Fraud, Waste, and Abuse Explained: Requirements, Examples, and Risk Mitigation

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Fraud, Waste, and Abuse Explained: Requirements, Examples, and Risk Mitigation

Kevin Henry

Risk Management

November 13, 2024

7 minutes read
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Fraud, Waste, and Abuse Explained: Requirements, Examples, and Risk Mitigation

Fraud, waste, and abuse (FWA) erode budgets, distort decisions, and damage trust. This guide clarifies each concept, shows how to spot them through concrete examples, and outlines practical risk mitigation steps you can apply in day-to-day operations.

Use these definitions and controls to strengthen Compliance Programs, align behaviors with policy, and protect resources across finance, operations, and procurement.

Defining Fraud

Fraud is an intentional act of deception for personal or organizational gain that causes—or is likely to cause—financial or reputational loss. It involves knowing misrepresentation, concealment, or collusion to obtain an unauthorized benefit.

From a control perspective, fraud triggers the highest level of scrutiny. You need robust Internal Controls, disciplined Audit Procedures, and reliable Reporting Mechanisms to prevent, detect, and respond to fraud effectively.

  • Key elements: intent to deceive, false statements or concealment, and an unauthorized benefit or loss.
  • Common contexts: billing and payroll, vendor and contract management, financial reporting, and asset handling.

Defining Waste

Waste is the careless, unnecessary, or inefficient use of resources that yields little or no value. Unlike fraud, waste does not require intent to deceive; it often stems from poor planning, weak Resource Management, or outdated processes.

Waste quietly drains capacity and budgets. Tightening planning, measurement, and accountability reduces waste without adding bureaucracy.

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  • Typical drivers: redundant work, underutilized assets, and processes that exceed what is required to meet objectives.
  • Control focus: performance metrics, cost-benefit checks, inventory discipline, and lifecycle management.

Defining Abuse

Abuse is the improper use of position, systems, or resources contrary to policy or norms, even if not explicitly illegal. It includes actions that circumvent controls or exploit loopholes for convenience or advantage.

Abuse thrives where oversight is weak and exceptions are routine. Clear Procurement Policies, approval thresholds, and consequence management are essential to deter abuse.

  • Typical behaviors: policy overrides without justification, preferential treatment, or excessive personal use of organizational resources.
  • Control focus: documented approvals, segregation of duties, conflict-of-interest disclosures, and monitoring of exceptions.

Illustrating Fraud Examples

  • False billing: submitting invoices for goods not delivered, services not rendered, or inflating quantities or rates.
  • Ghost employees: paying individuals who do not work for the organization, with wages diverted to an insider.
  • Kickbacks and bid rigging: steering awards to favored vendors in exchange for bribes or splitting bids to predetermine winners.
  • Expense fabrication: manufacturing receipts or altering amounts to claim reimbursements for fictitious costs.
  • Asset misappropriation: theft of cash, inventory, equipment, or manipulation of write-offs to conceal losses.
  • Timesheet fraud: intentionally overstating hours or recording time for another person (buddy punching).
  • Financial statement manipulation: recognizing revenue prematurely or hiding liabilities to meet targets or covenants.
  • Vendor collusion: colluding with suppliers to fix prices or rotate bids while appearing competitive.

Illustrating Waste Examples

  • Duplicate software licenses: paying for overlapping tools or seats that remain unused month after month.
  • Overstocked inventory: buying far beyond forecasted demand, leading to obsolescence or storage costs.
  • Unnecessary travel: in-person meetings with minimal value when virtual options suffice.
  • Gold-plating: adding features or quality beyond requirements without commensurate benefit.
  • Rush fees and premium shipping: recurring expedited orders caused by weak planning.
  • Idle assets: vehicles, laptops, or machinery sitting unused while new purchases continue.
  • Rework and waiting: process bottlenecks that force teams to repeat tasks or sit idle between steps.
  • Underutilized subscriptions: analytics, training, or support packages rarely accessed by staff.

Illustrating Abuse Examples

  • Policy workarounds: splitting purchases to stay below competitive bidding thresholds set by Procurement Policies.
  • Preferential treatment: directing awards to friends or relatives (nepotism) without transparent evaluation.
  • Excessive per diem or mileage: maximizing allowances beyond actual need or route taken.
  • Personal use of assets: using company vehicles, fuel cards, or equipment for non-business purposes.
  • Unwarranted overrides: managers bypassing controls or approvals without documented, risk-based justification.
  • Data misuse: accessing confidential information for personal advantage or outside business interests.
  • Intimidation or retaliation: discouraging employees from using Reporting Mechanisms or raising concerns.

Implementing Risk Mitigation Strategies

Build strong Compliance Programs

Design a program that sets expectations and sustains accountability. Anchor it in a clear code of conduct, leadership tone, and risk assessment. Define ownership across business units, compliance, and internal audit so everyone knows their role.

  • Document policies and procedures that define acceptable behavior and controls for high-risk processes.
  • Embed Ethics Training during onboarding and refreshers so staff recognize fraud, waste, and abuse scenarios.
  • Map risks to controls, owners, and testing plans, then review at least annually.

Strengthen Internal Controls

Design preventive and detective controls that make misconduct difficult and detection likely. Keep controls simple, automated where possible, and aligned to real risks.

  • Segregation of duties: separate requesting, approving, receiving, and recording activities.
  • Approval workflows: enforce thresholds, dual approvals for high-risk spend, and justification for exceptions.
  • Access and change controls: restrict system privileges and log administrative activity.
  • Asset controls: physical counts, barcoding, and reconciliations for cash, inventory, and equipment.

Execute risk-based Audit Procedures

Use data analytics and sampling to verify that controls work in practice. Combine periodic audits with targeted reviews when red flags emerge.

  • Analyze spend for duplicates, split purchases, round-dollar patterns, or weekend/after-hours transactions.
  • Perform surprise counts, vendor master file reviews, and payroll anomaly testing.
  • Track remediation to closure and retest to confirm sustainability.

Establish trusted Reporting Mechanisms

Make it easy and safe for people to speak up. Offer multiple intake channels and protect reporters from retaliation to surface issues early.

  • Provide anonymous hotlines, web portals, and open-door reporting to management and compliance.
  • Standardize triage, case management, evidence handling, and escalation criteria.
  • Communicate outcomes (as appropriate) to reinforce trust in the process.

Improve Resource Management to reduce waste

Plan, measure, and optimize how resources are acquired, used, and retired. Treat capacity and inventory like cash—visible, controlled, and performance-managed.

  • Adopt demand planning, inventory targets, and reorder points tied to realistic forecasts.
  • Rationalize software and subscriptions; retire tools with low usage and consolidate overlapping features.
  • Use KPIs such as utilization, cost per output, rework rate, and cycle time to drive continuous improvement.

Tighten Procurement Policies and third‑party oversight

Enforce fair competition and transparent supplier selection. Strong procurement reduces fraud schemes and abuse while cutting wasteful spend.

  • Require competitive bidding above defined thresholds and maintain auditable documentation.
  • Conduct vendor due diligence, including sanctions checks and beneficial ownership where appropriate.
  • Apply three-way match (purchase order, receipt, invoice) and block payments to unapproved vendors.
  • Mandate conflict-of-interest disclosures and recusal protocols for evaluators.

Respond and remediate decisively

When issues arise, act quickly and fairly. A disciplined response protects evidence, limits losses, and signals zero tolerance.

  • Initiate investigations, place holds on records, and preserve assets promptly.
  • Apply consistent consequences, seek recovery, and notify stakeholders as required.
  • Perform root-cause analysis and implement corrective actions to prevent recurrence.

Conclusion

Fraud, waste, and abuse differ in intent and impact, but all undermine performance. By building strong Compliance Programs, reinforcing Internal Controls, running focused Audit Procedures, promoting safe Reporting Mechanisms, sharpening Resource Management, and enforcing disciplined Procurement Policies, you can prevent issues, detect them early, and respond with confidence.

FAQs.

What are the common indicators of fraud?

Red flags include unusual vendor patterns (duplicate invoices, round-dollar amounts, sequential invoice numbers), unexplained lifestyle changes, frequent policy overrides, mismatched supporting documents, weekend or after-hours transactions, and payments to new vendors that share addresses or bank details with employees. One red flag is not proof, but clusters warrant prompt review.

How can organizations detect waste effectively?

Start with visibility. Track usage and outcomes, then compare costs to value. Use spend analysis to spot duplicate tools, inventory turns to flag overstock, and process metrics (cycle time, rework, queue lengths) to find bottlenecks. Conduct periodic utilization reviews for assets and subscriptions, and set thresholds that require justification for premium shipping or rush orders.

What steps reduce the risk of abuse in resource management?

Define clear rules and enforce them consistently. Establish approval thresholds, limit exceptions, and document rationale for overrides. Use segregation of duties, conflict-of-interest disclosures, and regular exception reporting. Align Procurement Policies with Resource Management so planning, purchasing, and asset use are measured against business need and policy.

How often should compliance training be conducted?

Provide Ethics Training at onboarding and at least annually thereafter, with targeted refreshers when policies or systems change. Reinforce with short, role-based micro-learnings and scenario exercises throughout the year to keep expectations current and practical.

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