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: 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: The LIHEAP contract between Missouri Department of Social Services (DSS) and LIHEAP contractors has an entire section title “Fraud and/or abuse” .The LIHEAP supplier Agreement between DSS and Home Energy Suppliers contain an entire section titled “Fraud prevention and Reporting” which advises the Energy Supplier how to report suspected issues of fraud as well as making the Energy Supplier aware of the consequences they would face if they concealed any confidential information at their disposal. The LIHEAP Policy and Procedures Manual includes information regarding Reporting LIHEAP Fraud and Reporting Department of Social Services Fraud to Other programs. 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: The State of Missouri’s current eligibility system, FAMIS contains application information from the Food Stamp Program and may also be used to verify whether a household’s member is considered a legal permanent Resident or whether they are excluded from the Food Stamp case for reason, “Citizenship”. 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: Household income is verified by: Verbal verification from a current or past employer. (Verification must be documented in the case file.) Employee wage document report. Statement from employer with current date. Income maintenance payroll information. Copy of benefit check. Child Support Payment records. Contracts: Signed and dated statement from tenant or cancelled checks. 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: 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: 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: State policies to protect client information: Logging off the system prior to leaving workstation. Paying attention to who can see your computer screens and what information is being displayed. Use Departmental Client Numbers (DCN) instead of SSN for emails or any internet transmission. Encryption is required when any email is sent which contains confidential information. Never share passwords. Shredding confidential information that is being discarded. Safe at Home (SAH) program available through the Secretary of State’s Office for survivors of sexual assault, rape, stalking, and domestic violence. SAH provides an assigned address for mail. This mail is then sent to the member(s) from the Secretary of State’s Office. Confidential information provided only to those household Members. Information may be released to a limited amount of people such as State Legislators, Personal Representatives or Advocates. In addition to the above the LIHEAP systems and reports masks SSN's by only allowing the last four (4) of the SSN to be visible at any given time on each LIHEAP screen. A Release of Information form to be signed by the applicant is required before any information is released to any requesting party. LIHEAP agency contracts include Information Security Management Requirements. 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: Policies/process for vendor authenticity: The DSS Home Energy Supplier Agreement contains an entire section titled, “Debarment Certification” which certifies that the Supplier is not presently debarred, suspended, proposed for debarment, declared ineligible, voluntarily excluded from participation, or otherwise excluded from or ineligible for participation under federal assistance programs. The DSS Home Energy Supplier Agreement, Business Compliance states, "The provider must complete and submit Exhibit #3 Registration of Business Name (if applicable) with the Missouri Secretary of State, prior to award of contract. "The vendor may access this information at http://www.sos.mo.gov/ records (Select Business Services, then Business Search from the drop-down box). 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: To protect against fraud, the LIHEAP Eligibility Energy Assistance (EA) System includes online transactions to standardize addresses with United States Postal Service verification program Code One Plus to prevent duplicate addresses from receiving more than one EA payment for the same household for a different fuel source. In addition, staff are not allowed to proceed with application processing until they determine that a duplicate address issue does not exist. If the case does not have a duplicate address issue, the manager may override the system and provide an explanation in the LIHEAP Case Notes (E1CN) screen. 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: 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 For potential client fraud, notification is sent to the clients of overpayments. The client has ninety (90) days to either sign a repayment agreement or request a hearing. If FSD receives no response, the overpayment is entered into the Claims and Restitution System (CARS). The amount is added to the computer system and an offset is set up against any future Energy Assistance (EA) payments. For agencies or employees that commit fraud, the FSD and DSS Welfare Investigator will conduct onsite and case review monitoring and interviews to determine if victims need to be referred to their local prosecuting attorney. The onsite monitoring may reveal systemic agency issues that need to be corrected. Claims of home energy supplier fraud are referred to state Attorney General Office Consumer Protection hotline. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? 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 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.