Ongoing compliance, performance and contract reviews
Customers, staff and third parties are subject to ongoing compliance, performance and contract reviews.
Some examples of this type of countermeasure include:
- The programme undertakes regular compliance checks with providers.
- System accesses are regularly reviewed to confirm users still require the access.
- Customers must meet monthly participation requirements to continue to receive payments.
- Staff performance is regularly reviewed and monitored.
- Contract performance is reviewed every 12 weeks to ensure requirements are being met.
Purpose of this countermeasure
Someone can act dishonestly providing false information or fail to disclose changes in circumstances in order to receive a benefit or avoid a loss. For example, they may providing false information about their work performance or the delivery of contract obligations.
Acting dishonestly to commit fraud is an offence under the Criminal Code Act 1995.
This type of control is supported by:
- Legislation or Policy
- Procedural instructions or guidance
- Staff are trained to apply correct processes and decisions
- A specific form, process or system must be used
- Identity is authenticated for each interaction
- Requests or claims must meet specific eligibility requirements
- Mandatory information is required to complete the request or claim
- Prompts and alerts
- Internal escalation procedures
- Information is verified
- Data matching
- Data protected from manipulation or misuse
- Data analytics
- Quality assurance checks
- Requests, claims or activities are approved by the appropriate decision-maker
- Internal or external audits or reviews
How do I know if my countermeasures are effective?
You can apply the following methods to measure the effectiveness of these types of countermeasures:
- Analyse completed reviews to confirm these are undertaken regularly/as required.
- Review a sample of completed requests/claims to confirm reviews are undertaken with appropriate rigour.
- Review procedures or guidance to confirm it clearly specifies how reviews are undertaken.
- Confirm reviews are consistently undertaken.
- Ask staff about the review processes or systems to ensure they have a consistent and correct understanding.
- Analyse Individual Performance Assessment data e.g. 'Back on Track' reviews.
- Identify how ongoing compliance, performance and contract requirements are communicated to staff, customers and third parties.
- Confirm that someone cannot bypass review requirements even when applying pressure or coercion.