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: Report to the State LIHEAP office. 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: 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 The SSN is required as a 9-digit identifier in the LIHEAP.net database to avoid overpayments to customers via duplicate benefits. The first "request" for proof of SSN is the card, thus "Requested" is selected. The SSN (with or without) the card is "Required", since the SSN may be verified in ways other than the SSN card. 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: 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: The State LIHEAP office has an interagency agreement with the Illinois Department of Employment Security (IEA) to assist with income verification. The State utilized the income verification on households applying for the Furnace Assistance Program. In addition, the State LIHEAP office has an interagency agreement with the Illinois Department of Human Services (DHS) for investigative and eligibility verification process such as: 1-identify fraudulent use of SSNs through comparison, 2-investigative intake staff error and make the appropriate correction and determine if errors exist by comparing household's information between DHS and the Illinois LIHEAP database "LIHEAP.net". 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: The State LIHEAP office has interagency agreements with the Illinois Department of Human Services (IDHS) and the Illinois Department of Employment Security (IDES) to assist with income verification. The State utilizes income verification on households applying for the Furnace Assistance Program. The State also assists the Local LIHEAP agencies with income verification when requested and when the data is available. 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: The State LIHEAP office has an interagency agreement with the Illinois Department of Human Services (DHS) for investigative and eligibility verification process such as: 1-identify fraudulent use of SSNs through comparison, 2-investigate intake staff error and make the appropriate correction and determine if errors exist by comparing household's information between DHS and the Illinois LIHEAP database "LIHEAP.net". In addition, the State LIHEAP office has an interagency agreement with the Illinois Department of Employment Security to assist with income verification. The LIHEAP.net database system tracks and retains all household membership information. The system does not allow duplication in any program year for a specific household member to be entered as a new application. In addition, duplicate benefits are prevented at both an individual member and vendor/account number combination level. 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: 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: 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: All new regulated and unregulated vendors must first provide a Federal Employer Identification (FEIN) and must sign a vendor agreement. A list of these vendors is provided to each agency. LIHEAP.net (State LIHEAP database) verifies the utility FEIN through regular verification transactions. At intake, documentation required for the program is the most current utility/energy bill where the applicant's address is listed. Agencies are required to enter the application data in real time. The vendors confirm the applicant's service address through the LIHEAP.net system. Verifiers at the LAA verify the data that has been entered in the system and compares it against the documentation provided by the customer. Every approved LIHEAP customer receives an approval letter indicating the benefit amount that will be applied to the energy provider(s). 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 Once it is determined that improper payments have been made, the LAA must request refunds of the LIHEAP benefits from the energy vendor(s). If the energy vendor is unable to refund the payment, the State LIHEAP office will begin a recoupment process with the household. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? One Program Year 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: Based on sufficient evidence of fraudulent activity, the Department may sanction LIHEAP customers, including LAA staff, intake contractors, volunteers, and vendors. 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.