Compliance Checklist: Eliminating Silos to Detect and Report Waste, Fraud, Abuse

Eliminating information silos is essential to a modern compliance checklist that helps you detect and report waste, fraud, and abuse quickly. By aligning data transparency regulations with clear workflows and accountable roles, you can surface risks earlier and act decisively.

This guide turns policy intent into practical steps you can implement today—spanning inter-agency data sharing, compliance monitoring protocols, audit and investigation procedures, and anti-fraud reporting systems that protect whistleblowers while safeguarding mission outcomes and federal funding oversight.

Executive Order on Eliminating Information Silos

The Executive Order on eliminating information silos directs agencies to unlock data for responsible use, reduce duplicative systems, and standardize secure sharing across missions. It emphasizes risk-based access, privacy-by-design, and timely exchange to strengthen prevention and detection of waste, fraud, and abuse.

Key objectives

• Establish common data standards and metadata to enable trustworthy inter-agency data sharing.
• Inventory high-value datasets and remove unnecessary barriers while honoring privacy and security requirements.
• Operationalize data transparency regulations through measurable milestones and governance.
• Use analytics to prioritize oversight, audits, and investigations where risk is highest.

Checklist

• Name an accountable executive to lead silo elimination and publish a time-bound roadmap.
• Adopt shared data taxonomies and APIs; require machine-readable formats for new systems.
• Document legal bases for sharing and apply standardized data-use agreements with built-in safeguards.
• Stand up metrics for timeliness, completeness, and data quality tied to leadership performance reviews.

Agency Responsibilities for Data Access

Agency heads must balance access with protection. Your program should define who can access which data, for what purpose, under what controls, and with what audit trail. Clear governance and role-based permissions prevent both overexposure and unnecessary roadblocks.

Core responsibilities

• Designate data owners and stewards to approve access based on mission need and risk.
• Implement least-privilege, multi-factor authentication, and continuous monitoring.
• Map data flows end-to-end, documenting provenance, retention, and sharing conditions.
• Maintain access logs and alerts that feed your compliance monitoring protocols.

Checklist

• Publish an access matrix aligning roles to datasets and approved uses.
• Automate joiner-mover-leaver processes to prevent stale entitlements.
• Require periodic recertification of access and track exceptions to closure.
• Integrate access approvals with case management for audits and investigations.

Enhancing Accountability through Collaboration

Breaking silos requires cross-functional collaboration—compliance, program offices, finance, acquisition, CIO/CISO, legal, and the Inspector General community. Collaboration strengthens federal funding oversight by aligning controls across the grant, contract, and payment lifecycles.

Collaboration practices

• Run joint risk reviews that combine financial, programmatic, and cyber indicators.
• Use shared workspaces and common identifiers to connect cases across agencies.
• Co-develop audit and investigation procedures and rehearse coordinated response.
• Create rapid referral pathways for suspected fraud, including cross-jurisdiction alerts.

Checklist

• Charter a cross-agency oversight working group with clear decision rights.
• Define data-sharing SLAs for time-sensitive requests tied to case timelines.
• Adopt a common risk taxonomy so red flags mean the same thing everywhere.
• Track collaboration metrics: joint cases opened, time-to-referral, and recoveries.

Compliance Program Elements

A durable compliance program embeds prevention, detection, and response throughout operations. You need a coherent set of elements that work together and continuously improve based on results and lessons learned.

Essential elements

• Governance: a chartered committee, policies aligned to data transparency regulations, and leadership accountability.
• Risk assessment: recurring, data-driven reviews that consider fraud typologies and control gaps.
• Policies and procedures: clear, accessible guidance mapped to processes and systems.
• Controls and monitoring: automated checks, exception reports, and analytics across the transaction lifecycle.
• Reporting and investigations: anti-fraud reporting systems with documented triage, evidence handling, and escalation.
• Training and communication: role-based curricula with practical scenarios and job aids.
• Remediation and improvement: root-cause analysis, corrective actions, and control re-testing.

Checklist

• Publish a control library with owners, frequencies, and test plans.
• Align monitoring with audit and investigation procedures to avoid duplicated work.
• Set KPIs (e.g., exception clearance time) and KRIs (e.g., anomalous vendor activity).
• Report program maturity annually with prioritized improvement actions.

Reporting Mechanisms for Fraud Detection

Effective reporting channels surface issues early and protect those who raise concerns. Build multiple, trusted avenues and a disciplined workflow that transforms tips and anomalies into actionable cases.

Channels and safeguards

• Hotlines, web portals, and secure email with options for anonymity or confidentiality.
• Clear statements on non-retaliation and coverage under whistleblower protection statutes.
• Metadata capture for tips (who, what, when, where, how) with attachments and evidence tagging.
• Integration with analytics to correlate tips with risk indicators and payments data.

Triage and escalation workflow

• Intake screening for jurisdiction, completeness, and immediate risk to funds or safety.
• Scoring model to prioritize cases; define thresholds for referral to inspectors general.
• Documented chain-of-custody, interview protocols, and hold orders for records.
• Outcome tracking: substantiated, unsubstantiated, referred, recovered, lessons learned.

Checklist

• Publish reporting options widely and in multiple languages where appropriate.
• Set SLAs for acknowledgment, triage, and initial determination.
• Automate reminders for case owners and audit-ready case files.
• Monitor hotline health: volume, channel mix, substantiation rate, and time-to-closure.

Training and Education on Compliance

Training makes policies real. Tailor content to roles and deliver it in short, practical modules that reinforce behaviors you expect in the field and at headquarters.

Role-based curriculum

• Executives: oversight responsibilities, tone at the top, and performance metrics.
• Program staff: eligibility rules, documentation standards, and red-flag recognition.
• Acquisition and grants: conflicts of interest, vendor risk, and payment integrity.
• IT and data teams: secure design, access controls, and data sharing requirements.
• Investigators and auditors: interviewing, evidence handling, and case documentation.

Delivery and measurement

• Blended learning: e-learning, workshops, simulations, and microlearning refreshers.
• Pre/post assessments tied to key risks; retraining for low scores.
• Dashboards that track completion, comprehension, and field performance indicators.
• Annual updates reflecting new policies and lessons from investigations.

Role of Compliance Officer

The Compliance Officer orchestrates the program and ensures independence, authority, and resources to act. This role translates policy into daily practice and keeps leadership focused on risk and results.

Responsibilities

• Lead the compliance framework, including policy management and compliance monitoring protocols.
• Chair cross-functional risk reviews and align controls with federal funding oversight priorities.
• Oversee hotlines and anti-fraud reporting systems, ensuring fair triage and timely referrals.
• Coordinate with legal, IG, CIO/CISO, finance, and HR on investigations and remediation.
• Report regularly to leadership on risks, controls, outcomes, and improvement plans.

Authority and independence

• Direct reporting access to the agency head or governing board.
• Budget and staffing commensurate with risk profile and case volume.
• Protected escalation channels and documented non-retaliation commitments.

Conclusion

When you align governance, data access, collaboration, training, and reporting, you eliminate silos and strengthen detection and reporting of waste, fraud, and abuse. Use this compliance checklist to focus resources where risk is highest and to deliver measurable, repeatable oversight results.

FAQs.

What is the Executive Order on eliminating information silos?

It is a directive for agencies to reduce barriers to responsible data use, standardize secure sharing, and apply analytics to detect and prevent waste, fraud, and abuse. It operationalizes data transparency regulations and promotes inter-agency data sharing with clear safeguards and accountability.

How do agency heads ensure compliance with data access requirements?

They assign data owners, define role-based permissions, and implement least-privilege controls with continuous monitoring. Agency heads also require periodic access recertifications, document legal authorities for sharing, and track metrics that tie data access to oversight outcomes.

What protections exist for whistleblowers reporting fraud?

Whistleblowers are protected by whistleblower protection statutes and agency non-retaliation policies. Your program should provide anonymous or confidential channels, clear retaliation reporting paths, and prompt, documented responses to safeguard those who raise concerns.

How can organizations improve reporting mechanisms for suspected abuse?

Offer multiple reporting channels, publish expectations and SLAs, and integrate tips with analytics and case management. Standardize triage, preserve evidence, coordinate audit and investigation procedures, and share lessons learned to strengthen anti-fraud reporting systems over time.