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: A dedicated fraud reporting hotline is in place for statewide fraud abuse and is not specific to LIHEAP. 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: N/A 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 Required Required Required Social Security Number (Without 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: ADES offers a variety of methods for identity verification depending on the applicant’s individual needs and preferences. The web- based portal is the most efficient method of application and requires an applicant to verify their identity through ID.me, a third-party digital identification tool, prior to completing an application. Alternative identity verification methods are available for applicants who do not wish to apply through the portal. All methods require a Government-issued identification card. 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: Clients must provide verification for unearned income. ADES requires documentation of income for all household members age 18 and above. ADES may, at their discretion, accept a participant statement as verification for income when the client has attempted but is unable to provide the verification, no other sources of verification are available, and agency staff has attempted to assist in obtaining the verification on behalf of the client. 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: N/A b. Describe any exceptions to the above policies. N/A 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: The Department has integrated an online identity verification service using ID.me. Applicants will be required to verify their identities using this tool. 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: N/A 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: ADES plans to have a Utility Vendor Agreement in place shortly and have Memorandum of Understandings (for Data Sharing) with the major utility vendors. 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: N/A 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: Some CAAs utilize computer databases to periodically review and verify accuracy and timeliness of payments made to utilities. There are also requirements in place to ensure the client has not received a duplication of benefits and hasn’t received LIHEAP in the last 12 months. Employees will monitor payments of funds to Clients to ensure that payments are in compliance with applicable guidance and do not exceed that to which the Client is entitled. Any payment of funds that exceeds the amount to which the Client is lawfully entitled (Overpayments)are recovered by the Grantee pursuant to either (1) recall procedures established by contractual agreement with vendors and/or third-parties, or (2) collections procedures by the ADES Office of Accounts Receivable (OARC) for Overpayments made to Clients and all other Overpayments. Regardless of the cause of Overpayment, the Client is liable for the amount of the Overpayment and subject to recovery of funds. All Overpayments will be processed for recovery, except those limited Overpayments which qualify for waiver. 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: ADES directly pays vendors and keeps accounting records, which are monitored to avert fraud and improper payments. 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 Employees will monitor payments of funds to Clients to ensure that payments are in compliance with applicable guidance and do not exceed that to which the Client is entitled. Any payment of funds that exceeds the amount to which the Client is lawfully entitled (Overpayments) are recovered by the Grantee pursuant to either (1) recall procedures established by contractual agreement with vendors and/or third-parties, or (2) collections procedures by the DES Office of Accounts Receivable (OARC) for Overpayments made to Clients and all other payments. Regardless of the cause of an Overpayment, the Client is liable for the amount of the Overpayment and subject to recovery of funds. All Overpayments will be processed for recovery, except those limited Overpayments which qualify for waiver. In instances of Overpayment involving investigative or judicial findings that fraud was committed, Overpayment processing will be initiated, and Client will be subject to an administrative disqualification action. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? 12-month disqualification for 1st violation. 24-month disqualification for 2nd violation. Permanent disqualification for 3rd violation. 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: 12-month disqualification for 1st violation. 24-month disqualification for 2nd violation. Permanent disqualification for 3rd violation. Clients who are suspected to have intentionally committed fraud will be provided notice of an Administrative Disqualification Hearing to determine whether the Client did commit fraud. Clients will be informed of their right to attend the hearing to contest the allegation, or waive the hearing. A finding against the Client at the Administrative Disqualification Hearing, or waiver of the Hearing, will result in disqualification. Administrative Disqualification Hearings will be conducted by the ADES Office of Appeals in accordance with Fair Hearing requirements (see Section 12). 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.