theinnerauditor

Miranda had responsibility for preparing personnel files for new hires, approval of wages, verification of time cards, and distribution of payroll checks. She “hired” fictitious employees, faked their records, and ordered checks through the payroll system. She deposited some checks in several personal bank accounts and cashed others, endorsing all of them with the names of the fictitious employees and her own. Her company’s payroll function created a large paper trail of transactions among which were individual earnings records, W-2 tax forms, payroll deductions for taxes and insurance, and Form 941 payroll tax reports. She mailed all the W-2 forms to the same post office box.

Miranda stole $160,000 by creating some “ghosts,” usually 3 to 5 out of 112 people on the payroll and paying them an average of $650 per week for three years. Sometimes the ghosts quit and were later replaced by others. But she stole “only” about 2 percent of the payroll funds during the period.

A tip from a fellow employee received by the company hotline resulted in the engagement of Tom Hudson, CFE.  Tom’s objective was to obtain evidence of the existence and validity of payroll transactions on the control premise that different people should be responsible for hiring (preparing personnel files), approving wages, and distributing payroll checks. “Thinking like a crook” lead Tom to readily see that Miranda could put people on the payroll and obtain their checks just as the hotline caller alleged. In his test of controls Tom audited for transaction authorization and validity. In this case random sampling was less likely to work because of the small number of alleged ghosts. So, Tom looked for the obvious. He selected several weeks’ check blocks, accounted for numerical sequence (to see whether any checks had been removed), and examined canceled checks for two endorsements.

Tom reasoned that there may be no “balance” to audit for existence/occurrence, other than the accumulated total of payroll transactions, and that the total might not appear out of line with history because the tipster had indicated that the fraud was small in relation to total payroll and had been going on for years.  He decided to conduct a surprise payroll distribution, then followed up by examining prior canceled checks for the missing employees and then scan personnel files for common addresses.

Both the surprise distribution and the scan for common addresses quickly provided the names of 2 or 3 exceptions. Both led to prior canceled checks (which Miranda had not removed and the bank reconciler had not noticed), which carried Miranda’s own name as endorser. Confronted, she confessed.

The major risks in any payroll business cycle are:

•Paying fictitious “employees” (invalid transactions, employees do not exist);

• Overpaying for time or production (inaccurate transactions, improper valuation);

•Incorrect accounting for costs and expenses (incorrect classification, improper or inconsistent presentation and disclosure).

The assessment of payroll system control risk normally takes on added importance because most companies have fairly elaborate and well-controlled personnel and payroll functions. The transactions in this cycle are numerous during the year yet result in lesser amounts in balance sheet accounts at year-end. Therefore, in most routine outside auditor engagements, the review of controls, test of controls and audit of transaction details constitute the major portion of the evidence gathered for these accounts. On most annual audits, the substantive audit procedures devoted to auditing the payroll-related account balances are very limited which enhances fraud risk.

Control procedures for proper segregation of responsibilities should be in place and operating. Proper segregation involves authorization (personnel department hiring and firing, pay rate and deduction authorizations) by persons who do not have payroll preparation, paycheck distribution, or reconciliation duties. Payroll distribution (custody) is in the hands of persons who do not authorize employees’ pay rates or time, nor prepare the payroll checks. Recordkeeping is performed by payroll and cost accounting personnel who do not make authorizations or distribute pay. Combinations of two or more of the duties of authorization, payroll preparation and recordkeeping, and payroll distribution in one person, one office, or one computerized system may open the door for errors and frauds. In addition, the control system should provide for detail control checking activities.  For example: (1) periodic comparison of the payroll register to the personnel department files to check hiring authorizations and for terminated employees not deleted, (2) periodic rechecking of wage rate and deduction authorizations, (3) reconciliation of time and production paid to cost accounting calculations, (4) quarterly reconciliation of YTD earnings records with tax returns, and (5) payroll bank account reconciliation.

Payroll can amount to 40 percent or more of an organization’s total annual expenditures. Payroll taxes, Social Security, Medicare, pensions, and health insurance can add several percentage points in variable costs on top of wages. So, for every payroll dollar saved through forensic identification, bonus savings arise automatically from the on-top costs calculated on base wages. Different industries will exhibit different payroll risk profiles. For example, firms whose culture involves salaried employees who work longer hours may have a lower risk of payroll fraud and may not warrant a full forensic approach. Organizations may present greater opportunity for payroll fraud if their workforce patterns entail night shift work, variable shifts or hours, 24/7 on-call coverage, and employees who are mobile, unsupervised, or work across multiple locations. Payroll-related risks include over-claimed allowances, overused extra pay for weekend or public holiday work, fictitious overtime, vacation and sick leave taken but not deducted from leave balances, continued payment of employees who have left the organization, ghost employees arising from poor segregation of duties, and the vulnerability of data output to the bank for electronic payment, and roster dysfunction. Yet the personnel assigned to administer the complexities of payroll are often qualified by experience than by formal finance, legal, or systems training, thereby creating a competency bias over how payroll is managed. On top of that, payroll is normally shrouded in secrecy because of the inherently private nature of employee and executive pay. Underpayment errors are less probable than overpayment errors because they are more likely to be corrected when the affected employees complain; they are less likely to be discovered when employees are overpaid. These systemic biases further increase the risk of unnoticed payroll error and fraud.

Payroll data analysis can reveal individuals or entire teams who are unusually well-remunerated because team supervisors turn a blind eye to payroll malpractice, as well as low-remunerated personnel who represent excellent value to the organization. For example, it can identify the night shift worker who is paid extra for weekend or holiday work plus overtime while actually working only half the contracted hours, or workers who claim higher duty or tool allowances to which they are not entitled. In addition to providing management with new insights into payroll behaviors, which may in turn become part of ongoing management reporting, the total payroll cost distribution analysis can point forensic accountants toward urgent payroll control improvements.

The detail inside payroll and personnel databases can reveal hidden information to the forensic examiner. Who are the highest earners of overtime pay and why? Which employees gained the most from weekend and public holiday pay? Who consistently starts late? Finishes early? Who has the most sick leave? Although most employees may perform a fair day’s work, the forensic analysis may point to those who work less, sometimes considerably less, than the time for which they are paid. Joined-up query combinations to search payroll and human resources data can generate powerful insights into the organization’s worst and best outliers, which may be overlooked by the data custodians. An example of a query combination would be: employees with high sick leave + high overtime + low performance appraisal scores + negative disciplinary records. Or, reviewers could invert those factors to find the unrecognized exemplary performers.

Where predication suggests fraud concerns about identified employees, CFEs can add value by triangulating time sheet claims against external data sources such as site access biometric data, company cell phone logs, phone number caller identification, GPS data, company email, Internet usage, company motor fleet vehicle tolls, and vehicle refueling data, most of which contain useful date and time-of-day parameters.  The data buried within these databases can reveal employee behavior, including what they were doing, where they were, and who they were interacting with throughout the work day.

Common findings include:

–Employees who leave work wrongfully during their shift;
–Employees who work fewer hours and take sick time during the week to shift the workload to weekends and public holidays to maximize pay;
–Employees who use company property excessively for personal purposes during working hours;
–Employees who visit vacation destinations while on sick leave;
–Employees who take leave but whose managers do not log the paperwork, thereby not deducting leave taken and overstating leave balances;
–Employees who moonlight in businesses on the side during normal working hours, sometimes using the organization’s equipment to do so.

Well-researched and documented forensic accounting fieldwork can support management action against those who may have defrauded the organization or work teams that may be taking inappropriate advantage of the payroll system. Simultaneously, CFEs and forensic accountants, working proactively, can partner with management to recover historic costs, quantify future savings, reduce reputational and political risk, improve the organization’s anti-fraud policies, and boost the productivity and morale of employees who knew of wrongdoing but felt powerless to stop it.