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What is government fraud, waste, and abuse?

05.31.23

Read this if you are looking to improve anti-fraud controls within your government agency. 

According to a 2022 report by the Association of Certified Fraud Examiners, occupational fraud is the most common form of financial crime in the world and costs government agencies a median loss of $138,000 per case. 

Black's Law Dictionary defines fraud as "all multifarious means which human ingenuity can devise, and which are resorted to by one individual to get an advantage over another by false suggestions or suppression of the truth. It includes all surprise, trick, cunning, or dissembling, and any unfair way by which another is cheated." 

Occupational fraud, a subset of fraud, is defined as the use of an employee’s occupation for personal gain by misusing or misapplying their employer’s resources or assets. 

What are the consequences of government fraud? 

Fraud significantly impacts organizations of any size. The greatest consequence of government fraud is the loss of public trust and taxpayer money. The misappropriation and misuse of government funds and property can: 

  • Delay the delivery of government services and programs 
  • Increase the cost of government services and programs 
  • Reduce organizational compliance and performance 

In order to address government occupational fraud, you first need to understand why it occurs.  

Why do people commit fraud?  

People may commit fraud for several reasons: 

  1. They rationalize the act or decision. They may think: “I deserve a raise” or “I’ll return the money” or “Someone else is getting away with it. 
  2. They feel significant financial or social pressure. They may be overwhelmed by personal debt or feel insecure about their future with the agency.  
  3. They have an opportunity for financial or personal gain. They recognize that the department or organization lacks internal controls or management oversight and seek to take advantage of this weakness. 

What are the most common government fraud schemes? 

One common example of government occupational fraud would be obtaining or disclosing personal or government data for personal gain. 

Other common types of government fraud schemes include, but are not limited to: 

  • Public corruption 
  • Procurement fraud 
  • Fraudulent claims and statements 
  • Healthcare fraud 
  • Grants fraud 

What are the signs to look for of fraud in local and state government? 

There are some commonalities among most types of government fraud. The following circumstances are often red flags for fraud: 

  • Large government budgets and expenditures 
  • Lax monitoring and oversight  
  • Poorly defined roles and responsibilities 
  • Poor inventory management and recordkeeping 
  • Poor vendor management 
  • Undisclosed conflicts of interest 
  • Lack of segregation of duties 

Identifying red flags and mitigating risk can renew public trust and confidence in government agencies and employees. We encourage management to conduct a risk assessment to determine if an environment is susceptible to fraud. 

To help you assess your current risks, the complimentary fraud vulnerability checklist is a quick self-assessment tool for any government agency or department to gauge if your organization would benefit from a comprehensive risk assessment.   

For more information on how to identify and mitigate fraud, waste, and abuse in your government agency, please contact our compliance and risk management consulting team. We’re here to help. 

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Read this if you are planning for, or are in the process of implementing a new software solution.

User Acceptance Testing (UAT) is more than just another step in the implementation of a software solution. It can verify system functionality, increase the opportunity for a successful project, and create additional training opportunities for your team to adapt to the new software quickly. Independent verification through a structured user acceptance plan is essential for a smooth transition from a development environment to a production environment. 

Verification of functionality

The primary purpose of UAT is to verify that a system is ready to go live. Much of UAT is like performing a pre-flight checklist on an aircraft. Wings... check, engines... check, tires... check. A structured approach to UAT can verify that everything is working prior to rolling out a new software system for everyone to use. 

To hold vendors accountable for their contractual obligations, we recommend an agency test each functional and technical requirement identified in the statement of work portion of their contract. 

It is also recommended that the agency verify the functional and technical requirements that the vendor replied positivity to in the RFP for the system you are implementing. 

Easing the transition to a new software

Operational change management (OCM) is a term that describes a methodology for making the switch to a new software solution. Think of implementing a new software solution like learning a new language. For some employees, the legacy software solution is the only way they know how to do their job. Like learning a new language, changing the way business and learning a new software can be a challenging and scary task. The benefits outweigh the anxiety associated with learning a new language. You can communicate with a broader group of people, and maybe even travel the world! This is also true for learning a new software solution; there are new and exciting ways to perform your job.

Throughout all organizations there will be some employees resistant to change. Getting those employees involved in UAT can help. By involving them in testing the new system and providing feedback prior to implementation, they will feel ownership and be less likely to resist the change. In our experience, some of the most resistant employees, once involved in the process, become the biggest champions of the new system.  

Training and testing for better results

On top of the OCM and verification benefits a structured UAT can accomplish, UAT can be a great training opportunity. An agency needs to be able to perform actions of the tested functionality. For example, if an agency is testing a software’s ability to import a document, then a tester needs to be trained on how to do that task. By performing this task, the tester learns how to login to the software, navigate the software, and perform tasks that the end user will be accomplishing in their daily use of the new software. 

Effective UAT and change management

We have observed agencies that have installed software that was either not fully configured or the final product was not what was expected when the project started. The only way to know that software works how you want is to test it using business-driven scenarios. BerryDunn has developed a UAT process, customizable to each client, which includes a UAT tracking tool. This process and related tool helps to ensure that we inspect each item and develop steps to resolve issues when the software doesn’t function as expected. 

We also incorporate change management into all aspects of a project and find that the UAT process is the optimal time to do so. Following established and proven approaches for change management during UAT is another opportunity to optimize implementation of a new software solution. 

By building a structured approach to UAT, you can enjoy additional benefits, as additional training and OCM benefits can make the difference between forming a positive or a negative reaction to the new software. By conducting a structured and thorough UAT, you can help your users gain confidence in the process, and increase adoption of the new software. 

Please contact the team if you have specific questions relating to your specific needs, or to see how we can help your agency validate the new system’s functionality and reduce resistance to the software. We’re here to help.   
 

Article
User Acceptance Testing: A plan for successful software implementation

The BerryDunn Recovery Advisory Team has compiled this guide to COVID-19 consulting resources for state and local government agencies and higher education institutions.

We have provided a list of our consulting services related to data analysis, CARES Act funding and procurement, and legislation and policy implementation. Many of these services can be procured via the NASPO ValuePoint Procurement Acquisition Support Services contract.

READ THE GUIDE NOW

We're here to help.
If you have any questions, please contact us at info@berrydunn.com

Article
COVID-19 consulting resources

Read this if you are a CFO, CEO, COO, or CLO at a financial institution.

The preparation of financial statements by financial institutions involves a number of accounting estimates, some of which can be quite complex. As these estimates are often a significant focus of audits of those financial statements, financial institution personnel affected by the audit process might benefit from a discussion of the rules auditors need to follow when auditing estimates.

Accounting estimates

Across all industries, there are financial statement items that require a degree of estimation because they cannot be measured precisely. These amounts, called accounting estimates, are determined using a wide array of information available to management. In using such information to arrive at the estimates, a degree of estimation uncertainty exists, which has a direct effect on the risks of material misstatement of the resulting accounting estimates. For financial institutions, common examples of accounting estimates include the allowance for loan losses, valuation of investment securities, allocation of the purchase price in a bank or branch acquisition, and depreciation and amortization of premises and equipment, in addition to intangibles and goodwill. 

For entities other than public companies, the auditing rules are established by the American Institute of Certified Public Accountants’ Auditing Standards Board (ASB). Under these requirements a financial statement auditor has a responsibility to assess the risks of material misstatement for accounting estimates by obtaining an understanding of the following items: 

  • The requirements of generally accepted accounting principles (GAAP) relevant to accounting estimates, including related disclosures. 
  • How management identifies those transactions, events, and conditions that may give rise to the need for accounting estimates to be recognized or disclosed in the financial statements. In obtaining this understanding, the auditor should make inquiries of management about changes in circumstances that may give rise to new, or the need to revise existing, accounting estimates. 
  • How management makes the accounting estimates and the data on which they are based. 

This final item—determining how management has calculated the accounting estimate in question—includes the following specific aspects for the auditor to address:

  • the method(s), including, when applicable, the model, used in making the accounting estimate; 
  • relevant controls; 
  • whether management has used a specialist; 
  • the assumptions underlying the accounting estimates; 
  • whether there has been or ought to have been a change from the prior period in the method(s) or assumption(s) for making the accounting estimates, and if so, why; and 
  • if so, how management has assessed the effects of estimation uncertainty. 

Professional skepticism

When analyzing management’s assessment of the effects of estimation uncertainty, the auditor needs to apply professional skepticism to the accounting estimate by considering whether management considered alternative assumptions, and, if a range of assumptions was reasonable, how they determined the amount chosen was the most appropriate. If estimation uncertainty is determined to be high, this is one indicator to the auditor that estimation uncertainty may pose a significant risk of material misstatement. An identified significant risk requires the auditor to perform a test of controls and/or details during the audit; in other words, analytical procedures and testing performed in previous audits will not suffice. 

CECL considerations

For audits of financial institutions, including those that have implemented the FASB CECL standard as well as those still using the incurred loss method, the allowance for loan losses will likely be deemed a significant risk due to its materiality, estimation uncertainty, complexity, and sensitivity from a user’s perspective.   

Additional factors the auditor needs to consider include whether management performed a sensitivity analysis as part of its consideration of estimation uncertainty as described above, and whether management performed a lookback analysis to evaluate the previous process used. Auditors of accounting estimates are required to do at least a high-level lookback analysis to gain an understanding of any differences between previous estimates and actual results, and to assess the reliability of management’s process. 

Auditing estimate procedures

Procedures for auditing estimates include an evaluation of subsequent events, tests of management’s methodology, tests of controls, and, in some instances, preparation of an independent estimate by the auditor. Tests of management’s method and tests of controls, including auditing the design and implementation of controls, are the most practical and likely procedures to apply to audits of the allowance for loan losses at financial institutions, both under the current guidance and following adoption of the current expected credit loss (CECL) method under Financial Accounting Standards Board (FASB) Accounting Standards Update No. 2016-13, Financial Instruments – Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments. As FASB has not prescribed a specific model, auditors must be prepared to tailor their procedures to address the facts and circumstances in place at each respective financial institution. 

In addition to auditing management’s estimate, auditors have the responsibility to audit related disclosures, including information about management’s methods and the model used, assumptions used in developing the estimate, and any other disclosures required by GAAP or necessary for a fair presentation of the financial statements. Throughout the audit process, auditors need to continue to exercise professional skepticism to consider what could have gone wrong during management’s process and to assess indicators of management bias, if any. 

For public companies, the Public Company Accounting Oversight Board (PCAOB) specifies auditors must evaluate both evidence that corroborates and evidence that contradicts management’s financial statement assertions in order to avoid confirmation bias. When considering the assessment of risks, as risk increases, the level of evidence obtained by the auditor should increase. As with audits of private companies, the auditor needs to consider whether the data is accurate, complete, and sufficiently precise and detailed to be used as audit evidence.

An added consideration under PCAOB rules is that the auditor is typically opining on the institution’s internal controls as well as its financial statements. This may restrict the results of control testing performed by parties independent of the function being tested from being used as audit evidence from a financial statement audit perspective. For financial institutions, this is often the case with independent loan review, since the loan review is considered part of the institution’s internal control upon which the auditor is opining. 

Supporting evidence

As with the incurred loss method, PCAOB auditing standards will require the auditor consider how much evidence is necessary to support the allowance for loan losses under CECL. All significant components of management’s allowance for loan losses estimate, including qualitative factors, will need to be supported by institution-specific data. If such data is unavailable (for example, because the institution introduces a new type of loan offering), the FASB standard indicates appropriate peer data may be acceptable. In such cases, management and the auditor may need to understand the controls in place at the vendor providing the peer data to determine its reliability. You may provide this information in the form of System and Organization Controls (commonly know as SOC1) reports of the vendor’s system.  

Recently, the International Auditing and Assurance Standards Board revised its auditing rules for estimates, with a goal of enhancing guidance regarding application of the basic audit risk model in the context of auditing estimates. The revised rules require that auditors must separately assess inherent and control risk when obtaining an understanding of controls, identifying and assessing risks, and designing and performing further audit procedures. The ASB seeks convergence of rules both internationally and domestically, and has therefore proposed changes to its requirements for auditing estimates to align with the IAASB revised rules. The ASB’s proposal on these changes indicated they would be effective beginning with audits of fiscal year ending December 31, 2022; the final effective date will be determined in conjunction with its issuance of the final rules.

The best CECL approach 

The best approach to take? Management should discuss planned changes to estimate the process with your auditors to get their perspective on best practices under CECL. Key areas to review in the discussion include documenting the decision-making process, key players involved, and the resulting review and approval process (especially for changes to methods or assumptions). Always retain copies of your final documentation for auditor review. If you would like more information, or have a specific question about your situation, please contact the team. We’re here to help. 

Article
CECL: Understand the audit requirements and prepare for what's to come

Read this if your organization, business, or institution has leases and you’ve been eagerly awaiting and planning for the implementation of the new lease standards.

Ready? Set? Not yet. As we have prepared for and experienced delays related to Financial Accounting Standards Board (FASB) Accounting Standards Codification Topic 842, Leases, we thought the time had finally come for implementation. With the challenges that COVID-19 has brought to everyone, the FASB recognizes the significant impact COVID-19 has brought to commercial businesses and not-for-profits and is proposing a one-year delay in implementation, as described in this article posted to the Journal of Accountancy: FASB effective date delay proposals to include private company lease accounting.

But what about lease concessions? We all recognize many lessors are making concessions due to the pandemic. Under current guidance in Topics 840 and 842, changes to lease contracts that were not included in the original lease are generally accounted for as lease modifications and, therefore, a separate contract. This would require remeasurement of the new lease contract and related right-of-use asset. FASB recognized this issue and has published a FASB Staff Questions and Answers (Q&A) Document,  Topic 842 and Topic 840: Accounting for Lease Concessions Related to the Effects of the COVID-19 Pandemic. Under this new guidance, if lease concessions are made relating to COVID-19, entities do not need to analyze each contract to determine if a new contract has been entered into, and will have the option to apply, or not to apply, the lease modification provisions of Topics 840 and 842.

Implementation of the lease accounting standard will most likely be delayed for Governmental Accounting Standards Board (GASB) entities as well. On April 15, 2020, the GASB issued an exposure draft that would delay most GASB statements and implementation guides due to be implemented for fiscal years 2019 and later. Most notably, this includes Statement 84, Fiduciary Activities, and Statement 87, Leases. Comments on the proposal will be accepted through April 30, and the board plans to consider a final statement for issuance on May 8. More information may be found in this article from the Journal of Accountancy: GASB proposes postponing effective dates due to pandemic.

More information

Whether you are a FASB or GASB entity, you can expect a delay in the implementation of the lease standard. If you have questions, please contact a member of our financial statement audit team. For other COVID-19 related resources, please refer to BerryDunn’s COVID-19 Resources Page.

Article
FASB and GASB news: Postponement of the lease accounting standards

Read this if you would like a refresher of common-sense approaches to protect against fraud while working remotely.

Coronavirus (COVID-19) has imposed many challenges upon us physically, mentally, and financially. Directly or indirectly, we all are affected by the outbreak of this life-threatening disease. Anxious times like this provide perfect opportunities for fraudsters. The fraud triangle is a model commonly used to explain the three components that may cause someone to commit fraud when they occur together:

  1. Financial pressure/motivation 
    In March 2020, the unemployment rate increased by 0.9 percent to 4.4 percent, and the number of unemployed persons rose by 1.4 million to 7.1 million.
  2. Perceived opportunity to commit fraud 
    Many people are online all day, providing more opportunities for internet crime. People are also desperate for something, from masks and hand sanitizers to coronavirus immunization and cures, which do not yet exist. 
  3. Rationalization 
    People use their physical, mental, or financial hardship to justify their unethical behaviors.

To combat the increasing coronavirus-related fraud and crime, the Department of Justice (DOJ) launched a national coronavirus fraud task force on March 23, 2020. It focuses on the detection, investigation, and prosecution of fraudulent activity, hoarding, and price gouging related to medical resources needed to respond to the coronavirus. US attorney’s offices are also forming local task forces where federal, state, and local law enforcement work together to combat the coronavirus related crimes. Things are changing fast, and the DOJ has daily updates on the task force activities. 

Increased awareness for increased threats

Given the increase in fraudulent activity during the COVID-19 outbreak, it’s important for employees now working from home to be aware of ways to protect themselves and their companies and prevent the spread of fraud. Here are some of the top COVID-19-related fraud schemes to be aware of. 

  • Phishing emails regarding virus information, general financial relief, stimulus payments, and airline carrier refunds
  • Fake charities requesting donations for illegitimate or non-existent organizations 
  • Supply scams including fake shops, websites, social media accounts, and email addresses claiming to sell supplies in high demand but then never providing the supplies and keeping the money 
  • Website and app scams that share COVID-19 related information and then insert malware that could compromise the device and your personal information
  • Price gouging and hoarding of scarce products
  • Robocalls or scammers asking for personal information or selling of testing, cures, and essential equipment
  • Zoom bombing and teleconference hacking

If you have encountered suspicious activity listed above, please report it to the FBI’s Internet Crime Complaint Center.

Staying vigilant

To protect yourself from these threats, remember to use proper security measures and follow these tips provided by the Federal Bureau of Investigation (FBI) and DOJ:

  • Verify the identity of the company, charity, or individual that attempts to contact you in regards to COVID-19.
  • Do not send money to any business, charity, or individual requesting payments or donations in cash, by wire transfer, gift card, or through the mail. 
  • Understand the features of your teleconference platform and utilize private meetings with a unique code or password that is not shared publicly.
  • Do not open attachments or click links within emails from senders you do not recognize.
  • Do not provide your username, password, date of birth, social security number, insurance information, financial data, or other personal information in response to an email or robocall.
  • Always verify the web address of legitimate websites and manually type them into your browser.
  • Check for misspellings or wrong domains within a link (for example, an address that should end in a ".gov" ends in .com" instead).

Stay aware, and stay informed. If you have specific concerns or questions, or would like more information, please contact our team. We’re here to help.
 

Article
COVID-19 and fraud―a security measures refresher

Read this if you are a business owner, in management, or in HR at a company with less than 500 employees.

We have received many questions regarding the FFCRA and its provisions and how it affects different employers and their employees. Here are some of the questions our clients have asked the most. Please contact us if you have questions regarding your specific situation. We’re here to help.  

Besides compensation, what other costs paid by an employer are eligible for the credit (i.e., employer paid health insurance, employer payroll taxes)?
Employers can deduct the cost of providing continuing health care coverage, and the employer’s share of Medicare taxes related to the leave wages. Any compensation paid under the FFCRA is not subject to the employer’s portion of the Social Security tax.

How do you determine the total number of employees? 
In calculating the total number of employees, all full-time or part-time employees working within the US, including all US territories or possessions, are counted, including all employees on leave and temp employees who are jointly employed with another company as determined under the Fair Labor Standards Act (FLSA). 

How does a business know if it employs less than 500 employees and is subject to the FFCRA?
Generally, a private sector employer is subject to the Family and Medical Leave Act of 1993 (FMLA) if it employs 50 or more employees for each working day during each of 20 or more calendar workweeks in the current or preceding calendar year. The FAQs issued by the Department of Labor (DOL) indicate an employer has fewer than 500 employees if, at the time an employee’s leave is to be taken, there are fewer than 500 full-time and part-time employees within the United States, which includes any state of the United States, the District of Columbia, or any territory or possession of the United States. 

In making this determination, an employer should include employees on leave; temporary employees who are jointly employed by you and another employer (regardless of whether the jointly-employed employees are maintained on only your or another employer’s payroll); and day laborers supplied by a temporary agency (regardless of whether you are the temporary agency or the client firm if there is a continuing employment relationship). Workers who are independent contractors under the FLSA, rather than employees, are not considered employees for purposes of the 500-employee threshold.

Where a corporation has an ownership interest in another corporation, the two corporations are separate employers unless they are joint employers under the FLSA with respect to certain employees. In general, two or more entities are separate employers unless they meet the integrated employer test under the FMLA.

Please check with your advisors if you believe the integrated employer test may apply to your businesses.

Which employees are entitled to the $511 payment under sick leave?
For an employee who is unable to work because of the coronavirus quarantine or self-quarantine or has COVID-19 symptoms and is seeking a medical diagnosis, the employee may receive sick leave wages equal to the employee’s regular rate of pay, up to $511 per day and $5,111 in the aggregate, for a total of 10 days. Note that only employers who employ less than 500 employer are required to provide sick leave payments. Such employees may also receive a refundable tax credit for sick leave paid to employees.

Which employees are entitled to the $200 payment under sick leave?
For an employee who is caring for someone with COVID-19, or is caring for a child because the child’s school or child care facility is closed, or the child care provider is unavailable due to the coronavirus, the employee may receive sick leave wages equal to two-thirds of the employee’s regular rate of pay, up to $200 per day and $2,000 in the aggregate, for up to 10 days. Note that only employers who employ less than 500 employer are required to provide sick leave payments. Such employees may also receive a refundable tax credit for sick leave paid to employees.

Which employees are entitled to the $200 payment under the family leave portion of FFCRA?
For an employee who is unable to work because of a need to care for a child whose school or child care facility is closed or whose child care provider is unavailable due to the coronavirus, the employee may receive family leave wages equal to two-thirds of the employee’s regular rate of pay, capped at $200 per day or $10,000 in the aggregate. Up to 10 weeks of qualifying leave can be counted towards the child care leave credit. Note that only employers who employ less than 500 employer are required to provide sick leave payments. Such employees may also receive a refundable tax credit for sick leave paid to employees.

What is “regular rate of pay” for purposes of the FFCRA?
For purposes of the FFCRA, the regular rate of pay used to calculate paid leave is the average of the employee’s regular rate over a period of up to six months prior to the date on which leave is taken. If an employee has not worked for the current employer for six months, the regular rate used to calculate paid leave is the average regular rate of pay for each week the employee has worked for the current employer.

If an employee is paid with commissions, tips, or piece rates, these amounts will be incorporated into the above calculation to the same extent they are included in the calculation of the regular rate under the FLSA.

You can also compute this amount for each employee by adding all compensation that is part of the regular rate over the above period and divide that sum by all hours actually worked in the same period.

What is the effective date of the sick leave/family leave provisions?
Employers must comply with the FFCRA from April 1, 2020, until it expires on December 31, 2020. Paid leave prior to April1, 2020 will not count. The IRS recently issued guidance indicating the tax credits for qualified sick leave wages and qualified family leave wages required to be paid by the FFRCA will apply to wages paid for the period beginning on April 1, 2020, and ending on December 31, 2020.

Who is considered a “health care provider”?
For the purposes of employees who may be exempted from paid sick leave or expanded family and medical leave by their employer under the FFCRA, a health care provider is anyone employed at any doctor’s office, hospital, health care center, clinic, post-secondary educational institution offering health care instruction, medical school, local health department or agency, nursing facility, retirement facility, nursing home, home health care provider, any facility that performs laboratory or medical testing, pharmacy, or any similar institution, employer, or entity. This includes any permanent or temporary institution, facility, location, or site where medical services are provided that are similar to such institutions. 

This definition includes any individual employed by an entity that contracts with any of the above institutions, employers, or entities institutions to provide services or to maintain the operation of the facility. This also includes anyone employed by any entity that provides medical services, produces medical products, or is otherwise involved in the making of COVID-19 related medical equipment, tests, drugs, vaccines, diagnostic vehicles, or treatments. This also includes any individual that the highest official of a state or territory, including the District of Columbia, determines is a health care provider necessary for that state’s or territory’s or the District of Columbia’s response to COVID-19.

To minimize the spread of the virus associated with COVID-19, the DOL encourages employers to be judicious when using this definition to exempt health care providers from the provisions of the FFCRA.

For more information
If you have more questions, or have a specific question about your particular situation, please call us. We’re here to help. 

Article
Families First Coronavirus Response Act (FFCRA): FAQs for businesses

Editor's note: read this blog if you are a state liquor administrator or at the C-level in state government. 

Surprisingly, the keynote address to this year’s annual meeting of the National Alcohol Beverage Control Association (NABCA) featured few comments on, well, alcohol. 

Why? Because cannabis is now the hot topic in state government, as consumers await its legalization. While the thought of selling cannabis may seem foreign to some state administrators, many liquor agencies are―and should be―watching. The fact is, state liquor agencies are already equipped with expertise and the technology infrastructure needed to lawfully sell a controlled substance. This puts them in a unique position to benefit from the industry’s continued growth. Common technology includes enterprise resource planning (ERP) and point-of-sale (POS) systems.

ERP

State liquor agencies typically use an ERP system to integrate core business functions, including finance, human resources, and supply chain management. Whether the system is handling bottles of wine, cases of spirits, or bags of cannabis, it is capable of achieving the same business goals. 

The existing checks and balances on controlled substances like alcohol in their current ERP system translate well to cannabis products. This leads to an important point: state governments do not need to procure a new IT system solely for regulating cannabis.

By leveraging existing ERP systems, state liquor agencies can sidestep much of the time, effort, and expense of selecting, procuring, and implementing a new system solely for cannabis sales and management. In control states, where the state has exclusively control of alcohol sales, liquor agencies are often involved in every stage of product lifecycle, from procurement to distribution to retailing.

With a few modifications, the spectrum of business functions that control states require for liquor—procuring new product, communicating with vendors and brokers, tracking inventory, and analyzing sales—can work just as well for cannabis.

POS

POS systems are necessary for most retail stores. If a state liquor agency decides to sell cannabis products in stores, they can use a POS system to integrate with the agency’s ERP system, though store personnel may require training to help ensure compliance with related regulations.

Cannabis is cash only (for now)

There is one major difference in conducting liquor versus cannabis sales at any level: currently states conduct all cannabis sales in cash. With cannabis illegal on the federal level, major banks have opted to decline any deposit of funds earned from cannabis-related sales. While some community banks are conducting cannabis-related banking, many retailers selling recreational cannabis in places like Colorado and California still deal in cash. While risky and not without challenges, these transactions are possible and less onerous to federal regulators. 

Taxes 

As markets develop, monthly tax revenue collections from cannabis continue to grow. Colorado and California have found cannabis-related tax revenue a powerful tool in hedging against uncertainty in year-over-year cash flows. Similar to beer sold wholesale, which liquor agencies tax even in control states, cannabis can be taxed at multiple levels depending on the state’s business model.

E-commerce

Even with liquor, few state agencies have adopted direct-to-consumer online sales. However, as other industries continue shifting toward e-commerce and away from brick and mortar retailing, private sector competition will likely feed increased consumer demand for online sales. Similar to ERP and POS systems, states can increase revenue by selling cannabis through e-commerce sales channels. In today’s online retail world, many prefer to buy products from their computer or smart phone instead of shopping in stores. State agencies should consider selling cannabis via the web to maximize this revenue opportunity. 

Applying expertise in the systems and processes of alcoholic beverage control can translate into the sale and regulation of cannabis, easing the transition states face to this burgeoning industry. If your agency is considering bringing in cannabis under management, you should consider strategic planning sessions and even begin a change management approach to ensure your agency adapts successfully. 

Article
Considering cannabis: How state liquor agencies can manage the growing industry

Editor’s note: If you are a state government CFO, CIO, project or program manager, this blog is for you. 

This is the second blog post in the blog series: “Procuring Agile vs. Non-Agile Service”. Read the first blog. This blog post demonstrates the differences in Stage 1: Plan Project in the five stages of procuring agile vs. non-agile services.

Overview of Procurement Process for Agile vs. Non-Agile IT Services

What is important to consider in agile procurement?

Here are some questions that can help focus the planning for procurement of IT services for agile vs. non-agile projects.

Plan Project Considerations for Agile vs. Non-Agile IT Services

Why are these considerations important?

When you procure agile IT services, you can define the scope of your procurement around a vision of what your organization intends to become, as opposed to being restricted to an end-date for a final delivery.

In an agile project, you get results iteratively; this allows you to constantly reassess requirements throughout the project, including the project plan, the guiding principles, and the project schedule. Your planning is not restricted to considering the effect of one big result at the end of the project schedule. Instead, your plan allows for sequencing of changes and improvements that best reflect the outcomes and priorities your organization needs

Since planning impacts the people-aspect of your strategy, it is important to consider how various teams and stakeholders will provide input, and how you will make ongoing communication updates throughout the project. With an agile procurement project, your culture will shift, and you will need a different approach to planning, scheduling, communicating, and risk management. You need to communicate daily, allowing for reviewing and adjusting priorities and plans to meet project needs. 

How do you act on these considerations?

A successful procurement plan of agile IT services should include the following steps:

  1. Develop a project charter and guiding principles for the procurement that reflect a vision of how your organization’s teams will work together in the future
  2. Create a communication plan that includes the definition of project success and communicates project approach
  3. Be transparent about the development strategy, and outline how iterations are based on user needs, that features will be re-prioritized on an ongoing basis, and that users, customers, and stakeholders are needed to help define requirements and expected outcomes
  4. Provide agile training to your management, procurement, and program operation teams to help them accept and understand the project will present deliverables in iterations, to include needed features, functionality and working products
  5. Develop requirements for the scope of work that align with services and outcomes you want, rather than documented statements that merely map to your current processes 

What’s next? 

Now that you have gained insight into the approach to planning an agile project, consider how you may put this first stage into practice in your organization. Stay tuned for guidance on how to execute the second stage of the procurement process—how to draft the RFP. Our intention is that, following this series, your organization will better understand how to successfully procure and implement agile services. If you have questions or comments, please contact our team.
 

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Plan agile projects: Stage 1