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Milwaukee County's Approach to Fortifying Its Fraud Fighting Function
By Matthew Hart

Milwaukee County has had a fraud hotline within its Audit function since 1994. In its first three months, the fraud hotline generated 169 telephone calls, 7 letters, 1 fax, and 5 personal conversations. Back then the County had a much larger workforce and managed a hospital, a power plant, and many more social welfare programs. Milwaukee County has divested much since 1994, but fraud in its many forms remains. The fraud hotline had been operating effectively for 20 years when I started working for Milwaukee County. 
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But like all things, it could be better. Coming from Chicago and an Inspector General’s Office, I wanted to create a fraud program for Milwaukee County that was built on a successful past and ready for current and future challenges. I focused my improvements on three concepts: structure, awareness, and partnership.


STRUCTURE

One of the first priorities was to pass a county ordinance which specifically prescribed the office’s powers and County stakeholders’ duties during fraud investigations. The ordinance was the office’s support—the justification and the rationale if and when someone questioned an investigation. The ordinance authorizes my office to conduct fraud investigations; commands cooperation by employees, elected officials, and vendors; provides access to records and locations; requires reporting allegations or known instances of fraud; prohibits retaliation against a person related to a fraud investigation; and prohibits making a complaint in bad faith.

We did not start from a blank slate. The Association of Inspectors General Principles and Standards for Offices of Inspector General has suggested powers and language to include in statute. Because the Yellow Book is fairly silent on how to conduct fraud investigations, the office also adopted the Principles and Standards Quality Standards for Investigations as the framework for fraud investigations.

A fraud investigation finding, likely more so than a finding in a performance audit, can potentially lead to someone getting suspended, losing their job, or even criminal prosecution and loss of liberty. A powerful way to attack a finding is to attack the steps that led to the finding. Because of this, the process of getting to that finding has to be strong, consistent, and defensible. This is one of the reasons that we adopted the investigation standards recommended by a reputable group like the Association of Inspectors General. My office revised and created policies which govern the most likely contestable investigation activities.

For example, we created a policy that the interview of the investigation subject has to be audio recorded and that there has to be two auditors present for the interview. We also developed a policy that auditors have to read the subject an interview protocol, which essentially establishes the person’s rights during the interview and establishes the person’s responsibility to cooperate and answer questions truthfully.

We created a policy for storing evidence so that the chain of custody is clear and unbroken. For computer-derived evidence, the policy establishes that a copy of the evidence is used during reviews. This protects the evidence so that the original data is not altered via the examination.


AWARENESS

Advertising the fraud hotline to county employees and the general public is a priority. Tips are the most common method for organizations to learn about fraud. We needed to let people know that there was someone in the county who wanted to hear about fraud, waste, and abuse.

Every year, county employees receive a large twelve-month calendar which highlights the county’s holidays and paydays. This calendar is made by the county’s House of Correction Print Shop. My office simply called the Print Shop and asked to add the fraud hotline telephone number and a short sentence about the fraud hotline to the calendar’s margins. They agreed, and now the fraud hotline number hangs prominently in offices and individual work stations.

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Additionally, the office developed a presentation about the fraud hotline to educate current employees about the fraud hotline’s history; what fraud, waste and abuse generally mean; and how to make a report. The core elements of the presentation have been included in an updated new employee orientation (NEO) program which started a few years ago.

For years my office has made custom magnets which advertise the fraud hotline. The current version lists the fraud hotline telephone number and includes a QR code link to our website. The magnets are given out to new hires at the NEO program.

In order to educate the general public, my office launched a short-term advertising campaign which focused on bus routes and bus shelters. The bus system is the mass transportation system for Milwaukee County. We looked at a route map and rider data provided by the bus operator—a quasi-governmental county agency—and developed a plan. We put advertisements in buses that ran high ridership north-south and east-west routes and advertised on the sides of bus shelters that were well-traveled. Our goal was to cover as much of Milwaukee County as practical.


PARTNERSHIP

My office has a number of strengths, but it does have some weaknesses; we do not have subpoena power and we are not a law enforcement agency. Fortunately though, my office has emphasized maintaining strong, positive relationships with a number of local and federal law enforcement agencies. We have built up these relationships by conducting professional, detailed, and organized investigations. These agencies, like the District Attorney’s Office and the FBI, can leverage their resources to aid our office’s investigations.

I regularly attend trainings on fraud trends and prevention that other government and private sector auditors and investigators attend. These trainings usually include a contact sheet for the training attendees in the handouts. Our office has made some great contacts using those contact sheets.

For example, my office was investigating an altered county check which was deposited into a local bank. I looked at a contact sheet for an investigator at that bank. I found one and sent her an email. I explained who I was, how I found her information, and why I was emailing her. She was extremely helpful. My office will continue to leverage the relationships made possible by these trainings.

Within the County, my office and the Ethics Board came to an arrangement in which office auditors can serve as “agents” of the Ethics Board to investigate complaints that may involve a breach of the County’s Code of Ethics. By ordinance, the disclosure of certain Ethics Board records requires notifying the filer that his or her records were released. While serving as agents of the Ethics Board, office auditors can gain access to Ethics Board records without triggering that notification. This step helps preserve the integrity of the investigation and does not alert the filer that his or her records were released.

The best partner was my office leadership. None of the initiatives listed above could have become reality without the support of my director. The person understood what I was trying to do and gave me the support and resources necessary to accomplish my program goals.