wic trafficking investigations.pdf
TRANSCRIPT
Alan Sheil, CFE WIC Compliance Investigator
Office of the Inspector General Wisconsin Department of Health Services
October 20, 2016
Providing cash in exchange for WIC/EBT benefits
Milwaukee, Racine and Kenosha
Approximately 1,200 authorized vendors statewide
1/3 of these vendors reside in 3 SE Wisconsin counties
Milwaukee County has the majority of high risk vendors
Trafficking occurs mainly at sole proprietors located in high-crime urban areas
Trafficking of WIC/EBT benefits occur
nationwide Infant formula is the #1 trafficked WIC food
item
Data Analysis Vendor Location and History Case Discussion and Planning Investigation Reports/Technology Criminal Referral/Administrative Hearing
Red Flags & Suspicious Data
Location, Ownership,
And Sanction History
• Previous owner permanently disqualified at this location for felony WIC trafficking
• Sanction amount $49,614
Action Plan
Data Analysis
Action
Compliance Buys
Audit
Combined No Action
Prepare all cases to meet highest standard Criminal prosecution
Audio/video recording is the gold standard for trafficking prosecution
Low cost, easy to use with a tremendous return
on investment Check your local/state consent requirements
Hotline Calls, Participant and Project
Complaints
State Model • FT Investigator (1) • Conducts UC buys • Manages own
investigation • Provides testimony
Wisconsin Model • Contract investigators (5) • Conducts UC buys • Investigation managed
by State Investigator
• UC or State Investigator testimony
13
Familiarity Buys
Cash, Alcohol & Tobacco
Diapers
Sweet Cereal
Buys 3-4 Non-authorized foods
Buys 1-3 Purchasing items with non-WIC tender
Buys 5-6 Non-authorized items
Buys 7-10
Undercover Investigator Role
Document and photograph evidence Transfer required evidence to supervisor Testify to findings at administrative hearings
and criminal trials
WIC Compliance Investigator Role
Secure evidence Document chain of custody Transfer cash to WIC Supervisor Deposit cash to Accounting Department
Prioritize trafficking investigations Notify USDA OIG before sending
sanction notices
Notify USDA FNS Regional Office when appeals are final
Criminal Convictions
Administrative Action
TV/Social Media Sites
Notice of Adverse Actions
The only way to guarantee your program has no fraud is
to never look for it
Contact Information
Alan Sheil 1 W Wilson Street
PO Box 2659 Madison, WI 53701-2659
[email protected] (608) 238-4719