1. Occupational Fraud
What Dentists Need to Know
Presented by
Erick Cutler &
Jerry Murray

2. Objectives
 Raise your occupational fraud awareness.
 Provide information and ideas for your practice.
Questions we will address:
• Percentage of occupational fraud cases in dental offices?
• What type of behaviors should dentists look for?
• How can dentists minimize occupational fraud risk in their office?
• What is the best method to approach an employee if there is a
suspicion of occupational fraud?
• Can and should a dentist legally pursue an employee if they have
evidence of occupational fraud?

3. Occupational Fraud Defined
 Employee deliberately misappropriates or
misuses company assets for personal benefit.
 “Company assets” is not just cash.
 Might be referred to as embezzlement or theft.
Detection is difficult because you only see what’s
showing……like an iceberg.

4. Occupational Fraud Risk Facts
5% of annual revenue lost to fraud
Median loss of $150 thousand (18 mos.)
85% of fraudsters are first time offenders
79% displayed warning signs
Asset misappropriation, billing and check
schemes were most common frauds
Weak or no internal controls
Too much control limited to one person
Most common detection....tips!!

5. Fraudster Example 1
Financial coordinator for dental practice
Time frame 18 months
Stole 237 checks written by patients and
insurance companies
Employee deposited into personal account via
ATM
Total loss $85,353
Discrepancies discovered in office’s operating
bank account – deposits per bank did not equal
amount posted to accounts receivable

6. Fraudster Example 2
Manager for medical practice
Time frame 2008-2011
Employee wrote checks to a business they
owned located out of state
Employee made electronic credit card and
student loan payments
Employee gave themself a bonus and paid for
unauthorized health insurance
Total loss $871,728
Uncovered via a tip from fellow employee

7. Fraudster Example 3
Office manager of dental practice
20 year “loyal and most trusted” employee
Wrote self 243 extra paychecks for various
amounts over several years
Total loss $359,458
Discovered when dentist received notices from
the IRS regarding shortage in payroll tax
remittances
When questioned, fraudster indicated:
“I did not feel it was stealing, but thought it was
owed to me for extra efforts both during the day
and after hours”

8. The Fraud Triangle
• Three common elements of fraud:
Motive
Opportunity
Rationalization
(MOR…. as in more than they deserve)
When motive and opportunity meet,
rationalization is just a baby step away.

9. Motive
Motives are ever changing.
What motivated you at age 20, today, tomorrow?
Personal finance issues
Greed
Addictions (drugs, alcohol, gambling, etc.)
Health issues and medical costs
Divorce
Elderly parent care
Living beyond their means
“The thrill of steal”

10. Opportunity
(The Keys to the Kingdom)
Whenever someone in the organization can initiate, execute and
conceal a monetary transaction without any checks and
balances.
 Giving someone signature authorization on your checking
account without compensating controls
 Allowing employees access to the office at times other
than normal working hours
 Allowing employees to make deposits with no crosschecks
 Not reconciling bank statements timely and accurately
 Not reviewing your 401K employee deferral deposits
 Not reviewing your payroll tax deposits.
This is the only factor in the fraud triangle you have any control
over!

11. Rationalization
(aka moral breakdown)
Rationalization for fraud can take many paths:
I am not paid enough
I work hard, I deserve this
I’ll just borrow the money and pay it back
No one will ever miss it
Wow, wonder if I can get away with
My kid really needs a new cell phone so his
friends won’t make fun of him

12. What’s wrong with this picture?
Billing manager:
- prepares and files claims
- opens the mail
- prepares and makes bank deposits
- posts receipts and makes adjustments to the
accounts receivable system
- receives billing inquiry calls from both patients
and payors
- reconciles the bank accounts
Billing manager rarely takes a vacation
Billing manager has new car, new clothes and
increased spending habits

13. OK, now what do I do?
Step One
Perform a risk assessment of your practice (foundation)
 “Follow the dollar” - study your internal processes from start to
finish and ask yourself “what could go wrong”?
 Identify where you have weak internal controls such as no checks
and balances, security, daily reconciliations (such as scheduling to
billings or deposits in bank to daily receipts)
 Pre-employment criminal background checks for all employees
plus a credit check for anyone with a financial role
 Follow through with reference checks and get references from the
references
 Consider obtaining fidelity bond insurance on employees

14. OK, now what do I do?
Step Two
Establish internal controls (walls)
 Establish the controls around the position….not
the person – very important
 You have protocols for dental procedures, why
not written finance policies and procedures?
 Communicate your financial policies and
procedures in writing and establish a fraud
policy as well as a robust anti-fraud program
 Be sure systems are secured and backed-up
daily where only you can control access.

15. OK, now what do I do?
Step Three
Monitor and Maintain (roof)
• Be unpredictable, periodically:
– open your mail for a few days
– periodically compare the deposit slip to cash posted to AR
– review the reconciliation of the daily schedule to the billings
– review the amount your employees are being paid
• Approve all accounts write-offs or adjustments
• Review the system audit trail for changes to prior
periods or other unusual or off-hour activity.
• Change your routine by arriving earlier than normal or
staying later than normal from time to time
• Require mandatory vacations and rotation of duties
• Re-evaluate changes such as opening a second office

16. Actionable Anti-Fraud Steps
Motive + Opportunity + Rationalization
 Don’t give your employees a reason to take from you.
 Be aware of changes in employee habits or circumstances.
 However, don’t get too close on a personal level as it could
cloud your skepticism radar.
 Establish AND Maintain the perception of detection.
 Design your controls around the position not the person.
 Clearly communicate expectations to all personnel in writing
as well as verbally, including ethics training.
 Consider a fraud tip reporting mechanism for employees.
 Be sure your systems are secured and backed-up daily where
only you can control access. Test your backups!
 Be proactive and unpredictable.
 Have your outside CPA conduct “surprise” inspections

17. What to do about Suspected Fraud
If you suspect fraud, contact your attorney immediately.
 You do NOT want to make a rash decision/false
accusation. Avoid the temptation to dismiss
immediately, as that may open you up to wrongful
termination claims.
 Do not confront the employee (as it may provide them
an opportunity to destroy evidence), but work through
the attorney to gather evidence and preserve
documentation. This may include the need for a fraud
investigator or forensic IT professional.
 Act quickly but not rashly.
 You may inadvertently destroy key evidence.

18. What to do about Suspected Fraud
Once you do have proof, you should have your
attorney quarterback and coach you through the
issue every step of the way:
If you find proof and have to let an employee go, you
must show them some evidence to justify your decision,
but NOT all the evidence. This should be done in the
presence of a witness.
After this, with the guidance of your attorney, determine
next steps (i.e. what kind of remedies are you looking for
and what do you want to get out of this).
Consider hiring a compliance consultant or creating
compliance manuals that the staff are aware of.

19. Specific Considerations for
Billing Fraud
• If the fraud is on the billing side, and it involves in
Medicare/Medicaid, then the legal ramifications
are much more complex.
Liability includes potential personal financial
loss, suspension or revocation of provider
number, and recoupment of payment from
services provided.
• This requires extremely quick action and self-
disclosure You, the dentist, must come forward
to explain specifically what has happened,
including the exact dollar amount compromised.

20. Anti-Fraud House
Risk assessment of your practice (foundation)
Strong system of internal controls (walls)
Monitor and maintain (roof)

22. If you have any questions, please feel
free to contact Jerry or Erick at:
Jerry Murray: (214)-635-2519
jmurray@gppcpa.com
Erick Cutler: (214) 635-2541
ecutler@gppcpa.com

23. References
Dawson, Steve. (2015). Fraud Prevention and Detection. [Lecture]. Fort Worth
CPA’s Free CPE Day.
Association of Certified Fraud Examiners – 2016 Report to the Nations on
Occupational Fraud.
A special thanks to Daniel Tatum, Attorney at Law from Friedman & Feiger:
dtatum@fflawoffice.com