Obsessed — Position Paper
Fraud, Waste, and Abuse — But Make It C-Suite
A note on scope: Fraud, Waste, and Abuse as a formal compliance category applies to organizations handling federal health programs and government funding. That is not what this paper is about. This paper is about the organizational pattern — where scrutiny lands and where it doesn't. Every organization has a version of this.
The compliance training taught you to spot it. It pointed the lens at the workers. The lens rarely points up. This paper does.
The Lens The Math The Cookbook Two Tracks The Bill
"There must be in-groups whom the law protects but does not bind, alongside out-groups whom the law binds but does not protect."
Frank Wilhoit / Scott Galloway
Obsessed · Position Paper
Fraud, Waste,
and Abuse —
But Make It C-Suite.
The compliance training taught you to spot it. It pointed the lens at the workers. The lens rarely points up. This paper does.
Non-compliance cost
$14.8M
Average annual cost to organizations experiencing non-compliance issues. The training that would have prevented it: scrutinized. The decisions that caused it: protected.
Average training spend 2025
$11.7M
Average training spend at large U.S. companies in 2025, per Training Magazine's 2025 Training Industry Report. Not the cost of training. The cost of training without measuring whether it works.
Who gets asked to prove ROI
L&D.
Always. While the digital transformation that produced a dashboard nobody uses files under "innovation."

A case study in the cost of getting training wrong — built from a real California regulatory requirement, verified wage data, and a one-slide meeting nobody followed up on.

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The lens only ever
points one direction.

For 15 years, the compliance training I built and delivered included a module on fraud, waste, and abuse. It taught people to recognize misuse of resources, document it, report it. It was thorough. It was evidence-based. And it pointed entirely at the workers.

A note on scope

Fraud, Waste, and Abuse as a formal compliance requirement applies to organizations handling federal health programs, Medicare, Medicaid, and government grant funding. That is not the argument here. This paper is about the organizational pattern that exists everywhere — where scrutiny consistently lands on the smallest expenditures at the bottom while the largest decisions at the top go unquestioned. Every organization has rules about not wasting company resources. Most apply them in one direction only.

"There must be in-groups whom the law protects but does not bind, alongside out-groups whom the law binds but does not protect."
Frank Wilhoit — Political Theorist
Plain language
"The wealthiest 1% are protected by the law but not bound by it. The bottom 99% are bound by the law but not protected by it." — Scott Galloway, Clinical Professor of Marketing, NYU Stern
The organizational translation
Some budget lines get protected without question. Others get scrutinized until they disappear.

Isn't it interesting that training is always in the second category.

The Sisyphus Contract — where recommendations stall when ownership, incentives, and knowledge transfer are weak — the unused software licenses, the digital transformation that produced a dashboard nobody uses — always in the first category.

That's not fiscal responsibility. That's a values statement dressed as a budget decision.
What gets interrogated
Training for the people doing the work — requires a business case, a measurement plan, stakeholder alignment, and someone willing to fight for it.
A $200 conference registration — three levels of approval required. The $20,000 team offsite went through on one signature.
Letting people go to class — managers block it. It shows on productivity metrics. The cost of keeping them at their desks: invisible.
The $50 professional development resource — denied. The catered lunch for the leadership meeting that could have been an email: approved.
What gets protected
The Sisyphus Contract — $50K–$1M+ for consulting recommendations that 30–50% of the time never get implemented. The boulder rolls back. The contract renews.
Software nobody uses — A Nexthink analysis of more than 6 million customer environments found that 49.96% of installed software was unused — with approximately $45M in estimated monthly waste across the analyzed environments. Auto-renewed. Nobody asks why adoption is low.
Coming to the office to Zoom — commute in, sit at your desk, attend the same virtual meeting you could have taken from home. Presence equals productivity. Didn't you know.
AI tools deployed with no training — organization-wide rollout. No governance. No training. No one responsible for outcomes. Filed under "digital transformation."
"The more visible the benefit to leadership, the less scrutiny the expense gets. The reverse is true for employee development: the benefit accrues broadly and later, so it is easier to cut — despite its potential to reduce costly turnover and mistakes." Synthesized from SHRM, High5Test, Perplexity Research 2025
The Onus is Always on the Top

The pattern has a
newest example.

The same scrutiny pattern that defunds training budgets and eliminates instructional designers also governs how organizations deploy AI. It is the most expensive version of this mistake yet — and the numbers make that impossible to argue with.

$2.59 trillion spent on AI in 2026.
6% of workers getting meaningful training on how to use it. 90% of firms reporting no measurable impact on productivity after three years. The scrutiny pattern did not change when AI arrived. The tool budgets got protected. The training budgets got cut. The result is exactly what you'd expect — and a fifth grader could have told you why.
💸
Approve the tool. Cut the training.
Nobody knows how to use it well.
🔄
Renew the license. Wonder why ROI isn't there.
🤷
Hire a consultant to find out why.
Global AI spend 2026
$2.59T
Gartner, May 2026. A 47% increase over 2025. The fastest technology spending growth in recorded history.
Workers getting meaningful AI training
6%
89% of workers need AI training. 6% are getting it meaningfully. The rest are figuring it out alone.
Firms reporting no productivity impact
90%
90%+ saw no employment effect. 89% saw no labor productivity impact. NBER working paper, ~6,000 senior executives, 2025–2026.

And the one that should be embarrassing to say out loud: half of all installed software goes unused. Not a little. Half. $45 million per month in waste. The licenses auto-renew. Nobody connects it to the training budget that was cut three years ago. Want to know why software goes unused? Because nobody trained anyone to use it. It eats itself.

"You can't govern what you don't talk about. Your choice was never train everyone or train strategically. Your choice was train everyone or let everyone keep using it in the dark while you congratulate yourself on your restraint."

The argument for universal AI training lives in a companion paper. Read Train Everyone. No Exceptions. This paper is not that argument. This paper is what the pattern cost you — in AI, in training, in every budget decision where the tool got protected and the people didn't.

Rope bridge

A note on where what follows comes from. The examples in the next section are drawn from over 15 years inside Learning and Development (L&D) and 25 years in corporate. That is the lens. These examples are specific not because the problem is specific to L&D — but because that is where I had a front-row seat to it for the better part of three decades.

L&D is my lens.
The pattern is everywhere.

Someone in supply chain sees it in procurement. Someone in IT sees it in software deployments. Someone in finance sees it in how headcount decisions get made. The tool budget gets protected. The expertise budget gets cut. The bill arrives somewhere else.

The cookbook
and the refrigerator.

What organizations are doing when they hand authoring tool licenses to subject matter experts and eliminate their training staff is putting a full refrigerator and a cookbook in front of someone who has never cooked — and walking away saying they've solved the dinner problem.

"Making a sandwich at home
is not the same as running a Subway."
Both involve sandwiches. Neither is interchangeable. The person who makes great sandwiches is not automatically the person who can build a system that makes 500 consistent sandwiches a day for 500 different people with 500 different needs. One is a meal. The other is an operation.

This is not an argument against subject matter experts. SMEs are essential. They know the content. The argument is against confusing them with the people who know how to build learning systems — because those are two different jobs. And while we're here: an instructional designer and a trainer are not the same job either. A trainer and a facilitator are not the same job. These distinctions exist for reasons. Here is what those reasons look like from the inside — as evidence of what gets lost when organizations collapse these roles to save money:

Subject Matter Expert
Knows the content. Does the job. Essential. Not a designer.
Knows what right looks like in practice
Identifies what must be learned
Validates content accuracy
Provides real examples from the work
Has a job doing the actual job
Instructional Designer
Architects the learning system. Works backward from behavior. Not a trainer.
Conducts needs analysis — determines if training is even the right solution
Writes measurable learning objectives tied to performance outcomes
Applies adult learning theory — how adults actually learn, not how we wish they did
Sequences content using ADDIE, SAM, or equivalent — structure is not accidental
Designs assessments before writing content — works backward from proof of learning
Maps content to Bloom's Taxonomy — knows the difference between recall and application
Collaborates with SMEs without being led by them
Designs for the target learner — not the expert who already knows it
Creates storyboards, scripts, and content architecture before building anything
Applies Kirkpatrick from the start — measurement is designed in, not retrofitted
Trainer / Facilitator
Delivers the experience. Reads the room. Not a designer.
Delivers live learning in real time
Answers questions on the spot
Adjusts pacing based on the room
Facilitator: creates conditions for the group to arrive at insights themselves — completely different from training
Surfaces what the design missed

And that is still just three of the roles. Before the cuts, a fully functioning L&D — or Organizational Effectiveness — operation was a system. Every role purpose-built to move an entire organization's behavior in the same direction. Here is what that system looked like:

12+
Distinct Roles

Every one purpose-built. None interchangeable. All working together to ensure the entire organization was moving in the same direction — which is what it actually takes to change behavior at scale.

Common objections. Answered. If you've read this far and a question is forming — good. Here are the ones that come up most often, with answers that don't require you to take anyone's word for it.

Organizations translating AI pilots into measurable impact
95%
MIT Project NANDA, 2025. Only about 5% of organizations translated AI pilots into measurable operational or financial impact. AI produces something that looks finished. That is not the same as something that works.
Enterprises reporting meaningful AI earnings impact
80%
McKinsey's 2025 global survey found only 39% of respondents reported any enterprise-level EBIT impact from AI — and most of those said AI accounted for less than 5% of EBIT. The investment without the capability is just a refrigerator.
AI tools that can watch a learner pause
0
No AI tool can sit behind a learner, watch where they stop before clicking, and ask: what just happened there? That is the job. That is what is not replaceable.

AI generates from pattern matching. The instructional designer generates from context. One of them cannot replace the other for the part that matters most.

Diagnosing a gap before defaulting to training is correct. Not every problem is a training problem. That principle is valid.

The organizations using "be strategic" as the reason they have eight instructional designers for 8,000 employees are not being strategic.

They are being penny-wise and pound-foolish and calling it strategic.

Two tracks.
Watch what happens.

A real California regulatory requirement. A real organization. A real training failure. The company is unnamed. The regulation is public. The consequences are exactly what happens when you measure the wrong things.

The Bill Always Comes Due — The only question is who pays it.
Cost Model Basis — 100-Person Organization
Organization size100 total — approximately 80 DSPs, 12 supervisors, 8 administrative/HR staff
DSP hourly wage$19.60/hour — California average (Indeed, 14,300+ data points, 2026)
Supervisor hourly wage$28/hour — used for all supervisor time calculations
HR/admin hourly rate$35/hour — used for all HR time calculations
DSP annual turnover rate45–50% nationally (Relias 2025 DSP Survey Report) — 36–40 replacements per year at this org
Cost per DSP turnover$3,278 — separation $892 + hiring $437 + training to competence $1,949 (published research, Bancroft NeuroHealth)
All figuresConservative throughout. Actual costs typically run higher.
The Bad Track
What actually happened
The Right Track
What it should have looked like

Reveal each step to compare both tracks side by side — and watch the costs add up.

Step 1 of 8
Someone decides a new documentation standard is needed.
A slide is created. No one reads Title 17. No one asks the DSPs what questions they have. No SME is consulted. Nobody talked to anyone who actually does this job.
This step: ~$80
Bad Track Total$0
Step 1 of 8
Read the regulation before building anything.
Pull Title 17 CCR and DDS documentation standards. Read them. Understand what participant-centered documentation requires and why. Two hours. Prevents every step on the bad track.
This step: ~$140
Right Track Total$0
Step 2 of 8
Training announced mid-month. Via email.
Staff are halfway through their documentation cycle. The email says fix the last 15 days of notes retroactively — to a standard nobody explained. The slide is attached as a PDF.
This step: ~$392
Bad Track Total$0
Step 2 of 8
Talk to the DSPs before building anything.
Pilot conversation with 5–6 DSPs. Ask what questions they have. Ask what they see peers doing wrong. Ask about the range of participants they support. One hour. Changes everything.
This step: ~$260
Right Track Total$0
Step 3 of 8
The meeting. One slide. 45 minutes.
Two random examples. No before-and-after. No context for why the standard changed. No practice. Questions surface. The presenter cannot answer them. They say they will follow up. They do not.
This step: ~$2,352
Bad Track Total$0
Step 3 of 8
Build with real examples for the full range of participants.
Severe to high functioning. Real before-and-after note examples. One rule: if staff appears more than once in the note, rewrite it. At least one practice opportunity. Designed for the person who needs the most help.
This step: ~$800
Right Track Total$0
Step 4 of 8
Contradictory follow-up emails.
One email says document this way. Different sender: why are you doing it that way? The staff member who followed the first email saves both. She is not wrong. No single source of truth was ever established.
This step: ~$280
Bad Track Total$0
Step 4 of 8
Supervisors communicate it first. In person. Not by email.
"We're updating documentation because of a California state requirement. Here's why it matters for the people we support. Here's what's changing." 15 minutes per supervisor. Changes the reception entirely.
This step: ~$84
Right Track Total$0
Step 5 of 8
Individual follow-up. One person at a time. Thirty times.
The same correction delivered 30 different ways to 30 different people. Say something wrong once, correct it 100 times — half still remember the first version. That is neuroscience. Not employee failure.
This step: ~$1,680/month ongoing
Bad Track Total$0
Step 5 of 8
Staff completes training before the group meeting — paid time built in.
60-minute window built into the schedule. Staff are paid because California law requires this training. Supervisors collect questions during the week. When the group meets, they've already done the work.
This step: ~$1,568
Right Track Total$0
Step 6 of 8
Staff does their own research. On their own time.
One staff member goes to the California DDS website and finds the Title 17 requirements herself. In 20 minutes. The person who built the training should have done this. The training never mentioned it existed.
This step: ~$98
Bad Track Total$0
Step 6 of 8
Group session answers real questions with real answers.
FAQ built from questions collected during the week. Common patterns addressed before they become 30 individual conversations. People who got it right hear why. People who struggled hear the correction once, clearly, in front of everyone.
This step: ~$1,568
Right Track Total$0
Step 7 of 8
HR says the training hour requirement is flexible. It is not.
California law requires a minimum of one hour for this regulatory training. HR was wrong. The employee knew the law. HR did not. This is not a new pattern at this organization.
Legal exposure: WIC 4695.2 — unquantified but real
Bad Track Total$0
Step 7 of 8
Supervisor follow-up — built in, not added on.
Sample of notes reviewed in the two weeks following. Specific feedback. The training is the single source of truth. New hires complete the same training in onboarding — no rebuild required.
This step: ~$336
Right Track Total$0
Step 8 of 8 — And on it goes.
Failing forward at scale.
Six months later: same questions, same meeting, same slide. New hires get the same bad training and start the confusion cycle from zero. 45% turnover means 36 new people per year running this. Nobody owns it. Nobody measured it. Nobody fixed it.
This cost does not end. It compounds every hire.
Bad Track Total$0
Step 8 of 8 — Done.
Documentation quality improves. The loop closes.
Within 30 days documentation quality shows measurable improvement. Same questions don't resurface. New hires onboard into a system that already works. The next bimonthly meeting doesn't have a slide about documentation because this one is resolved.
Ongoing: standard supervision — not remediation forever.
Right Track Total$0
Bad Track — Running Total
$0
Grows to $169,000+ over 12 months
0 of 8 steps revealed
Right Track — Running Total
$0
One time. Then it works.
What got measured got done.
This is what happens when you measure the wrong things. The 30-day cost looks close. The 12-month reality is not even in the same ballpark.
Cost Category When Training Gets Cut When Done Right
Initial training cost / "savings"$289 saved$4,756
Supervisor rework × 12 months$20,160$336 (2 weeks only)
Staff confusion and rework$12,000$0
45% turnover — 36 DSPs × ~$3,278$117,994Reduced
New hire cycleResets every hireSame training, no rebuild
Compliance exposureUp to $14.8MProtected
Conservative 12-month total$169,000+<$10,000
You didn't save $289. You wasted $169,000.

The bill always
comes due.

You just don't see it on the same line.

The penny gets saved in one column. The pound gets spent in six others. Because the columns have different owners, nobody ever sees the full number. And then — with a certain audacity — they blame the workers.

What "one slide" actually produced

The training in this case study was literally one slide — in a bimonthly meeting, announced mid-month, with no follow-up, no single source of truth, and no one assigned to measure whether anything changed.

Contradictory emailsMultiple senders, conflicting instructions. No shared baseline. Staff who followed the first email were told they were wrong.
HR citing incorrect lawHR told staff a regulatory training requirement did not apply to them. Staff looked it up and found otherwise. The employee knew the regulation. HR did not.
30 individual conversationsThe same correction delivered 30 separate ways because there was nothing to point back to. No single source of truth.
Failing forward at scale45% annual turnover means 36 new people per year starting the same confusion cycle from zero. The training was never fixed.

One slide was the training. Here is what a real training built for this same regulatory requirement actually looks like. See the DSP Documentation Training →

You will not need to see the original slide to understand the gap. The comparison makes itself.

California DSP average wage
$19.60
Per hour. For people doing some of the most consequential human services work in the state. Source: Indeed, 14,300+ data points, 2026.
National DSP turnover rate
50%
Annually. One in eight DSP roles consistently vacant. Cost per departure: $3,278 in 2004 dollars, approximately $4,630 in 2021 dollars. Source: Relias 2025 DSP Survey; Larson et al.
CEO-to-worker pay ratio
281×
In 2024, CEOs at the 350 largest U.S. firms were paid 281 times as much as typical workers (Economic Policy Institute). The Institute for Policy Studies reported a 632-to-1 ratio among the nation's 100 largest low-wage employers.

Here is what the DSPs supporting adults with developmental disabilities in California do for $19.60 an hour:

DocumentationLegally consequential notes that reflect participant choices, growth, and voice — and protect participants' rights under the Lanterman Act.
Skills DevelopmentSupporting people to build independence — managing appointments, money, daily living, community navigation.
Communication SupportInterpreting verbal and nonverbal communication across a full spectrum of ability. Building relationships that take months to develop and matter enormously to the person on the other side.
Behavioral SupportDe-escalating crises. Implementing specialist-designed support plans. In real time. Often alone. In the community.
Medical MonitoringObserving health changes. Administering medications. Communicating with healthcare providers. Knowing when something is wrong before it becomes an emergency.
ComplianceMaintaining documentation that survives audits, protects organizational licensure, and demonstrates services were delivered as required by California law.

The salary is a legislative problem — a Medicaid reimbursement issue that individual organizations cannot unilaterally solve. But training? Communication? A supervisor who follows up? A single source of truth everyone can find? Those are choices. Within the organization's control. Requiring no legislation. No budget increase from Sacramento.

You cannot always pay them more. But you can always treat them like the work matters. And when you do — they stay. The $169,000 stays in the budget. The boulder stays at the top.

Two decisions. Same organization. Same resources. The onus never moves. The weight does.

The Transfer and The Lift — The Onus is Always on the Top
You didn't save $289. You wasted $169,000. Run and tell that.

Someone told me: people just don't want to learn.

I have based my entire career on the belief that people want to do a good job. But when you give them bad training, send contradictory instructions, and make them figure out a compliance requirement on their own time — at some point you have used up something you cannot get back.

Trust doesn't reset. It compounds in the other direction. The next person walks in carrying what the last person experienced. The credibility didn't disappear overnight. It eroded. One policy email at a time. One "that's not my department" at a time.

People noticed. They always notice. You don't get more rope when you fail people. You get less. Every time.

Fool me once...

The onus is
always on the top.

The people who control the budget, the structure, and who gets promoted for what -- they made the decision to give people one slide. The notes that followed -- the confusion, the turnover, the $169,000 -- those are theirs.

The people whose notes did not improve were not the problem. The notes were the output of a system that gave them a slide, no follow-up, contradictory instructions, and no single source of truth. The system produced exactly what it was designed to produce. The only question is who gets held accountable for it -- and the answer, as always, is the people at the bottom.

"Penny-wise and pound-foolish has a mechanism. You save the penny in a column you're watching and spend the pound in columns no one is adding up. The fraud, waste, and abuse is real. It just lives in a budget line with a better name."

If you made it this far, thank you for reading.
This is how I think, how I learn, and how I show up in my work and my life.