Imposter Nurse Sentenced to Prison for Fraud and Tax Evasion

A woman formerly employed by an Ann Arbor, Michigan, health care consultancy was sentenced to 65 months in prison for defrauding employers of over $2.2 million and evading more than $697,000 in taxes, announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division and U.S. Attorney Matthew J. Schneider for the Eastern District of Michigan.

According to documents and information provided to the court, Sonja Emery, using several aliases including “Sonja Lee Robinson,” “Sonjalee Emery-Robinson,” and “Sonjalee Emery,” resided in Georgia, New Jersey, New York, and California. From 2011 through 2018, Emery falsely represented her professional status, educational background, and work experience to secure and maintain highly paid consulting positions in the health-care industry. She falsely claimed to be a Registered Nurse licensed in New York, Georgia, Connecticut, and California, and provided employers with licensure numbers that belonged to other people. In fact, she never was a Registered Nurse. Emery also falsely told employers she had a Bachelor of Science in Nursing, a Master’s degree in Health Administration, a Master’s degree in Business Administration, and a Doctor of Philosophy degree from Emory and New York Universities, but Emery never attended those schools or received such degrees.

Using these false representations, from 2011 through 2018, Emery secured high-level health-care positions. She worked as a senior vice president for an Ann Arbor, Michigan, healthcare consulting firm earning an annual salary of approximately $285,000; as a consultant for a community health system in Wisconsin earning approximately $267,000; and as a health care consultant for a Massachusetts company that paid her approximately $226,000. From 2015 until her arrest in May of 2018, Emery worked as a senior executive for a county government health services agency in California that paid her a total of approximately $960,000.

During these years, Emery either did not file or late-filed tax returns, despite owing more than $400,000 in taxes. She sought to avoid being detected by providing employers with different names and false social security numbers, by falsely instructing employers that she was “exempt” from taxes, and by supplying an employer with an identification number that did not belong to her.

On Feb. 18, 2020, Emery pleaded guilty to mail fraud and tax evasion.

In addition to the term of imprisonment, U.S. District Linda V. Parker ordered Emery to serve three years of supervised release and to pay approximately $2.2 million in restitution to the employer victims and $697,000 in restitution to the United States.

Principal Deputy Assistant Attorney General Zuckerman, U.S. Attorney Schneider, Treasury Inspector General for Tax Administration (TIGTA) Special Agent in Charge William A. Kalb, and Internal Revenue Service-Criminal Investigation (IRS-CI) Special Agent in Charge Sarah Kull thanked special agents of TIGTA and IRS-CI, who investigated the case, and Trial Attorneys Jack Morgan and Jeffrey McLellan of the Tax Division, who prosecuted the case.

Additional information about the Tax Division and its enforcement efforts may be found on the division’s website.

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    To combat money laundering, the Financial Crimes Enforcement Network (FinCEN) issued a geographic targeting order (GTO) in 2016 that required title insurers to report information on certain all-cash purchases of residential real estate by legal entities in specified areas. According to FinCEN analysis, the use of legal entities to purchase high-value real estate, particularly in certain U.S. cities, was prone to abuse. FinCEN determined that imposing the real estate GTO reporting requirements on title insurers would cover a large number of transactions without unnecessary complexity. FinCEN renewed the real estate GTO multiple times—finding it has yielded information useful to law enforcement investigations—and periodically expanded the types of monetary instruments and geographic areas included and decreased the price reporting threshold (see fig.). Issuance and Renewals of the Real Estate Geographic Targeting Order (GTO) Unlike prior GTOs, which FinCEN officials said they issued at the request of and with the involvement of law enforcement agencies, FinCEN issued the real estate GTO on its own initiative. Thus, FinCEN had to take the lead in implementing and evaluating the GTO but lacked detailed documented procedures to help direct the GTO's implementation and evaluation—contributing to oversight, outreach, and evaluation weaknesses. For example, FinCEN did not begin examining its first title insurer for compliance until more than 3 years after issuing the GTO and did not assess whether insurers were filing all required reports. Similarly, while FinCEN initially coordinated with some law enforcement agencies, it did not implement a systematic approach for outreach to all potentially relevant law enforcement agencies until more than 2 years after issuing the GTO. FinCEN also has not yet completed an evaluation of the GTO to determine whether it should address money laundering risks in residential real estate through a regulatory tool more permanent than the GTO, such as a rulemaking. Strengthening its procedures for self-initiated GTOs should help FinCEN more effectively and efficiently implement and manage them as an anti-money laundering tool. Bad actors seeking to launder money can use legal entities, such as shell companies, to buy real estate without a loan. Doing so potentially can conceal the identities of bad actors and avoid banks' anti-money laundering programs. To better understand this risk and help law enforcement investigate money laundering, FinCEN issued its real estate GTO. Although GTOs are limited to 180 days, they may be renewed if FinCEN finds reasonable grounds for doing so. Because of concerns about the potential for bad actors to exploit regulatory gaps to launder money through the U.S. real estate market, GAO was asked to review FinCEN's real estate GTO. This report examines, among other things, the GTO's issuance and renewal, oversight, outreach, and evaluation. GAO reviewed FinCEN's records, orders, and policies and procedures; laws and regulations; and studies and other related materials. GAO also interviewed FinCEN, federal law enforcement agencies, and other stakeholders. GAO recommends that FinCEN provide additional direction for self-initiated GTOs, including how to plan for oversight, outreach, and evaluation. FinCEN concurred with GAO's recommendation. For more information, contact Michael E. Clements, (202) 512-8678, ClementsM@gao.gov.
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    Today, the Department of Justice announced it has charged more than 500 domestic violence cases involving firearms during Fiscal Year (FY) 2020. A department priority since 2019 when Attorney General William P. Barr created the Department of Justice’s first ever-Domestic Violence Working Group, these charges are the result of the critical law enforcement partnership between United States Attorneys’ Offices and the Bureau of Alcohol, Tobacco, Firearms and Explosives, led by Acting Director Regina Lombardo, who has made domestic violence firearms-related investigations a priority.
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  • Medicaid: Data Completeness and Accuracy Have Improved, Though Not All Standards Have Been Met
    In U.S GAO News
    GAO found that the completeness and accuracy of Transformed Medicaid Statistical Information System (T-MSIS) data have improved. Over the past decade, the Centers for Medicare & Medicaid Services (CMS) has been implementing T-MSIS, which is the agency's initiative to improve state-reported data available for overseeing Medicaid. CMS's assessment of two key T-MSIS data sources reflect these improvements. I. Priority items. Priority items are areas of data CMS identified as critical for program oversight, such as beneficiary eligibility and managed care. CMS's assessment of states' data submissions for the first 12 priority items identified significant improvement in meeting CMS data standards over a 22-month period. CMS's assessments of additional priority items similarly indicate improved completeness and accuracy. Improvements in the Number of States Meeting CMS Standards for Transformed Medicaid Statistical Information System Priority Items One through 12 Number of priority items that met standards Number of states as of October 2018 Number of states as of August 2020 10 or more 6 41 7 to 9 26 10 6 or less 18 0 Source: GAO analysis of the Centers for Medicare & Medicaid Services (CMS) priority item data. │ GAO-21-196 Note: CMS assessed data from all 50 states and the District of Columbia. CMS excluded Wisconsin from its October 2018 assessment, because the state had not submitted sufficient data. II. Analytic files. Analytic files are publicly available, research-ready T-MSIS data. GAO's review of CMS's assessments found that all states submitted some data for 67 of the 69        topics relevant to their Medicaid programs. This is an improvement from what GAO found in 2017, when none of the six states reviewed submitted all T-MSIS data applicable to their programs. GAO also found that states' data for 52 of the 69 topics were acceptable—meaning that CMS determined most states' data did not have significant problems that would affect their usability. While CMS's assessments of priority item and analytic file data indicate improvement in the completeness and accuracy of T-MSIS data, GAO also found that these assessments highlight areas where data do not meet the agency's standards. For example, 30 states did not submit acceptable data for inpatient managed care encounters. Accurate encounter data are critical to ensuring that Medicaid managed care beneficiaries obtain covered services and that payments to managed care organizations are appropriate. GAO has made at least 13 recommendations related to improving T-MSIS data and expediting their use for program oversight. CMS has addressed five of these recommendations, and has not fully addressed eight—including recommendations to improve data for overseeing payments to providers and managed care organizations. Implementing these recommendations would help CMS strengthen program oversight through improved T-MSIS data. Since adding Medicaid to its High Risk List in 2003, GAO has identified multiple limitations in program data affecting CMS's ability to ensure beneficiaries' access to care and proper payments to health care providers. CMS intends T-MSIS be a national repository of data to manage and oversee Medicaid, which served approximately 77 million individuals at an estimated cost of $673 billion in fiscal year 2020. Prior GAO work found issues with the completeness and accuracy of T-MSIS data and recommended that CMS expedite efforts to improve T-MSIS data and to use them for program oversight. CMS has taken steps to improve T-MSIS data and has made some T-MSIS data publicly available. Yet, questions remain about the usability of T-MSIS data for program oversight. Under the Comptroller General's authority, GAO initiated this review to examine what is known about the completeness and accuracy of T-MSIS data. GAO reviewed CMS's assessments of two T-MSIS data sources: (1) states' submissions of T-MSIS priority items; and (2) the 2016 T-MSIS analytic files, which was the most recent analytic file data available when GAO began this work. GAO also reviewed CMS documents, prior GAO reports, and reports published by others examining T-MSIS data. GAO interviewed officials from CMS and seven states selected based on variation in their progress submitting complete and accurate priority item data, among other factors. The Department of Health and Human Services provided technical comments on a draft of this report, which GAO incorporated. For more information, contact Carolyn L. Yocom at (202) 512-7114 or yocomc@gao.gov.
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  • Sexual Harassment: NNSA Could Improve Prevention and Response Efforts in Its Nuclear Security Forces
    In U.S GAO News
    What GAO Found The National Nuclear Security Administration (NNSA)—within the Department of Energy (DOE)—and its contractors may have limited information on the prevalence of sexual harassment within the nuclear security forces. NNSA's nuclear security forces include federal agents in NNSA's Office of Secure Transportation (OST), which is responsible for transporting nuclear materials, and contracted guard forces at four of its sites. Federal officials at NNSA and contractor representatives at four NNSA sites that process weapons-usable nuclear material reported very few cases of sexual harassment from fiscal years 2015 through 2020. Research shows that the least common response to harassment is to report it or file a complaint. The U.S. Equal Employment Opportunity Commission (EEOC)—which enforces federal laws prohibiting harassment—suggests organizations survey employees to assess the extent to which harassment is a problem in their organization. NNSA does not survey employees on this topic, nor does NNSA call for such surveys in its contracts for security forces. Because NNSA relies solely on reported incidents, it may not have full knowledge into the nature or extent of sexual harassment in OST or by its contractors at its sites. Surveying employees would better position them to identify actions to effectively prevent and respond to harassment. To varying degrees, NNSA and its contractors follow EEOC's recommended practices to prevent and respond to sexual harassment in their nuclear security forces. For example, with respect to recommended training practices, NNSA and its contractors provide antiharassment training to all employees, but only one force offers workplace-specific training that addresses sexual harassment risk factors relevant to the security forces. Because NNSA has not formally reviewed EEOC's practices and considered which to adopt for its nuclear security forces, or made similar considerations for its security force contractors, the agency may be missing opportunities to prevent and respond to sexual harassment. Selected EEOC Practices for Effective Training to Prevent and Respond to Sexual Harassment and Number of NNSA's Nuclear Security Forces That Reflect Those Practices in Training EEOC Promising Practice Number of forces that reflect the practice Provided to employees at every level and location of the organization 5 of 5 Tailored to the specific workplace and workforce 1 of 5 Explains the complaint process, as well as any voluntary alternative dispute resolution processes 2 of 5 Explains the range of possible consequences for engaging in prohibited conduct 1 of 5 Source: GAO comparison of National Nuclear Security Administration (NNSA) and protective force contractor information with the U.S. Equal Employment Opportunity Commission's (EEOC) November 2017 Promising Practices for Preventing Harassment . | GAO-21-307 EEOC has found that NNSA and DOE do not meet all EEOC requirements relevant to preventing and responding to sexual harassment. For example, NNSA does not have an antiharassment program or a compliant antiharassment policy. According to EEOC officials, NNSA and DOE efforts to date have improved some aspects of their EEO programs, but because the agencies have not fully implemented their plans to address deficiencies identified by EEOC, DOE and NNSA may be missing opportunities to establish and maintain effective programs that include protection from and response to sexual harassment. Why GAO Did This Study Federal law prohibits sexual harassment in the workplace. Besides being harmful to those harassed, sexual harassment can decrease organizational performance and increase turnover. In January 2019, public allegations of sexual harassment in NNSA's nuclear security forces drew attention to this issue. House Report 116-120 provided that GAO review sexual harassment in NNSA's nuclear security force. This report examines (1) what NNSA and its contractors know about the prevalence of sexual harassment in their nuclear security forces, (2) the extent to which NNSA and its contractors implement EEOC recommendations to prevent and respond to sexual harassment, and (3) the extent to which EEOC found that NNSA and DOE meet its requirements relevant to sexual harassment. GAO reviewed information on sexual harassment and programs to address such harassment at DOE and NNSA from fiscal years 2015 through 2020. GAO analyzed documents and data, conducted a literature review, interviewed NNSA officials, and compared NNSA and contractor actions with EEOC-recommended practices for preventing harassment.
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