18 January Online access to groceries for SNAP recipients January 18, 2017By Jon Coss - Blog Manager General Snap, Supplemental Nutrition Assistance Program 0 The USDA recently announced a pilot program, starting this August, to offer online access to groceries for Supplemental Nutrition Assistance Program (SNAP) recipients in seven states. Groceries will be delivered to the recipients’ homes by seven participating retailers including familiar names such as Amazon, Safeway, and Shoprite.For many SNAP participants, this is both a tremendous convenience (saving them time) and a potential necessity (providing access to healthy foods in rural and urban “food deserts”). In fact, America’s poor have higher access to the Internet than they do to cars: 88% to 79.6%. And no one can argue that time spent with family, working, or seeking work is more valuable than time spent commuting to and shopping in grocery stores.Of course, online transactions often lead to more opportunities for fraud. And for their part, the USDA is mandating stricter controls than those required for non-SNAP transactions, including the use of a secure PIN number on all SNAP transactions. They have also provided funding in recent years to help states address benefit card trafficking problems.It is also known that when large sums of money are distributed through online transactions, bad actors will innovate new ways to defraud the system. In 2014, while the improper payment rate in SNAP was relatively low at 3.66%, this still represented over $2.5 billion. Perhaps more concerning is that for 2015, after the USDA worked with all 50 states to assess their payment accuracy rates, they were not able to provide an overall improper payment rate for the SNAP program because data from 42 of the 53 reporting agencies could not be validated.In many ways, this situation encapsulates the challenges facing government organizations. While their main directive is to provide important services to citizens – which I believe includes online access to nutritious foods—they also must protect the taxpayers’ money and make sure benefits go to those who are qualified to receive them. We wish the USDA luck with this new pilot and stand ready to assist our state government clients in their program integrity efforts. Related Posts Congress Turns its Attention to SNAP Trafficking Fraud A few months ago, I wrote an article offering our support to the USDA Food and Nutrition Service (FNS) as it rolls out a new program offering online access to groceries for Supplemental Nutrition Assistance Program (SNAP) recipients. My main concern with the new initiative was that FNS cannot provide an accurate SNAP fraud rate because of unreliable data coming in from the states. And we all know that offering goods and services online presents even more opportunities for fraud.Now Congress is asking FNS additional questions in a letter sent to them on February 8th. Outlining the lawmakers’ concerns, the letter points out that as many as 10% of retailers who accept SNAP EBT cards participate in illegal trafficking schemes. These schemes pay recipients a discounted amount of cash or unapproved grocery items in exchange for their cards. They go on to point out that total annual fraud in the program is over $858 million.The massive size of the SNAP program is one of the major reasons, historically at least, it is so difficult to detect fraud. In 2016, the program distributed $67 billion in benefits to 44 million Americans through 260,000 authorized retailers. Interestingly though, as much as 85% of the retailer fraud is committed by small grocery and convenience stores, or even flea markets like the one in Opa-Locka, FL that we recently wrote about.With the advent of cloud computing and advanced analytics solutions, FNS now has access to the tools required to make a real difference in their fight against fraud. And by addressing the retailer side of the equation, they will also find, through association, many of the fraudulent individuals in the system as well. It would certainly make sense for FNS to leverage modern fraud detection technologies at the same time that they offer online access to groceries.It is also important to note that the number of SNAP program retailers and recipients, while large, is very manageable. Consider that at Pondera we’ve performed equally complex fraud analytics on Medicaid programs with as many as 200,000 providers and Unemployment Insurance systems with over 1,000,000 employers. And when one considers that the overwhelming majority of SNAP trafficking fraud occurs in a concentrated subsection of small and medium retailers, the problem becomes even more manageable. Two Interesting Cases of SNAP Fraud It has been an interesting few weeks for the Supplemental Nutrition Assistance Program (SNAP), formerly known as the Food Stamp program, with two high profile busts. Both cases illustrate common schemes used to defraud the SNAP program, which distributed over $70 billion in food-purchasing assistance last year to 44 million Americans.In Georgia, two convenience store owners used stolen identities to apply for SNAP benefits which were then loaded onto EBT cards (similar to credit cards) and mailed to addresses they controlled. Once received, they swiped the cards at their own convenience stores and pocketed over $800,000 before being caught. The U.S. Attorney assigned to the case said, “They used the SNAP system as an ATM for their personal gain, diverting critical benefits that help those who need assistance in our communities.”Then, in Delaware, seven case workers at the Department of Health and Social Services were indicted for creating 100 fake accounts and cashing $959,000 in benefits. After creating the accounts, the case workers had the EBT cards mailed to state service centers where they simply intercepted them and used the cards themselves. Their scheme was detected when a supervisor noticed incomplete application data for one of the cards.The Georgia case illustrates just how easy it can be (at least for a time) to use stolen identities to defraud government programs. Even if the suspects hadn't owned the convenience stores, it would not have been difficult for them to find one that would pay them a discounted price in cash for their cards.The Delaware case is one we commonly see across states and programs where unscrupulous employees use their knowledge of the system to defraud their own government agency. Large amounts of money, combined with loose supervision, often prove too tempting for those with questionable morals.A quick check of the government’s fraud reporting website, paymentaccuracy.gov, reveals that improper payment rates for SNAP are still not posted because of reporting problems. I look forward to updated numbers when they are available because even a small number like the 3.2% reported rate for 2014 translates to over $2.2 billion per year in improper payments. 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. 36% of Lifeline Recipients Can’t be Validated Another federal subsidy program is garnering congressional attention for large amounts of fraud, waste, and abuse. This time it’s the Lifeline program that provides discounts to low-income households for home or wireless telephone and broadband service. This program, which many Americans have likely never heard of, distributed $1.5 billion in subsidies to 12.3 million households in 2016.The problem is that a recent study by the General Accounting Office (GAO) could not confirm the eligibility of a whopping 36% of program beneficiaries. The surprising part of this is that validating eligibility is as straightforward as checking an applicant’s enrollment form against a qualifying benefit program, such as Medicaid-- if someone has already been deemed eligible for Medicaid, then they are also eligible for Lifeline.It is also troubling to note that the 84-page GAO report comes after a 2010 study that found problems with the program and led to a number of recommended reforms in 2012. Fast forward five years to today, and the problems persist.Fraud in Lifeline stems from several factors common to most government programs: pressure to distribute timely benefits, a lack of effective data matching, and service providers (in this case telecommunications carriers) that benefit from a lack of control. The GAO actually called this last one out in their report when they explained that “companies may have financial incentives to enroll as many customers as possible” despite questionable eligibility.None of the problems outlined in the report are particularly difficult to solve from a technical standpoint. But turf battles often lead to data sharing problems that lead to eligibility validation issues. And an unwillingness to enforce fraud reforms on businesses provides them with incentives to simply “look the other way”. Multiply this problem over the 2,300 federal subsidy programs operating today, and this adds up to a lot of money, all lost due to fraudulent, wasteful behavior. Binary Nature of Fraud Big data analytics and the predictive engines they spawned give Internet companies a way to monetize the online experience. By tracing online behavior, companies can target advertising, promotions, and point of sale opportunities based upon past buying decisions. Online habits of Web users can be associated with ideologies, interests, and values. Increasingly sophisticated probability engines predict future buying decisions with enough accuracy to fuel a dramatic increase in online sales and commerce over the past decade. Analysts use temporal versions of these tools to forecast market trends and evaluate risk.In the fraud detection market however, early attempts to detect fraudulent behaviors using these same probabilistic engines have achieved limited success.What makes detecting fraud different than detecting interests, values, and ideologies? The simple answer: Fraud is binary in nature–either a particular sequence of behaviors is fraud or it is not. For example, if an individual provider of medical services submits claims to an insurance company for 5,000 hours of services in a week (an instance from actual data), there had better be around 100 employees licensed to provide that service. If there are only three or four employees with the required licenses, the provider has committed fraud. Probabilistic engines struggle to detect fraud because they are not capable of modeling this“all or nothing”nature of violating a law.At Pondera, we still make use of predictive analytics. But rather than detecting absolute fraud, we use the algorithms mostly to inform our fraud scores and to detect emerging fraud methods.Once reliable methods of detecting fraud have been developed, predictive engines can also play an important part in helping insurance companies, financial institutions, and government agencies prioritize targets of investigation. Predictive models can identify the highest value targets that will recover the most money or disrupt the largest criminal organizations. Old Fashioned Credit Card Fraud While shopping for groceries this week, my wife turned from her cart when a man stumbled and fell in the aisle. Less than 30 seconds later, she noticed that her wallet was missing from her purse which was sitting in the cart. Total distance from her wallet: 5 feet.Within 3 minutes, she’d called me and alerted the store about what had happened. Within 15 minutes, I’d blocked our ATM card, our credit card, and a specialty retailer card. Total Time: 18 minutes and 30 seconds.What had the robbery netted? A $1,000 gift card purchased at a kiosk at a nearby retailer with our credit card. A second $1,000 gift card purchased at the same kiosk with our ATM card (I was under the mistaken impression that this would require the PIN number). And a $5,000 gift card purchased with the specialty retailer card. Total take: $7,000. In just 18 1/2 minutes.Of course, the thieves also got away with about $150 in cash and my wife’s driver license. She was worried that we were going to be robbed that evening “because they now had our address” but I convinced her that “having our address” made us no more likely to be robbed. We also freeze our credit which offers us some protection from identity theft. So this gave us some comfort.After this incident, I wondered just how much “old fashioned” credit card fraud still exists in the United States. As it turns out, quite a bit, as 23% of the $3 billion in annual credit card fraud is still the result of lost or stolen cards. I was surprised at this number given today’s more sophisticated identity theft and forgery schemes.As often is the case with fraud though, the aftermath can be even more costly than the initial theft. Financially, even though we were not directly responsible for the fraudulent transactions, in the end, we pay through higher fees and rates. And of course, it’s very difficult to assign a cost to the trauma of being robbed at your neighborhood grocery store.The lesson in all of this for me? While it’s important to protect your identity online, don’t forget that thieves still snatch wallets, look for credit card offers in your mailbox and trash, and call your home to try to trick or intimidate you into providing sensitive information. Comment (0) Comments are closed.