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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:

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

Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? a minimum of 1 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:

If the investigation determines that fraudulent activity did indeed occur, then the following steps may follow depending upon the time of discovery: a. If it is determined that it appears that false information was provided during the application process, the applicant file must be denied and the client notified in writing. b. If it is determined that the client received benefits based on false information provided by the client, it is considered an overpayment. The Subgrantee should attempt to recapture the funds and the client must be given an opportunity to repay the funds in question by either reimbursement to the Subgrantee/Grantee or recoupment from the Utility Vendor. If the client makes contact with the Subgrantee, payment arrangements may be discussed and formalized per the Subgrantee's policy. The Subgrantee should track all payments and notify the client when the obligation has been met. Once every attempt has been made to contact and work with the client for recovery of overpayments and the client has been unresponsive or uncooperative, the information should be turned over to local law enforcement. The Subgrantee should continue to work with the prosecuting officials, and the Subgrantee can, if requested, receive and track repayments from the client. All repayments must be returned to the Grantee. The Subgrantee must contact Grantee and keep staff informed as to the progress of the investigation, the disposition, and if any funds will be returned.

If any of the above questions require further explanation or clarification that could not be made in Page 41 of 55