As investigators, one thing we encounter every time
we speak to a group of dentists is that, in the area of embezzlement,
they consistently underestimate the capabilities of
their opponents.
The most common question asked of us is, “Will this
control/procedure/auditing step work?” followed by some
procedural change that the questioner intends to implement.
Normally, this change is designed to block a specific
embezzlement methodology.
For example, one question recently asked in a presentation
was whether using a “lockbox” system, where all mail
gets delivered to a third party (which then opens the mail
and inventories the contents), would prevent embezzlement.
This question is an example of denial of opportunity strategies for controlling embezzlement, because its goal is
to block a specific embezzlement pathway.
While we don’t think that strategies of this type are necessarily
bad ideas, we do believe that their effectiveness in
controlling embezzlement is overestimated.
Why Do People Steal?
Let’s start by debunking one of the myths about dental
embezzlement. Many dentists believe that embezzlement
occurs as a result of hiring mistakes and poor background
checking. Serial embezzlers (i.e., those who have stolen from
other offices before) definitely exist, but they account for less
than 15 percent of our investigations. The vast majority of
our perpetrators have no criminal record and no adverse
work history. However, since being hired by you, some pressure
has caused them to begin stealing.
In some cases, it is financial desperation the thief is
responding to. Various factors can make someone’s financial
position unworkable. It could be a spouse losing their
job, some kind of addiction or a divorce. These people,
who we label the “needy,” steal to preserve the basic needs
of their family.
We call the second group the “greedy.” These thieves
tend to be bright, and viewed objectively, are somewhat
underemployed in your office. It is common for them to
consider themselves (sometimes justifiably) as your intellectual
equal, and therefore the perceived income discrepancy
between you seems unfair. Of course, in this simplistic
comparison, they fail to consider the educational differences
and sacrifices that you made to achieve your position.
Their social circle tends to include people who are better
off financially. Money that is stolen is often spent on conspicuous
displays of affluence.
Whether they are needy or greedy, embezzlers are
responding to some powerful pressures. A motivated thief
who possesses an intimate knowledge of your procedures
and how you think is a truly dangerous opponent, and one
who is unlikely to be deterred simply because you have
blocked some, but not all, options for stealing.
Embezzlement Versus Controls
Let’s revisit the denial of opportunity strategies and see
how they withstand assault from a determined, knowledgeable
thief. We should mention that it is our policy
not to discuss specific embezzlement methodologies in
articles, so in order to protect dentists, we will confine
ourselves to a general discussion of how a thief will overcome
controls, but will not give information that might
aid thieves.
The first thing we will point out is that any control
or procedure that is dependent on implementation by a
staff member is doomed. For example, many dentists
have a policy that incoming checks are stamped “for
deposit only” in the hope of stopping an embezzler from
cashing them.
The flaw in this logic is that we shouldn’t expect an
embezzler to stamp the back of any checks that he or she
plans to steal. So unless the dentist stamps the checks personally, this control is useless against embezzlement.
And as we have pointed out on occasion, stamping the
checks personally won’t accomplish anything unless you
also personally receive, open and keep complete custody
of the mail until the checks are stamped. And even if you
do all those things yourself (which might make you wonder
why you even have a receptionist at all) we have seen
many creative thieves find a way to redirect a portion of
the incoming checks to a different address to escape the
dentist’s control.
We have also been told by dentists that
embezzlement isn’t possible in their office
because they diligently check their dayend
report against the bank deposit. We
disagree, as do many embezzlers. We do
believe that every dentist should review the
day-end report, because he or she will
sometimes catch honest errors and because
it is a good way to monitor practice performance.
However, any embezzler who
knows that the dentist compares the day
sheet against the deposit will not steal in a way that leaves
a visible discrepancy; they will instead construct a method
of embezzling that somehow hides the out-of-balance situation.
And while again we won’t discuss specifics, there
are a number of possibilities for creating a situation where
money was stolen but the daysheet and deposit agree.
While we certainly agree that a “deposit shortfall” is
indicative of a problem, the reverse isn’t true.
Many dentists tend to view their day-end report, especially
if they have checked it against their appointment
book, as gospel, and they don’t consider that thieves normally
control what information gets entered into the dentist’s
practice management software.
Regrettably, there are hundreds of ways to steal from a
dentist. For internal controls to be effective there would
have to be a control to stop each embezzlement methodology
an employee could use. This is impractical from both
an economic and procedural perspective. Additionally,
most implemented internal controls are already known to
the thief and can be discretely “tested” for effectiveness.
We must also consider that embezzlers are adaptive to
new controls that are implemented. We have had numerous
cases where a doctor, suspicious that an employee
might be stealing, implemented additional internal controls.
Typically, the suspect quickly adapted and began
using a different embezzlement modality. This points both
to the cleverness of the thieves involved and the strength
of their compulsion.
Why Ethics and Best Practices are Important
A common thread in many embezzlement lectures and
articles is that it is paramount for dentists to behave in an
ethical manner and institute best-practice procedures. We
concur. However, the prevailing thought is that engaging in
ethical behavior will instill ethical behavior in staff and
therefore discourage embezzlement. This is where we disagree.
As already discussed, whether embezzlers are “needy”
or “greedy,” they are under intense pressure to commit their
crimes. Once they decide to steal, that fact that you are
behaving ethically might make them feel guiltier about
their crime, but your behavior isn’t strong enough to compete
with their need to steal.
So, why do we stress that dentists should behave ethically?
Most importantly, it is simply the right thing to do.
Second, for your staff members who are not embezzling,
your ethical behavior will set an example to follow. For the
embezzler, however, we consider ethical behavior vital for a
simple reason: You don’t want to issue a “Get Out of Jail
Free Card.”
When embezzlers know their doctor has been engaging
in unethical behavior or hasn’t instituted best-practice procedures,
they have a powerful weapon at their disposal.
One of the most frustrating aspects of our work occurs
when we detect embezzlement, but the doctor is in no
position to file a criminal or civil complaint because the
embezzler has information that can literally make the doctor’s
life miserable.
Some examples could include skimming cash that isn’t
reported to the IRS, up-coding procedures, filing fraudulent
insurance claims, improperly delegating duties to clinical
staff, OSHA and HIPAA violations, or having an
inappropriate relationship with a staff member.
By avoiding ethical lapses, doctors are better positioned
to take action against an embezzler. Imagine the situation
of an embezzling staff member who walks freely out of
your office and then works for another doctor.
Regrettably, we encounter this more often than we like. It is paramount to act ethically and maintain best practices
not only because it is the right thing to do, but
because doctors need to have all options available if
embezzlement is detected in their practices.
The Honesty Test
Another recommendation we occasionally hear is
to go “undercover” and place some extra cash in the
cash drawer or other location where a suspect will discover
it. The presumption is that if the cash disappears,
the employee is dishonest. While we agree that
if the cash overage is not reported to you it means that
you have an issue, the reverse is probably not true.
We have observed that the typical embezzler steals
somewhere between 2-4 percent of collections. So for a
thief who is stealing thousands of dollars from you on
a monthly basis who finds an errant $50 in the cash
drawer, what is the best investment they can make with
the $50? It’s to hand it back to you, with the predictable
result that you believe that you have a very
honest employee. This gives the employee a “green
light” to continue to embezzle; often with greater magnitude
than before the honesty test was conducted.
Another tool we sometimes see advocated as a
means of preventing embezzlement is to install surveillance
cameras. There are two problems with this. First,
cameras are best suited for monitoring events where
the time of occurrence can be closely determined. For
example, if a computer monitor disappears when the
front desk is left unattended for a minute, cameras are
valuable, because the video from that time can be
examined. In contrast, embezzlement can happen at
any time, and the amount of camera footage required
to be monitored to spot it would be huge.
Second, since a thief would normally know that
cameras are in use, only the dumbest of thieves will
commit a visibly dishonest act on camera anyway.
While we have heard of the occasional dental embezzler
being caught on film, it hasn’t happened in any
of our investigations.
What Does Work?
So if thieves are smart, aware of the control systems
in place and motivated, how do you stop them?
The answer is far simpler than many dentists think.
Research by the Association of Certified Fraud
Examiners suggests that more than 80 percent of
embezzlers act in a manner consistent with stealing.1
This is affirmed by a 2007 study conducted by the
American Dental Association that showed more than
two-thirds of embezzlement was revealed by behavioral
(as opposed to financial) inconsistencies.2
Behavioral signs of embezzlement include things like
a reluctance to take vacation, territoriality about job
duties and work space, resisting the involvement of
consultants or other advisers, and evasiveness when
discussing practice finances.
And the good news? Behavioral monitoring is easier
and far less time consuming than overinvesting
time and money in cameras and financial monitoring.
One of our most potent monitoring tools is our
Embezzlement Risk Assessment Questionnaire,
which can be found at dentalembezzlement.com.
Published statistics suggest that 60 percent of
dentists will eventually be embezzlement victims.
We believe that underestimation of the determination
and capabilities of embezzlers is a major contributing
factor.
References
- “Report to the Nations on Occupational Fraud and Abuse: 2012 Global Fraud Study”, Association of Certified Fraud Examiners, Austin TX, http://www.acfe.com/rttn-highlights.aspx
- Author’s reanalysis of “2007 Survey of Current Issues in Dentistry: Employee Termination and Embezzlement”, American Dental Association, Chicago, IL
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