mistakes or subterfuge can happen anywhere
This page is pre-emptive only. I am unaware of any recent or on-going practices with current city employees or leadership that would constitute fraud. That said, our city and schools have experienced fraud or the appearance of fraud. (2013) (2019) (2023)
Sallisaw is similar to other towns and small cities. A realistic acknowledgment of Sallisaw’s strengths and struggles is required. The About Sallisaw page outlines our strengths, needs, and opportunities.
City and county governments must allocate resources to tackle pressing issues such as crime, trafficking, and code enforcement. Of course, these key areas require attention, and potential issues inside the city government also warrant attention.
This website—and my intention—is to celebrate our city and cast a vision for what we might become and how we might arrive there. I do not intend to judge or disparage the good people working on our behalf. Of those I have spoken with over the last three months, the city’s employees perform their work honestly and with integrity.
Even so, Financial Controls must be in place as guardrails. Three broad areas of occupational abuse are corruption, asset misappropriation, and financial statement fraud. Each of these areas is discussed below. I have also prepared a white paper outlining strategies to combat fraud in municipal management.
I am concerned about our use of differing accrual methods. While generally, this is an accepted practice in municipalities, it can shade the true financial position of a city toward the end of a fiscal year (even if innocently done).
While all forms of fraud and abuse of government money and assets are equally egregious, the expression “Corruption” seems to draw the most visceral headlines and press. This is closely followed by “Asset Misappropriation,” including cash, inventory, and other assets. Misappropriation is generally easy to understand, both what it is and how it might be done.
The third category deals with financial reporting and financial statement subterfuge. Except for those most familiar with finance and accounting practices, activity issues in this area can sometimes take time to grasp.
Conflicts of Interest
Conflicts of interest can take the form of sales or purchasing schemes. Actions taken through conflicts of interest, particularly in sales and purchasing, is a significant issue in many organizations, including government entities.
These conflicts arise when individuals involved in the procurement process have personal interests that could influence their decisions, compromising the integrity of the purchasing process.
Sales and purchasing issues often involve scenarios where decision-makers may benefit from the contracts or purchases they oversee. These could manifest in various ways, such as accepting—in the most sever forms—kickbacks, influencing contract terms in favor of specific vendors, or having undisclosed supplier relationships. Please note that I am not intending to imply these issues exist here. I am communicating that they can happen anywhere.
To combat these potential issues, strict policies regarding disclosure of interests, clear guidelines for procurement processes (e.g., consistent with state statutes), and regular audits are essential. Training employees on ethical conduct and transparency can also help prevent conflicts of interest from becoming a gateway to questionable actions.
With our city, among the recommendations described already, I recommend hiring a certified procurement officer if we do not already have that in place. APICS (for example) has a rigourous certification process that includes a great deal of emphasis on ethics. There are specific Oklahoma State Statutes that outline appropriate practices.
Asset Misappropriation
I will continue emphasizing that these paragraphs are not an accusation. These paragraphs describe actions that can happen anywhere, in any municipality. Further, these have happened in publicly traded businesses, small and medium businesses, not-for-profit, as wall as municiple organizations. Sallisaw might have accounting controls for all or most of these.
Cash Misappropriation
Skimming: An employee takes cash from sales before it is recorded in the sales ledger, effectively pocketing the money without any record.
Lapping: An employee uses customer payments from one account to cover shortfalls in another account, creating a cycle of deception to conceal theft.
Ghost Employees: A payroll specialist adds fictitious employees to the payroll system, receiving paychecks for individuals who do not exist.
False Refunds: An employee processes a refund for a nonexistent product return, diverting the funds into their account.
Cash Register (Cash Box) Theft: An employee manipulates cash register totals to conceal losses, removing cash directly from the register without ringing up sales. These examples illustrate how cash misappropriation can take various forms but ultimately results in the unauthorized loss of funds from an organization.
Billing Schemes
Billing schemes involve submitting fraudulent invoices or charges for goods or services that were either never provided or inflated beyond their actual value, resulting in improper payments to vendors or individuals.
Fake Invoices: A fraudster creates and submits invoices for nonexistent services or goods to receive unlegitimate payments.
Kickback Arrangements: A vendor submits inflated invoices, sharing a portion of the extra payment with an employee who facilitated the fraudulent billing.
Overbilling: An employee inflates the amount billed on an invoice, charging the organization more than the actual value of the goods or services received.
Shell Companies: An employee establishes a fake company to bill their employer for services, allowing them to receive payments for work that was never done.
Duplicate Billing: An employee submits the same invoice multiple times, receiving payment more than once for the same goods or services. Note that this category (duplicate billing) can be more complex, especially in organizations that employ invoice-matching procedures. But it can still occur:
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- Manual Errors: Employees who process invoices manually may unintentionally submit the same invoice due to oversight or lack of attention. This could happen if they still need to document that an invoice has already been processed.
- Different Departments: If multiple departments handle invoices for the same products or services, one department may need to know that another has already paid for the same invoice, leading to duplicate payments.
- Vendor Practices: Some vendors may intentionally send duplicate invoices due to their accounting issues or as a strategy to increase their revenue. If internal controls do not thoroughly check for this, the organization could pay for the same service twice.
- Invoice Modifications: An employee may slightly modify a previously submitted invoice (e.g., changing the invoice number or date) and re-submit it, which can sidestep some matching processes focusing on exact matches.
- Timing Differences: Invoices could be submitted close together in time for the same service, and if they are not clearly labeled, a company might inadvertently pay both if they are processed without careful matching. Effective internal controls and careful monitoring are essential in preventing such duplicate billing. However, vulnerabilities can still exist in various areas of the processing workflow.
Payroll Schemes
This scheme involves adding fictitious employees to the payroll system. The perpetrator processes payroll for these nonexistent employees, collecting paychecks that are then pocketed.
Payroll Manipulation: Employees may manipulate the number of hours worked or the pay rate for themselves or others. This could involve falsifying clock-in and clock-out times to inflate hours or changing pay rates improperly.
False Overtime Claims: Employees submit claims for overtime that they did not work. This could involve fabricating overtime hours or claiming overtime that was never approved.
Falsified Timecards: Employees may create or alter timecards to show more hours worked than they put in. This can involve collusion with supervisors or using fraudulent methods to manipulate the timekeeping system.
Extra Pay for Work Not Performed: An employee may claim to pay for work that was never completed, such as requesting vacation or sick leave pay, while not eligible for it.
Phantom Employees or Duplicate Payments: This involves processing duplicate payments or creating phantom employees in the payroll system to receive additional undeserved funds.
Kickbacks from Payroll Fraud: Employees may collude with payroll staff, providing kickbacks in exchange for extra pay or benefits they are not entitled to. Each of these schemes can significantly impact an organization’s finances and integrity, making it essential to implement proper controls and audits to mitigate these risks.
Expense Reimbursement
This type of fraud occurs when employees submit false or inflated expense claims for reimbursement. This can include submitting receipts for non-business-related expenses, inflating the amounts on legitimate expenses, or claiming expenses for items or services that were never purchased or used for business purposes. Since employees often have direct access to the reimbursement process and can easily submit claims without scrutiny, it tends to happen more frequently. (Also see Petty Cash)
Payment Tampering
While also a serious issue, this type involves altering payment records or checks to redirect funds, usually requiring higher access to financial systems or accounts. This makes it somewhat less common than expense reimbursement fraud, as it typically entails more risk and complexity.
Inventory and Other Assets
Internal Theft: Employees may steal physical inventory items for personal use or resale. This can involve taking items from storage or manipulating inventory records to cover the Theft.
External Theft occurs when non-employees (like shoplifters) steal inventory from the organization. While not directly related to employee actions, it can still significantly affect inventory levels.
Inventory Manipulation and Falsifying Inventory Counts: Employees may deliberately misreport inventory counts to hide Theft or losses. This could involve inflating inventory figures on reports to make it appear that more products are present than is the case.
Concealed Obsolescence: Manipulating inventory records to hide or delay the write-off of obsolete or unsellable items, resulting in inflated asset values.
Unauthorized Personal Use of Company Equipment: Employees may use company-owned equipment for personal purposes without authorization, which can lead to wear and tear or damage that the organization is responsible for.
Misappropriation of Assets: Employees might remove or use company machinery, vehicles, or tools for personal projects, leading to financial loss or operational inefficiency.
Fraudulent Returns and Exchanges (Return of Stolen Goods): Employees may steal inventory and return it for legitimate refunds or exchanges to pocket the cash.
Falsified Receipts: Using fake documents to process returns for nonexistent items, allowing employees to obtain cash or store credit fraudulently.
Ghost Inventory by Creating Nonexistent Inventory: Employees may fraudulently create inventory records for items that do not exist, leading to financial misstatements. This could involve manipulating inventory management systems to inflate asset values.
Supplier Fraud: Employees may collude with suppliers to inflate billing or accept overpriced inventory based on kickbacks. This results in the organization acquiring more inventory than necessary, impacting financial resources.
Inaccurate Record-Keeping: Not maintaining accurate records of inventory usage can obscure real losses and lead to inefficiencies, increasing the chance of inventory fraud going unnoticed.
Summary
Fraud can happen in any town, including Sallisaw, which faces its own set of challenges and strengths. It’s important for city and county governments to focus on issues like crime and code enforcement, while also ensuring that financial controls are established to prevent fraud. This includes being aware of three main areas: corruption, asset misappropriation, and financial statement fraud. Corruption often attracts attention due to its seriousness, while asset misappropriation involves taking cash or resources unlawfully. To protect public funds, it’s essential to implement policies that promote transparency and accountability.
One significant type of fraud is conflicts of interest, particularly in sales and purchasing, where decision-makers might benefit personally from contracts. This can lead to unethical practices like kickbacks and unfair vendor relationships. Establishing a fraud hotline and attentiveness toward the potential issues will serve our city well.
Addressing these issues requires strict rules and regular audits, as well as training employees on ethical behavior. Additionally, asset misappropriation can involve tactics like skimming cash, creating fake invoices, or overbilling. By understanding these forms of fraud and taking proactive steps, Sallisaw can work toward a more secure and transparent municipal management system.
This page represents my opinions. It does not intend to accuse or imply impropriety by current practices in the City Government or by any individual or groups of individuals. I am not an attorney or a Certified Professional Accountant (CPA).