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Section 12: Program Operations 12.1 Internal Operations and Controls This Intake and Operations Program Manual describes the LSP’s minimum requirements for administering LIHEAP but does not provide information about how such responsibilities are to be performed. As such, each LSP is expected to maintain its own internal policies and procedures regarding administration of LIHEAP. These written policies and procedures must ensure accurate client eligibility determination, benefit approval, and protection of the funds from fraud, waste, and abuse, particularly in cases where the policies presented in this manual provide flexibility. These policies and procedures are to be collected into a document referred to as Internal Operations and Controls. At a minimum, the Internal Operations and Controls document must outline the following: • LSP Operations o Addressing crisis in a timely manner o Confidentiality and security o Completing appointments, mail-in applications, and online applications o Procedures for processing transmittals o Handling of appeals o ERR procedures • Fraud, Waste, and Abuse o Identifying and handling conflicts of interest o Handling of applications by agency staff, board members, subcontractors, or relatives of such o Investigating fraud, waste, and abuse by an employee o Investigating noncompliance or fraud by an applicant o Actions to be taken upon substantiated fraud, waste, or abuse by an employee or an applicant Internal Operations and Controls will be submitted to IHCDA as part of the Subrecipient Plan Packet and reviewed. These procedures will also be reviewed during monitoring to ensure internal compliance. Internal Operations and Controls must be updated at least annually; however, all LSPs are strongly encouraged to review and update their Internal Operations and Controls regularly throughout the year to ensure that the document always reflects current practices and remains consistent and compatible with IHCDA- issued guidance. When taken together with the Intake and Operations Manual, the Internal Operations and Controls document should provide a clear picture of the agency’s EAP operations.