Dental Practice Embezzlement: How to Prevent Employee Theft
- Aho & Associates
- 2 days ago
- 6 min read
Introduction: A rising threat to dental office profitability
Embezzlement and employee theft in dental practices are more common—and more costly—than you might realize. According to the Association of Certified Fraud Examiners (ACFE), organizations in general typically lose about 5% of their revenue to occupational fraud each year. These cases often run for around 12 months before being detected, and more than half stem from either a lack of internal controls or the override of existing ones.
Your risk as a dental practitioner is especially high. A California Dental Association (CDA) risk-management brief, summarizing ADA survey findings, reported that 48% of responding dentists had experienced embezzlement. Long-tenured, financially entrusted employees were disproportionately involved. When you operate with a small team, high patient trust, and complex receivables workflows, you create fertile ground for fraud—unless you implement targeted controls.
Why Your Dental Practice is Vulnerable
You handle cash, cards, and insurance reimbursements daily, but you may rely on a lean administrative staff where one person manages multiple functions—patient intake, posting, deposits, and reconciliations. When you don’t segregate duties effectively, you expand the “opportunity” leg of the fraud triangle. ACFE’s global data consistently shows that weak controls and overrides are the most frequent enablers of occupational fraud.
The ADA also warns that inconsistent discounting and write-off policies can be exploited. A dishonest staff member might overstate a “courtesy discount” and pocket the difference. To protect your practice, you should standardize financial policies, lock up check stock and prescription pads, and perform random monitoring—baseline measures recommended for practices of any size.
Understanding the Fraud Triangle in Your Practice
The fraud triangle explains why people commit fraud, based on three key components: opportunity, incentive, and rationalization. Fraud is more likely when someone has the means to commit it, a reason to do so, and a way to justify their actions.
Pressure: Personal financial stress, debts, or lifestyle demands.
Opportunity: Excessive system access, poor segregation of duties, minimal oversight.
Rationalization: “I’m underpaid,” “I’ll pay it back,” or “everyone does it.”
You can’t reliably eliminate someone’s personal pressure or rationalization—but you can reduce opportunity through better processes and visibility. The AICPA reinforces this approach: strong preventive and detective controls, paired with periodic corrective actions, form the backbone of fraud risk reduction.
Common Embezzlement Schemes You Should Watch For
Fraud in dental practices typically falls under asset misappropriation, the largest category in the ACFE’s fraud tree. Here are some schemes you should be aware of:
Skimming patient payments: Cash co-pays or discounted cash payments may be taken off the top before being posted to the ledger. The ledger is then “balanced” with bogus write-offs or discounts. If your discount policies and cash handling practices are inconsistent, it becomes easier for someone to conceal this behavior.
Diverting insurance checks: Staff may intercept insurer payments and deposit them into personal or shell accounts, sometimes forging your signature or using a signature stamp. In one case, a dental office manager (who was also the dentist’s spouse) called the insurance company and had ACH reimbursement payments redirected to her personally. The CDA has documented other cases where this type of interception was paired with duplicate payroll or personal credit card charges, making detection even harder.
Shell vendors and false invoices: A staff member might create a fake supplier and issue checks for non-existent goods or services. ACFE case data shows that billing schemes are among the most common in small entities like yours.
Card misuse and refunds: Someone could use your corporate card for personal expenses or issue fraudulent refunds to their own card, then tamper with practice management records to hide the transactions. Both the ADA and AICPA emphasize the importance of locking down check stock, card access, and user permissions to prevent this.
Real-World Case Snapshots
Government prosecutions show how quickly losses can mount when opportunity goes unchecked:
Southern District of Texas (2025): A financial coordinator created a shell company, diverted insurance checks, and manipulated records. A private audit identified $243,597 in losses; the court imposed a 41-month sentence.
District of Massachusetts (2020): An office manager forged the owner’s signature and deposited at least 276 insurance checks into her own account, embezzling $348,000. She was sentenced to 41 months in prison for bank and tax fraud.
District of Arizona (2024): After a practice sale, the prior owner and the office manager (his spouse) allegedly kept an old business account open and diverted at least $73,000 while manipulating records—an example of collusion and post-transaction control gaps.
These fact patterns mirror ACFE findings: schemes often exploit control voids around incoming receipts and system access, persist for months, and are frequently revealed by a tip or third-party review.
Prevention: Internal Controls That Work for Dental Offices
Here are pragmatic, proportionate controls you can implement without turning your practice into a fortress:
Segregate cash, posting, and reconciliation duties: No single person should collect payments, post them, close the day, prepare deposits, and reconcile the bank. Route bank and merchant statements directly to yourself or an external bookkeeper; reconcile monthly and spot-check weekly. This is foundational AICPA guidance and the most effective way to shrink the “opportunity” leg of the fraud triangle.
Standardize discounts, refunds, and write-offs: Adopt written financial policies and require documentation (EOBs, receipts) for any non-standard transaction. Review end-of-day, adjustment, and deletion reports yourself. The ADA emphasizes that inconsistent discounting elevates theft risk and that daily owner visibility deters manipulation.
Lock down physical and digital assets: Secure blank checks, deposit slips, prescription pads, and high-value supplies. Limit user permissions in your practice and accounting software, enforce unique logins, and retain audit logs. These steps reflect ADA practice guidance and AICPA control principles.
Control mail and EOBs: Route insurer remittances and explanations of benefits to a locked inbox or directly to yourself. Endorse checks on receipt and reconcile remittances to postings and deposits. DOJ cases show that intercepting insurance checks is a common scheme; owner-level visibility helps break it.
Establish speak-up channels and monitor tips: Approximately 43% of frauds are detected by tips, making this the leading detection method. Create reporting channels that enable confidential reporting (email alias, hotline), train your staff, and enforce non-retaliation. Even micro practices benefit from clear reporting paths.
Implement a right-sized compliance program: The HHS Office of Inspector General (OIG) provides Compliance Program Guidance for Individual and Small Group Physician Practices that scales to dental offices: written standards, designated oversight, training, auditing/monitoring, and timely response to concerns. Building these elements into your operations reduces fraud risk and strengthens payer compliance.
Strengthen cybersecurity to prevent payment rerouting: Business Email Compromise (BEC) schemes can trick staff into changing remittance instructions or issuing fraudulent refunds. The FBI recommends out-of-band verification—a type of two-factor authentication—for any change in payment details and vigilance with email hygiene. The AMA frames cybersecurity as a patient safety issue and offers practical checklists for small practices.
Protect ePHI and financial data with HIPAA Security Rule basics: Follow the HIPAA Security Rule’s administrative, physical, and technical safeguards (risk analysis, access controls, device security, and audit logs). Although designed for privacy and security, these controls also prevent unauthorized record edits that could mask theft.
Rotate duties, require vacations, and cross-train: Rotation and mandatory time away can expose hidden schemes and reduce the risk of a single “indispensable” employee monopolizing sensitive processes—an ACFE-consistent approach to constraining opportunity.
Schedule periodic forensic accounting reviews: Beyond routine bookkeeping, a periodic independent forensic spot check can compare bank/merchant activity to posted production, scan for outlier adjustments and refunds, and review audit trails before irregular patterns become six-figure losses. This also reinforces a culture of accountability.
Build a Culture That Deters Rationalization
Controls close doors, but culture shapes behavior. Provide annual training on fraud awareness and office financial policies. Document acceptance of policies and demonstrate—by example—that exceptions will be questioned and verified. The HHS OIG emphasizes training and consistent enforcement in small practice compliance programs, while ACFE data confirms that engaged management and training correlate with faster detection and lower losses.
What to Do If You Suspect Embezzlement
Secure the perimeter: Immediately restrict access to banking, merchant, and practice systems. Preserve audit logs and backups, and suspend user accounts as needed. The AMA notes that HIPAA-aligned access controls and quick response are vital when systems or data may be compromised.
Do not tip off suspects: Avoid confrontations until you speak with counsel and your insurer. Quiet preservation of evidence is critical. Premature confrontation can jeopardize recovery and prosecution.
Engage qualified help: Consult legal counsel and your insurer. Depending on the nature of the problem, you may need to bring in a forensic accountant to preserve evidence, reconstruct tampered or destroyed records, quantify losses, and prepare civil and criminal referrals.
Report when appropriate: If federal health care programs might be involved, the HHS OIG Hotline accepts tips about potential fraud affecting Medicare/Medicaid. Law enforcement referrals can lead to restitution orders, as recent cases show.
Harden controls: Whether or not theft is proven, implement the control set above. Most victims enhance controls after an incident, but proactive action is far less costly.
Prevention Beats Recovery
The most effective dental practices attack the fraud triangle where they can: you shrink opportunity with segregation of duties, locked-down assets, direct owner oversight of bank and payer data, standardized financial policies, and basic cyber hygiene. You increase detection with tip channels, random checks, and audit trail reviews. You temper rationalization by setting expectations through training and visible enforcement of policy. These measures reflect ACFE’s data on what works, align with AICPA fundamentals of internal control, and dovetail with ADA/CDA and HHS OIG guidance tailored to small health care offices.
Ultimately, your goal isn’t to run your practice with suspicion—it’s to design it so that good people can do good work and opportunities for misconduct are scarce. In a profession built on trust, thoughtful controls protect that trust—for your patients and your team.
