Terry Gerton You’ve done some looking into a data set that the DOGE team inside the Health and Human Services agency released. It described it as the largest Medicaid data set in department history. From your legal perspective, what was different about this release compared to prior transparency or fraud prevention efforts?
John Barry Well, there’s a couple things. This is the first time that the Department of Health and Human Services has ever released provider-level Medicaid data to the public. Previously, there were very limited ways to access Medicaid provider-level data, meaning data that you could look at specific providers and what they were billing, but that was required often institutional access and cost money. This is the first time that this has ever been available to the public, and specifically, a data set released to the public for the public to look at and try to find…
PAYROLL & HR CONTROLS (PREVENTING “GHOST” SCHEMES)
Payroll fraud is often the hardest to detect because it “looks” like a normal business expense.
- Segregation of Duties (SoD): The person who adds new employees to the system must not be the same person who approves the monthly pay run.
- Mandatory Vacation Policy: Require all financial and HR staff to take 5–10 consecutive days of leave annually. Fraud often surfaces when the perpetrator isn’t there to “hide” the trail.
- Ghost Employee Audit: Perform a quarterly “Headcount Reconciliation” where managers must physically verify every name on their payroll list exists.
- Self-Pay Blocking: Ensure the payroll software has a hard-coded block preventing administrators from editing their own salary or bank details.