wic trafficking investigations.pdf

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

https://www.youtube.com/watch?v=pShdvZ7NmmM

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

alan.sheil@wi.gov (608) 238-4719