2 August 36% of Lifeline Recipients Can’t be Validated August 2, 2017By Jon Coss - Blog Manager General Assistance Program, Broadband service, Lifeline Program, Low-Income Household, Wireless Service 0 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. Related Posts Online access to groceries for SNAP recipients 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. 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. 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. The Irreplaceable Human Mind At Pondera, we are often asked whether fraud detection algorithms will ever completely replace human investigators. And while I can’t address the “ever” part of the question, I can confidently state that it will not happen in the foreseeable future. One of the major reasons for this? Prediction models, like many people, struggle to distinguish between cause and effect.A Stanford University professor recently shared her studies on this topic which support many of our own findings. She noted that while prediction algorithms are excellent at finding patterns in large data sets, their effectiveness is limited because they struggle with determining causation. An example she used is that algorithms have been shown to help identify patients who should not receive hip surgery because they would likely die of other causes. However, the algorithms are unable to prioritize those patients who should receive the surgery.In several cases, the professor notes that correlation can be as low as 50%. And she properly notes that while this may be fine in certain situations, governments simply cannot conduct such high-risk experiments with social welfare, economic policies, and other important matters. And unlike controlled environments, such as those that use placebos to test medications, the real world is simply too messy and unpredictable to control all factors.This problem of causation identifies an important intersection between human reasoning and prediction algorithms. We believe that in complex, rapidly changing environments like fraud detection, effective detection systems combine the power of modern detection algorithms with experienced human reasoning.By leveraging the individual strengths of both machine and human learning, we can analyze massive data sets and make sense of the findings. We regularly use the system to find the problem and ask the human experts to help explain the problem. This makes the results actionable, which ultimately is what our government partners require. How Fraudsters Stole Money from Venmo Users In yet another example of the creativity of fraudsters exploiting security flaws in commonly used services, the Federal Trade Commission recently announced a settlement with Venmo, the popular money exchange service. The charges, filed in 2016, include some surprisingly basic security flaws in Venmo, which boasts of “bank-grade security”. One major problem was found in Venmo’s cash reconciliation process. It would notify users that money had been deposited in their accounts when, in reality, many of the transactions were still under review. This allowed fraudsters to “purchase” and receive products before their payments were validated. Sellers, assuming that cash had been received, would ship the product and then find themselves without an actual payment. One scammer used this technique over several years to steal over $125,000 before being discovered.In addition to this security flaw, federal regulators also noted that Venmo neglected to notify users of username and password changes or when new devices were added to their accounts. This allowed hackers to hijack accounts without any warnings to the actual account owners.While the FTC’s settlement does not include any cash damages, it is likely that Venmo will face a slew of upcoming lawsuits. Beyond this, Venmo’s issues are particularly concerning to consumers. We often assume a certain level of security and common-sense practices when we use well-known applications and services. Clearly, we should all be concerned about trusting our money and identities with any company—regardless of how safe it appears to be. Nigerian Email Fraud In December, a 67-year-old Louisiana man was charged with 269 counts of money laundering for serving as a middle man in a Nigerian Internet scam. These scams, which everyone with an email account has encountered, promise large sums of money from inheritance or from a “prince” trying to leave the country in exchange for your financial information. Typically, they then require you to send money to release the funds and the operation continues to run into obstacles for which more money is required.When I receive these emails, I’m always struck by just how ridiculous the stories are. They are so obviously fake that only the most naïve would lend them any credence. Given the sophistication of some of the fraudsters we combat at Pondera, I’ve always wondered why these clearly unsophisticated scammers can’t put out more believable emails.After a bit of research on the subject, it turns out I’m the unsophisticated one. In fact, Microsoft Researcher Cormac Herley wrote a thought-provoking paper on the Nigerian Scams that concludes in part “By sending an email that repels all but the most gullible, the scammer gets the most promising marks to self-select, and tilts the true to false positive ratio in his favor.” So, like any good salesperson would do, the scammers are essentially feeding only the best leads into their pipeline and eliminating the poor leads early in the process so they don’t waste time pursuing them.Pretty brilliant actually, if you’re in to despicable crimes. And the results show it. The FBI’s Crime Complaint Center says that over the past five years it has received an average of 280,000 complaints and, more importantly, it estimates that victims have lost over $4.6 billion in that time. In the most extreme cases, victims were lured to Nigeria, held against their will, and extorted for additional money.If you’re interested in reading more about this, check out Mr. Herley’s paper at the link below:https://www.microsoft.com/en-us/research/wp-content/uploads/2016/02/WhyFromNigeria.pdf Comment (0) Comments are closed.