Using Evidence in the Fight Against Fraud

With contributions by Sarah Cunningham and Hayley Carter

Protecting government programs from fraud is a continually evolving challenge, and one that’s getting harder as fraudsters get more sophisticated. Fraudsters are weaponizing technology like AI and taking advantage of federal recovery and resilience programs responding to disasters like pandemics, hurricanes, wildfires, and more. In this environment, federal agencies like the U.S. Small Business Administration (SBA) are using evidence in new ways to modernize fraud risk mitigation processes and build a fraud-fighting culture to stay ahead of the game.

The SBA’s ongoing efforts to build a culture of fraud risk awareness and prevention reflect how responsibility for fraud risk mitigation is collaborative and agencywide. In 2022, the SBA established the Fraud Risk Management Board (FRMB) as its designated anti-fraud entity. Among its many responsibilities, the FRMB facilitates Fraud Risk Assessments (FRAs), through which program offices conduct standardized, evidence-based reviews of program risks and controls. Another important responsibility of the FRMB is developing trainings on fraud risk awareness, from agencywide trainings for all SBA staff to more targeted trainings for program offices conducting FRAs or staff in specific roles.

In support of these ongoing efforts, Summit recently completed a formative evaluation of fraud risk mitigation oversight at the SBA. Our evaluation identified opportunities for improvement and assessed readiness for an outcome evaluation of the FRMB. As part of this work, Summit developed key metrics to track annually, which will build an evidence base to measure and evaluate FRMB success in fraud mitigation. Summit also developed recommendations to help the SBA increase agencywide knowledge and awareness of fraud risk mitigation processes and the FRMB through ongoing training and communication.

At the end of the evaluation, Summit shared evaluation results with the SBA’s Evidence and Evaluation Community of Practice (COP). Summit was honored to facilitate a panel discussion titled “How SBA Is Fighting Fraud with Evidence.” Summit director Sarah Cunningham joined the SBA’s chief risk officer, Walter B. Hill, Jr., and fraud risk manager Penny Popps. Their conversation highlighted the opportunities and responsibilities of using evidence and evaluation to improve fraud-fighting capacity. This COP event had a large attendance by SBA staff, highlighting the agencywide interest in building a culture that fights fraud and protects program integrity.

Fraud risk mitigation is an essential part of maintaining the integrity and effectiveness of federal programs. The SBA’s proactive approach, supported by evidence-based practices, sets a commendable example for other agencies. Fighting fraud with evidence enables agencies like the SBA to build the evidence base through administrative data and fraud risk assessments to intentionally craft a high-performing culture and empower staff to fight fraud at all levels.

For more on this project, check out the case study on our website and the final evaluation report. Our evaluation is also highlighted in this Forbes article by Doug Criscitello on the SBA’s dedication to improving and enhancing its fraud-fighting capabilities.