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?

 

5.       Please describe your process for identifying and handling improper payments.

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.)

Calculation based on:

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 :) ______________________________________________________________________________

q Findings from state or local fraud units (Please specify :) ______________________________________________________________________________

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 :)

 

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.)

 

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.)

 

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.

 

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.)

Table 10

Factors contributing to improper payments	Great extent	Moderate extent	Little extent	No extent	Don’t know
Related to clients
a. Nonreporting/underreporting of income		X
b. Client receiving payment in more than one jurisdiction				X
d. Incorrect reporting of household size			X
e. Incorrect citizenship or immigration status			X
f. Incorrect information on client’s compliance with program requirements, such as participating in required activity		X
g. Other (Please specify):  Assets			X
Related to providers
h. Overstating performance			X
i. Claiming for services not rendered			X
j. Other (Please specify): Child Care Provider (FX) receiving benefits e.g., food stamps, etc. and not reporting income from Child Care Payments

 

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.)

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.

Table 12

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	At application and redeterminations	6 mos.	X
b. Fingerprint clients	q Yes   X No
c. Access online databases	X Yes   q No	At application and redeterminations	6 mos.	X
d. Match automated computer files	X Yes   q No	New Hires monthly and IEVS quarterly	Monthly quarterly	X
e. Conduct telephone, fax, or email contacts	X Yes   q No	At application and redeterminations	Ongoing
f. Conduct home visits	X Yes   q No	Only as needed and not in all CWAs.  Quality Control staff do 100% for all sampled cases	As needed
g. Initiate a fraud investigation if warranted	X Yes   q No	As needed
h. Conduct program integrity/quality control review	X Yes   q No	Random Sample reviewed monthly	Ongoing monthly
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.)

Table 13

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 application and redetermination	quarterly	X
b. Other human services programs in your agency/State	X Yes  q No	At any time
c. State department of labor or employment security	q Yes  X No	 
d. State directory of new hires	X Yes  q No	At application and redetermination	Monthly	X
e. State department of motor vehicles	X Yes  q No	At application and redetermination	6 mos.
f. Public Assistance Reporting Information System (PARIS)	X Yes  q No		6 mos.
g. State data (from other States) on length of TANF receipt	q Yes  X No
h. State data (from other States) on potential concurrent TANF receipt	X Yes  q No	At any time
i.  State data (from other States) on client or provider debarment from benefits, for fraud or other infraction	q Yes  X No
j. Lottery agencies	X Yes  q No	At any time
k. Prisons and criminal justice agencies at State level	q Yes  X No
l. National Criminal Information Center (NCIC)	q Yes  X No
m. Local jails	q Yes  X No
n. Credit bureaus	q Yes  X No
o. Financial institutions	q Yes  X No
p. State tax intercepts	X Yes  q No	At any time
q. Immigration authorities	q Yes  X No
r. K-12 school systems	q Yes  X No
s. Community colleges	q Yes  X No
t. Other providers of services, education, training	q Yes  X No
u. Child support	X Yes  q No	At any time
v. Social Security Administration (SSA) form W-2 (wage statements)	X Yes  q No	At application and redetermination	6 mos.
w. SSA Social Security number verification	X Yes  q No	At application and redetermination	6 mos.
x. SSA Supplemental Security Income (SSI) data	X Yes  q No	At application and redetermination	6 mos.
y. SSI death information	X Yes  q No	At application and redetermination	6 mos.
z. Other (Please specify :)	q Yes  q No

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.)

 

Fraud:  Intentional Overpayments

16.   How does the TANF Lead Agency define “fraud”?

NJAC 10:90-1.13(b) - If a client deliberately misrepresents or conceals relevant facts in order to obtain or attempt to obtain payments of assistance for which the individual is not eligible, fraud may be suspected and a referral for fraud/intentional program violation (IPV) shall be initiated (see N.J.A.C. 10:90-11.)

NJAC 10:90-11.1(a) - Intentional program violation (IPV) is any statement or act by an individual for the purpose of establishing or maintaining the assistance unit’s eligibility for WFNJ assistance, for increasing or preventing a reduction in the WFNJ assistance, or to prevent denial or termination of WFNJ assistance, which is intentionally: a false or misleading statement or misrepresentation, concealment, or withholding of facts; or an act intended to mislead, misrepresent, conceal, withhold facts, or to propound a falsity.

 

17.  Does your agency maintain data on fraudulent payments in the program as a subset of your improper payments data? (Please check one response.)

 

18. What steps, if any, beyond improper payments prevention, does your State take to specifically prevent fraud?

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.)

 

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.

 

 

Thank you very much for your time and assistance!

 

Improper Payments Information Survey for the New Jersey TANF Program form, in (Word), (PDF) file format