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Pondera FraudCast

Welcome to the Pondera FraudCast, a weekly blog where we post information on fraud trends, lessons learned from client engagements, and observations from our investigators in the field. We hope you’ll check back often to stay current with our efforts to combat fraud, waste, and abuse in large government programs.

Funding Donald Trump’s Child Care Program

Funding Donald Trump’s Child Care Program

Donald Trump recently announced plans for a new child care and paid family leave plan. While I will not be offering any opinions on the plan or on Donald Trump as a candidate, I was interested to see that the announcement sparked discussion of government fraud, waste, and abuse. In this case, the discussion surrounds the Unemployment Insurance (UI) program because Mr. Trump claims that he will reduce fraud in UI by over a billion dollars each year to help pay for his proposed child care plan.

Paymentaccuracy.gov, a government website devoted to providing information on payment inaccuracies, estimates a 10.7% improper payment rate in UI for 2016 resulting in $3.5 billion in erroneous payments. While a small amount of this actually represents underpayments, the majority of the $3.5 billion is waste. The trick, of course, is reducing fraud without delaying benefits to those who are eligible and without spending more money on improving the system than you actually save!

This is where things get interesting. The White House Office of Management and Budget claims that UI program integrity improvements, over the next 10 years, would result in just $150 million a year in savings, or just over 4% of the $3.5 billion. The Congressional Budget Office’s estimates are even worse. They estimate annual savings of $40 million at a cost of $17 million per year, for a net gain of just $23 million per year!

These dramatically different viewpoints between Mr. Trump and government regulators point out two problems when discussing government fraud, waste, and abuse. On the one hand, aspiring politicians and much of the public dramatically underestimate how difficult it can be to detect, investigate, and enforce fraud findings. On the other hand, many government agencies only report on the fraud they know about and estimate savings based on using traditional techniques against those unrealistically small numbers.

Here’s what I can tell you from our experience working in Unemployment Insurance. By combining modern detection techniques with cooperation between states and the federal government, we could net far greater savings than are estimated today. Whether or not other facets of Mr. Trump's program are viable is up to you, the voter, to decide. However, I think we can all agree that there are better uses for those funds than making payments to fraudsters.
SNAP Fraud Testimony

SNAP Fraud Testimony

On June 9th of this year, Mike Carroll, the Secretary of the Florida Department of Children and Families provided powerful testimony to the House Oversight and Government Reform Subcommittee on Government Operations. Secretary Carroll outlined some of the many successes Florida has achieved in fighting SNAP fraud. He also clearly articulated a point that we constantly stress here at Pondera. In his words…
“We are not talking about “mom and pop” storefront operations or cottage industries. We are talking about major criminal enterprises with ties to other serious and dangerous criminal activities including drug sales, prostitution and human trafficking.”
He went on to describe the SNAP program’s largest bust ever at a flea market in South Florida. Since 2011, the flea market had served 41,000 SNAP recipients and processed $89 million in transactions. Investigators found display stands using plastic fruit and vegetables, rotten produce, guns, and large amounts of cash at the retailers.
While 22 arrests have already been made, authorities still have a huge investigation in front of them. In addition, Florida is taking what they’ve learned and using it to identify other suspect locations.
This case, while large, is clearly not an isolated incident. Consider that even using the government’s own 3.7% improper payment rate translates to $2.6 billion per year in SNAP fraud and waste. Those numbers surely support a large number of organized schemes. So for those of you that think SNAP fraud is a “victimless crime”, it’s clearly time to reconsider your position.
Pondera’s Founding

Pondera’s Founding

I am often asked what motivated me to start Pondera. So… Here goes.

In 2011, after my previous company was acquired, a good friend working at Google asked me to visit their Mountain View campus. He was interested in learning how to embed Google products in large government programs like Medicaid, Unemployment Insurance, and eligibility systems.

Over the course of a couple of days, I was briefed on Google’s products and capabilities and I was struck by the massive computing power that their customers could literally “rent” as needed. Having spent over 20 years in technology, it was becoming clear to me that cloud computing was more than the latest tech buzzword. But it was during a discussion about the Google Prediction API though, that my imagination was really piqued.

With Prediction API, I realized, government organizations could analyze huge amounts of data to predict future events and identify data anomalies. All without ever buying a single piece of hardware or software. Thinking back to my time working on large government systems, I realized that this new technology had the potential to solve one of the problems that had always bothered me: fraud, waste, and abuse.

Over the years, I had worked on over 100 large government projects. And it had always amazed me that despite the fact that improper payments often exceeded 10% of program disbursements, most government bids had only a handful of requirements to address the problem. My government colleagues explained that they were under such pressure to deliver their services with such limited budgets that they simply could not invest appropriately in fraud detection.

Sitting in that room at Google headquarters, it was apparent to me that emerging technologies offered a new way to solve an old problem. One week later, I founded Pondera and set out to change the fraud detection market. Five years later, we’ve helped our clients prevent and collect hundreds of millions of dollars in improper payments. And we’re just getting started...


Why It’s Important To Be Nimble When Fighting Fraud

Why It’s Important To Be Nimble When Fighting Fraud

Fighting fraud is an interesting challenge. When an organization shuts down a fraud scheme, bad actors don’t suddenly become good citizens. Rather, they evolve. They evolve by designing and testing new methods that, when they succeed, are exploited until they too are detected and shut down. In fact, many of the more enterprising fraudsters proactively try out new methods to avoid any “breaks in revenue”. This constant game of “whack-a-mole” is well known to program integrity staffs.

This ever-changing nature of fraud schemes demands an ever-changing detection system. If an organization’s fraud detection methods look more or less the same as they did the year before, I can almost guarantee you that their fraud rates have returned to the levels prior to the introduction of the detection systems. Bad actors will simply find another way to conduct their business.

For these reasons, it is important to be nimble in fighting fraud. Complex technologies and massive data warehouses will lose effectiveness over time. If it takes a year to negotiate a change order, to deploy new technologies, or to integrate new data sources, literally billions of dollars in improper payments can be lost. The trick is to stay even with or just a “step” behind the bad actors, not miles behind.

While all state agencies want to choose the right partner to help them with their fraud detection efforts, I would challenge them to ask themselves the following questions: How easy is the company to work with? How willing will they be to incorporate new technologies (even if not their own)? How important is fighting government fraud to their company versus everything else they do? How passionate are they about the problem? Honest answers to these questions will reveal a lot about the future success of your efforts.
RFPs: The Devil is in the Details

RFPs: The Devil is in the Details

As a company that works with government clients, we spend a tremendous amount of time and money responding to Requests for Proposals (RFPs). We understand that governments use RFPs to ensure competitive bidding processes and to articulate their requirements. However, the process still causes enough angst for prospective bidders that, ironically, it often actually limits competition.

We wrote in a previous blog post about the lengthy RFP procurement cycles and their impacts on the final project. Today I’d like to discuss the formats of the RFPs themselves which often cause confusion, leading to large numbers of vendor questions, which in turn leads to delayed timelines and incorrectly submitted bids. I confess that I have never been on the “other side of the table” writing an RFP and I can only imagine how difficult it must be. But I still have one simple suggestion that I wish government agencies would take prior to releasing an RFP.

Before releasing an RFP to the vendor community, I suggest that government run an internal “mock” procurement: “release” the bid to a few agency employees and ask them to respond to it. They don’t have to provide actual answers, just an outline so they can make sure they understand what the RFP requires, where responses should go, how the format works, and other structural issues. It’s important that these people had nothing to do with the writing of the RFP document itself because then they’d naturally understand what they intended when they wrote it.

Commonly confusing issues we see in RFPs include where to place a Statement of Work (in tables or in text), repeated questions, seemingly mutually exclusive statements or requirements, and “thrown in” requirements that belong in other sections and break up the flow of the response.

I think government officials would be amazed at how much confusion and time they could take out of their procurements by performing this simple quality assurance exercise. This would also reduce the number of questions the state would have to respond to and provide more focus on issues of substance rather than administrative or formatting issues. Finally, it would lead to more uniformity of responses allowing governments to evaluate responses for their merit rather than having to search for answers to their requirements.
The Most Important System Feature

The Most Important System Feature

I believe that simple things can make a big difference. This week, for example, I went through self-checkout at a local grocery store and the keypad gave me the options of “debit card” or “all other tenders” to complete my transaction. “All other tenders”—who talks like that? No doubt there was a group of people that decided that, technically, “tenders” was the best word to cover all the other options. It doesn’t really matter that it makes the system more confusing. That’s my problem.

Software systems suffer from this problem perhaps more than any other consumer product. I remember the old joke about having to go to the “start” button to stop the computer. This still happens, despite the fact that experience has shown us that the single most important feature contributing to the success of software is usability.

Put simply, even the most powerful system is completely worthless if people can’t figure out how to use it. My own brother discovered this when he recently decided to switch from the iPhone to an Android phone for the additional capabilities. Not a very technical person, he quickly switched back complaining that he was utterly confused by the “full fledged computer” he was carrying around in his pocket.

At Pondera, we make the claim that our system is “built by investigators, for investigators.” And it’s true. Our most important design principle is to “mask” the underlying complexity of the system and provide analysts and investigators with an intuitive system that works the way they do. Technical people can’t do this. Data scientists can’t do this. Only investigators can do this. That’s why we hire them and task them with our most important work.
Ugly Case of Health Care Fraud

Ugly Case of Health Care Fraud

A few weeks ago, I published a blog post titled “Money Obtained Fraudulently is Rarely Used for Good Purposes”. In it, I made the argument that government fraud is a serious, and at times very ugly problem. Now I no longer have to make that argument because the United States Justice Department is making the argument for me.

Last week, the Justice Department announced the largest health care fraud case it’s ever prosecuted; one that defrauded over $1 billion over the past 14 years. The alleged perpetrators of the fraud are said to have leased private jets and chauffeured limousines. One even bought a $600,000 watch! Remember, this is your tax money we’re talking about. The system ran on a complex network of bribes and kickbacks.

And if that’s not enough, here is one of the schemes they allegedly ran. They “treated” seemingly healthy, elderly people with medications they did not need in order to create addictions which would lead to further treatments. Pure evil. Unfortunately, fraudsters are most active where large amounts of money meet vulnerable populations. This is yet another example of that and more reason for us to do what we do.
Pondera’s High Potential Leader:  Amanda Huston

Pondera’s High Potential Leader: Amanda Huston

Established in 1636, Harvard University is the United States' oldest institution of higher learning and one of the world's most prestigious universities. A couple of weeks ago, I had the remarkable opportunity to participate in the Harvard Business School Executive Education Program for High Potential Leaders. To step foot on this amazing campus filled with brick buildings plush with deep green climbing ivy, you almost immediately feel like you are part of something special (or perhaps inside some Matt Damon/Ben Affleck movie). Stepping foot in the state-of-the-art classroom with the instructor "pit" in the center, surrounded by 100 of the world's most talented and up-and-coming leaders, I wondered if I fit in this group or would have any common ground.

My learning group, a smaller team designed to facilitate debate and discussion on assigned topics, included eight talented young professionals; only two originally from the United States. They represented a variety of industries, none of which had anything to do with mine.

What I learned by working with this group, is that despite my initial hesitation, we were far more alike than I could have imagined. No matter their business, job title, or Country of operation, we faced so many of the same challenges and experiences in our professional lives. During one group activity, I began to think about how this applied to the clientele I serve at Pondera. Whether it's a small State unemployment program or the Nation's largest Medicaid program, these teams of dedicated professionals face so many of the same challenges and share similar experiences. Perhaps, I could bring them together through the Pondera client network and facilitate cross-state, cross-program sharing and learning. My brain was really starting to kick into high gear now.

Reflecting back on my time at Harvard, I decided to focus on the key ways I could translate my experience into benefit for my company and clients. I decided upon three themes:

  • Bold, passionate, inspiring leaders can change everything. No matter if you are managing financial accounts worth billions or a Government employee overseeing a Federal entitlement program, the culture created from these kinds of leaders brings success to the whole organization. Skills can be taught, management can be improved, but make no mistake, there is no substitute for extraordinary leadership. We must find these leaders, and then cultivate and cherish them.
  • Networks are critical to continued learning and success; make time to grow and nurture yours. Your network could be persons within or outside of your organization, family, friends, peers, professional mentors, etc. Networks serve as a vibrant source of creative energy, partnership, and may just offer the solution to whatever challenge you or your organization is facing. Make time in your daily grind to have a coffee, make a quick call, or even share a meal with key persons in your network.
  • Always be willing to adapt and evolve or be prepared for extinction. This is especially true in leading innovation, particularly in the data analytics arena. Fraud schemes change, data sources emerge, programs transform. At Pondera, we can never get comfortable or diminish our aggressive pursuit to lead the way. Governments must embrace the "information age" and transform their processes, modernize their programs, and challenge the status quo.

Graduation

The Problem With Knowing What You Know

The Problem With Knowing What You Know

I bet you cna’t bvleiee taht you can uesdtannrd waht you are rdnaieg. Unisg the icndeblire pweor of the hmuan mnid, aocdcrnig to rseecrah at Cmabrigde Uinervtisy, it dseno't mttaer in waht oderr the lterets in a wrod are, the olny irpoamtnt tihng is taht the frsit and lsat ltteer be in the rhgit pclae. The rset can be a taotl mses and you can sitll raed it whoutit a pboerlm. Tihs is bucseae the huamn mnid deos not raed ervey ltteer by istlef, but the wrod as a wlohe.

The preceding paragraph, which has made its way around the Internet for years, can be really fun to share with friends. However, it also serves as a caution to anyone involved in fraud detection. In many ways, bad actors, knowingly or unknowingly, have depended on how the human mind works to perpetrate fraud schemes. Like the old expression goes, sometimes the best place for fraud to hide is in plain sight.

This is especially true in government programs that process massive amounts of transactions and must adhere to a staggering number of program regulations. Traditional “top down” systems can analyze large data sets and find nothing wrong (after all, the first and last letters are in the right place). “Bottom Up” systems, on the other hand, will identify individual problems (the word is scrambled) but may miss the patterns in the data (this entire paragraph is scrambled). A common example of this is the medical provider that always “flies just below the radar” by maximizing claim amounts and frequencies.

The best detection processes take both a “top down” and “bottom up” approach. They can identify individual transaction problems as well as identify patterns of bad behavior over time. In this way, you can make the old “80-20” rule work in your favor. 80% of improper payments are likely caused by 20% of program participants. If you only address each individual transaction, you’ll never run out of work but you also never really improve your program integrity efforts.

Click here for an infographic on the "80-20 rule".
Is your organization ready for change?

Is your organization ready for change?

By the time we engage with an agency, they are fully convinced that they need to change something: the way they are detecting fraud, waste, and abuse, or maybe the way they are managing cases. When it comes to change though, we’ve found that the devil truly is in the details.

Each of your staff will typically fall into one of the following categories. It’s important to recognize this and to staff your change projects appropriately.

Champions: These people embrace the future vision and want to help achieve it. They love new challenges but also expect that they’ll need to find ways around unexpected problems. They vocalize successes and accept changes for the “long haul”. Projects without champions will never meet their potential.

Cynics: Unlike champions, these people think that the change, usually any change, is not necessary. They perceive their value in their knowledge of how “things have always worked” and any threat to this is a threat to them. There is no way to change a cynic’s mind and no way to bring them on board. Cynics are never good for a change project. It’s important to recognize them and keep them to the side.

Skeptics: Skeptics, which can often be confused for cynics, need proof to get on board with a change effort. They need to be convinced that the change is good for the agency or for them. Skeptics are a vital component to project staffing because the rest of your agency will clearly see when a skeptic has been “converted” to a champion.

Followers: This category makes up the majority of staff assigned to most projects. At the beginning of the project, they will contribute and won’t do anything to undermine the effort. As the project progresses, they will move to whichever side is gaining momentum: success or failure. This is why champions and converted skeptics are so important—they generate excitement and commitment from followers.

If this all sounds obvious, I challenge you to think back to a change effort that you’ve observed that should have succeeded but managed to fail short of expectations. You may very well find that the reason was that identifying “change readiness” was either done incorrectly or ignored altogether. We’re not advocating expensive, complex, and lengthy change processes. But we are suggesting that you think about this before engaging in any important project or process change.

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About Our Company

Pondera leverages advanced prediction algorithms and the power of cloud computing to combat fraud, waste, and abuse in government programs.



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