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.)

This ranking reflects results of the Quality Control Reviews:

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	Pre-approval, redetermination, & when conflicting information is received	Every 6 months	X
b. Fingerprint clients	q Yes   X No
c. Access online databases	X Yes q No	During application and redetermination process	When program change is initiated in the online approval system	X
d. Match automated computer files	X Yes q No	Post-approval, redetermination & when conflicting information is received	Data match alerts are delivered to eligibility staff on an ongoing schedule	X
e. Conduct telephone, fax, or email contacts	X Yes q No	When required to complete application / reapplication process, or when conflicting information is received
f. Conduct home visits	X Yes q No	To resolve discrepancies, or to complete the application / reapplication process
g. Initiate a fraud investigation if warranted	X Yes q No	Pre-approval / post-approval	When evidence alleges possible fraud
h. Conduct program integrity/quality control review	X Yes q No	Pre-approval / post-approval	When evidence alleges possible fraud
i. Other (Please specify :)	q Yes   q No	Post-approval	Monthly

 

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	Post approval	Depending upon the source	X
b. Other human services programs in your agency/State	Yes	This occurs in some counties, usually within the same county
c. State department of labor or employment security	No
d. State directory of new hires	Yes	Pre-approval and online alerts	Weekly	X
e. State department of motor vehicles	Yes	This occurs in some counties, usually within the same county	Schedule differs depending on the county
f. Public Assistance Reporting Information System (PARIS)	No
g. State data (from other States) on length of TANF receipt	No	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.
h. State data (from other States) on potential concurrent TANF receipt	No	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.
i.  State data (from other States) on client or provider debarment from benefits, for fraud or other infraction	No	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.	Though we do not operate a formal data matching system with these sources, counties do verify this information with other states when there is an indication that the applicant/recipient resided, or was born, in another state.
j. Lottery agencies	No
k. Prisons and criminal justice agencies at State level	Yes	Post approval	Monthly
l. National Criminal Information Center (NCIC)	Yes	Post approval	Monthly
m. Local jails	Yes	In some counties, usually within the same county
n. Credit bureaus	Yes	This occurs in some counties
o. Financial institutions	No
p. State tax intercepts	Yes	Post approval, for collection of delinquent repayment of overpayments	Weekly	X
q. Immigration authorities	Yes	Pre-application
r. K-12 school systems	No
s. Community colleges	No
t. Other providers of services, education, training	No
u. Child support	Yes	This occurs in some counties.	As needed
v. Social Security Administration (SSA) form W-2 (wage statements)	Yes	This occurs in some counties.	As needed
w. SSA Social Security number verification	Yes	Pre & post approval	As needed
x. SSA Supplemental Security Income (SSI) data	Yes	Pre & post approval	As needed
y. SSI death information	Yes	Pre & post approval
z. Other (Please specify :)

 

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”?

Ohio Revised Code Section 5101.83 and Ohio Administrative Code Section 5101:1-23-75 define TANF fraud as follows:

(1)       In accordance with section 5101.83 of the Revised Code, "fraudulent assistance" means assistance and services, including cash assistance provided under the OWF program established under Chapter 5107. of the Revised Code, or the prevention, retention and contingency (PRC) program established under Chapter 5108. of the Revised Code, to or on behalf of an assistance group that is provided as a result of fraud by a member of the assistance group, including an intentional violation of the program's requirements. Fraudulent assistance does not include assistance or services payment to or on behalf of an assistance group that is provided as a result of an error that is the fault of the CDJFS or the ODJFS.

(2)       For purposes of this rule, an "intentional violation of the program's requirements" is defined as an act by an individual, for the purpose of establishing or maintaining the family's eligibility for OWF or PRC or for increasing or preventing a reduction in the amount of assistance, which is intentionally: a false or misleading statement or misrepresentation, concealment, or withholding of facts; or any act intended to mislead, misrepresent, conceal, or withhold facts or propound a falsity, as set forth in Chapter 5101:6-20 of the Administrative Code.

 

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.

Ohio would like to have the ability to submit TANF overpayments to the Treasury Offset Program (TOP) for recovery of delinquent debts.

 

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 Ohio TANF Program form, in (Word), (PDF) file format