Improper Payments Information Survey for the TANF Program
State of Minnesota
Instructions |
In accordance with the Paperwork Reduction Act of 1995, collection of this information has been approved by the Office of Management and Budget (OMB) under OMB Control Number 0970-0290, expiration date 10-31-2008. Submission of this information, however, is voluntary. The public reporting burden for this collection of information is estimated to average 24 hours per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection of information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
Please enter the following information for the individual(s) completing this questionnaire and attachments, so we may contact them to clarify information, if necessary.
Date : December 2005
Name: Sally Fashant
Title: Program Assessment and Integrity Manager
State Agency: Minnesota Department of Human Services
(Area Code) Phone Number: (651) 296-2088
E-mail Address: sally.fashant@state.mn.us
Please return the completed questionnaire and attachments in the enclosed business reply envelope. Alternatively, you may fax your completed questionnaire and brief attachments to the attention of Dennis Poe at 202-205-5887, or preferably email an electronic copy of the questionnaire and any attachments to him at dspoe@acf.hhs.gov.
If you have any questions or comments regarding your submissions, please contact Dennis Poe at 202-401-4053, or at dspoe@acf.hhs.gov.
Please return the questionnaire and attachments by December 30, 2005.
As a point of reference, under the Improper Payments Information Act of 2002, the term, “Improper Payment”
(a) means any payment that should not have been made or that was made in an incorrect amount (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; and
(b) includes any payment to an ineligible recipient, any payment for an ineligible service, any duplicate payment, payments for services not received, and any payment that does not account for applicable discounts.
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General Overview: Policies and Infrastructure |
1. How does the TANF Lead Agency define improper payments? Improper payments are those payments that are either:
The following information is taken from our policy manual, the Minnesota Department of Human Services Combined Manual (MDHS CM).
OVERPAYMENT :
Benefits which ASSISTANCE UNITs receive that exceed the amount for
which they are eligible.
UNDERPAYMENT:
A benefit which is less than the amount to which the client is entitled.
2. Provide a description (electronic copy, if available) of the organizational structure of the agency in your State that handles improper payments in the TANF program. If available, please submit an organizational chart, or provide the web site address where it can be found.
Minnesota’s TANF program is state supervised and county administered. The Children and Family Sevices Administration (CFS) within the Department of Human Services (DHS) has oversight responsibility for the TANF program. Within CFS the Program Assessment and Integrity Division focuses on program evaluation and integrity. This includes quality control initiatives, fraud and recoveries.
A link to the Minnesota DHS organizational chart is included as a separate attachment in the e-mail.
3. Please check all of the topics or activities listed below for which
your State has policies or regulations in place for the program. (Please
check all that apply.)
x Steps involved in identifying a potential improper payment
x Steps involved in verifying an improper payment
x Establishing claims for improper payments
x Collecting improper payments, including, for example, the authority to reduce payments to recover overpayments
x Distribution of recovered improper payments
q Sources of funding for addressing improper payments
q Other (please specify : )
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Identification and Assessment of Improper Payments |
4. Has your State performed an assessment or analysis to determine whether the program is at risk of improper payments?
q Yes.
For which of the following uses of program funds did your state perform an assessment or analysis to determine whether the program is at risk of improper payments? (Please check all that apply.)
q a. Monthly cash assistance payments
q b. “Nonassistance” benefits or services, for example, one-time cash payments designed to
divert a family from welfare or payments for car repairs or rental assistanceq c. Other types of benefits and services for families not receiving cash assistance
q d. Payments to service providers
q e. Other (Please specify:) ________________________________________________________
___________________________________________________________________________X No.
5. Please describe your process for identifying and handling improper payments.
The following website takes you to MDHS CM Chapter 25, which provides information on underpayments, overpayments and relative contributions to assist eligibility workers to determine when to issue a corrective payment, adjust benefits or pursue overpayment recovery. It includes information on determining if a fraud investigation is appropriate on client errors.
http://www.dhs.state.mn.us/main/groups/county_access/documents/pub/dhs_id_048261.hcsp
6. Which methods, if any, did your state use to identify a total amount of improper payments for the program? (Please check all that apply.)
q Findings from the state’s Single Audit
q Other audit findings from state auditors
q Findings from other state or local auditors, including legislative review entities (Please specify ) _____________________________________________________________________
X Findings from state or local fraud units (Please specify :) Minnesota is state supervised and county administered so fraud programs are administered at the county level with state oversight. Counties report the results of their investigations to the Department.
q Reviews of service providers and/or contractors
q Reviews of sampled cases, although not statistically representative of all program payments
X Statistically representative sample of payments
q Other (Please specify :) ____________________________________________________________________
NOTE: The Minnesota Department of Human (DHS) collects data on improper payments both through its quality control (QC) process and as a result of fraud referrals/investigations statewide. Because QC and fraud data come from different sources, collection methods are different, etc. any meaningful integration of the data would be difficult. However, information from both sources is used to improve the integrity of Minnesota’s TANF program.
7. Does your State calculate an improper payments (including fraudulent payments) rate, that is, a measure of the percentage of total payments that are determined to be improper? (Please check one response and provide the appropriate data.)
q Yes. Please describe the methodology used to arrive at the error rate.
X No
NOTE: Based on the results of the QC reviews, DHS staff computes a statewide error rate. The error rate is arrived at by dividing the total error payments by the total payments for the sample of cases reviewed. We also compile data on our fraud efforts. Both data sources provide useful information for improving the integrity of Minnesota’s TANF program. However, for the reasons mentioned in the previous answer, we do not integrate QC and fraud data.
q Information not available.
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Describing Improper Payments: Sources, Types, Causes |
8. Please rank the following sources of improper payments (1 to 7) for the program in your State over the past two fiscal years, beginning with one (1) indicating the primary source of improper payments. Error is defined as an inadvertent mistake whereas fraud is defined as a willful misrepresentation. (Please rank each source below.)
Ø _2__ Client error
_*__ Provider error
Ø _1__ Agency error
Ø _3__ Client fraud
_*_ Provider fraud
_*_ Agency fraud
___ Other (Please specify) _________________________
Ø Information based on FFY 2003 and FFY 2004 quality control (QC) reviews.
* data not available
9. Of all improper payments in your State, what proportion of those payments would you estimate are overpayments, and what proportion would you estimate are underpayments? An overpayment is defined as a payment larger than what should have been made/received or any payment that is received when none should have been received. An underpayment is defined as a payment smaller than what should have been made/received or no payment was received when there should have been one.
Overpayments 87%
Underpayments 13%
* Information based on FFY 2003 and FFY 2004 quality control (QC) reviews.
10. To what extent, if any, have the following factors contributed to improper payments in your State over the past two fiscal years? (Please check one answer in each row.)
Factors contributing to improper payments |
Great extent |
Moderate extent |
Little extent |
No extent |
Don’t know |
|---|---|---|---|---|---|
Related to clients |
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a. Nonreporting/underreporting of income |
X |
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b. Client receiving payment in more than one jurisdiction |
X |
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d. Incorrect reporting of household size |
X |
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e. Incorrect citizenship or immigration status |
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X |
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f. Incorrect information on client’s compliance with program requirements, such as participating in required activity |
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X |
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g. Other (Please specify): Assets |
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Related to providers |
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h. Overstating performance |
* |
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i. Claiming for services not rendered |
* |
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j. Other (Please specify): Child Care Provider (FX) receiving benefits e.g., food stamps, etc. and not reporting income from Child Care Payments |
* |
X - Information based on FFY 2003 and FFY 2004 QC reviews.
* - Information not available.
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Prevention of Improper Payments |
11. Please describe your top 3 priorities for preventing and reducing improper payments (e.g., training/meetings for providers on rules and responsibilities; training for agency staff on correct implementation of rules and responsibilities; clear communication with parents on rules and responsibilities; use of information technology.)
MAXIS – MAXIS is Minnesota’s automated eligibility system
· MAXIS is automated for most MFIP policy. DHS continues to pursue enhancements to the MAXIS system to reduce errors.
· There are on-line policy (MDHS CM) and procedures manuals (MDHS TEMP) that workers can access directly from the MAXIS screen they are working on.
· Eligibility workers in the counties are supported by eight MAXIS Help Desk staff that are available to respond to questions from counties related to the functionality of the system.
Training
· DHS continues to require training for new workers. In addition, training staff provide targeted workshops upon request from the counties or DHS staff who identify issues.
· The Public Welfare Financial Worker Program (PWFW) continues to be offered at Pine and St. Cloud Technical Colleges. The PWFW program provides counties with trained candidates to fill eligibility worker vacancies around the state.
· Web Based Training modules continue to be developed. Within the next year a module on assessing for Food Support when MFIP closes will be developed. This will instruct workers on actions to take when MFIP closes.
Communication and data sharing with our partners
· DHS believes it is essential to maintain a high level of communication with counties at all levels, from directors to line staff. DHS staff continues to attend the monthly director and Minnesota Association for Financial Assistance Supervisor (MAFAS) meetings and Training Advisory Committee meetings, in addition to having representation on the board of the Financial Worker’s Association. DHS also holds monthly mentor meetings, where DHS staff update county mentors on new policies and procedures, upcoming changes, and hot topics.
· It is also essential to have open communication and cooperation within the Department. As issues arise through special studies, case reviews, and county feedback, DHS works with all areas in the department to address the issues raised.
· New information is communicated to the counties in a variety of ways. The Minnesota Department of Human Services Combined Manual (MDHS CM) is the primary vehicle for communicating and clarifying policy. In addition, DHS continues to supplement CM updates with other communications such as informational and instructional bulletins, MAXIS e-mail, temporary (TEMP) manual updates, InfoPac reports, and attendance at regional meetings.
· The Local Agency Support Policy Center responds to county inquiries related to cash and food support programs when answers are not available or are unclear in the CM. County policy coordinators may submit questions to the policy center via internet e-mail. The process of submitting, responding and storing answers to policy inquiries has been upgraded over the last year to include a database of answers available to counties through a “County Link” to the DHS website. Counties may now search for questions and answers to previous submitted policy questions on-line.
· DHS continues to enhance DHS web access for counties, and increase the availability of important program information. In particular, counties can now access payment accuracy information via a link to the DHS website. DHS will continue to devise reports to post to the DHS website for county access to assist them in tracking their performance.
12. For each activity listed below, indicate whether or not your State performs it to verify the accuracy of information needed to determine eligibility for and/or proper amount of a program payment. If yes, indicate when in the process the step or activity is performed and how often it is performed.
NOTE: The following information reflects the possible actions a Minnesota eligibility worker might take to determine eligibility and/or the correct benefit amount. It does not reflect activities that might be taken by a Minnesota QC reviewer or fraud worker. We chose not to rank the activities performed by Minnesota workers. All of the activities, when performed as needed, have value.
Steps or activities performed |
Is the step/activity performed? |
If yes, at what stage in the process (e.g., pre-approval/approval; redetermination at 3 mos., 6 mos. or 12 mos. ;etc.)? |
If yes, how often? |
Please insert a checkmark by the 3 items you consider the most effective. |
|---|---|---|---|---|
a. Require documentation from client |
x Yes q No |
Depending on the information to be verified, at the pre-approval/approval, redetermination or when a change is reported |
Depends on item being verified |
x |
b. Fingerprint clients |
q Yes x No |
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c. Access online databases |
q Yes x No |
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d. Match automated computer files |
x Yes q No |
At pre-approval/approval for applicants. For recipients it depends on the type of match. Some are monthly, some quarterly and one is annually |
Depends on the type of match |
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e. Conduct telephone, fax, or email contacts |
x Yes q No |
Is one method of verification but not mandatory. Could be used at pre-approval/approval, redetermination or when a change is reported |
As Needed |
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f. Conduct home visits |
x Yes q No |
Is one method of verification but not mandatory. Could be used at pre-approval/approval, redetermination or when a change is reported |
As Needed |
x |
g. Initiate a fraud investigation if warranted |
x Yes q No |
Caseworkers are to refer anyone they suspect of fraud for investigation so this could happen at any time |
As warranted |
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h.
Conduct program
integrity/quality control |
x Yes q No |
The sample is pulled from active cases. A supplemental sample is pulled to get sample month approvals |
Monthly |
x |
i. Other (Please specify :) |
q Yes q No |
13. Data sharing is a method used to obtain and disclose information about individuals from within your agency, from other agencies and/or from independent, third party sources, including federal and State agencies or private companies. These activities can be conducted before an initial payment is made to an individual or provider (pre-payment) and also after payment is made (post-payment) to verify eligibility and payment accuracy. For each source listed below:
Indicate whether or not your agency or State utilizes this data source to better ensure accurate payments under the program. If your State utilizes the source, indicate when in the process the source is used (before the payment is issued or at some point after the payment is issued), and/or indicate how often that source is used. (Please check all appropriate responses for each row.)
NOTE: The following information reflects data sources a Minnesota eligibility worker might access as part of an eligibility determination, data sources used by QC reviewers and data sources used by fraud workers. We chose not to rank the data sources. All of the sources, when accessed as needed, have value.
Data source |
Is the source used? |
If yes, when in the process (e.g., pre-approval/approval; redetermination at 3 mos., 6 mos. or 12 mos. ;etc.)? |
If yes, how often? |
Please insert a checkmark by the 3 items you consider the most effective. |
|---|---|---|---|---|
a. Income Eligibility Verification System (IEVS) |
x Yes q No |
At least monthly for applicants and monthly for most match types on recipients. The exceptions are wage and UNVI |
Monthly for most match types |
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b. Other human services programs in your agency/State |
x Yes q No |
Pre-approval/approval |
As Needed |
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c. State department of labor or employment security |
x Yes q No |
Fraud investigations (FI) and if related to eligibility at pre-approval/approval or when they occur |
As Needed |
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d. State directory of new hires |
x Yes q No |
Monthly for both applicants and recipients |
As Needed |
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e. State department of motor vehicles |
x Yes q No |
FI |
As Needed |
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f. Public Assistance Reporting Information System (PARIS) |
q Yes x No |
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g. State data (from other States) on length of TANF receipt |
x Yes q No |
Pre-approval/approval |
As Needed |
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h. State data (from other States) on potential concurrent TANF receipt |
x Yes q No |
Pre-approval/approval |
As Needed |
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i. State data (from other States) on client or provider debarment from benefits, for fraud or other infraction |
x Yes q No |
Pre-approval/approval |
As Needed |
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j. Lottery agencies |
x Yes q No |
FI |
As Needed |
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k. Prisons and criminal justice agencies at State level |
x Yes q No |
FI |
As Needed |
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l. National Criminal Information Center (NCIC) |
x Yes q No |
FI |
As Needed |
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m. Local jails |
x Yes q No |
FI |
As Needed |
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n. Credit bureaus |
x Yes q No |
FI |
As Needed |
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o. Financial institutions |
x Yes q No |
Pre-approval/approval, redeterminations and when new information is reported and FI |
As Needed |
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p. State tax intercepts |
x Yes q No |
FI and Collections |
As Needed |
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q. Immigration authorities |
x Yes q No |
Prior to approval or when a change in status is reported |
As Needed |
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r. K-12 school systems |
x Yes q No |
If related to eligibility at pre-approval/approval or when they occur |
As Needed |
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s. Community colleges |
x Yes q No |
If related to eligibility at pre-approval/approval or when they occur |
As Needed |
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t. Other providers of services, education, training |
x Yes q No |
If related to eligibility at pre-approval/approval or when they occur |
As Needed |
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u. Child support |
x Yes q No |
If related to eligibility at pre-approval/approval or when they occur |
As Needed |
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v. Social Security Administration (SSA) form W-2 (wage statements) |
x Yes q No |
See IEVS |
See IEVS |
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w. SSA Social Security number verification |
x Yes q No |
At pre-approval/approval |
Monthly |
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x. SSA Supplemental Security Income (SSI) data |
x Yes q No |
At pre-approval/approval, redetermination or when changes occur. Also as part of IEVS |
As Needed |
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y. SSI death information |
q Yes x No |
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z. Other (Please specify :) |
q Yes q No |
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Recovery of Improper Payments |
14. For the most recently completed fiscal years, how much in program improper payments has your agency, or another agency within your State, recovered? (Please indicate your responses in the space provided below.)
Most recently completed fiscal year $6,089,146 **(Specify ending month/ year) 06/2005 (Minnesota’s state fiscal year runs July through June)
q Includes fraudulent improper payments YES
Next most recently completed fiscal year $6,179,497**(Specify ending month/ year) 06/2004(Minnesota’s state fiscal year runs July through June)
**includes TANF and old AFDC
q Includes fraudulent improper payments YES
q Not tracked
15. What penalties does your program mandate for clients, agencies, or providers, who commit an error leading to improper payments? Civil Penalties/Disqualifications
A. Agency:
None
B. Clients/Parents:
The following website takes you to MDHS CM Chapter 25, Section 0025.24.06 which gives Minnesota’s fraud disqualification provisions.
http://www.dhs.state.mn.us/main/groups/county_access/documents/pub/dhs_id_048261.hcsp
C. Providers:
None
D. County/Local Agency:
Agency errors in determining payment amounts are recoverable from the client.
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Fraud: Intentional Overpayments |
16. How does the TANF Lead Agency define “fraud”?
The following website takes you to MDHS CM Chapter 25, Section 0025.24 which gives Minnesota’s definition of fraud.
http://www.dhs.state.mn.us/main/groups/county_access/documents/pub/dhs_id_048261.hcsp
17. Does your agency maintain data on fraudulent payments in the program as a subset of your improper payments data? (Please check one response.)
Yes
If yes, please list the methods you use for finding occurrences of fraud and indicate whether you would rate each method as very effective, somewhat effective, somewhat ineffective, or very ineffective.
X No
The Minnesota Department of Human (DHS) collects data on improper payments both through its quality control (QC) process and as a result of fraud referrals/investigations statewide. Because QC and fraud data come from different sources, collection methods are different, etc. any meaningful integration of the data would be difficult. However, information from both sources is used to improve the integrity of Minnesota’s TANF program.
Does any other entity in your State maintain this information, such as a State fraud unit or Inspector General? If yes, please provide us with a contact name and phone number:
18. What steps, if any, beyond improper payments prevention, does your State take to specifically prevent fraud? Customer Educational Training regarding reporting requirements, etc.
The Minnesota Department of Human Services’ Program Assessment and Integrity Division, in cooperation with county agencies, is responsible for preventing and reducing recipient fraud in most of the state’s cash, child care, health care and Food Support programs.
The work falls into three broad categories:
- An intensely focused, “front-end” process to identify fraud early and prevent overpayments by denying, stopping or reducing benefits to ineligible applicants and recipients
- Traditional criminal investigative procedures for addressing welfare fraud, as a crime of theft, through the state’s civil or criminal justice systems
- A collections program that uses various means to recover money from recipients who were ineligible for benefits.
Front-end process
The Fraud Prevention Investigation Program, Minnesota’s front-end program, is a nationally recognized model for quickly resolving issues of questionable eligibility for public assistance. Through this investigative process, eligibility workers refer potentially fraudulent applications and open cases to trained investigators. In 2004, they:
- Completed more than 8,000 investigations; in 45 percent of them, benefits were stopped or reduced
- Found and corrected information discrepancies in 70 percent of the investigations; this aspect of fraud investigations contributes to fewer errors found during state and federal quality control reviews
- Identified more than $13.5 million in cost-avoidance (not paying benefits to ineligible applicants and recipients) and overpayments
- Saved or collected $4.91 for every $1 spent in the program in administrative costs
- Identified more than 400 recipients in the program who committed fraud and were disqualified from public assistance.
Criminal investigations
When investigations find that individuals did not provide complete or accurate information to receive public assistance, the counties and Minnesota Department of Human Services take actions to prevent them from participating in public assistance programs. Some welfare fraud cases rise to the felony theft level and require involvement of the criminal justice system. In 2004:
- Investigators completed more than 2,000 criminal investigations; in 59 percent of them, investigators proved benefits had been illegally obtained and, at a minimum, overpayments were assessed
- Investigators disqualified recipients in 490 instances from programs
- Recipients, in 89 cases prior to trial, admitted guilt and agreed to restitution, with sentencing deferred.
Welfare fraud cases that go to trial may receive publicity which raises awareness of the possibility of detection and helps deter fraud.
Collections
The Treasury Offset Program (TOP) intercepts federal payments and tax returns to recover Food Support debt. In 2004, state staff collected $1.6 million. Total collections are $17.7 million for the 10 years Minnesota has participated in the program. In TOP recoveries, Minnesota currently ranks second in the nation in dollars collected per dollars spent.
In 2004, Minnesota counties recovered an additional 2.3 million in Food Support debt from individuals who were overpaid. County agencies also recovered cash directly from individuals who were overpaid TANF program benefits. The TANF and old AFDC recoveries are reported in question #14
19. Is your agency required to report, or to have information available, on improper payments to the State legislature, the Governor, or any other higher-level agencies? (Please check one response.)
q Yes ® Please provide a copy of the report(s), and indicate who received them.
X No
While no report is required, reports are produced on a monthly basis with the results of the QC reviews. This information with shared within the Department and with our county partners to assist in improving performance.
While no report is required, we do compile front end/ Fraud Prevention Investigation (FPI) Program statistics and issue county agencies an annual program evaluation report. By state statute, the administrative costs of funding the FPI program must be cost neutral to the state. The statute reference: http://www.revisor.leg.state.mn.us/stats/256/983.html
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Other |
20. Describe any other information that may be relevant to improper payments in the program that you wish to share with us.
21. Please submit copies of pertinent sections of manuals and other State-issued guidance that you would like to make available, or provide the web site address where they can be found.
As mentioned earlier, the following website takes you to MDHS CM Chapter 25, which provides information on underpayments, overpayments and relative contributions to assist eligibility workers to determine when to issue a corrective payment, adjust benefits or pursue overpayment recovery. It includes information on determining if a fraud investigation is appropriate on client errors.
http://www.dhs.state.mn.us/main/groups/county_access/documents/pub/dhs_id_048261.hcsp
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Thank you very much for your time and assistance! |
Improper Payments Information Survey for the Minnesota TANF Program form, in (Word), (PDF) file format
Improper Payments - General - Attachment 1, in (Word), (PDF) file format
Improper Payments - Fraud - Attachment 2, in other file format (Word), (PDF) file format
Minnesota Department of Human Services organizational chart in PDF file format
MN Child Care Assistance Program - Program Integrity Initiatives, in (Word), (PDF) file format
Child Care Assistance Program Integrity/Fraud Prevention Workgroup - Recommendation froms Program Integrity Workgroup, in (Word), (PDF) file format
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This document was last modified on
Sep-26-2006
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