Washington River Protection Solutions: Overtime Codes and Audit Independence in the 2017 Settlement

Whistleblower Justice Network

Washington River Protection Solutions agreed to pay $5,275,000 in a 2017 settlement over false-timecard allegations involving overtime codes and audit independence. The government alleged that workers claimed emergency-call premiums without an emergency, managers accepted incomplete overtime records, and the company’s internal audit leadership avoided meaningful oversight. If you knew when those shifts were arranged or how the audits were run, you may recognize what the billing left out.

The Justice Department’s January 19, 2017 announcement covered claims to the Department of Energy from October 2008 through July 2013 at Hanford’s Tank Farms. It connected false timecards to management decisions about how overtime was recorded, paid and checked.

Overtime Accountability at the Tank Farms

The government alleged that Washington River Protection Solutions accepted overtime records that left the Department of Energy unable to determine how much of the claimed work employees had actually performed.

According to the Justice Department, federal law enforcement explicitly warned WRPS about systemic timecard fraud when the company received the Tank Farms contract in October 2008. WRPS had kept its predecessor’s workforce and loose overtime accounting procedures. The government alleged that WRPS took no steps to change those procedures until after July 2013 and that managers and executives looked the other way as the practices continued.

The most common alleged practice was incomplete accounting for claimed overtime, with management’s acceptance.

In federal contracting, the records behind a labor charge matter to the payment. Under federal hourly-payment rules, time worked, employee qualifications and the applicable rate matter to what the contractor can bill. The Hanford cases show the practical chain: recorded time, management acceptance, the contractor’s reimbursement request and government payment. An employee may see the work while someone in payroll sees only the entry that turns it into a charge.

Emergency Call in Overtime Codes Raised the Rate

Emergency Call In overtime carried a higher rate under WRPS’s collective bargaining agreement with its Tank Farms workforce. The Justice Department described a specific condition for using that code: an actual emergency had to leave the worker with less than 16 hours’ advance notice of the overtime shift.

The government alleged that WRPS almost always allowed employees to use the higher-paying Emergency Call In code when no emergency or urgency existed. According to the announcement, that practice caused the Department of Energy to pay hundreds of thousands of dollars in inflated overtime labor rates.

A timecard could describe overtime and still misstate the circumstances that entitled the worker to the emergency premium.

That is a distinction someone arranging shifts or processing payroll can recognize. The person who knew when the work was scheduled may know something the coded timecard leaves out. We connect that knowledge to the premium claimed and the charge passed to the government. A few letters on a timecard can carry a more expensive story than the shift actually supports.

Why Internal Audit Independence Mattered

Washington River Protection Solutions’ Tank Farms contract required an Internal Audit Department. The government alleged that the company compromised that oversight by placing its general counsel in charge during the contract’s first three years.

The Justice Department said the Department of Energy generally knew about the organizational arrangement, but did not know the full extent of the general counsel’s direction of day-to-day auditing. It alleged that the general counsel lacked auditing experience and consistently avoided meaningful oversight of the ongoing timecard problem.

When the Department of Energy learned more about that role, it required WRPS to remove the general counsel from the head of internal audit and hire a manager who could exercise independent judgment and provide the oversight the contract required. The agency’s response reached who ran the department and how that person could challenge the company’s practices.

We see the absurdity in an audit department whose leadership allegedly avoided examining the very conduct it was there to catch. The timecards passed through a business that had an audit function. The government’s allegation was that the function failed to provide the independent scrutiny the contract called for.

A study published in the Journal of Forensic and Investigative Accounting in 2019, Unique Characteristics of Management Override Fraud Cases, helps explain why that distinction matters. Using occupational-fraud survey data, it compared cases involving management overriding controls with cases involving a lack of controls. Internal audit, independent financial-statement audits, anti-fraud policies and codes of conduct were more closely associated with the override group. The paper’s conclusion describes how an organization can invest in oversight and still be vulnerable:

However, another type of organization also can be victimized: the organization that invests in anti-fraud measures (e.g., an internal audit function, independent audits of the financial statements, an anti-fraud policy, and a code of conduct) and extensive controls, but still falls prey to those who override the otherwise effective controls.

Unique Characteristics of Management Override Fraud Cases, Journal of Forensic and Investigative Accounting, 2019

For an internal auditor, the useful question is who can act on an uncomfortable finding. In WRPS’s case, the government’s allegations made the audit department’s leadership and daily work part of the false-claims story.

Separate Hanford Cases, Separate Conduct

The predecessor’s timecard case helps explain the government’s concern about the procedures WRPS inherited. Under the criminal non-prosecution agreement accompanying its civil settlement, CH2M Hill Hanford Group admitted participating in a conspiracy with employees to submit false timecards. The government’s WRPS announcement pointed to that predecessor’s admission when describing WRPS’s alleged continued use of loose overtime accounting.

Washington River Protection Solutions paid $6.5 million in its later idle-time settlement, announced in 2025, including $3 million in restitution. WRPS admitted receiving reimbursement for excessive idle time from October 2017 through December 2024 and failing to schedule or assign sufficient work. The Justice Department reported a $1.4 million whistleblower reward for an employee in that later case.

What WRPS Changed After July 2013

The Justice Department reported that Washington River Protection Solutions changed its procedures, introduced a proxy card system, negotiated changes to the collective bargaining agreement and worked toward more meaningful internal auditing after the July 2013 notification about its controls.

Those changes touched the same parts of the operation described in the allegations: how time was accounted for, the agreement governing premium pay and the oversight of charges.

The department also credited the company’s career internal auditors for continuing their work despite the alleged systemic failings. The government’s criticism focused on the arrangement under which the department operated and the oversight its leadership allegedly avoided.

What Proof Do You Need as a Whistleblower?

We work with you to connect the billing evidence to what you know about the work and the decisions behind the charge. A timekeeper may understand the code used, a supervisor the reason for the call-in, and an auditor how the company responded when its controls were questioned.

The warning to WRPS is a particularly concrete part of the government’s account. The government said federal law enforcement had warned the company and alleged that management continued the same procedures. That makes knowledge inside the company part of the story alongside the payment itself. Your view of who understood the problem can explain something a payroll total cannot.

What the Settlement Resolved

The Justice Department said the settlement amount exceeded double the Department of Energy’s alleged loss.

The Department of Energy Office of Inspector General investigated the case. The U.S. Attorney’s Office for the Eastern District of Washington and the Justice Department’s Civil Frauds Section handled the government’s case against the company.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know What the Overtime Code Meant

If you know how a Hanford overtime charge was approved or why an audit failed to challenge it, speak to one of our Whistleblower Experts about how the overtime was billed. We build your strongest government procurement whistleblower case around the work, the payment and the decisions inside the contractor, and bring in government procurement fraud whistleblower lawyers who understand labor charging and audit obligations. You have us beside you from the first conversation through the case.

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