NDIA Accountability Project

This project is in DRAFT

Strategic Risks (3)

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Strategic Risks (3)

The community has ownership, confidence and pride in the National Disability Insurance Scheme and the National Disability Insurance Agency

  • Stakeholders perceive that the Scheme has failed to meet the needs of people with disability and/or is too costly
  • Sufficient competent providers fail to emerge to meet the new and expanded demand for services
  • Sufficient qualified provider staff fail to emerge to meet the new and expanded demand for services
  • The Agency fails to meet its reporting obligations to Governments and the Commonwealth Parliament
  • The Agency fails to establish an organisational culture and management systems that foster accountability and continuous learning
  • The Agency fails to attract and retain sufficient talented leaders and staff to meet the challenges of start-up and/or full scheme rollout

Progress

  • Strategy
  • Strategic risks
  • Framework
  • Risk Management Manual
  • Intranet site
  • Risk Management Champions
  • Business Planning processes

Your role

  • Be familiar with the Agency’s risk management strategy and policy;
  • Alert managers to the presence of risks and participate in their management; and
  • Use the tools available to identify and manage risks in the workplace
  • Give us feedback

Fraud Control

“Dishonestly obtaining a benefit, or causing a loss, by deception or other means”

Fraud against the Commonwealth

Includes (but is not limited to):

  • Theft
  • Accounting fraud (false invoices, misappropriations etc.)
  • Unlawful use of, or unlawfully obtaining, property, equipment, material or services
  • Causing a loss, or avoiding and/or creating a liability
  • Providing false or misleading information to the Commonwealth, or failing to provide it when there is an obligation to do so
  • Misuse of Commonwealth assets, equipment or facilities
  • Making or using false, forged or falsified documents
  • Wrongfully using Commonwealth information or intellectual property
  • Bribery, corruption or abuse of office

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Fraud and Error

  • Fraud is a criminal offence

  • Fraud is based on deception

  • An error is not fraud

  • If you make a mistake — Tell your supervisor about the error — Follow it up with an email — Keep a record of the email

Agency’s Approach to Fraud Control

  • Fraud Control Framework & Plan
  • APS Values and Code of Conduct
  • Fraud Policy Statement
  • Fraud Awareness Education
  • Financial rules
  • Governance arrangements — Prevention and detection strategies

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Internal Fraud

  • Involves staff
  • Examples:
    • Falsifying a medical certificate or statutory declaration
    • Cheating on a flex sheet
    • Unauthorised disclosure of information
    • Claiming travel allowance you are not entitle to
    • Failing to record, or incorrect recording of, leave
    • Misuse of Cabcharge vouchers
    • Use of the Corporate credit card for personal gain

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… and more

— Using office printers for non-work related printing

— Internet — unreasonable personal use of internet, including emails and communicator/Lync

— Failing to secure portable assets such as TVs during relocation/renovations

— Personal use of pool vehicles/fuel cards

— Stealing laptops/phones/GPS devices

False information

  • Providing false information includes:
    • Backdating and post signing of records
    • Altering funding agreements/contracts etc. after the event
    • Submitting information in reports, acquittals, returns etc. that the author knew did or did not happen, and is untrue

Internal Fraud - Penalties

  • Internal fraud can result in criminal prosecution, and/or investigation under the APS Code of Conduct.

  • Penalties can include:

    • Dismissal
    • Demotion
    • Loss of Commonwealth contributed superannuation
    • Criminal conviction
    • Imprisonment

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Corruption & Collusion

  • How can it happen?

  • Internal/external collusion — if a staff member colludes with an external supplier to procure goods/services to get a personal benefit

  • “kick-backs” — payments made by service provider organisations to their employees/executive using Commonwealth funding

  • Acceptance of gifts/hospitality over specified amounts

Conflict of Interest

• A conflict of interest occurs when an employee is influenced, or may be perceived to be influenced, by personal interests when conducting his/her official duties

• If you have a conflict of interest, or are unsure, talk to your manager

External Fraud

  • Fraud by participants
  • Fraud by providers

External fraud — some examples

  • Examples include:
    • Community organisations receiving funds from the Agency and fraudulently misusing the money
    • Providing false or misleading financial information/reports to the Agency
    • Overcharging the Commonwealth for services
    • Submitting false invoices
    • Misuse of assets (including unauthorised acquisition or disposal)
    • Submitting audit reports that are not independent or are inaccurate

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Things to watch out for

• Things to watch out for:

  • Breeches to funding agreement/grants guidelines
  • Delays in providing reports or answering communications
  • Failure to submit reports required
  • Lack of records for invoices and purchase orders
  • Conflicts of interest in the Board/CEO
  • Complaints from ex-staff or clients
  • Poor internal controls and lack of policies in organisations
  • High staff turnover
  • Poor governance – no separation of duties, one person performing multiple roles

External fraud - penalties

  • Penalties and sanctions may include:
    • Criminal conviction
    • Imprisonment
    • Fine
    • Repayment of monies
    • Confiscation of assets

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Your role

  • You can report any suspected fraudulent or unethical behaviour to your immediate supervisor or the NDIA Fraud Manager.

  • You can provide information about suspected fraudulent or unethical behaviour impacting NDIA [redacted — s22(1)(a)(ii)] or the Scheme by email to [redacted — s22(1)(a)(ii)] or by calling 1800 650 717. Information may be provided anonymously.

What not to do

  • DO NOT — Attempt to investigate the fraud yourself — Alert the suspect — Mark or unnecessarily handle documents or material — keep in original condition — Discuss the matter with anyone, including colleagues, other than for appropriate reporting purposes

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  • Helen McKenna – (02) 6146 3464