Anti-fraud Playbook to Provide Actionable Guidance to Agencies in Fighting Fraud
Published: October 25, 2018
Earlier this month the CFO Council and the Bureau of the Fiscal Service released an anti-fraud playbook to help agencies improve program integrity, reduce improper payments and combat fraud in federal programs.
According to data from Paymentaccuracy.gov, federal improper payments totaled $141 million in FY 2017. Of this $8.8 billion was reported as confirmed fraud. FY 2017 is the first year that the improper payments data set has broken out improper payment amounts identified as fraud. HHS showed the highest amount categorized as fraud at $6 billion followed by DOD at $1.1 billion.
The Program Integrity: The Antifraud Playbook was developed for use by the entire financial management community, including federal, state, and local agencies to “help advance the goal of safeguarding public resources.” The website states, “The playbook and accompanying appendices are designed to provide practical guidance, leading practices, and helpful resources for agencies to establish or enhance their antifraud programs and meet the requirements of the Fraud Reduction and Data Analytics Act of 2015 and OMB Circular A-123.” The playbook also specifies actions to streamline program integrity initiatives with the intent of assisting agencies in reducing the amount of money lost through improper payments.
The 102 page document organizes 16 plays into four phases:
Create a Culture
1. How Exposed Are You?
2. Know Where You Are and Where You Want to Be
3. Fraud is Not a Four-Letter Word
4. Create the Antifraud Dream Team
Identify and Assess
5. Think Like a Fraudster
6. Discover What You Don’t Know
Prevent and Detect
7. Build on What You Have
8. Look for Quick Wins When Starting Fraud Analytics
9. Stay a Step Ahead
10. Rain Your People
11. Know Thyself (and Thy Agency)
12. Sharing is Caring
13. Take What is Theirs and Make It Yours!
14. Establish a Feedback Loop with Your IG
Insight into Action
15. Take Action
16. Check Your Progress
Each play offers an explanation for why that play is important, key points, and a checklist for guiding agencies through implementing the aspects of the play.
A panel of experts spoke about the playbook in September at the Association of Government Accountants’ 2018 Internal Control & Fraud Prevention Training symposium in Washington, DC. Linda Miller, Director at Grant Thornton LLP, moderated the session with Tammie Johnson of the Financial Innovation and Transformation Office within the Treasury Fiscal Service and Heather Pajak, Senior Policy Analyst at OMB.
Miller asked why Treasury developed an antifraud playbook. Johnson said that her office conducted a financial management strategy study to find out “where are we now and where should we be going?” They found within their organization they spend a lot of time on business transaction processes and reporting, but not much time using the data to discover fraud. So they are working on Robotic Process Automation (RPA) and how can they use data analytics to detect fraud. VA is also a strategic partner.
Pajak believes the playbook will help the federal government move to be more pro-active, getting away from recovery and moving toward prevention.
Johnson remarked that the government needs to operationalize the fraud framework. There needs to be a culture where people are not afraid to talk about fraud and sharing information about risks. She also stated that the playbook intentionally aligns with GAO’s Fraud Risk Framework which was developed in 2015.
The panel agreed that federal agencies are at different levels in maturing their program integrity models. They believe the playbook will provide a step by step guide for agencies to follow. There’s an interplay between the fraud risk framework, the playbook and improper payments, according to the group.
Combating waste, fraud and abuse in federal programs is a high priority for the administration. This playbook should provide guidance and more direction for agencies in their fight against fraud. As federal agencies continue to explore new and innovative ways to address fraud and improper payments, opportunities for contractor products and services may emerge in the areas of big data, analytics, recapture audits, ID authentication, data warehousing, data authentication, predictive modeling, forensic accounting, and fraud case management.