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SECTION 400 PROGRAM INTERGRITY
LIHEAP MANUAL JANUARY 2022 25
401.3 EMPLOYEE SEPARATION OF DUTIES
The Community Action Agency must maintain a separation of duties among employees who perform certain functions for the Low Income Home Energy Assistance Program. Separation of duties helps ensure that legitimate applications are created, keyed, approved and paid. At minimum, procedures must be in place to ensure that: • Intake Workers do not key applications, review reports for approval or sign checks for any applications they complete. • Data Entry Operators do not key applications, review reports for approval or sign checks for any applications that they complete. • LIHEAP Coordinators do not sign checks. • Staff should be cross trained to perform other duties during staff shortages or an increase in the number of applicants requesting assistance. 401.4 EMPLOYEE APPLICATIONS
The LIHEAP Coordinator or the Executive Director's approved designee must complete LIHEAP applications for employees. The Executive Director or approved designee must approve the application for the employee. Changes may be made to the employee application process with DHS approval. Employee applications must be filed separately in a secure location with access limited to the EAP coordinator and the Executive Director.