Instructions

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 : 12/30/05

Name: Carole W Rebert

Title: Director, Bureau of Program Evaluation

State Agency: Department of Public Welfare (DPW) / Office of Income Maintenance (OIM)

(Area Code) Phone Number (717)-783-7625

E-mail Address: crebert@state.pa.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.

General Overview: Policies and Infrastructure

1. How does the TANF Lead Agency define improper payments?

The Department of Public Welfare (DPW) is the TANF Lead Agency. The Department does not have a codified definition of “improper payments” but does have various processes in place to identify overpayments, underpayments, and payments to persons who are ineligible or payments for services for which a recipient was not eligible or did not receive. Various Offices in the Commonwealth have responsibility for fiscal auditing and monitoring of TANF-funded programs – not all located within the Department of Public Welfare. Each of these entities has published Laws or Regulations that govern their procedures with defined terms.

The Auditor General, State Inspector General and the Comptroller are not within the Lead Agency (DPW).

· The Auditor General has responsibility to conduct audits of randomly selected cases in the County Assistance Offices. An improper payment is called an “Exception—A finding by an auditor of an action or process which is not in accord with the rules and regulations of the Department. It may be a discrepancy of either omission or commission.” Refer to the Pennsylvania Code Title 55, Chapter 109. Pennsylvania Code. The Auditor General also performs the Single Audit for the Commonwealth.

· The State Inspector General handles restitution – policy and procedures are published in the PA Code Title 55 Chapter 255: Pennsylvania Code

· The Comptroller has additional responsibility for identifying improper payments.

Within DPW, the Office of Child Development, the Office of Income Maintenance and the Office of Administration have various responsibilities for improper payments.

In general, an overpayment occurs when a budget group receives assistance for which it is ineligible; and underpayment occurs when a budget group receives less assistance than it was eligible to receive. Refer to § 183.121, Incorrect Payments: 055 Pa. Code § 183.121. Incorrect payments.</B>

and the Supplemental Handbook 910.2, When Does an Overpayment Exist:

http://www.dpw.state.pa.us/oimpolicymanuals/manuals/bop/supp/910/910-01.htm#P367_5436

Individuals have a right to receive corrective payments when they have been underpaid due to agency error or delay. Corrective or delayed payments are issued consistent with requirements and timeframes outlined in. CHAPTER 181 - DELAYED AND CORRECTIVE PAYMENTS and in 55 PA Code 175.23(b)(1)(iii) Pennsylvania Code and 227.24 (d)(1)(ii)(A) and (B) Pennsylvania Code.

· The Bureau of Program Evaluation, Division of Quality Control identifies ineligible payments, overpayments and underpayments – called “findings.” A Quality Control review will result in one of four “findings” – that the payment for the month was:

· Correct

· To an ineligible individual or household

· An Overpayment

· An Underpayment

· The Office of Child Development defines overpayments and underpayments for child care.

o TANF childcare overpayments are defined as:

An advance payment for child care when the TANF client does not receive child care services during the period the payment covers.

A child care allowance paid to a TANF recipient who is later determined ineligible for the allowance. In the event that a recipient is found ineligible for a child care allowance, the overpayment is only for that portion of the allowance for which the recipient was determined ineligible. The overpayment is submitted against the client and not the provider.

A child care payment made to a provider through OIM Direct Pay covering a period for which the provider did not charge or the provider was not entitled to payment.

o TANF childcare underpayments or corrective payments are defined in the Cash Assistance Handbook, Chapter 181 Delayed and Corrective Payments – the same as other TANF corrective payments noted above.

· The Office of Administration – Bureau of Financial Operations – performs internal audits to determine payment or program accuracy (including contractors) as requested by various DPW Offices. Overpayments are referred to the Office of Inspector General (OIG) for restitution. See responses to questions 14, 15 and 16.

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.

Note: The Auditor General does not appear on the chart below but has audit responsibilities for TANF expenditures including, but not limited to, the Single Audit.

PA_org_chart

Web Link to Organizational Chart: http://www.oa.state.pa.us/oac/lib/oac/Org_Charts/dpw.pdf

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 – the Comptroller has responsibility: As funds are recovered the Federal Financial Participation is computed and accounted for appropriately in the state accounting system (SAP) and reported on the CMS 64. The recovered funds are added to the appropriation’s available balance and become available for future claims.

x Sources of funding for addressing improper payments: For both SFY 05-06 and 06-07, the Office of Inspector General is funded $1.5 million from the TANF Block Grant to address improper payments.

Other (please specify : )

Identification and Assessment of Improper Payments

Has your State performed an assessment or analysis to determine whether the program is at risk of improper payments?

X 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.)

X a. Monthly cash assistance payments

X 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 assistance

X c. Other types of benefits and services for families not receiving cash assistance

X d. Payments to service providers

q e. Other (Please specify:)

Please describe your process for identifying and handling improper payments.

County Assistance Office staff are initially responsible to identify and correct underpayments and to identify overpayments and refer them to the Office of Inspector General (OIG) for collection or prosecution, if fraud is determined. Overpayments and underpayments may also be identified through regular or special supervisory case reviews or monitoring by CAO management. These reviews and monitoring processes are conducted to assure quality and program accuracy. Many CAOs have Corrective Action Plans in place in response to findings from various oversight entities such as Quality Control, Bureau of Financial Operations, the Comptroller and/or the Auditor General. Caseworkers can refer cases to “front-end” staff from the Office of the Inspector General for further investigation if the application information is questionable and needs further development.

The Quality Control process (including CAO reviews and corrective action plans) is the most comprehensive system in place to identify errors and calculate a payment error rate. The Quality Control (QC) Division conducts independent case record reviews to determine program eligibility and benefit accuracy.

· The records are selected by a random sampling procedure, which is valid statistically to ensure that the review is representative of a statewide caseload.

· QC secures all necessary verification for non-financial and financial eligibility criteria to determine program eligibility and payment amount for the review month. If there is a discrepancy for more than $25.00 between the results of the QC review and the County Assistance Office (CAO), an error exists. QC determines if the client or the agency caused the error. QC notifies the CAO in the form of a memo of its findings for each case determined to be in error.

· Follow-up includes a rebuttal process, if requested by the CAO, analysis of errors, development of Corrective Action Plans and referring identified overpayments to the Office of Inspector General for collection or fraud determination and prosecution.

· Results of the QC reviews are published statewide to the CAOs and are used by headquarters and management to monitor CAO performance and analyzed to inform policy decision-making and address identified policy or systems issues.

In addition to the CAO internal and external reviews, DPW headquarters staff routinely monitor and measure quality of service and payment accuracy for child care and employment and training services for TANF clients. Improper payments for these services may be withheld or collected from the providers.

Department audit procedures are published each year and are located on the DPW website: Audits.

Child care audit procedures are also located on the website:

Child Care Information Services Agency (CCIS) Audit Guidelines - Fiscal Year 2004-2005.

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:

X Findings from the state’s Single Audit - a calculated error rate is reported to the state as a result of various parts of the Single Audit conducted by the Auditor General.

X Other audit findings from state auditors – calculated for individual County Assistance Offices by Auditor General.

qFindings from other state or local auditors, including legislative review entities

X Findings from state or local fraud units (Please specify :) - Office of Inspector General

X Reviews of service providers and/or contractors

X Reviews of sampled cases, although not statistically representative of all program payments

X Statistically representative sample of payments – Quality Control

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.)

X Yes. Please describe the methodology used to arrive at the error rate.

Quality Control determines a Payment Error Rate as the total of error dollars identified by QC for the program divided by the total dollars of benefits received in the program for the Federal Fiscal Year.

Describing Improper Payments: Sources, Types, Causes

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.)

This ranking is for Overpayments only - based on data on Overpayments, Prosecutions and Recoveries from the Office of the Inspector General (OIG). Underpayments are not referred to the OIG and are not considered in this ranking:

_1_ Client error

_4_ Provider error

_3_ Agency error

_2_ Client fraud

_5_ Provider fraud

_6_ Agency fraud

__ Other (Please specify)_________________________

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.

For the Quality Control Reviews –

FFY 2005 – 80% Overpayments - 20% Underpayments

FFY 2004 – 86% Overpayments - 14% Underpayments

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	Moderate extent	Little extent	No extent
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	X
g. Other (Please specify): Bank accounts, stocks and bonds, non-resident property, vehicles, administrative error, and system error		X
Related to providers
h. Overstating performance
i. Claiming for services not rendered
j. Other (Please specify):

Prevention of Improper Payments

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.)

· Comprehensive training for all levels of Department staff and contractors.

· Development and maintenance of clear policy and procedures with automated systems to support benefit calculation and accurate decision making and access to decision makers for clarification and guidance when there are questions or issues.

· Routine quality and fiscal audits of CAOs and providers.

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, and upon receipt of new information	Pre-approval, redetermination, At least every 6 months, and receipt of new information
b. Fingerprint clients	q Yes X No
c. Access online databases	X Yes q No	Pre-approval and redetermination	Pre-approval and redetermination receipt of new information	X
d. Match automated computer files	X Yes q No	Pre-approval, redetermination, and upon receipt of new information	Pre-approval, redetermination, and receipt of new information
e. Conduct telephone, fax, or email contacts	X Yes q No	Pre-approval, redetermination, and upon receipt of new information	Pre-approval, redetermination, and receipt of new information	X
f. Conduct home visits	X Yes q No	Home visits can be done to assist in the initial evaluation	Only as warranted
g. Initiate a fraud investigation if warranted	X Yes q No	As warranted Referrals can be made at application, reapplication, or CAO Activity	As needed
h. Conduct program integrity/quality control review	X Yes q No	QC – Monthly Statistically Valid Random Sample E&T - For vendors, fiscal reporting is reviewed monthly. Programmatic performance is reviewed at least annually for each contractor.	QC - Monthly E&T - Monthly and Annually
i. Other (Please specify :) AG – CAO Performance Audits	X Yes q No	AG - Depends on county size – Large Counties Annually	AG - Depends on county size – Large Counties Annually
CAO Supervisory Reviews	X Yes q No	Varies – may be pre-approval or post-approval	Routine or as needed	X
Bureau of Financial Operations	X Yes q No	Audits of provider or program as requested by DPW	Ad Hoc
DPW Comptroller	X Yes q No	System audits of TANF payments	Routine quarterly

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	Pre-approval, redetermination, and upon receipt of new information	Pre-approval, redetermination, and receipt of new information
b. Other human services programs in your agency/State	X Yes q No	Pre-approval, redetermination,	Pre-approval, redetermination
c. State department of labor or employment security	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination and receipt of new information	X
d. State directory of new hires	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination and receipt of new Information
e. State department of motor vehicles	X Yes q No	QC - Authorization, redetermination, and receipt of new information	QC - Authorization, redetermination, and receipt of new information
f. Public Assistance Reporting Information System (PARIS)	X Yes q No	Pre approval, redetermination, and receipt of new information	PARIS Information Posted Quarterly
g. State data (from other States) on length of TANF receipt	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
h. State data (from other States) on potential concurrent TANF receipt	X Yes q No	Pre-approval, redetermination	Pre-approval, redetermination PARIS posted Quarterly
i. State data (from other States) on client or provider debarment from benefits, for fraud or other infraction	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination and receipt of new information
j. Lottery agencies	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
k. Prisons and criminal justice agencies at State level	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
l. National Criminal Information Center (NCIC)	qYes X No
m. Local jails	X Yesq No	Pre-approval, redetermination, and upon receipt of new information	Pre-approval, redetermination, and receipt of new information
n. Credit bureaus	q Yes X No
o. Financial institutions	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
p. State tax intercepts	X Yes q No	Authorization, redetermination, and receipt of new information E&T - For vendors, contracts cannot be executed unless the vendor is in compliance with state tax payments.	Authorization, redetermination, and receipt of new information E&T - processing of vendor contracts.
q. Immigration authorities	X Yes q No	Pre-approval Questionable Information only	Once
r. K-12 school systems	X Yes qNo	Pre-approval, redetermination, and receipt of new information ages 16 and above	Pre-approval, redetermination, and receipt of new information ages 16 and above
s. Community colleges	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
t. Other providers of services, education, training	X Yes q No	As needed Contractors provide monthly data interface	As needed Contractors provide monthly data interface
u. Child support	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information	X
v. Social Security Administration (SSA) form W-2 (wage statements)	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information	X
w. SSA Social Security number verification	X Yes q No	Pre-approval, redetermination, and upon receipt of new information	Pre-approval, redetermination, and receipt of new information
x. SSA Supplemental Security Income (SSI) data	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
y. SSI death information	X Yes q No	Pre-approval, redetermination, and receipt of new information	Pre-approval, redetermination, and receipt of new information
z. Other (Please specify :) PA. Vital Statistics	X Yes q No	As Needed	As Needed

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 $3, 034,522.00 (Specify ending month/ year) 06/2005

X Includes fraudulent improper payments

Next most recently completed fiscal year $3,333,072.00 (Specify ending month/ year) 06/2004

X Includes fraudulent improper payments

15. What penalties does your program mandate for clients, agencies, or providers, who commit an error leading to improper payments?

The Office of the Inspector General (OIG) handles restitution and disqualification. The policy is codified in 55 PA Code, Chapter 255. Overpayments are referred by the CAO to the OIG for processing. Forged or falsely endorsed checks are investigated by the Treasury Department and overpayments are referred to the OIG.

Overpayments are handled according to the following procedures:

“(b) The general restitution policy of the Department will be as follows:

(1) The course of action of the Department in respect to overpayments will be directly related to the cause or reason underlying the client’s receipt of assistance for which the client was not eligible. When the overpayment appears due to fraud, the Public Welfare Code (62 P. S. § § 101—1412) will set the course of action to be taken.

(2) The decision as to whether or not fraud is suspected will be an administrative decision which will place on the Department the responsibility of distinguishing between overpayments due to fraud, and those due to error. To carry out this responsibility, the Department has developed certain objective criteria which will be used in deciding the appropriate action for an overpayment.

……

(c) In addition to being subject to other civil or criminal penalties, a…recipient who has been found by a Federal or State court or by the Department, following an administrative disqualification hearing…to have committed am intentional program violation shall be disqualified from receiving Cash Assistance for 6 months for the first offense, 12 months for the second offense and permanently for the third offense. The Department will not take the disqualified individual’s needs into account when determining the budget group’s need for and amount of assistance. The Department will consider available to the budget group countable income and resources of the disqualified individual.

(f) If the individual is eligible for benefits under the program in which the intentional program violation occurred, the Department will impose the disqualification within 45 days of the date of the finding of the court, administrative disqualification hearing final order or signing of a consent agreement or waiver of administrative disqualification hearing …If the individual, …is not eligible…, the Department will impose the disqualification effective on the date of the finding of the court, administrative disqualification hearing final order or signing of a consent agreement or waiver of administrative disqualification hearing. Once the Department imposes the disqualification, the disqualification period shall continue uninterrupted.”

http://www.pacode.com/secure/data/055/chapter255/s255.1.html

Providers: The DPW developed penalties for providers of Employment and Training Services, which vary depending upon the circumstances associated with errors and are included in the terms of the contract agreements. Vendors could be required to accept training and technical assistance. They could also be required to submit a corrective action plan. In cases of fraud, the vendor’s contract would be canceled in addition to seeking repayment.

Fraud: Intentional Overpayments

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

Pennsylvania defines fraud in the PA Code as follows: http://www.pacode.com/secure/data/055/chapter255/s255.2.html

“The following words and terms, when used in this section and § § 255.1, 255.3, 255.4 and 255.71, have the following meanings, unless the context clearly indicates otherwise:

Found by a State or Federal court—The term includes one of the following:

Intentional program violation—An action by an individual applying for or receiving AFDC or GA for himself or others for the purpose of establishing or maintaining his own, his household’s or his family’s eligibility for AFDC or GA or for the purpose of increasing or preventing a reduction in the amount of the grant, which involves one of the following:

(i) An intentionally made false or misleading statement or misrepresentation or concealment or withholding of a fact.

(ii) An act intended to mislead, misrepresent, conceal or withhold a fact or propound a falsity.

Overpayments—Classified either as suspected fraud, or as nonfraud will be made by relating the case facts nonfraud for purposes of administrative action. The decision as to whether or not the overpayment is suspected fraud will be made by relating the case facts to the following definitions and criteria.

(i) Causes of overpayment. There are two basic causes of overpayment: fraudulent misrepresentation by the client and error on the part of the agency or the client.

(ii) Fraud. Suspected if the overpayment was caused by what appears to be willful withholding of information on the part of the client.

(iii) Nonfraud. An overpayment resulting from the client’s misunderstanding of eligibility requirements or of his responsibility for providing the county office with information, from the innocent concealment of facts, or from county office omission or administrative error in securing or acting on information.

(iv) Suspicion of fraud. When a person is believed to have knowingly and deliberately withheld information or provided incorrect information to obtain assistance for which he would otherwise not be eligible, a suspicion of fraud will exist. Only the court will have jurisdiction to convict for fraud. Under the Public Welfare Code (62 P. S. § § 101—1503), obtaining, or aiding or abetting a person in obtaining assistance by means of a willfully false statement or misrepresentation, or by impersonation, or other fraudulent means, is a misdemeanor. A person convicted of fraud under this statute will be sentenced to make restitution of the money received by virtue of his fraudulent acts and, in addition, will be subject to fine or imprisonment.

(v) Willful withholding. The person had in fact been told by the CAO, knew and understood what was required and the consequences of any action or lack of action. It further means that noncompliance with known requirements was planned for the express purpose of getting assistance that would not otherwise have been granted.”

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

q 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 (not in DPW)

Does any other entity in your State maintain this information, such as a State fraud unit or Inspector General?

Yes - The Office of the Inspector General (OIG).

If yes, please provide us with a contact name and phone number:

Office of the Inspector General: http://www.oig.state.pa.us/inspgen/site/default.asp

Contact – C. Jeffrey Goble, Director of Special Investigations at 717-787-6835 - e-mail address cgoble@state.pa.us

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

Periodic training with staff at the County Assistance Office Level through Management Bureau Staff in Headquarters.
Maintenance of policy and procedures through the Cash Assistance Manual, “Using CIS” Manual, Operations Memoranda, and Policy Clarifications which are easily accessible on the Pennsylvania OIM Web Site.
Benefit security through Electronic Benefit Transfer (EBT) Cards requiring a client selected PIN Number and Client Photo ID for issuance.
Internal monitoring by the Bureau of Operations at the County Assistance Level.
County Assistance Office internal reviews through targeted and/or comprehensive case reviews (including the Case Accuracy Review Team in Philadelphia), and audits by the Auditor General Office.
The Bureau of Operation institutes and maintains security for the operation of all DPW computers and software to limit access to authorized individuals only. The systems are monitored to maintain the integrity of security to prevent fraud. Controls are in place at the County Assistance level for limited authorization for benefits issuance. Every action taken in the Client Information System (CIS) is tracked and available for audit.
Annual audits of the County Assistance Office and audits every three years of the Division of Quality Control are conducted by the Internal Revenue Service to ensure that IRS information is safeguarded.
Audits of the Division of Quality Control functions are conducted annually by the Auditor General as part of the Single Audit to ensure the integrity of the QC review.
Fiscal and Program monitoring for all providers.
Bureau of Employment and Training (BETP) Programs - For every program operated by contracted employment and training vendors, BETP issues written operational guidelines, which must be followed. BETP provides ongoing training to vendors to ensure their understanding of the rules. BETP also provides technical assistance to each vendor on site. Further, BETP conducts annual financial and fiscal monitoring.

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.)

X Yes ® Please provide a copy of the report(s), and indicate who received them. See Attached:

The attached Quality Control reports are routinely posted to an internal website and also provided to the Legislature, to the Governor’s Budget office, and to policy officials. The Department also publishes quality and payment accuracy information in the State Budget Measures and PeopleStat Reports (Program Outcome Reports. The internal website information is available to the Department and other authorized Users.

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.

Pennsylvania Code web site - http://pacode.com/

Handbooks and Manuals - http://www.dpw.state.pa.us/General/003671714.htm

Thank you very much for your time and assistance!

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

Pennsylvania (TANF Ten Year Trend Report - period: October 1994 to September 2004 (PDF)

Pennsylvania (TANF Early Error Indentification Report - period: October 1999 to September 2004 (PDF)

Related to clients

Related to providers