State Survey Analysis Report
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Measures Taken to Prevent Collusion
20. What measure does your agency take to prevent collusion?
Twenty-four State agencies provide narrative descriptions of measures used to prevent collusion.
- Thirteen State agencies describe using a combination of assuring agency internal controls, segregation of duties between eligibility, provider contracts and payment authorization and having these functions reflected in security levels in automated systems (AL, AZ, CA(DSS), CT, KY, MA, MT, NH, PR, WA)
- Nine State agencies describe having policies, procedures and penalties (CA(DE), DC,KS, MD, MN, NE,NC, PR)
- Six State agencies describe the use of Electronic Benefit Transfer (EBT) Systems, data matching, red flag reports, training, and provider monitoring audits (AZ, CT, DC,GA, KS, OK). (See Appendix 20 for detailed narrative responses.)

