In times of crisis, things such as fraud and risk grow to levels that leave organisations scrambling in their efforts to reduce or prevent significant damage. Public Spectrum caught up with Ben Lumley on his thoughts about the trends and challenges the NDIA face when it comes to fighting against fraud and non-compliance.
Ben Lumley is currently the Head of Government Solutions Australia at Quantexa and worked as the Director of Data & Analytics for the Scheme Integrity Branch at the National Disability Insurance Agency (NDIA) at the time the interview was conducted.
In this, you will find insights into the NDIA’s journey, and Ben’s thought leadership for driving outcome-focused and tech-enabled anti-fraud solutions.
What are the key fraud trends and or pain points you face currently?
Ben Lumley: Some of the key trends we are seeing are:
- Service not delivered as specified. This could include not delivering for the length of time specified, the quantity specified or the incorrect support or service.
- Inappropriate use of plan funds by participants. This is where a participant used their NDIS plan funding for things not considered reasonable or necessary.
- Sharp practice and inappropriate services and supports. This can include repairs or replacements that are not needed or excessive in their costs.
Some of the pain points we are experiencing with the detection of fraud and non-compliance are:
- The complex and changing policy environment of the NDIS
- The disparate corporate system make it difficult is have all the required data in a central and accessible location
- Incomplete set of data in which to apply analytics to
- Poor business administration practice by providers. This led to detection methods identifying false-positive suspected fraud and non-compliance cases.
- Lack of data input validation with the agency business systems lead to poor data quality and also contributes to many of the false-positive suspected fraud and non-compliance cases.
What impact, if any, has COVID had on fraud activity and practices in your organisation?
Ben Lumley: In response to COVID-19, like many government entities, NDIA introduced new payments and policies to support both NDIS participants and providers. These changes included provider stimulus payments and relaxing cancellation rules which did increase the opportunity for potential fraud and non-compliance behaviour.
As such the Agency had to also respond with new risk detection and monitoring profiles to detect fraud and non-compliance relating to these changes. Given the need to introduce these changes and controls quickly, the Agency had to reprioritise its planned fraud and non-compliance activity.
In regards to COVID-19’s impact on fraud activity, like in all sectors, there has been an increase in scam and email hijacking related activity.
Interestingly the restrictions put in place by various jurisdictions, have helped to more accurate address risks around services not delivered and the agency is currently exploring data related to this. COVID has made fieldwork a challenge but hasn’t stopped it.
What technology or other solutions are you adopting to help address these trends and or pain points?
Ben Lumley: Developing and prioritising risk detection profiles – SAS based business rules using data points that indicate certain behaviour
Partnering with an industry leader to pilot advanced analytics focused on determining when services were not delivered as specified and better use of data and information held by the agencies’ corporate systems.
We are also developing an analytics maturity road map to chart a course to better investment and use of technology to combat fraud and non-compliance.
What outcomes, if any, have these technologies or solutions provided so far?
Ben Lumley: The SAS-based risk detection profiles have been in play for a while now and are producing actionable output and identifying instances of suspected fraud and non-compliance.
In regards to the piloting of advanced analytics, it’s a little too early to discuss outcomes but the agency is confident that there will be demonstrable benefits to come.
Given the current landscape, what tips do you have for fraud teams and professionals when it comes to assessing and refining their anti-fraud programs for current times?
Ben Lumley: One aspect in applying regulation or fraud and non-compliance activities in a government context is to be fully informed of the policy context that underpins the activity. What I mean by that is, often you can get caught up chasing undesirable behaviour or practices that in the end are unable to be addressed due to a lack of legislative or policy guidance. Essential, it can be practices that are contrary to the policy, scheme or program’s intent but are not illegal or enforceable.
Another is working closely with your agency or organisation’s fraud risk team that is responsible for the overall fraud risk assessment. All your activity should be anchored to the risks and mitigation strategies contained within the fraud risk assessment. If not then either it needs updating and we all have a responsibility there, or what you are doing may not be contributing to addressing what in the fraud risk assessment.
Lastly, I’d like to raise the idea of piloting new processes and techniques in detecting fraud. If we are able to foster a “trial and error” culture then we may be able to better keep pace with emerging fraud risks.