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by kemenaran 920 days ago
As noted by the other investigating organization (La Quadrature du Net), the problem is worse than just the question of the algorithm implementation.

The problem is that the CNAF deliberately targets small unintentional errors rather than large-scale intentional fraud.

Why that? Because fraud is harder to detect and to prove (you have to provide evidence it was intentional).

So smaller and poorer families are disproportionately affected by the controls, because the algorithm was designed to do so. No computational adjustment can fix that: it is the initial intent that is broken.

Source: https://www-laquadrature-net.translate.goog/2023/11/27/notat... (auto-translated in english)

6 comments

> The problem is that the CNAF deliberately targets small unintentional errors rather than large-scale intentional fraud.

The French welfare system is incredibly complex - see for instance this [0] simplified description of housing allowances which is 80 (!) pages long. This is not the most complex part of the system. With such a system, there are massive amounts of errors, both too-much-money-given and not-enough-money-given. The scale is so large that the French Court of Accounts refused to certify the CNAF accounts last year[1]: thoses errors represent about 7.5% of the CAF budget.

So basically the probability to have an error is just a function of how complex your situation is, and thus the "algorithm" targets more complex situations - change in your marital situation, having adult children (which may or may not need to be taken into account when applying for benefits depending on a bazillion variables), and so on, increases your probability to be targeted.

[0] https://www.ecologie.gouv.fr/sites/default/files/Brochure-ba...

[1] https://www.ccomptes.fr/fr/publications/certification-des-co...

As a french person, I don't get why no politician ever talks about simplifying those things. It sounds so easy and such a quick win, leading to more visibility on the budget, and people getting easily access to their due money. But I think I know the answer: current government doesn't want to make welfare easy to access, they want to actually deter people to use it unless they absolutely need it.
If France is anything like the Netherlands, the benefits system isn't used by a few poor's, it's used by the majority of the country, instead of adapting tax codes. Simplifying it is going to (unintentionally and intentionally) hurt some groups, and nobody what's to be on the hook for it, despite it having been an increasingly large election theme.

France at least has a culture of constitutional reboots.

> current government doesn't want to make welfare easy to access, they want to actually deter people to use it unless they absolutely need it.

The more complex a system, the more skill and resources (ability, time, finances) it takes to navigate it.

Eventually, complexity serves to exclude everyone but people who are able to make a career out of pursuing benefits - who are also more likely to be fraudsters.

some cabinets have had a "ministère de la simplification"
It's quite simple I think:

1. for any given budget, there is no Pareto-improving reallocation: if you want to give more money to someone, then the money has to come from someone else.

2. given the current complexity, there are a _lot_ of edge cases to account for. If you do not want to make any loser after a reform, and not have as many edge cases, then you'd need to pump a lot of money to a lot of people so that "edge case people" who become "average joe" do not lose out. See for instance the people who end up with less disposable income when their pension is raised (https://www.alternatives-economiques.fr/vrais-faux-gagnants-...) (!). See also the riffraff about the "montant net social" - now the exact income (which is basically net salary + a bunch of things your employer pay for you and are counted as income) you need to report on welfare application is written on pay slip. Nice simplification here, right? People who reported wrong income (only net salary generally) were upset that it was a plot to decrease welfare.

3. people genuinely genuinely love special cases. Hence the tradeoff for the government between adressing a special case but adding more complexity always end up with more special cases, more complexity.

Some examples: since housing is expensive, people want to help renters with cash payment (of course it can't be bundled with the basic income, it has to be its own benefit), but they also want some public housing with below market rents. Now you need to acocunt for the in kind benefit of having a below market rent in the rules of housing benefits if you want to be relatively just between those two populations.

Recently, the cash benefit for handicaped people computation was changed - it depends only on the receiver's income and not on household's income (the main argument was that household income as an input makes handicapped less autonomous on one hand, and decreases working incentives for them). Now this means that some benefits are computed at the individual level, other at the household level. Of course there is a transitory period where people can be grandfathered-in the old rules so as not to make any losers.

And so on and so forth.

Large families need their own benefits, because they have unique(tm) needs, you just can't make a per child benefit that just scale.

And so on and so forth.

Did I mention that you want to help overseas territories with special fiscal rules?

And so on and so forth.

I think the two most prominent examples of this were the two failed Macron reform: the first pension reform (universal public pension fund instead of several) and the basic income (revenu universel d'activité - basically a merger of APL+RSA+PA at least). Always a special category that lose out if they own complexity-inducing special case is ironed out.

4. because of points 1-4, no one understands anything and thus there is a strong suspicision that the government is here to rob you of [your benefits | your pension | etc] when there is a reform proposal.

Same issue as with tax fraud. Governments prefers dealing with mistakes and small frauds they are cheap fast success, simple to detect, no lawyer to fight back, but the opposite for large frauds.

This was explain to me by an accountant when I wondered why they wanted to have me fix what felt like I significant errors, mean while a big corporation was in the news for what was clearly tax fraud but the government was dragging they feet about it.

It's also, generally, a complexity problem.

Corporate accounting is more complicated than family accounting. Even if the corporation isn't trying to do anything complicated!

Consequently, there are more edge cases and grey areas. As an accountant friend said to me, it's more like law than science -- knowing lots of laws and regulations, plus history, and deciding how to mostly correctly classify various things.

So something like trying to write the most efficient assembly algorithm possible, while Congress is modifying the ISA every year.

(Which isn't to say that loopholes don't exist, corporations don't abuse them, or corporate tax attorneys don't delay enforcement actions... but is to say that even in best case, family accounting is much simpler than corporate)

> It's also, generally, a complexity problem.

I don't think so in 2023. I worked several years in a tax agency and it was mainly a problem of "motivation". I have a friend who pursued "data warehouse" for 30 years there... nowadays you can crunch all the information and find patterns . I would even suggest that tax agencies should anonymize data and create data bounties to help them. In the same way DARPA creates cyberchallenges [1].

[1] https://www.darpa.mil/about-us/timeline/cyber-grand-challeng...

How much of internal accounting state leaks into tax filings?

I assume when you're looking at forensic tax accounting, you're identifying present-year vs previous-year discrepancies?

Or is there enough required in filings to generate something like a complete shadow accounting for a company?

There are relationships between agencies and corporations to link information. It is not only your filings what is at stake.
I think it'd be impossible to anonymize data in such a way that it's still useful but not easily identifiable with public or partial private information.
> The problem is that the CNAF deliberately targets small unintentional errors rather than large-scale intentional fraud.

I think your observation is the greatest one: you don't target "Madoffs or SBFs" you just look at the low hanging fruit where you look at simple probabilistic causality A => B instead of, or at the same time, targetting big malicioous actors. Big and/or complex crimes and corruption are protected.

The irony is that many times the crimes commited by big actors could be simpler to analyze based on tax and financial information.

Related: The AI Incident Database [1]

> The AI Incident Database is dedicated to indexing the collective history of harms or near harms realized in the real world by the deployment of artificial intelligence systems. Like similar databases in aviation and computer security, the AI Incident Database aims to learn from experience so we can prevent or mitigate bad outcomes.

[1] https://incidentdatabase.ai/

Are they taking this approach only in the negative form?

Ie; if they detect you’ve made a mistake an and not claimed something you are eligible for. Or paid some tax that you are actually eligible to deduct/offset somehow, does it notify or automate the process of fixing that error?

I’m not opposed to the idea of automate to ensure compliance with the law / regulations. But enforcement should go both ways. The goal of automation of policy should be for the policy to be maximally effective. It shouldn’t just penalise those who incorrectly claim, but rather maximise eligible claims. And by that same measure, ensure those ineligible are rejected.

Obviously without any penalities, this would lead to over claiming, and reliance on the system to reject. But I think the system should be resilient enough to handle that.

While it’s not to such an extreme extent, there is a polar opposite attitude / policy towards entitlement of government benefits in Australia and New Zealand. In Australia you may be eligible for something, but it’s your responsibility to know that and claim it. And the government takes a ‘we defend the benefits from those who are ineligible’ attitude (more so if the Liberal party is in power, see Robo Debt scandal).

In New Zealand they take a ‘these benefits must go to those who are eligible’ attitude. And they model the extent to which they fulfil that objective based on how many claim vs how many their model states are eligible.

The outcome is that in NZ they call after you’ve had a baby to ensure you’re receiving additional tax benefits, services, etc. In Australia you’d only receive a call / letter to notify your benefits are being cut off, and there’s some difficult->impossible method of re-applying. Such as contacting a call centre that’s queue is full by 9:30 and stops accepting calls…

The purpose of a system is what it does.