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Enforce ongoing compliance, performance and contract reviews

Type of countermeasure

This is a prevention countermeasure. Prevention countermeasures are the most common and cost effective way to stop fraud. They prevent or limit the size of the fraud risk by reducing the likelihood and consequences of fraud.

Summary

Require clients, staff and third parties to have ongoing compliance, performance and contract reviews.

Why this countermeasure matters

Lack of ongoing compliance, performance and contract reviews may lead to clients, staff and third parties:

  • acting dishonestly or without care once a benefit, grant or contract has been awarded
  • providing false information about their ongoing work performance or the delivery of contract obligations
  • failing to disclose changes in circumstances that might affect their ongoing entitlement to a benefit or payment
  • failing to disclose changes that may affect their ability to meet contract conditions
  • retaining access to systems or information when it is no longer required.

How to put this countermeasure in place

Some ways to implement this countermeasure include:

  • undertaking regular compliance checks with providers and clients
  • reassessing the suitability of service providers, contractors or vendors
  • regularly reviewing system accesses to confirm users still require the access
  • only allowing clients to continue to receive payments if they meet monthly participation requirements
  • regularly reviewing and monitoring staff performance
  • regularly reviewing contract performance to make sure requirements are being met.

How to measure this countermeasure's effectiveness

Measure the effectiveness of this type of countermeasure by using the following methods:

  • Analyse completed reviews to confirm these are undertaken regularly as required.
  • Review a sample of completed requests/claims to confirm reviews are undertaken with appropriate attention to detail.
  • Review procedures or guidance to confirm it clearly specifies how reviews are undertaken.
  • Confirm reviews are consistently undertaken.
  • Ask staff about the review processes or systems to make sure they have a correct understanding.
  • Analyse statistics and reports on staff performance reviews.
  • Identify how ongoing compliance, performance and contract requirements are communicated to staff, customers and third parties.
  • Confirm that someone cannot bypass review requirements even when applying pressure or coercion.

Related countermeasures

Develop clear instructions and guidance for activities and processes, such as instructions for collecting the right information to verify eligibility or entitlements, procedures to help staff apply consistent and correct processes and guidance to help staff make correct and ethical decisions.

Set up system prompts and alerts to warn users when information is inconsistent or irregular, which either requires acceptance or denies further actions.

Escalate non-standard requests or claims for further review or scrutiny. Non-standard requests or claims might include those that are late, do not meet normal conditions, include evidence that is difficult to verify (such as from overseas) or are for amounts that are higher than normal.

Automatically match data with another internal or external source to obtain or verify relevant details or supporting evidence. This countermeasure is supported by the Office of the Australian Information Commissioner's Guidelines on data matching in Australian government administration.

Conduct internal or external audits or reviews to evaluate the process, purpose and outcome of activities. Clients, public officials or contractors can take advantage of weaknesses in government programs and systems to commit fraud, act corruptly, and avoid exposure.

Related Fraudster Personas

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