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?

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 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

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

q d.  Payments to service providers

q e.  Other (Please specify:) ________________________________________________________

q No.

 

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:

x 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 :)

Findings from state or local fraud units are from monthly and annual statistical reports.

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

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.)

q No 

q Information not available.

The Quality Assurance unit conducts reviews to measure the application of various policies which govern eligibility requirements for applicants and recipients of WV Works (TANF) benefits by DHHR staff. A statistically-reliable sample of TANF cases is selected each month. The results of these efforts provide a measure of the integrity in the TANF program. Improper payments in the TANF program are estimated by the ratio of improper payments discovered in the review process to the total payments authorized to the sampled cases.

 

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.)

___ Provider error

_1_ Agency error

_3_ Client fraud

___ Provider fraud

___ Agency fraud

___ Other (Please specify)_________________________

 

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, reviews and when changes are reported.	6-12 Months
b. Fingerprint clients	q Yes  x No		1
c. Access online databases	x Yes   q No	When system alerts are received. And at application, review and when changes are reported	Check alerts daily, review at report of change or review	x
d. Match automated computer files	x Yes   q No	When system alerts are received. And at application, review and when changes are reported	Check alerts daily, review at report of change or review	x
e. Conduct telephone, fax, or email contacts	x Yes   q No	When client needs help providing verification	As necessary
f. Conduct home visits	x Yes   q No	At application, at least yearly and when sanctions are imposed	At least yearly
g. Initiate a fraud investigation if warranted	x Yes   q No	When referrals are made	As necessary
h. Conduct program integrity/quality control review	x Yes   q No	Randomly selected cases by QA, Case reviews and application reviews by district supervisors	Monthly at district level & State QA reviews randomly selected cases from across the State	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.)

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 approval, redeterminations and when alerts appear through data exhanges	6 mo/ 12 mo rev & recerts. Daily system alerts
b. Other human services programs in your agency/State	x Yes   q No	When reported	As received
c. State department of labor or employment security	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges	6 mo/ 12 mo rev & recerts. Daily system alerts
d. State directory of new hires	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges	6 mo/ 12 mo rev & recerts. Daily system alerts
e. State department of motor vehicles	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges	6 mo/ 12 mo rev & recerts. Daily system alerts	x
f. Public Assistance Reporting Information System (PARIS)	x Yes   q No	Information has been matched with PA and MD,	Currently in infancy
g. State data (from other States) on length of TANF receipt	x Yes   q No	No date exchange, but the Worker contacts other states	At application
h. State data (from other States) on potential concurrent TANF receipt	x Yes   q No	No date exchange, but the Worker contacts other states	At application
i.  State data (from other States) on client or provider debarment from benefits, for fraud or other infraction	x Yes   q No	Received system’s alerts on IPVs	Daily
j. Lottery agencies	x Yes   q No	Workers review lottery reports	when published
k. Prisons and criminal justice agencies at State level	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges 6 mo/ 12 mo rev & recerts. Daily alerts	6 mo/ 12 mo rev & recerts. Daily alerts
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	q Yes   x No
q. Immigration authorities	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges 6 mo/ 12 mo rev & recerts. Daily alerts	6 mo/ 12 mo rev & recerts. Daily alerts
r. K-12 school systems	q Yes   x No	Although Workers contact local schools	Whenever needed
s. Community colleges	q Yes   x No	Although Workers contact local schools	Whenever needed
t. Other providers of services, education, training	q Yes   x No	Although Workers contact local schools	Whenever needed
u. Child support	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges 6 mo/ 12 mo rev & recerts. Daily alerts	6 mo/ 12 mo rev & recerts. Daily alerts	x
v. Social Security Administration (SSA) form W-2 (wage statements)	x Yes   q No	At approval, redeterminations and when alerts appear through data exhanges 6 mo/ 12 mo rev & recerts. Daily alerts	6 mo/ 12 mo rev & recerts. Daily alerts	x
w. SSA Social Security number verification	x Yes   q No	Through daily system alerts	When generat
x. SSA Supplemental Security Income (SSI) data	x Yes   q No	Through daily system alerts	When generat