hire them and pay them. Holmes said that he
was required to pay Levy a certain dollar amount for training, and the remainder of the
money was used to pay, “… his people and use for the organization.” Holmes noted to
investigators that when he was approached by Perkins, he did not have any employees,
and only used 1099 contractors when needed. Holmes told investigators that he had to pay
BD half ($30,000) of what he had received ($60,000) from ODEV. Holmes explained that
he was required by BD to sign a promissory note they sent to him, which guaranteed that
BD/Levy would be paid half of what he had received. Holmes said that when he signed the
promissory note, he was instructed by BD to issue a check, write “VOID” on the check, and
send it to BD.
On October 26, 2023, investigators interviewed Jane Doe (name redacted due to the
confidentiality requirements of The Source information), owner of Wynnett Consulting LLC
via Microsoft Teams. Investigators determined Doe received $60,000 from the TC program,
and paid $30,000 to BD. Doe told investigators that she was a high school teacher and her
friend Dana Perkins contacted her with information about the Scrum certification process,
and stated that Doe’s students could participate in the program to become Scrum certified.
Doe told investigators that she signed a promissory note with BD before taking the course
and that her company paid for the training after they took the course from BD. Doe said the
promissory note with BD was for the amount of $30,000 and she was required to send BD
$15,000 after she received her reimbursement from the TC program.
On September 28, 2023, investigators interviewed Tommy Alexander, owner of Bronzeville
IT Academy LLC (BI). Investigators determined Alexander received $25,500 from the TC
program, and paid $15,000 to BD. Alexander told investigators that he learned about the
TC program through the internet and a publication. Alexander said he created BI on May 4,
2020, and that BI had no W-2 employees.
Alexander explained he had several potential individuals he was looking to upskill, but
these individuals were not on his payroll. Alexander said he had been in the IT community
for nearly 20 years and that he had been acquainted with BD and Brian Levy for years.
Alexander said he reached out to Levy to inquire about training and was contacted by one of
Levy’s representatives to arrange the dates for his training class. Alexander said he did not
pay BD prior to receiving the training, but paid BD once he had received his reimbursement
from TC. Alexander explained that he submitted two checks to ODEV for reimbursement.
Alexander stated that he wrote the checks payable to BD for the training, and that he
stamped “CANCELED” on the checks, which is what he understood the TC program required
for submission. Alexander confirmed these two checks never cleared the bank.
32
Office of the Ohio Inspector General / 2024 Annual Report
Alexander was asked if he used other providers other than BD for training and said he
used Cyber Security Professionals and was reimbursed for nine people who attended their
trainings.
Investigators asked Alexander about a check he had written and stamped “CANCELED” in
the amount of $18,000 that was submitted to ODEV for training services provided by Cyber
Security Professionals. Investigators reviewed the certifications that Alexander submitted
to ODEV for the training course that the nine individuals completed. Investigators found
that the certificates provided to ODEV included the following statements on the certificates:
“This is a certificate of participation/attendance only and is not an official APMG certificate
awarded upon successful completion of the associated exam. The candidate has attended
the course but is not officially qualified.”
The documents Alexander provided were only certificates of attendance at a one-day
training course and were not proof of completing the certification exam and should not
have been accepted by ODEV. As such, investigators concluded ODEV should not have
reimbursed Bronzeville IT $18,000 for this training course.
Investigators asked Alexander how much he paid to the provider, Cyber Security
Professionals. Alexander responded that his payment to Cyber Security Professionals
should have been the whole $18,000, but that he would have to check his records to verify
the amount. Investigators informed Alexander that they had reached out to Cyber Security
Professionals and was informed Alexander only paid a little over half of the $18,000 invoiced
amount. Alexander told investigators that he would have to review his banking records to
provide an accurate answer.
From their analysis of records and interviews conducted, investigators concluded that the 20
companies under review had submitted invoices that falsely reported the actual costs of the
credential(s) and what was actually expended by the companies for these trainings provided
by BD.
In addition, the Ohio TechCred program (TC) guidelines state that employers can only be
reimbursed for individuals who are W-2 employees
of their companies and who have successfully
completed and obtained a certification from Ohio TechCred
participating in a training applicable to the TC Program Guidelines
program. Ohio law requires all employers subject to
“... guidelines state that
Ohio unemployment insurance laws to file quarterly employers can only be
reports detailing the wages paid to each employee. reimbursed for individuals
Quarterly wage detail reports can be filed online who are W-2 employees of
at the State of Ohio Unemployment Resource for their companies and who
Claimants and Employers (The Source). have successfully completed
and obtained a certification
from participating in a training
Investigators obtained and reviewed Wage and applicable to the TC program. “
Earnings records that were filed in The Source for
the period of January 1, 2022, to March 31, 2023, and
33
Office of the Ohio Inspector General / 2024 Annual Report
found that of the 24 companies that received reimbursements from the TC program during
this time period, three companies had wages reported in The Source for individuals who
were employed by the
company; two companies
had a profile set up in The
Source but failed to report
their employees’ wages;
and 19 companies failed
to set-up a profile in The
Source, and therefore did
not report any wages for
their employees.
Investigators found that
the companies listed in
the chart on the right did
not have a profile or had
a profile but did not have
wages reported in The
Source and did not appear
to have employees.
For the following three
companies that had wages
reported in The Source,
investigators determined
that not every employee
who was submitted for
reimbursement had wages
reported, as summarized in the chart below:
The Ohio Inspector General
determined that the companies
under review failed to comply
with the Ohio TechCred
Program guidelines and The
Source requirements, and
were improperly reimbursed a
total of $1,093,500 from the TC
program.
As a result of this investigation,
the Ohio Inspector General
made six recommendations to
the Ohio Department of Development, and the report of investigation was provided to the
Ohio Auditor of State, the Franklin County Prosecutor’s Office, and the Cuyahoga County
Prosecutor’s Office for consideration.
34
Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF TAXATION
FILE ID NO: 2023-CA00013
In September 2023, the Ohio Inspector General received a referral from the Ohio
Department of Taxation (ODT) reporting suspected illegal activity by Criminal Investigation
Division Tax Agent Matthew Shell and Criminal Investigation Division Tax Agent Mandowl
Nixon. ODT Criminal Investigations Division (CID) tax agents enforce the tax laws by
conducting inspections of businesses to ensure cigarette packs have the tax stamp on the
packs, serve letters of delinquency to vendors, cancel the vendor’s license of noncompliant
businesses, and investigate assigned complaints. In their referral to the Ohio Inspector
General, ODT reported the following timeline and details of Shell’s and Nixon’s alleged illegal
activities.
On September 18, 2023, ODT Tax Agent A (unnamed) reported to ODT Regional Supervisor
Myron Hartman that Tax Agent Matthew Shell had a friend who was a police officer
employed by an entity outside of ODT. This friend/police officer shared with Shell that his
(the friend’s) wife was having an affair with a former police officer who was currently a
business owner in Chillicothe, Ohio. The business owner held a sales tax vendor’s license
and was scheduled to file tax returns on a semiannual basis. The business owner’s most
recent sales tax return was due on July 23, 2023, for the period of January 1, 2023, through
June 30, 2023.
On or around August 30, 2023, Shell attempted
to persuade Agent A to issue a citation and file
misdemeanor charges against the business owner
associated with the affair because, according to Shell,
the business owner had not yet filed the semiannual
return due on July 23, 2023. Agent A refused to take this
action because of the personal nature of the request
involving Shell and the business owner. Agent A stated
to ODT Tax Agent Supervisor Hartman that on August 31,
2023, he had planned to work together with Shell. Their
plan to work as a team was initiated because Agent A’s
partner was unavailable for work that day, as was Shell’s
partner, CID Tax Agent Mandowl Nixon. All four of the
agents were assigned to the ODT Central Ohio Region.
Agent A was then rescheduled to work elsewhere that
Source: https://tax.ohio.gov/professional/
day and did not work with Shell on August 31. criminal-investigations-division/enforcement/
helpfulresources
After several follow-up conversations, Shell then
approached Nixon, who on September 1, 2023, issued a citation to the business owner for
failure to file a semiannual tax return. On that same day, the business owner filed the late
return and paid a tax liability of approximately $100. On September 5, 2023, Nixon filed
unclassified misdemeanor charges with the Chillicothe Clerk of Courts against the business
owner for failing to file and pay the sales tax collected.
35
Office of the Ohio Inspector General / 2024 Annual Report
On September 20, 2023, the Ohio Inspector General opened an investigation to evaluate
the alleged illegal actions by Criminal Investigation Division Tax Agent Matthew Shell and
Criminal Investigation Division Tax Agent Mandowl Nixon.
Investigators interviewed ODT Internal Audit Administrator James J. Roche who explained
the sales tax return filing process and how businesses are notified when they fail to file
and pay their taxes when required. Roche told investigators that the taxpayer/business
owner involved in this investigation was filing his taxes semi-annually and the sales tax for
his business was due on July 23, 2023. Roche stated that should it have been warranted,
a billing notice would have been sent to the taxpayer/business owner approximately 30
days after his business’ sales tax due date (July 23, 2023) and that the taxpayer would have
30 days to respond to ODT. Therefore, Roche noted, in this particular case, the billing
notice would have been mailed by ODT to the taxpayer no earlier than August 22, 2023,
and the taxpayer would have been allowed until September 21, 2023, to respond by either
challenging the bill or paying the bill. However, Roche explained that the taxpayer was
never permitted to follow the normal ODT sales tax payment process because he was cited
by the CID agents on September 1, 2023, well before the deadline (September 21, 2023) that
would have been extended to all other taxpayers.
Investigators interviewed ODT Tax Agent Supervisor Myron Hartman, who was the
supervisor of Nixon and Shell. Hartman explained the two agents were required to work
in teams of two whenever making contact with the public and only investigate complaints
assigned to them. Hartman confirmed to investigators that neither Nixon or Shell was
assigned to investigate the business in question, nor did they screen or review their intended
actions with the proper supervision regarding the business in question.
On October 11, 2023, and December 5, 2023, investigators interviewed ODT Tax Criminal
Investigation Agent Mandowl Nixon and on October 11, 2023, investigators interviewed
ODT Tax Criminal Investigation Agent Matthew Shell. Based on the interviews and records
reviewed, investigators determined Shell used his position as a ODT CID Tax Agent to issue a
citation to a business owner for Shell’s own personal interest. Shell tried to hide his personal
involvement by unsuccessfully attempting to enlist Tax Agent A to issue the citation, and
then successfully enlisted CID Tax Agent Nixon to issue the citation to the business owner
for delinquent taxes.
Investigators learned that Nixon was aware
that the reason Shell wanted the Chillicothe ... investigators determined Shell used
business owner cited was predetermined and his position as a ODT CID Tax Agent to
personal in nature. However, Nixon falsified issue a citation to a business owner for
his arrest report and case summary by Shell’s own personal interest.
omitting the reason the business in question
was selected and claiming the two agents
stopped at this business as a routine visit. Furthermore, Nixon initially lied to investigators
by claiming that their investigation of the business was a routine matter, but later admitted
to investigators that Shell had shared with him that the business owner was having an affair
with the wife of a friend of Shell.
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Office of the Ohio Inspector General / 2024 Annual Report
Nixon also lied to investigators during his first interview about Shell entering the business
during Nixon’s conversation with the business owner. During a second interview, Nixon
admitted to investigators that Shell did not enter the business but was instead in his vehicle
listening to the conversation between the business owner and Nixon using his cellphone
speaker. Nixon’s and Shell’s actions violated the Tax Criminal Investigations Agent
Expectations issued to ODT staff on January 8, 2013, and received and acknowledged by
Nixon on June 10, 2013; and issued on March 10, 2016, and received and acknowledged by
Shell on April 4, 2016, respectively.
Investigators determined that Shell and Nixon were not assigned to issue a citation to
this business, and they failed to screen or review their intended actions with proper ODT
supervision regarding this business. These actions violated the requirements in ODT General
Order 42.1.2 - Procedure for the Screening of Investigations and/or Continuing or Suspending
Investigations.
Furthermore, investigators determined Nixon had improperly accessed the Ohio Law
Enforcement Gateway (OHLEG) network to retrieve information about the business owner,
motivated by the personal interest of Shell rather than for a valid business reason. Nixon’s
action violated Ohio Law Enforcement Gateway – OHLEG Rules and Regulations which defines
misuse as utilization, “… not directly related to the administration of criminal justice.”
Lastly, investigators determined that Shell improperly accessed and queried the State
Taxation Accounting and Revenue System (STARS) database on August 30, 2023, at 12:49
p.m. and researched the vendor’s license number for the business in question, two days
prior to issuing the citation. Investigators determined there was no proper business reason
for Shell to access records for the business in question in STARS, since the business in
question was not on the delinquent list and a supervisor had not assigned a case involving
the business in question to Shell.
The Ohio Inspector General concluded ODT CID agents Matthew Shell and Mandowl Nixon
violated ODT Policy ODT-002 – Standards of Conduct - Section 5.7.11., and engaged, “… in any
act or omission on the job that a reasonable person would regard as manifestly outside the
scope of employment or official responsibilities or with malicious purpose, in bad faith, or in
a wanton or reckless manner.” In addition, investigators determined these actions violated
guidance in ODT General Orders 1.2.7 and 42.1.2, OHLEG Rules and Regulations, and Ohio
Revised Code §1347.15.
Shell and Nixon were placed on administrative leave following the initial interviews with the
Ohio Inspector General and the Ohio Department of Taxation’s Administrative Investigation.
The agents were removed from employment with ODT effective December 15, 2023.
The Ohio Inspector General referred this report of investigation to the Franklin County
Prosecutor and the Ohio Ethics Commission for consideration. This report of investigation
was also referred to the Ohio Bureau of Criminal Investigation for consideration regarding
the improper use of OHLEG.
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Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF MENTAL HEALTH AND ADDICTION SERVICES (OhioMHAS)
FILE ID NO: 2023-CA00014
On September 27, 2023, the Ohio Inspector General’s Office received a referral from
representatives of the Ohio Attorney General’s Medicaid Fraud Control Unit (MFCU)
involving two Ohio Department of Mental Health and Addiction Services employees
(OhioMHAS) assigned to the Northwest Ohio Psychiatric Hospital (NOPH) located in Toledo,
Ohio. MFCU representatives alleged that OhioMHAS Physician Specialist Christian Maduoma
was providing services and completing paperwork for patients seen in his private clinic, Hill
Clinic LLC (the Clinic), during times he was working for and being paid by OhioMHAS. In
addition, MFCU representatives alleged similar concerns about NOPH Financial Associate
Kristine Dowell, who was also employed by Hill Clinic LLC as a billing specialist during the
same period she was working for and being paid by OhioMHAS.
This investigation was conducted in conjunction with the Ohio Attorney General’s Office
Medicaid Fraud Control Unit and with assistance from the Ohio Ethics Commission.
Christian Maduoma
The Ohio Inspector General’s Office reviewed and analyzed records obtained from NOPH
and OhioMHAS and those obtained by MFCU supporting services provided to Clinic patients
and Maduoma’s personal cellular phone records. Investigators also issued subpoenas
to vendors to obtain for examination the Clinic’s payroll records and the personal cell
phone records for Maduoma. Lastly, investigators reviewed the summaries of interviews
conducted by MFCU for information relevant to the Ohio Inspector General’s Office’s
ongoing investigation. The following summarizes investigators’ findings from their analysis
of these records.
Outside Employment
Investigators conducted a search of the Ohio Secretary of State’s website and found that
Maduoma had registered four companies after being hired by NOPH on January 12, 2015.
During his interview, Maduoma explained two of the companies, ProCare Health Systems
LLC and ProCare Staffing, Inc. ceased operations in 2018. Maduoma confirmed the remaining
two companies, Thy Will Be Done LLC and Hill Clinic LLC were still in operation. Maduoma
also acknowledged to investigators that he was familiar with the OhioMHAS Policy No. HR-
32 - Outside Employment. This policy requires an employee to report to and obtain approval
from the Appointing Authority or Designee for his outside employment.
From a review of Maduoma’s personnel file, investigators found that Maduoma had
submitted and completed in April 2022 an Authorization for Secondary Employment form
(Form) for his outside employment with Hill Clinic LLC. Contrary to what was reported on
Maduoma’s submitted Form, investigators later learned that Maduoma’s employment at Hill
Clinic began in September 2019.
Also, investigators did not find in Maduoma’s personnel file similar Forms for Maduoma’s
two remaining companies, Thy Will Be Done LLC or ProCare Staffing, Inc. Maduoma
admitted to investigators that he did not submit a Form to NOPH management for his
38
Office of the Ohio Inspector General / 2024 Annual Report
employment with these two businesses. Maduoma did not submit a Form to NOPH for
ProCare Staffing, Inc. because it was an unsuccessful business and had ceased operations.
Maduoma also stated he did not submit a Form to NOPH for Thy Will Be Done LLC
because the business owned real estate and rental properties and did not require his
daily involvement. However, investigators found Thy Will Be Done LLC records stored on
Maduoma’s OneDrive showed he was involved with the business’s property rentals and
property management from 2019 to 2023 and that one property managed by this company
had been occupied since July 2021.
The Ohio Inspector General’s Office concluded that Maduoma violated OhioMHAS Policy
No. HR-32 - Outside Employment, Section (E) by failing to complete and submit for approval
Authorization for Secondary Employment forms to the appointing authority or their
designee at the times of his outside employment with ProCare Staffing, Inc. and Thy Will Be
Done LLC, and at the correct time he started his outside employment with Hill Clinic LLC.
Improper Use of Agency Facilities and State Time
MFCU representatives told investigators that they were concerned Maduoma was providing
telehealth services to his Clinic patients during times he was working at NOPH. These
concerns were based on information learned during eight patient interviews and a review of
Maduoma’s personal cell phone records and NOPH Kronos records.
OhioMHAS Policy No. HR-32 Outside Employment, Section (D) provides guidance that outside
employment, “… shall not involve the use of state time, facilities, personnel, … or any other
state resource.” Furthermore, NOPH Policy No. HR-0329 Personal Cell Phone Use Section (B)
(6) states that personal cell phones may be used for personal business only during breaks
and lunch periods [emphasis added] in designated … ” areas.
Investigators obtained and examined Maduoma’s personal cell phone records and
conducted research to identify phone number subscribers’ information to determine
whether Maduoma made or received personal phone calls or exchanged personal text
messages during his reported work times at NOPH. Investigators compared Maduoma’s cell
phone activity to records related to his reported NOPH workday start- and end-times from
the Kronos payroll record software system maintained by OhioMHAS. From their analysis,
investigators determined Maduoma made/received the following personal phone calls and
text messages using his personal cell phone during his reported NOPH workdays:
Phone Calls
• Maduoma made/received 980 phone calls that were related to his Clinic work.
• Maduoma made/received 529 phone calls to/from his family members
• Maduoma made/received 222 phone calls that were deemed personal in nature.
• Maduoma made/received 69 phone calls to/from medical providers that were not
related to his NOPH duties.
• Maduoma made/received 801 calls to/from unknown subscribers who were not
related to his NOPH duties.
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Office of the Ohio Inspector General / 2024 Annual Report
Text Messages
• Maduoma sent/received 814 text messages to/from his patients, spouse, Clinic staff,
or an unknown subscriber.
• Maduoma exchanged 1,524 text messages exchanged specifically with NOPH
Financial Associate and then-Clinic Billing Associate Kristine Dowell of which 340
messages exchanged were during times Maduoma reported working at NOPH and
Dowell was not working at NOPH.
Investigators learned that NOPH provided Maduoma two 15-minute breaks and one
30-minute lunch break per workday. NOPH also permitted staff the option to combine
the three breaks into a one-hour break per workday. During his interview, Maduoma told
investigators that he did not believe he conducted Clinic business during times he was
working for and being compensated by OhioMHAS for his work at NOPH. Additionally,
Maduoma told investigators that the personal phone calls and text messages identified in
their investigative analysis occurred when he was “on break.” Maduoma further admitted
to investigators that he provided his personal cell phone number to his Clinic patients. When
his Clinic patients, his spouse, or others sent him a text, Maduoma told investigators that he
did not respond at the time the texts were received and only responded to the texts when
he was “on break.” Maduoma later admitted to investigators in a supplemental response
that, “… calls that spilled over one hour were mostly emergent family matters and not for
Hill Clinic patients.”
For the period from May 10, 2022, through October 25, 2023, investigators calculated the
total time Maduoma spent on his personal cell phone each day when working for NOPH to
determine whether the times he spent using his personal phone exceeded the break times
he was allotted each workday. From their analysis, investigators determined that for 85
days or 29% of the 290 days reviewed, Maduoma spent more than one hour each workday
using his personal cell phone while working at NOPH. Furthermore, from their analysis
of records, investigators found that the occurrence of Maduoma’s personal phone calls
did not spike
during the times
he reported
taking his two
15-minute breaks
and 30-minute
lunch break.
The table at
right shows
Maduoma’s
personal phone
calls occurring
at various times
throughout
his reported
workday at
NOPH.
40
Office of the Ohio Inspector General / 2024 Annual Report
Investigators calculated the total time Maduoma spent using his personal cell phone to
make personal phone calls during his reported NOPH workday and the corresponding
compensation Total Time Spent On Compensation Paid
Maduoma Number of Phone During Associated for Time Spent
received from Category Calls NOPH Workday on Personal Cell Phone
OhioMHAS for Hill Clinic Related 980 70:16:37 $6,152.52
his work at NOPH Relatives and Family Members 529 61:24:21 $5,033.40
(See chart at Personal and Medical Providers [1] 281 51:44:15 $4,276.59
right). Unknown Phone Owner 801 41:45:04 $3,623.41
2591 225:10:17 $19,085.92
[1] Categories were combined based on Dr. Maduoma’s assertions the medical providers were for himself or his mother.
The Ohio
Inspector
General’s Office determined Maduoma violated OhioMHAS Policy No. HR-32 Outside
Employment Sections (D)(3) and (D)(4) and NOPH Policy HR-0329 Personal Cell Phone Use.
Improper Use of Agency Resources
Investigators obtained and analyzed Maduoma’s state-issued laptop, OhioMHAS email
account, files stored to his OhioMHAS OneDrive, Google Chrome Browser History, and
internet browser history to evaluate whether Maduoma used these resources for Clinic
or other non-NOPH related activities. From their analysis of those records, investigators
determined (See chart below):
Activity Related to
ProCare
Health Thy Will
Hill Clinic Systems Be Done Other
Category LLC LLC LLC Organizations Personal Total
Number of Files Stored on Dr. Maduoma's One Drive 151 219 6 12 309 697
Number of Emails Sent/ Received by Dr. Maduoma 65 0 0 0 2 67
Investigators also reviewed Maduoma’s Google Chrome Browser history and internet history
found on his state-issued laptop and determined:
• From May 27, 2022, through August 5, 2023, Maduoma’s state-issued laptop and his
login credentials were used in 192 instances during his reported NOPH workday to log
into the Clinic’s electronic medical records system.
• From September 8, 2023, through November 7, 2023, Maduoma’s state-issued laptop
and his login credentials were used in 363 instances to access the Clinic’s electronic
medical records system of which 144 distinct patient files were accessed during the
period. Additionally, for 85 of the 363 instances, Maduoma’s laptop browser history
and personal cell phone records support that he spoke or attempted to speak with
the Clinic’s patient whose file he accessed in the electronic medical records system
on the same date during his NOPH workday.
During his interview, Maduoma admitted to investigators he was prohibited by OhioMHAS
or NOPH agency guidance and polices to use his state-issued laptop or email address for
personal use, store personal files, or to operate a business. Maduoma also admitted to
storing one file related to his businesses on his state-issued laptop. When investigators
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Office of the Ohio Inspector General / 2024 Annual Report
asked whether he used his state-issued email account to store contacts or conduct Clinic
business, Maduoma stated that he did not, “… use my state issued email to conduct
business.” However, Maduoma later admitted to investigators to using his state-issued
laptop during his NOPH workdays to access the Clinic’s electronic medical records system
when he had problems accessing it using his personal cell phone. Maduoma stated that if
he had a problem, and because he did not have a network that he could use at the Clinic, he
would sometimes use his state-issued computer instead.
The Ohio Inspector General’s Office determined Maduoma violated OhioMHAS Policy No.
HR-32 - Outside Employment Section (D)(4); OhioMHAS Policy No. IT-10 Use of Internet, Email
and Other IT Resources Sections (D)(4), (D)(12), and (I)(2); and the OhioMHAS Personal
Computer Usage Guidelines.
Christian Maduoma: Overlap of NOPH and Clinic Duties
During the investigation, MFCU representatives notified the Ohio Inspector General’s Office
of instances when the Clinic submitted claims to the Ohio Department of Medicaid (ODM)
for services provided by Maduoma on the same date and time when Maduoma reported
working at NOPH. In addition, investigators obtained from an informant screenshots of text
messages involving Maduoma, in which Maduoma made references to leaving NOPH to go
to the Clinic to complete a task. However, when comparing these references to Maduoma’s
NOPH Kronos payroll records, they did not show Maduoma clocking out to leave NOPH to
go to his Clinic.
Investigators learned that Maduoma was not required by NOPH to clock out/in from/to
work for his one-hour breaks. However, if he was going to be away from work for over an
hour, NOPH policy required Maduoma to clock out/in from/to work. During his interview,
Maduoma told investigators that the Clinic was a 12–15-minute drive from NOPH. Maduoma
admitted to investigators that he left NOPH to go to the Clinic during his NOPH workday and
recalled one or two instances when he was gone for an hour and five minutes or 10 minutes.
For the period from March 19, 2020, through March 22, 2022, investigators obtained the
Clinic’s Medicaid billing data from MFCU that showed the total number of office visits by
CPT® code for each day the Clinic submitted office visits to the Ohio Department of Medicaid
(ODM). For each CPT® code, investigators used authoritative sources to identify the
minimum time to be spent when a unit of service was billed. Investigators then used the
minimum time of service for each CPT® code to calculate time Maduoma spent each day for
office visits that were submitted to ODM.
The calculated total amount of time spent by Maduoma for performing office visits that
were billed by the Clinic and sent to ODM was then compared to Maduoma’s reported work
hours at NOPH. Investigators identified 278 days that the Clinic submitted claims to ODM
for Maduoma’s office visits that occurred on the same days he reported working for and
was compensated by OhioMHAS for his work at NOPH. From this analysis, investigators
identified a total of 1,453.01 regular or on-duty hours, plus a COVID hazard pay supplement
of 685.43 hours, totaling $131,013.05, that was paid to Maduoma for work at NOPH while
also concurrently billing ODM for office visits at the Clinic.
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Office of the Ohio Inspector General / 2024 Annual Report
Additionally, investigators analyzed the units billed by CPT® code for each date of service
obtained from MFCU for services Maduoma provided and determined the Clinic submitted
non-facility claims for a total of 2,924 units of services Maduoma provided to Clinic Medicaid
patients. Investigators determined that the 2,924 units of service were during the same
time Maduoma was compensated by OhioMHAS for his work at NOPH. The Ohio Inspector
General’s Office used Ohio Administrative Code §5160-1-60 Appendix DD to identify the
maximum non-facility payment rate for each of the six CPT® codes in which the Clinic
submitted claims for units of services provided by Maduoma. Investigators determined the
Clinic could have potentially received $199,847.67 for the 2,924 units submitted by the Clinic
to ODM for services Maduoma provided to Medicaid patients.
Investigators determined the Clinic received payment for units billed to ODM for work
Maduoma performed at the Clinic during the same days Maduoma concurrently reported
working at NOPH. Investigators concluded that Maduoma acted improperly because
it was not possible for Maduoma to be
compensated by OhioMHAS for performing ... OhioMHAS conducted an agency
work at NOPH while concurrently performing administrative investigation and
services for or at the Clinic. removed Dr. Maduoma from his
position “due to the egregiousness of
OhioMHAS conducted an agency the findings.”
administrative investigation and removed
Dr. Maduoma from his position “due to the
egregiousness of the findings.” OhioMHAS terminated Maduoma on August 2, 2024.
Kristine Dowell
The Ohio Attorney General’s Medicaid Fraud Control Unit (MFCU) referred a matter to the
Ohio Inspector General’s Office involving Kristine Dowell who worked for both NOPH as a
financial associate and for Hill Clinic LLC as a billing specialist. MFCU expressed concerns
that Dowell might be performing Clinic activities during times she was working for and being
paid by OhioMHAS at NOPH.
The Ohio Inspector General’s Office requested and obtained from OhioMHAS copies of
Dowell’s personnel file, her desk phone records, and her OhioMHAS email box from her
employment at NOPH and issued subpoenas for records maintained by the Clinic’s payroll
vendor and for Dowell’s personal cell phone usage. The following summarizes investigators’
findings from their analysis of these records.
Outside Employment
Investigators examined Dowell’s OhioMHAS personnel file and email box. From their
review of these records, investigators found an Authorization for Secondary Employment
form (Form) submitted for her employment with Hill Clinic LLC (the Clinic) dated August 24,
2022. Though investigators learned Dowell’s employment at the Clinic actually started in
July 2020, the Form she submitted reported that she started working at the Clinic in August
2021. When investigators asked Dowell about this discrepancy, she replied that the date she
wrote down on the Form as her start date at the Clinic was a “mistake.” The Ohio Inspector
43
Office of the Ohio Inspector General / 2024 Annual Report
General’s Office concluded that Dowell violated OhioMHAS Policy No. HR-32 - Outside
Employment, Section (E) by failing to accurately complete and submit an Authorization for
Secondary Employment form at the time she began her outside employment at Hill Clinic
LLC.
Improper Use of Agency Facilities and State Time
Investigators learned that Dowell was assigned to work remotely from April 2020 through
the end of September 2020 during the pandemic. During this time, Dowell was not provided
a state-issued cell phone to conduct NOPH business. Additionally, Dowell’s job duties
required her to work at the hospital two specific days a week to complete the Medicaid and
Medicare recertifications and other paperwork requiring signatures.
The Ohio Inspector General’s Office issued a subpoena to obtain records showing Dowell’s
phone calls and text activity for the period March 1, 2020, through October 25, 2023, to
identify any phone calls she may have made to Maduoma or Clinic staff during times she
reported working at NOPH. These records were analyzed in conjunction with her NOPH
payroll records to determine whether she was speaking to or exchanging text messages
with Clinic staff or patients during her reported NOPH workdays. This analysis found:
• Dowell made or received three phone calls during her NOPH workday with either
Clinic staff or Maduoma when he was scheduled to be working at NOPH, and that she
spoke with Maduoma for an unknown reason using her personal cell phone when
they were working at NOPH.
• Dowell originated 728 of the exchanged 3,053 text messages during her NOPH
workday with Maduoma or Clinic staff. Of the 3,053 texts, 90 texts were exchanged
with Maduoma during concurrent times when she was working at NOPH and he was
working at the Clinic.
During an interview, Dowell admitted to investigators that she accepted calls from Clinic
staff during her NOPH workdays but noted that she, “tried not to.” Investigators then
directed Dowell to spreadsheets showing a significant number of text messages exchanged
between herself and Maduoma during their reported NOPH workdays. Investigators asked
Dowell to explain the large volume of texts exchanged between herself and Maduoma
during her NOPH workday and how these were related to NOPH business. Dowell stated the
texts involved problems Maduoma was having at the Clinic and discussions about people at
NOPH. The Ohio Inspector General’s Office determined Dowell violated OhioMHAS Policy
No. HR-32 Outside Employment Sections (D)(3) and (D)(4) and NOPH Policy HR-0329 Personal
Cell Phone Use.
OhioMHAS conducted an agency administrative investigation and determined Dowel should
be provided “counseling as a result of the evidence presented.”
The Ohio Inspector General’s Office forwarded this report of investigation to the City of
Columbus Prosecuting Attorney, the Franklin County Prosecutor’s Office, the Lucas County
Prosecutor’s Office, the Ohio Attorney General’s Medicaid Fraud Control Unit, the Ohio
Ethics Commission, the State Medical Board of Ohio, and the Ohio Auditor of State for
consideration.
44
Office of the Ohio Inspector General / 2024 Annual Report
OHIO DEPARTMENT OF PUBLIC SAFETY
FILE ID NO: 2023-CA00020
On November 16, 2023, the Ohio Department of Public Safety (ODPS) notified the Ohio State
Highway Patrol (OSHP) Office of Investigative Services of a then-current ODPS employee
who was fraudulently claiming unemployment compensation and accepting benefits from
the Ohio Department of Job and Family Services (ODJFS). OSHP opened an investigation,
and investigators learned that current full-time ODPS IT Administrative Professional 4 Brandy
Ward was hired in November 2018 and had been employed by ODPS without interruption
since that date. OSHP also learned Ward’s IT work schedule was Monday through Friday,
8:00 a.m. to 4:30 p.m., and that she worked remotely at home Mondays and Fridays, and in
the ODPS office on Tuesdays, Wednesdays, and Thursdays.
Investigators determined that during her period of employment with ODPS, Ward was
temporarily employed with Robert Half International, Inc. (Robert Half) from March 2, 2022,
to August 21, 2023, and was scheduled to work Monday through Friday, 8:00 a.m. to 5:00
p.m. Investigators also learned that Ward’s paid wages from Robert Half were close to 40
hours for most weeks. Ward’s duties at Robert Half were to conduct basic background
checks of job applicants, including verifying educational degrees, criminal and civil court
records, and driving records.
After her employment with Robert Half ended, Ward applied for unemployment
compensation benefits on August 25, 2023, when she was still employed full time by
ODPS. According to the Ohio State Highway Patrol, ODJFS awarded Ward unemployment
compensation benefits in the amount of $680 per week beginning September 2, 2023, and
received unemployment compensation for five consecutive weeks, totaling $3,400. ODPS
was identified as an employer to be notified of Ward’s unemployment claim and ODPS
notified ODJFS that Ward was still employed by the department.
Ward told investigators that when her employment ended with Robert Half, she
was informed by a Robert Half human resources supervisor that she could file for
unemployment. When investigators showed Ward her first weekly filing for unemployment,
which was on September 6, 2023, she confirmed that she had answered “yes” to the
question of whether she worked that week and included her weekly pay from ODPS. She
also confirmed that she answered “no” to that question on all subsequent weekly filings she
submitted. Ward explained that she was told by an ODJFS representative that she had to
answer “no” to that question if she wanted to receive unemployment payments.
After being notified of Ward’s employment status with the State of Ohio, ODJFS determined
the overpayment of benefits to Ward to be “Fraudulent Misrepresentation.” ODJFS
issued the notice and repayment instructions to Ward for a total amount of $4,250, which
included the benefit amount awarded to Ward of $3,400, plus an $850 penalty fee. ODJFS
did not pursue prosecution for Ward’s fraudulent unemployment claim but did submit
the overpayment to the Ohio Attorney General’s (AG) office, as the entity responsible for
pursuing collections on behalf of ODJFS. As a result, OSHP closed its investigation.
45
Office of the Ohio Inspector General / 2024 Annual Report
On December 21, 2023, the Ohio Department of Public Safety (ODPS) notified the
Inspector General’s Office of “Employee Suspected Improper or Illegal Activity” involving
IT Administrative Professional 4 Brandy Ward. Because the matter of the improper
unemployment claim was resolved, the Inspector General’s Office’s investigation focused on
Ward’s failure to report and obtain authorization from ODPS for her secondary employment
and Ward working concurrent reported hours for both ODPS and Robert Half International,
Inc.
On January 3, 2024, investigators requested and received the following records from ODPS:
the building swipe card activity for Ward that showed her access into the ODPS building,
the ODPS secondary employment policy, and Ward’s timesheets and work schedule. On
January 4, 2024, investigators issued a subpoena to Robert Half International, Inc. for Ward’s
personnel records and device usage data from her assigned laptop computer. On March 8,
2024, investigators received from Robert Half device usage data from the laptop used by
Ward.
Investigators evaluated and
compared the timesheets Ward
submitted to both ODPS and
Robert Half, her ODPS building
ODPS Timesheet
access records, and her device
activity to document when and
where Ward was conducting
Robert Half work during her
reported State of Ohio work
times. The data usage analysis
of Ward’s Robert Half laptop
device showed that she was
logged into the Robert Half Robert Half Timesheet
system during her scheduled
remote work hours for ODPS. The device usage data also showed Ward brought her Robert
Half laptop to the ODPS building and that she connected the laptop to the ODPS Wi-Fi
internet connection. During an interview conducted on April 25, 2024, Ward admitted to
investigators that she at times worked on Robert Half employment matters during her
reported State of Ohio work hours. She also admitted bringing her Robert Half laptop into
the ODPS building and added that she had used her Robert Half laptop for other purposes
unrelated to her secondary employment.
Investigators also found that Ward’s ODPS building swipe card records showed she routinely
entered the ODPS building after her 8:00 a.m. start time, and that Ward did not truthfully
report her actual start- and end-work times in the Kronos timekeeping system used to
calculate the payment of wages to an employee. The ODPS building swipe records do not
record an employee’s exit times.
The Inspector General’s Office compared Ward’s ODPS timesheet records with her Robert
Half timesheet records from July 18, 2022, to August 21, 2023. The comparison showed an
46
Office of the Ohio Inspector General / 2024 Annual Report
overlap of 1,775 hours that Ward claimed to be working for ODPS and Robert Half at the
same time.
During her interview regarding the reporting of her secondary employment, Ward admitted
to investigators that she did not have an approved Application for Secondary Employment
(DPS 0042) form on file at ODPS. She claimed that she did not believe she needed one
because the Robert Half employment was not a “tech job.”
The DPS-501.13 Work Rule - Secondary Employment Policy requires ODPS employees to notify
and receive authorization before accepting or engaging in secondary employment unless
an Application for Secondary Employment (DPS 0042) has been submitted and is approved
pursuant to this policy, or if a request for secondary employment has been denied. An
employee who fails to obtain prior approval (DPS 0042) for any secondary employment, fails
to complete an Application for Secondary Employment (DPS 0042) when required, or works
secondary employment without following the conditions or limitations of approval is subject
to disciplinary action. This policy also prohibits ODPS employees from working on secondary
employment while on State of Ohio work time or using state equipment. Investigators
determined that Ward had not completed an Application for Secondary Employment
(DPS 0042) or received authorization for her secondary employment with Robert Half
International, Inc.
The DPS-501.17 Teleworking Policy establishes guidelines and requirements for when an
employee is directed or permitted to work remotely from a designated alternate workplace.
Teleworkers approved for secondary employment by the Director or designee may not
perform any duties associated with the secondary employment during scheduled work
hours; and may not use any state equipment, software, online computer systems, or
supplies to perform any duties associated with the secondary employment. Ward admitted
to investigators that during her scheduled remote work hours for ODPS, she did conduct
secondary employment work for Robert Half International.
The Inspector General’s Office referred this report of investigation to the Franklin County
Prosecuting Attorney, Ohio Auditor of State, Ohio Ethics Commission, and the Columbus City
Attorney’s Office for consideration.
47
Office of the Ohio Inspector General / 2024 Annual Report
Ohio Department of Transportation
2024 Report
The responsibilities of the deputy inspector general for the Ohio Department of
Transportation (ODOT) were created in 2007 with the enactment of Ohio Revised Code
§121.51. This section directs a deputy inspector general to investigate “... all wrongful
acts and omissions that have
been committed or are being
committed by employees of the The 12 Geographic Districts of
department.” In addition, the
The Ohio Department of Transportation
deputy inspector general is charged
with conducting “... a program of
random review of the processing
of contracts associated with
building and maintaining the state’s
infrastructure.”
The vast majority of ODOT’s budget
is supported by federal and state
motor fuel tax revenues and bond
proceeds appropriated in HB 23, the
FY 2024 - FY 2025 transportation
budget bill. ODOT appropriations
under HB 23 total $10.4 billion for
the biennium. ODOT is one of the
state’s largest agencies, with more
than 5,000 staff members located
in 12 districts throughout the state,
and a headquarters in Columbus.
Oversight is important to ensure
that operations are conducted
efficiently and effectively.
Source: www.transportation.ohio.gov
Since the role of the deputy
inspector general for the Ohio Department of Transportation was created in August 2007,
there has been a continued focus on safeguarding the proper use of state resources, as
well as all aspects of contract processes and procedures, including the bidding process,
purchasing of services, and cost overruns.
The cooperation and working relationship between the Inspector General’s Office, ODOT’s
leadership team, and chief investigators office supports ODOT’s endeavor to serve Ohio’s
transportation needs by responsibly managing the public’s money.
In 2024, there were nine cases opened and four cases closed in the Transportation Area of
the Inspector General’s Office. As part of the lifespan of a case, the number of cases closed
may reflect cases that were opened in previous years.
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Office of the Ohio Inspector General / 2024 Annual Report
Summary of Selected Case - Transportation
OHIO DEPARTMENT OF TRANSPORTATION
FILE ID NO: 2023-CA00012
On August 30, 2023, the Ohio Department of Transportation (ODOT) notified the Inspector
General’s Office of allegations involving the Calendar Year (CY) 2023 District 02 Lighting
Services Contract awarded to U.S. Utility Contractor Co., Inc. (U.S. Utility). Ohio Department
of Transportation District 02 is headquartered in Bowling Green, Ohio, and serves eight
counties in northwest Ohio. ODOT Lighting Services Contracts are awarded to contractors
to maintain the State of Ohio’s highway lighting system for roadway and sign lighting in
order to keep Ohio’s roadways safe and reliable for public use. In the complaint, ODOT
explained that ODOT District 02 staff, “… advised they have been having some issues with
the contractor [U.S. Utility] getting work done and had concerns with them constantly
using ODOT work zones.” ODOT acknowledged that it was acceptable for U.S. Utility to
use ODOT work zones, “… at times when we were already working behind a zone … .”
However, ODOT representatives expressed concerns that U.S. Utility was, “… constantly
using ODOT work zones,” and that staff felt this “use seemed excessive.” Furthermore,
ODOT expressed concerns that there was a benefit being given to U.S. Utility, “… by our
night manager for the lighting contract by constantly coordinating traffic control for them.”
Lastly, ODOT noted that they suspected the U.S. Utility project manager and an ODOT night
crew manager had a familial relationship.
The Inspector General’s Office opened an investigation to examine the extent to which
ODOT District 02 staff members provided or coordinated traffic control for the lighting
contractor and whether such activity was permissible per the contract specifications and/or
ODOT guidance. This investigation also evaluated whether U.S.
Utility provided services in compliance with the 2023 Lighting
Services Contract Specifications and the ODOT Construction
Materials and Specifications manual.
From their examination of records and interviews conducted,
investigators found U.S. Utility and their subcontractor,
American Roadway Logistics, Inc., had failed to comply in certain
instances with the ODOT Standard Construction Drawings for
maintenance of traffic referenced in the D02 Lighting Services
Contract. Additionally, investigators determined U.S. Utility:
• Failed in certain instances to supply the appropriate and
qualified manpower. Specifically, ODOT inspectors noted in 13 daily diary entries
instances of U.S. Utility employees either working on a non-ODOT project or who left
an ODOT project to work on a non-ODOT project when ODOT contract work orders
were still outstanding.
• Failed in certain instances to notify inspectors more than 24 hours before the work
was to start. These requests were often submitted the same day or within 24 hours
of the work being performed.
49
Office of the Ohio Inspector General / 2024 Annual Report
• Failed in 10 instances to submit the request for a lane closure five or more business
days prior to the closure to perform work.
• Failed to complete work orders for the identified repairs within the required 28-day
period. The Inspector General’s Office determined that when U.S. Utility failed to
complete identified repairs within the required 28-day period (for those instances
which were not the result of delayed receipt of materials) ODOT appropriately issued
liquidated damages to U.S. Utility and deducted those damages from payments
made.
Investigators also evaluated ODOT’s concern that U.S. Utility may have received a benefit by
using ODOT work zones. An ODOT engineer noted to investigators that the 2023 Lighting
Services Contract was bid at a fixed amount for maintaining traffic, and that each time U.S.
Utility did not need to set up their own work zone to work behind, they would not incur
traffic control costs. The ODOT engineer explained that ODOT was obligated to pay the
entire bid amount specified in the contract for traffic control even if U.S. Utility did not need
to set up their own work zone because they were using an ODOT work zone and equipment.
Investigators determined an increase in U.S. Utility using ODOT work zones and equipment
instead of subcontracting with a vendor to establish the work zones and provide equipment
would reduce U.S. Utility’s overall cost for providing traffic control for the contract. The
monetary difference between what U.S. Utility would need to pay their subcontractor to
set up a work zone, provided their overall costs for the project was less than the amount
bid, and the monetary amount U.S. Utility received from ODOT to perform the work would
essentially be an additional profit for U.S. Utility.
Investigators found that no statewide policy exists for the ODOT districts to follow when
receiving, evaluating, and approving a request from a contractor to work behind an ODOT
established work zone. The Inspector General’s Office noted concerns as to whether this
unwritten practice of allowing contractors to work within an ODOT-established work zone
could result in increased liability and potential financial loss to ODOT should employees of
the contractors be injured while working within an ODOT-established work zone.
Investigators also examined the level of oversight
used by ODOT to ensure U.S. Utility had complied
with the contract provisions and guidance issued
by ODOT. Investigators determined that in most
instances, ODOT inspectors were on site observing
the work being performed and verifying it was
completed in accordance with the contract and
ODOT guidance; held periodic progress meetings
and informal discussions to address issues with
the contractor; assessed liquidated damages
when appropriate; and issued letters to U.S. Utility
documenting their noncompliance.
Investigators learned from interviews that early on in the contract, ODOT had difficulties
in obtaining the required submissions from U.S. Utility. The Inspector General’s Office
50
Office of the Ohio Inspector General / 2024 Annual Report
determined that U.S. Utility failed to remit the required submittals and forms on the date
required by the contract. The Inspector General’s Office also determined that U.S. Utility did
not complete the annual tower inspections in April 2023, as required by the contract, and
instead completed the last annual tower inspection on May 22, 2023.
Familial Relationship Between ODOT and U.S. Utility Employees
In its complaint to the Inspector General’s Office, ODOT staff expressed concerns that U.S.
Utility had received a benefit from the ODOT District 02 “… night manager [Dennis Schultz]
for the lighting contract by constantly coordinating traffic control for them.” ODOT Night
Manager Dennis Schultz is the father of U.S. Utility Project Manager Tyler Schultz. From
the interviews conducted, ODOT District 02 personnel told investigators that they had no
specific knowledge of instances where Dennis Schultz had coordinated or notified U.S.
Utility or his son Tyler Schultz of the locations where ODOT District 02 night crews were
establishing maintenance of traffic work zones. Additionally, ODOT personnel stated
they were not aware of any specific instances of ODOT Night Manager Dennis Schultz
coordinating the maintenance of traffic performed by the ODOT night crews with Tyler
Schultz of U.S. Utility. However, an ODOT engineer noted to investigators that he never
sent any upcoming ODOT traffic control notices to U.S. Utility, and as such, was unsure how
U.S. Utility had obtained that information.
Investigators analyzed phone call and text activity on the part of Dennis and Tyler Schultz
and conducted inquiries about the communications identified. Investigators found calls
made between Dennis and Tyler Schultz; however, without the context of those calls,
investigators were unable to determine whether these calls were related to the ODOT work
zones being set by the night crew managed by Dennis Schultz. The Inspector General’s
Office concluded that there was no evidence supporting communications between Dennis
and Tyler Schultz resulting in ODOT providing maintenance of traffic services or allowing U.S.
Utility to work behind a work zone established by ODOT and use of traffic control equipment
belonging to ODOT.
Investigation Recommendations and Referrals
The Inspector General’s Office made 14 recommendations to the director of the Ohio
Department of Transportation to clarify existing contract provisions for both contractors
and ODOT employees and to strengthen the agency’s internal control systems related to
the monitoring of these contracts for compliance with contract specifications. This report
of investigation was provided to the Ohio Auditor of State’s Office and the Ohio Attorney
General’s Antitrust Division for consideration.
51
Office of the Ohio Inspector General / 2024 Annual Report
Ohio Bureau of Workers’ Compensation and
Ohio Industrial Commission
2024 Report
In July 2007, the Ohio General Assembly
passed legislation that created the position of
deputy inspector general for the Ohio Bureau
of Workers’ Compensation (OBWC) and the
Ohio Industrial Commission (OIC) within the
Inspector General’s Office. This legislation
stated that the inspector general shall appoint
a deputy inspector general, and the deputy
inspector general shall serve at the pleasure of
the inspector general.
The deputy inspector general is responsible for
investigating wrongful acts or omissions that
have been committed or are being committed
by officers or employees of the OBWC and the
OIC. The deputy inspector general has the
same powers and duties regarding matters
concerning the bureau and the commission as
those specified in Ohio Revised Code §§ 121.42, William Green Building
Ohio Bureau of Workers’ Compensation
121.43, and 121.45. and Ohio Industrial Commission.
Source: https://www.ic.ohio.gov/
In 1912, Ohio law created an exclusive state fund
to provide workers’ compensation benefits
to workers who were unable to work due to a work-related injury. In Ohio, all companies
or employers must have coverage from either state funds or be self-insured. For those
companies or employers with no employees who meet specific requirements, Ohio law
makes workers’ compensation
coverage elective. OBWC
manages seven service offices and
approximately 1,600 employees.
Currently, the Ohio Bureau of
Workers’ Compensation system
is one of the largest state-funded
insurance systems in the nation.
According to the bureau’s Fiscal
Year 2023 Annual Report, OBWC
served 258,263 active employers
and paid nearly $1.27 billion in
benefits to injured workers.
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Office of the Ohio Inspector General / 2024 Annual Report
Established in 1912, the OIC is a separate
adjudicatory agency whose mission is to serve
injured workers and Ohio employers through
prompt and impartial resolution of issues arising
from workers’ compensation claims and through
the establishment of an adjudication policy.
Hearings on disputed claims are conducted at three
levels within the commission: the district level,
staff level, and commission level. The governor
appoints the three-member commission and the Ohio Senate confirms these appointments.
By previous vocation, employment, or affiliation, one member must represent employees,
one must represent employers, and one must represent the public.
The OIC has approximately 290 employees and operates five regional offices and seven
district offices throughout the state. According to the commission’s Fiscal Year 2023 Annual
Report, the three commissioners and agency hearing officers collectively heard 87,146
hearings during the fiscal year.
In 2024, the Inspector General’s Office staff attended or reviewed board meeting materials
for select OBWC board of directors’ audit, investment, actuarial, governance, and/or medical
services and safety committee meetings to receive updates on OBWC’s divisional activities
and new initiatives. The Inspector General’s
Office provided the OBWC board of ... [the OIC] mission is to serve injured
directors, administrator, and commissioners workers and Ohio employers through
of the Industrial Commission with copies of prompt and impartial resolution
the FY annual report containing overviews of of issues arising from workers’
noteworthy investigations. compensation claims and through the
establishment of an adjudication policy.
Also in 2024, the Inspector General’s Office ...
worked jointly with various departments
within OBWC, including Special Investigations, Employee Safety & Integrity Unit, Human
Resources, Employee/Labor Relations, and Legal. Additionally, the Inspector General’s
Office worked closely with various departments within the OIC, including the Executive
Director’s Office, Hearing Services, Human Resources, Legal, and Information Technology.
In 2024, there were four cases opened and two cases closed in the OBWC/OIC area of the
Inspector General’s Office. As part of the lifespan of a case, the number of cases closed may
reflect cases that were opened in previous years.
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Summary of Selected Case - OBWC/OIC
OHIO INDUSTRIAL COMMISSION
FILE ID NO: 2023-CA00016
On October 16, 2023, the Inspector General’s Office received a referral from the Ohio
Industrial Commission (OIC) reporting concerns about whether OIC Claims Examiner 2
LaTasha Greene was actually working at her job during dates and times she reported
working for OIC on her timesheets. The OIC referral stated that after Greene’s 2023 annual
employee evaluation in which issues were identified regarding the quality of her work
product, the OIC conducted an initial review of Greene’s reported start- and end-work times
on her submitted timesheets for a three-month period from October 1, 2022, to December
30, 2022. OIC compared Greene’s reported work times to her work activity times indicated
in the OIC Case Manager (CM) system. From this comparison, the OIC found discrepancies
totaling 143.9 hours between Greene’s reported work times on her timesheets to Greene’s
work activity times shown in the OIC Case Manager (CM) system. The OIC referral noted
that although Greene was meeting the required quota for the quantity of OBWC claims
she was expected to process, Greene was continuously making errors when performing
rudimentary tasks that she should not be making as a nine-year employee.
The Inspector General’s Office obtained and reviewed the following records involving
Greene’s work activities for the period from May 22, 2023, to November 3, 2023: the OIC
Case Manager (CM) User Action Report; the OIC Documents Re-Indexed Report; the OIC
Commission Adjudication System (CAS) User Action Report; Greene’s VPN sign-in logs;
Greene’s OIC timesheets; Greene’s OIC Miscellaneous Time Reports; and Greene’s State of
Ohio email account.
To determine Greene’s work activity during the period under review, investigators compared
the start times Greene logged in to VPN each day to Greene’s work activity times first
recorded in CM, CAS, or Greene’s Miscellaneous Time Reports, and to the dates and times
Greene reported working on her timesheets. Investigators learned Greene’s assigned work
schedule was Monday through Friday, 7:00 a.m. to 3:30 p.m., and investigators confirmed
Greene generally logged in to VPN around 7:00 a.m. each day. Investigators analyzed
Greene’s State of Ohio email account and found that for the period under review, except
for one day, Greene had sent an email to her supervisor either shortly before or after her
reported start-work times specified on her timesheets and had indicated “GM” on the
emails’ subject lines. Investigators compared Greene’s reported start-work times on her
timesheets to the earliest time her work activity was captured each day in either the OIC
CM or CAS systems and found numerous daily time discrepancies totaling 277 hours for the
period under review, averaging 2 hours and 38 minutes per workday. Additionally, during
a review of CM User Action Reports, investigators discovered nine days when Greene had
performed work activity in CM for more than 30 minutes after the 3:30 p.m. end-work times
she reported on her timesheets.
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On March 21, 2024, investigators interviewed Greene. Investigators asked Greene about
the time discrepancies between the start-work times she reported on her timesheets
and her work activity start times recorded in the CAS and CM systems, which were often
several hours later than the times she had reported on her timesheets. Greene said that the
discrepancies were at times due to the time she spent reindexing documents, which she tried
to complete every morning. Greene noted reindexing documents was tedious and required
much time and that she generally conducted this task at the beginning of her work day to
“ease into it” because of a medical condition for which she received FMLA. Investigators
reviewed Greene’s Earnings Lookup Report in Ohio Business Intelligence for the period under
review and found no FMLA hours listed on Greene’s Earnings Lookup Report.
Investigators learned that in addition to User Action Reports that documented Greene’s
activity in OIC’s CM and CAS, there was also a report capturing when documents were
reindexed, called the OIC Documents Re-Indexed Report. Investigators reviewed the
work times recorded for Greene on the OIC Documents Re-Indexed Report and compared
these times to the earliest work activity that had been captured for Greene in the CM or
CAS systems. From this comparison for the period under review, investigators discovered
that although Greene’s earliest daily work activity was mostly captured on the CM or CAS
User Action Reports, there were some days when Greene’s earliest activity was captured
on the OIC Documents Re-Indexed Report. When comparing the times of Greene’s earliest
work activity from the CM User Action Reports, the CAS User Action Reports, and the
OIC Documents Re-Indexed Report, to those start-work times Greene reported on her
timesheets, investigators redetermined the
discrepancy of Greene’s work times for the When comparing the times of Greene’s
period under review from a total of 277 hours earliest work activity to those start-
to total of 275 hours. work times Greene reported on her
timesheets, investigators determined
OIC employees are required to follow OIC there was a discrepancy of 275 hours.
Policy HR057 – Hours of Work, which states
that OIC employees are responsible for
accurately recording all hours worked on a daily [emphasis added] basis, including start and
end times, lunch, schedule adjustment, tardiness, leave time, and overtime/compensatory
time, via the time keeping system (e.g., Kronos). Employees shall be ready to commence
work at their scheduled start time [emphasis added].
Though Greene consistently logged in to VPN at her scheduled start time and emailed
her supervisor the required morning email documenting her attendance, investigators
determined from their review of the CM and CAS User Action Reports and the OIC
Documents Re-Indexed Report that Greene’s daily user activity started several hours later
than her reported start-work times on her submitted timesheets. Additionally, during a
review of CM User Action Reports, investigators discovered nine days when Greene had
performed work activity in CM greater than 30 minutes after her reported end-work times
(3:30 p.m.) on her submitted timesheets. The Inspector General’s Office found reasonable
cause to believe wrongful acts or omissions occurred, and made three recommendations to
the Ohio Industrial Commission for consideration.
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Office of the Ohio Inspector General / 2024 Annual Report
2024 Community Outreach
Inspector General’s Office Participates in Buckeye Boys State Program
For 14 years, the Inspector General’s Office has participated in the American Legion
Buckeye Boys State. The American Legion Buckeye Boys State (BBS) is an eight-day
hands-on experience, “…in the operation
of the democratic form of government, the
organization of political parties, and the
relationship of one to the other in shaping
Ohio government.” BBS offers various
sessions to students on how the different
divisions of Ohio government interact
and function. Representing the Inspector
General’s Office in 2024, Deputies Inspector
General Kerri Kellogg and Nancy Moore
advised three young men on how to establish
a working inspector general’s office, define its
duties, and conduct investigations.
uuu
Inspector General Meets with
International Dignitaries and U.S.
Department of State Representatives
The International Visitors Council
(IVC) of Columbus was established in 1965, “… to build partnerships between Central
Ohioans and citizens of other countries that strengthen democratic ideals, encourage
economic development, and promote cultural understanding through the exchange of
knowledge and ideas.” IVC is affiliated with the U.S. Department of State and coordinates
meetings between international government representatives and state government
officials.
In 2024, Inspector General Meyer spoke
to nine delegates representing five
countries: India, Nepal, Pakistan, Sri Lanka,
and Ukraine. During these meetings, the
Inspector General explained the role of the
Office of Inspector General (OIG) and its
mission to investigate corruption and uphold
government accountability. Since 2011,
Inspector General Meyer has met with over
260 delegates representing 42 countries.
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Office of the Ohio Inspector General / 2024 Annual Report
Appendices
Appendix 1: Statutory References
OHIO REVISED CODE
The following are Ohio Revised Code sections relating to the powers and duties of the Ohio
Inspector General:
121.41 Inspector General Definitions
121.42 Inspector General - Powers and duties
121.421 Investigation of casino control commission enforcement personnel
121.43 Subpoena power – contempt
121.44 Reports of investigation
121.45 Cooperating in investigations
121.46 Filing complaint - form
121.47 Confidential information
121.48 Appointment of Inspector General
121.481 Special investigations fund
121.482 Disposition of money received
121.483 Deputy inspector general as peace officer
121.49 Qualifications
121.50 Administrative rules
121.51 Deputy inspector general for transportation department
121.52 Deputy inspector general for workers’ compensation
121.41 Inspector General Definitions
As used in sections 121.41 to 121.50 of the Revised Code:
(A) “Appropriate ethics commission” has the same meaning as in section 102.01 of
the Revised Code.
(B) “Appropriate licensing agency” means a public or private entity that is
responsible for licensing, certifying, or registering persons who are engaged in a
particular vocation.
(C) “Person” has the same meaning as in section 1.59 of the Revised Code and also
includes any officer or employee of the state or any political subdivision of the state.
(D) “State agency” has the same meaning as in section 1.60 of the Revised Code
and includes the Ohio casino control commission, but does not include any of the
following:
(1) The general assembly;
(2) Any court;
(3) The secretary of state, auditor of state, treasurer of state, or attorney general
and their respective offices.
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(E) “State employee” means any person who is an employee of a state agency, or
any person who does business with the state including, only for the purposes of
sections 121.41 to 121.50 of the Revised Code, the nonprofit corporation formed under
section 187.01 of the Revised Code.
(F) “State officer” means any person who is elected or appointed to a public office in
a state agency.
(G) “Wrongful act or omission” means an act or omission, committed in the course of
office holding or employment, that is not in accordance with the requirements of law
or such standards of proper governmental conduct as are commonly accepted in the
community and thereby subverts, or tends to subvert, the process of government.
121.42 Inspector General - Powers and duties
The inspector general shall do all of the following:
(A) Investigate the management and operation of state agencies on his own initiative
in order to determine whether wrongful acts and omissions have been committed or
are being committed by state officers or state employees;
(B) Receive complaints under section 121.46 of the Revised Code alleging wrongful
acts and omissions, determine whether the information contained in those
complaints allege facts that give reasonable cause to investigate, and, if so,
investigate to determine if there is reasonable cause to believe that the alleged
wrongful act or omission has been committed or is being committed by a state
officer or state employee;
(C) Except as otherwise provided in this division, contemporaneously report
suspected crimes and wrongful acts or omissions that were or are being committed
by state officers or state employees to the governor and to the appropriate state or
federal prosecuting authority with jurisdiction over the matter if there is reasonable
cause to believe that a crime has occurred or is occurring. In addition, the inspector
general shall report the wrongful acts or omissions, as appropriate under the
circumstances, to the appropriate ethics commission in accordance with section
102.06 of the Revised Code, the appropriate licensing agency for possible disciplinary
action, or the state officer’s or state employee’s appointing authority for possible
disciplinary action. The inspector general shall not report a wrongful act or omission
to a person as required by this division if that person allegedly committed or is
committing the wrongful act or omission.
(D) Except as otherwise provided in this division, contemporaneously report
suspected crimes and wrongful acts or omissions that the inspector general becomes
aware of in connection with an investigation of a state agency, state officer, or state
employee, and that were or are being committed by persons who are not state
officers or state employees to the governor and to the appropriate state or federal
prosecuting authority with jurisdiction over the matter if there is reasonable cause
to believe that a crime has occurred or is occurring. In addition, the inspector general
shall report the wrongful acts or omissions, as appropriate under the circumstances,
to the appropriate ethics commission in accordance with section 102.06 of the
Revised Code, the appropriate licensing agency for possible disciplinary action, or
the person’s public or private employer for possible disciplinary action. The inspector
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general shall not report a wrongful act or omission to a person as required by this
division if that person allegedly committed or is committing the wrongful act or
omission.
(E) Prepare a detailed report of each investigation that states the basis for the
investigation, the action taken in furtherance of the investigation, and whether the
investigation revealed that there was reasonable cause to believe that a wrongful
act or omission had occurred. If a wrongful act or omission was identified during the
investigation, the report shall identify the person who committed the wrongful act
or omission, describe the wrongful act or omission, explain how it was detected,
indicate to whom it was reported, and describe what the state agency in which the
wrongful act or omission was being committed is doing to change its policies or
procedures to prevent recurrences of similar wrongful acts or omissions.
(F) Identify other state agencies that also are responsible for investigating, auditing,
reviewing, or evaluating the management and operation of state agencies, and
negotiate and enter into agreements with these agencies to share information and
avoid duplication of effort;
(G) For his own guidance and the guidance of deputy inspectors general, develop and
update in the light of experience, both of the following:
(1) Within the scope of the definition in division (G) of section 121.41 of the Revised
Code, a working definition of “wrongful act or omission”;
(2) A manual of investigative techniques.
(H) Conduct studies of techniques of investigating and detecting, and of preventing
or reducing the risk of, wrongful acts and omissions by state officers and state
employees;
(I) Consult with state agencies and advise them in developing, implementing, and
enforcing policies and procedures that will prevent or reduce the risk of wrongful
acts and omissions by their state officers or state employees;
(J) After detecting a wrongful act or omission, review and evaluate the relevant
policies and procedures of the state agency in which the wrongful act or omission
occurred, and advise the state agency as to any changes that should be made in
its policies and procedures so as to prevent recurrences of similar wrongful acts or
omissions.
121.421 Investigation of casino control commission enforcement personnel
(A) Notwithstanding division (D)(3) of section 121.41 of the Revised Code, in order to
determine whether wrongful acts or omissions have been committed or are being
committed by present or former employees, the inspector general shall investigate
employees of the office of the attorney general who are contractually vested with
duties to enforce Chapter 3772. of the Revised Code, including any designated
bureau of criminal identification and investigation support staff that are necessary
to fulfill the investigatory and law enforcement functions of the Ohio casino control
commission. The inspector general and any deputy inspector general may administer
oaths, examine witnesses under oath, and issue subpoenas and subpoenas duces
tecum to employees of the office of the attorney general to compel the attendance
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of witnesses and the production of all kinds of books, records, papers, and tangible
things deemed necessary in the course of any such investigation.
(B) The inspector general may enter into any contracts that are necessary to
complete an investigation. The contracts may include contracts for the services of
persons who are experts in a particular field and whose expertise is necessary for
successful completion of the investigation.
(C) If the authority of the attorney general terminates or expires, the authority
vested in the inspector general by this section terminates upon the conclusion of
ongoing investigations or upon issuance of the final report of the investigations.
121.43 Subpoena power - contempt
In performing any investigation, the inspector general and any deputy inspector general may
administer oaths, examine witnesses under oath, and issue subpoenas and subpoenas duces
tecum to compel the attendance of witnesses and the production of all kinds of books,
records, papers, and tangible things. Upon the refusal of a witness to be sworn or to answer
any question put to him, or if a person disobeys a subpoena, the inspector general shall
apply to the court of common pleas for a contempt order, as in the case of disobedience
to the requirements of a subpoena issued from the court of common pleas, or a refusal to
testify in the court.
121.44 Reports of investigations
(A) Except as otherwise provided in this section, the report of any investigation
conducted by the inspector general or any deputy inspector general is a public
record, open to public inspection. The inspector general, or a deputy inspector
general, with the written approval of the inspector general, may designate all or
part of a report as confidential if doing so preserves the confidentiality of matters
made confidential by law or appears reasonably necessary to protect the safety of
a witness or to avoid disclosure of investigative techniques that, if disclosed, would
enable persons who have been or are committing wrongful acts or omissions to
avoid detection. Confidential material shall be marked clearly as being confidential.
(B) The inspector general, free of charge, shall provide a copy of each report of an
investigation, including wholly and partially confidential reports, to the governor.
In addition, the inspector general, free of charge, shall provide a copy of the
report of any investigation, including wholly and partially confidential reports, to a
prosecuting authority who may undertake criminal prosecution of a wrongful act
or omission described in the report, an ethics commission to which a wrongful act
or omission described in the report was reported in accordance with section 102.06
of the Revised Code, and a licensing agency, appointing authority, or public or
private employer that may take disciplinary action with regard to a wrongful act or
omission described in the report. The inspector general shall not provide a copy of
any confidential part of the report of an investigation to a person as required by this
division if that person allegedly committed the wrongful act or omission described
in the report. The governor, a prosecuting authority, ethics commission, licensing
agency, appointing authority, or public or private employer that receives a report,
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all or part of which is designated as confidential, shall take all appropriate measures
necessary to preserve the confidentiality of the report.
(C) The inspector general shall provide a copy of any nonconfidential report, or the
nonconfidential parts of any report, to any other person who requests the copy and
pays a fee prescribed by the inspector general. The fee shall not exceed the cost of
reproducing and delivering the report.
121.45 Cooperating in investigations
Each state agency, and every state officer and state employee, shall cooperate with,
and provide assistance to, the inspector general and any deputy inspector general in the
performance of any investigation. In particular, each state agency shall make its premises,
equipment, personnel, books, records, and papers readily available to the inspector general
or a deputy inspector general.
The inspector general and any deputy inspector general may enter upon the premises of
any state agency at any time, without prior announcement, if necessary to the successful
completion of an investigation. In the course of an investigation, the inspector general and
any deputy inspector general may question any state officer or state employee serving in,
and any other person transacting business with, the state agency, and may inspect and copy
any books, records, or papers in the possession of the state agency, taking care to preserve
the confidentiality of information contained in responses to questions or the books, records,
or papers that is made confidential by law.
In performing any investigation, the inspector general and any deputy inspector general
shall avoid interfering with the ongoing operations of the state agency being investigated,
except insofar as is reasonably necessary to the successful completion of the investigation.
Each state agency shall develop, implement, and enforce policies and procedures that
prevent or reduce the risk of wrongful acts and omissions by its state officers or state
employees.
Other state agencies that also are responsible for investigating, auditing, reviewing, or
evaluating the management and operation of state agencies shall negotiate and enter into
agreements with the office of the inspector general for the purpose of sharing information
and avoiding duplication of effort.
121.46 Filing complaint - form
Any person who knows or has reasonable cause to believe that a state officer or state
employee has committed, or is in the process of committing, a wrongful act or omission may
prepare and file with the inspector general, a complaint that identifies the person making
the report and the state officer or state employee who allegedly committed or is committing
the wrongful act or omission, describes the wrongful act or omission, and explains how the
person reporting knew or came to his reasonable cause to believe that the state officer or
state employee committed or is in the process of committing the wrongful act or omission.
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Office of the Ohio Inspector General / 2024 Annual Report
The preparation and filing of the complaint described in this section is in addition to any
other report of the wrongful act or omission the person is required by law to make.
The inspector general shall prescribe a form for complaints under this section. The inspector
general shall provide a blank copy of the form to any person, free of charge. No complaint is
defective, however, because it is not made on the form prescribed by the inspector general.
121.47 Confidential information
No person shall disclose to any person who is not legally entitled to disclosure of the
information, any information that is designated as confidential under section 121.44 of
the Revised Code, or any confidential information that is acquired in the course of an
investigation under section 121.45 of the Revised Code.
121.48 Appointment of Inspector General
There is hereby created the office of the inspector general, to be headed by the inspector
general.
The term of the inspector general serving on the effective date of this amendment ends
January 11, 2021. The inspector general shall be appointed by the governor quadrennially
thereafter, subject to section 121.49 of the Revised Code and the advice and consent of the
senate, and shall hold office for a term of four years commencing on the second Monday of
January. The governor may remove the inspector general from office only after delivering
written notice to the inspector general of the reasons for which the governor intends to
remove the inspector general from office and providing the inspector general with an
opportunity to appear and show cause why the inspector general should not be removed.
In addition to the duties imposed by section 121.42 of the Revised Code, the inspector
general shall manage the office of the inspector general. The inspector general shall
establish and maintain offices in Columbus.
The inspector general may employ and fix the compensation of one or more deputy
inspectors general. Each deputy inspector general shall serve for a term coinciding with
the term of the appointing inspector general, and shall perform the duties, including the
performance of investigations, that are assigned by the inspector general. All deputy
inspectors general are in the unclassified service and serve at the pleasure of the inspector
general.
In addition to deputy inspectors general, the inspector general may employ and fix the
compensation of professional, technical, and clerical employees that are necessary for the
effective and efficient operation of the office of the inspector general. All professional,
technical, and clerical employees of the office of the inspector general are in the unclassified
service and serve at the pleasure of the appointing inspector general.
The inspector general may enter into any contracts that are necessary to the operation
of the office of the inspector general. The contracts may include, but are not limited to,
contracts for the services of persons who are experts in a particular field and whose
expertise is necessary to the successful completion of an investigation.
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Not later than the first day of March in each year, the inspector general shall publish an
annual report summarizing the activities of the inspector general’s office during the previous
calendar year. The annual report shall not disclose the results of any investigation insofar as
the results are designated as confidential under section 121.44 of the Revised Code.
The inspector general shall provide copies of the inspector general’s annual report to the
governor and the general assembly. The inspector general also shall provide a copy of the
annual report to any other person who requests the copy and pays a fee prescribed by
the inspector general. The fee shall not exceed the cost of reproducing and delivering the
annual report.
Amended by 132nd General Assembly File No. TBD, HB 49, §101.01, eff. 9/29/2017.
Effective Date: 09-26-2003; 2007 HB119 09-29-2007.
121.481 Special investigations fund
The special investigations fund is hereby created in the state treasury for the purpose of
paying costs of investigations conducted by the inspector general. In response to requests
from the inspector general, the controlling board may make transfers to the fund from the
emergency purposes appropriation of the board, subject to the following conditions:
(A) The inspector general shall not request a transfer that would cause the
unobligated, unencumbered balance in the fund to exceed one hundred thousand
dollars at any one time;
(B) In requesting a transfer, the inspector general shall not disclose any information
that would risk impairing the investigation if it became public, provided that after
any investigation using money transferred to the fund from an emergency purposes
appropriation has been completed, the inspector general shall report to the board
the object and cost of the investigation, but not any information designated as
confidential under section 121.44 of the Revised Code.
121.482 Disposition of money received
Money the inspector general receives pursuant to court orders or settlements shall be
deposited into the state treasury to the credit of the general revenue fund.
121.483 Status of deputy inspector general as peace officer
A deputy inspector general appointed under section 121.48 of the Revised Code, who has
been awarded a certificate by the executive director of the Ohio peace officer training
commission attesting to the person’s satisfactory completion of an approved state,
county, or municipal peace officer basic training program, shall, during the term of the
deputy inspector general’s appointment, be considered a peace officer for the purpose of
maintaining a current and valid basic training certificate pursuant to rules adopted under
section 109.74 of the Revised Code.
121.49 Qualifications
(A) Subject to division (B) of this section, only an individual who meets one or more
of the following qualifications is eligible to be appointed inspector general:
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Office of the Ohio Inspector General / 2024 Annual Report
(1) At least five years experience as a law enforcement officer in this or any other
state;
(2) Admission to the bar of this or any other state;
(3) Certification as a certified public accountant in this or any other state;
(4) At least five years service as the comptroller or similar officer of a public or
private entity in this or any other state.
(5) At least five years service as a deputy inspector general in this or any other
state.
(B) No individual who has been convicted, in this or any other state, of a felony or of
any crime involving fraud, dishonesty, or moral turpitude shall be appointed inspector
general.
121.50 Administrative rules
The inspector general, in accordance with Chapter 119 of the Revised Code, shall adopt, and
may amend and rescind, those rules he finds necessary for the successful implementation
and efficient operation of sections 121.41 to 121.48 of the Revised Code.
121.51 Deputy inspector general for transportation department
There is hereby created in the office of the inspector general the position of deputy inspector
general for the department of transportation. The inspector general shall appoint the
deputy inspector general, and the deputy inspector general shall serve at the pleasure of
the inspector general. A person employed as the deputy inspector general shall have the
same qualifications as those specified in section 121.49 of the Revised Code for the inspector
general. The inspector general shall provide technical, professional, and clerical assistance to
the deputy inspector general.
There is hereby created in the state treasury the deputy inspector general for ODOT fund.
The fund shall consist of money credited to the fund for the payment of costs incurred by
the deputy inspector general in performing the duties of the deputy inspector general as
specified in this section. The inspector general shall use the fund to pay costs incurred by
the deputy inspector general in performing the duties of the deputy inspector general as
required under this section.
The deputy inspector general shall investigate all wrongful acts or omissions that have been
committed or are being committed by employees of the department. In addition, the deputy
inspector general shall conduct a program of random review of the processing of contracts
associated with building and maintaining the state’s infrastructure. The random review
program shall be designed by the inspector general. The program shall be confidential and
may be altered by the inspector general at any time. The deputy inspector general has the
same powers and duties regarding matters concerning the department as those specified in
sections 121.42, 121.43, and 121.45 of the Revised Code for the inspector general. Complaints
may be filed with the deputy inspector general in the same manner as prescribed for
complaints filed with the inspector general under section 121.46 of the Revised Code. All
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investigations conducted and reports issued by the deputy inspector general are subject to
section 121.44 of the Revised Code.
All officers and employees of the department shall cooperate with and provide assistance
to the deputy inspector general in the performance of any investigation conducted by the
deputy inspector general. In particular, those persons shall make their premises, equipment,
personnel, books, records, and papers readily available to the deputy inspector general. In
the course of an investigation, the deputy inspector general may question any officers or
employees of the department and any person transacting business with the department and
may inspect and copy any books, records, or papers in the possession of the department,
taking care to preserve the confidentiality of information contained in responses to
questions or the books, records, or papers that are made confidential by law. In performing
any investigation, the deputy inspector general shall avoid interfering with the ongoing
operations of the department, except insofar as is reasonably necessary to complete the
investigation successfully.
At the conclusion of an investigation by the deputy inspector general, the deputy inspector
general shall deliver to the director of transportation and the governor any case for which
remedial action is necessary. The deputy inspector general shall maintain a public record of
the activities of the deputy inspector general to the extent permitted under this section,
ensuring that the rights of the parties involved in each case are protected. The inspector
general shall include in the annual report required by section 121.48 of the Revised Code a
summary of the deputy inspector general’s activities during the previous year.
No person shall disclose any information that is designated as confidential in accordance
with section 121.44 of the Revised Code or any confidential information that is acquired in
the course of an investigation conducted under this section to any person who is not legally
entitled to disclosure of that information.
121.52 Deputy inspector general for workers’ compensation
There is hereby created in the office of the inspector general the office of deputy inspector
general for the bureau of workers’ compensation and industrial commission. The inspector
general shall appoint the deputy inspector general, and the deputy inspector general shall
serve at the pleasure of the inspector general. A person employed as the deputy inspector
general shall have the same qualifications as those specified in section 121.49 of the Revised
Code for the inspector general. The inspector general shall provide professional and clerical
assistance to the deputy inspector general.
The deputy inspector general for the bureau of workers’ compensation and the industrial
commission shall investigate wrongful acts or omissions that have been committed by or
are being committed by officers or employees of the bureau of workers’ compensation and
the industrial commission. The deputy inspector general has the same powers and duties
regarding matters concerning the bureau and the commission as those specified in sections
121.42, 121.43, and 121.45 of the Revised Code for the inspector general. Complaints may be
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Office of the Ohio Inspector General / 2024 Annual Report
filed with the deputy inspector general in the same manner as prescribed for complaints
filed with the inspector general under section 121.46 of the Revised Code. All investigations
conducted and reports issued by the deputy inspector general are subject to section 121.44
of the Revised Code.
There is hereby created in the state treasury the deputy inspector general for the bureau
of workers’ compensation and industrial commission fund, which shall consist of moneys
deposited into it that the inspector general receives from the administrator of workers’
compensation and receives from the industrial commission in accordance with this section.
The inspector general shall use the fund to pay the costs incurred by the deputy inspector
general in performing the duties of the deputy inspector general as required under this
section.
The members of the industrial commission, bureau of workers’ compensation board of
directors, workers’ compensation audit committee, workers’ compensation actuarial
committee, and workers’ compensation investment committee, and the administrator,
and employees of the industrial commission and the bureau shall cooperate with and
provide assistance to the deputy inspector general in the performance of any investigation
conducted by the deputy inspector general. In particular, those persons shall make their
premises, equipment, personnel, books, records, and papers readily available to the deputy
inspector general. In the course of an investigation, the deputy inspector general may
question any person employed by the industrial commission or the administrator and any
person transacting business with the industrial commission, the board, the audit committee,
the actuarial committee, the investment committee, the administrator, or the bureau and
may inspect and copy any books, records, or papers in the possession of those persons or
entities, taking care to preserve the confidentiality of information contained in responses to
questions or the books, records, or papers that are made confidential by law.
In performing any investigation, the deputy inspector general shall avoid interfering with
the ongoing operations of the entities being investigated, except insofar as is reasonably
necessary to successfully complete the investigation.
At the conclusion of an investigation conducted by the deputy inspector general for the
bureau of workers’ compensation and industrial commission, the deputy inspector general
shall deliver to the board, the administrator, the industrial commission, and the governor
any case for which remedial action is necessary. The deputy inspector general shall maintain
a public record of the activities of the office of the deputy inspector general to the extent
permitted under this section, ensuring that the rights of the parties involved in each case are
protected. The inspector general shall include in the annual report required under section
121.48 of the Revised Code a summary of the activities of the deputy inspector general
during the previous year.
No person shall disclose any information that is designated as confidential in accordance
with section 121.44 of the Revised Code or any confidential information that is acquired in
the course of an investigation conducted under this section to any person who is not legally
entitled to disclosure of that information.
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Office of the Ohio Inspector General / 2024 Annual Report
Table of Organization
Appendix 2: Table of Organization
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Office of the Ohio Inspector General / 2024 Annual Report
Contact Information
Mailing Address:
Office of the Ohio Inspector General
James A. Rhodes State Office Tower
30 East Broad Street, Suite 2940
Columbus, Ohio 43215-3414
Phone:
(614) 644-9110 (General Line)
(800) 686-1525 (Toll-Free)
(614) 644-9504 (FAX)
Email and Internet:
watchdog@oig.ohio.gov (Email)
watchdog.ohio.gov (Website)
Follow us on LinkedIn:
https://www.linkedin.com/company/ohio-office-
of-the-inspector-general
68
Office of the Ohio Inspector General
Rhodes State Office Tower 30 East Broad Street - Suite 2940 Columbus, Ohio 43215-3414
Office of the
Phone: 614-644-9110 FAX: 614-644-9504 Toll Free: 800-686-1525 Ohio Inspector General
Randall J. Meyer
Email: watchdog@oig.ohio.gov Website: watchdog.ohio.gov
2024
Annual
Report
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