17 Program Integrity, 2605(b)(10)

17.1 Fraud Reporting Mechanisms a. Describe all mechanisms available to the public for reporting cases of suspected waste, fraud, and abuse. Select all that apply. Online Fraud Reporting Dedicated Fraud Reporting Hotline Report directly to local agency/district office or Grant recipient office Report to State Inspector General or Attorney General Forms and procedures in place for local agencies/district offices and vendors to report fraud, waste, and abuse Other - Describe: The Division of Public Assistance (DPA) provides several clear and accessible mechanisms for the public to report suspected cases of waste, fraud, and abuse. Individuals can report concerns directly through DPA’s public website or by contacting the virtual call center. DPA includes guidance on how to identify and report fraud on its website. DPA also educates all LIHEAP vendors on fraud prevention and reporting procedures through the LIHEAP Vendor Manual. DPA distributes the manual to all vendors when it approves or renews their vendor agreements. The manual includes detailed instructions on how vendors can recognize and report fraudulent activity. b. Describe strategies in place for advertising the above-referenced resources. Select all that apply Printed outreach materials Posted in local administering agencies offices. Addressed on LIHEAP application Website Other - Describe: •Fraud brochure – available in all local public assistance lobbies and on the Alaska DPA website. •Heating Assistance application - Fraud is discussed in the "Rights and Responsibilities" section of the application. • Award notices issued to recipients informing them it is illegal to trade, sell or barter their fuel paid for with heating assistance funds. • Fraud training is held annually with AHFC and our weatherization partners. This training reviews how to identify and report any applicant they feel may be committing fraud. The training also reminds AHFC accounting staff to identify and address any fraudulent activity committed by their subcontractors (if any). 17.2. Identification Documentation Requirements a. Indicate which of the following forms of identification are required or requested to be collected from LIHEAP applicants or their household members. Collected from Whom? Type of Identification Collected Applicant Only All Adults in Household All Household Members Required Required Required Social Security Card is photocopied and retained Requested Requested Requested Social Security Number (Without Required Required Required actual Card) Requested Requested Requested Required Required Required Government-issued identification card (i.e.: driver's license, state ID, Tribal ID, passport, etc.) Requested Requested Requested Other Applicant Only Required Applicant Only Requested All Adults in Household Required All Adults in Household Requested All Household Members Required All Household Members Requested 1 17.3. Citizenship/Legal Residency Verification What are your procedures for ensuring LIHEAP recipients are U.S. citizens or qualified non-citizens who are eligible to receive LIHEAP benefits? Select all that apply. Clients sign an attestation of citizenship or U.S. Citizen or Qualified Non-Citizen Client's submission of certain Social Security Administration cards is accepted as proof of U.S. Citizen or Qualified Non-Citizen. Non-Citizens must provide documentation of immigration status Citizens must provide a copy of their birth certificate, naturalization papers, or passport Non-Citizens are verified through the SAVE system Tribal members are verified through Tribal enrollment records/Tribal ID card Other - Describe: The State has established procedures to ensure that all LIHEAP recipients are U.S. citizens or qualified non-citizens who are eligible to receive LIHEAP benefits. To verify citizenship or legal residency, the State matches applicants’ Social Security Numbers with existing records in the state’s eligibility or case management systems, such as those used for the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF). The State also conducts data matching with the state Department of Labor systems to further validate identity and legal status. In addition, the State verifies immigration status through the Instant Eligibility Verification System (IEVS), which is aligned with the Systematic Alien Verification for Entitlements (SAVE) program administered by the United States Citizenship and Immigration Services (USCIS). These integrated verification processes ensure that only individuals who meet the federal citizenship or qualified non-citizen criteria are approved for LIHEAP benefits, in accordance with applicable laws and regulations. 17.4. Income Verification What methods does your agency utilize to verify household income? Select all that apply. Require documentation of income for all adult household members Pay stubs Social Security award letters Bank statements Tax statements Zero-income statements Unemployment Insurance letters Other - Describe: Computer data matches: Income information matched against state computer system (e.g., SNAP, TANF) Proof of unemployment benefits verified with state Department of Labor Social Security income verified with SSA Utilize state directory of new hires Other - Describe: Instant Eligibility Verification System (IEVS) b. Describe any exceptions to the above policies. 17.5 Identification Verification Describe what methods are used to verify the authenticity of identification documents provided by clients or household members. Select all that apply Verify SSNs with Social Security Administration Match SSNs with death records from Social Security Administration or state agency Match SSNs with state eligibility/case management system (e.g., SNAP, TANF) Match with state Department of Labor system Match with state and/or federal corrections system Match with state child support system Verification using private software (e.g., The Work Number) In-person certification by staff (for tribal Grant recipients only) Match SSN/Tribal ID number with tribal database or enrollment records (for tribal Grant recipients only) Other - Describe: Instant Eligibility Verification System (IEVS) 17.6. Protection of Privacy and Confidentiality Describe the financial and operating controls in place to protect client information against improper use or disclosure. Select all that apply. Policy in place prohibiting release of information without written consent Grant recipient LIHEAP database includes privacy/confidentiality safeguards Employee training on confidentiality for: Grant recipient employees Local agencies/district offices Employees must sign confidentiality agreement Grant recipient employees Local agencies/district offices Physical files are stored in a secure location Electronic files are protected in a secure location. Other - Describe: Approved vendor office employees who work with LIHEAP customers sign a confidentiality agreement. The vendors keep these signed agreements on file and make them available to the State of Alaska upon request. 17.7. Verifying the Authenticity What policies are in place for verifying vendor authenticity? Select all that apply. All vendors must register with the State/Tribe. All vendors must supply a valid SSN or TIN/W-9 form Vendors are verified through energy bills provided by the household Grant recipient and/or local agencies/district offices perform physical monitoring of vendors Other - Describe and note any exceptions to policies above: Vendors requesting to participate as an approved LIHEAP vendor are screened for complaints through the Better Business Bureau. • Vendors are required to establish and maintain an active vendor account in the Alaska Department of Administration, Division of Finance’s financial/procurement system, IRIS. • Clients whose primary heating fuel is self-harvest firewood, purchased firewood, or wood pellets are not required to use an approved vendor. Due to supply and variations in quality and quantity, firewood and pellet clients have greater success in obtaining quality producst when all suppliers in the market are accessible to them. A direct payment is issued to the client if they claim self-harvested firewood, purchased firewood, or wood pellets as their primary heating fuel. • 17.8. Benefits Policy - Gas and Electric Utilities What policies are in place to protect against fraud when making benefit payments to gas and electric utilities on behalf of clients? Select all that apply. Applicants required to submit proof of physical residency Applicants must submit current utility bill Data exchange with utilities that verifies: Account ownership Consumption Balances Payment history Account is properly credited with benefit Other - Describe: Centralized computer system/database tracks payments to all utilities Centralized computer system automatically generates benefit level Separation of duties between intake and payment approval Payments coordinated among other energy assistance programs to avoid duplication of payments Payments to utilities and invoices from utilities are reviewed for accuracy Computer databases are periodically reviewed to verify accuracy and timeliness of payments made to utilities Direct payment to households are made in limited cases only Procedures are in place to require prompt refunds from utilities in cases of account closure Vendor agreements specify requirements selected above, and provide enforcement mechanism Other - Describe: 17.9. Benefits Policy - Bulk Fuel Vendors What procedures are in place for averting fraud and improper payments when dealing with bulk fuel suppliers of heating oil, propane, wood, and other bulk fuel vendors? Select all that apply. Vendors are checked against an approved vendors list Centralized computer system/database is used to track payments to all vendors Clients are relied on for reports of non-delivery or partial delivery Two-party checks are issued naming client and vendor Direct payment to households are made in limited cases only Vendors are only paid once they provide a delivery receipt signed by the client Conduct monitoring of bulk fuel vendors Bulk fuel vendors are required to submit reports to the grant recipient. Vendor agreements specify requirements selected above, and provide enforcement mechanism Other - Describe: Benefits are paid directly to clients whose primary heating fuel is self-harvested wood, purchased firewood, or wood pellets. 17.10. Investigations and Prosecutions Describe the Grant recipients procedures for investigating and prosecuting reports of fraud, and any sanctions placed on clients, staff, or vendors found to have committed fraud. Select all that apply. Refer to state Inspector General Refer to local prosecutor or state Attorney General Refer to US DHHS Inspector General (including referral to OIG hotline) Local agencies/district offices or Grant recipient conduct investigation of fraud complaints from public Grant recipient attempts collection of improper payments. If so, describe the recoupment process When a client provides inaccurate information that results in an improper or overpayment, the Division of Public Assistance (DPA) sends a letter requesting full repayment of the overpaid amount. If the client cannot pay the full amount, the office instructs the client to call and establish a repayment schedule. If the client fails to follow through, the office reduces the client’s benefit in the following program year by the amount owed to the program. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? Contracts with local agencies require that employees found to have committed fraud are reprimanded and/or terminated Vendors found to have committed fraud may no longer participate in LIHEAP Other - Describe: If any of the above questions require further explanation or clarification that could not be made in the fields provided, attach a document with said explanation here.