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Internal escalation procedures


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Non-standard requests or claims are escalated, e.g. for review by a policy team or ICT helpdesk.


Some examples of this type of countermeasure include:

  • Claims that exceed a certain threshold are escalated for further scrutiny.
  • Non-standard or late claims must be reviewed and actioned by a separate policy team.

Purpose of this countermeasure

Someone can provide false or misleading information or evidence to support a request or claim, or fail to disclose information that would affect their entitlement.

Additionally, a staff member can abuse their position of trust to process fraudulent requests or claims for themselves or another person or entity.

Acting dishonestly or influencing a Commonwealth public official to commit fraud are offences under the Criminal Code Act 1995.

Not having processes in place to escalate non-standard requests or claims can lead to:

  • disorganised, inconsistent practices and decision-making, and
  • other control weaknesses.

Fraudsters can deliberately use confusion and deception to exploit these weaknesses to:

  • receive payments or services they are not entitled to, or
  • access information or systems without a business need.


This type of control is supported by:

How do I know if my countermeasures are effective?

You can apply the following methods to measure the effectiveness of these types of countermeasures:

  • Review the policies and procedures for escalating requests or claims.
  • Confirm non-standard requests and claims are escalated to someone with sufficient delegation, independence or expertise.
  • Confirm escalation processes are consistently applied.
  • Undertake quantitative analysis of non-standard requests or claims. What percentage of claims fall in this category? Does this align with the number of escalations?
  • Review a sample of non-standard requests or claims to confirm correct escalation processes were followed.
  • Ask staff about internal escalation processes to ensure they have a consistent and correct understanding.
  • Undertake testing or a process walk-through to confirm that escalation processes cannot be bypassed (even when pressure or coercion is applied).
  • Identify how escalation requirements are communicated to staff.
  • Confirm that someone cannot bypass escalation processes or systems, even when subject to pressure or coercion.
  • Review the training staff receive to ensure it includes information about escalation procedures.


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