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: The Department of Health and Human Services has a fraud toll free hot-line and a website for individuals to report suspect fraud. The suspec reports are logged and researched to determine appropriate action. In addition, intentional program violations determined for Child Care Assistance, CHIP, Supplemental Nutrition Assistance and Temporary Assistance for Needy Families programs are reviewed to detemine if there is a LIHEAP c action needs to be taken on the LIHEAP case. 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: As part of the DHHS delivery system in North Dakota, LIHEAP has a visible presence in all 53 of the state’s counties (19 Human Service Z addition, DHHS has a toll-free fraud hot-line and an e-mail address on the website by which cases of suspected fraud can be reported at any time (w dhs). The Department has an active public information unit which publishes press releases which include the website address. A fraud log is used to document all calls and emails regarding possible fraud that are received from interested parties. The log is maintained administers and support staff. The log includes the issue complaint, the research and the finding which may or may not have been determined to be 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: DHHS' various interfaces are able to provide verification of citizenship, qualified noncitizens through SAVE as an interface and web service further information. 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: In addition, LIHEAP eligibility workers have access to additional information received through other major programs such as Numident thro Social Security verification system, IRS information on income and assets, and PARIS interface information. They may also access SAVE to determ alien status. In FY2022, LIHEAP became part of SPACES (Self-Service Portal and Consolidated Eligibility System). Medicaid, Child Care Assistance, S TANF are also included in SPACES. All individuals entered into SPACES go through a file clearance process that checks if the individual is already known to the system. When is known to the system, all prior applications and information are associated with that individual. In addition to the file clearance process, SPACES with the Social Security Administration (SSA). Search results from this interface provide verification of an individual’s social security number whe Additional interfaces such as ND Vital Records, Job Services of ND, ND Motor Vehicle and ND Game and Fish can also be used to verify identity. The following interfaces are included as part of SPACES to verify information needed to determine eligibility: Birth/Death records (ND Vital Records) • Health Insurance • ND Child Support • ND Department of Corrections • ND Motor Vehicle/Watercraft (ND Motor Vehicle/Game & Fish) • ND State Director of New Hire • ND State Hospital (Admission/Discharge) • ND Unemployment Insurance Benefits (Job Service) • Social Security Administration • SNAP Intentional Program Violations • WSI Medical Claims Status • Request UPA • Request 40 Quarters • Access to these interfaces is provided to workers based on their role (i.e., eligibility worker). LIHEAP also allows for other means of verification, such as hard copy verification from applicants or third parties, to support eligibility dete 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: In addition, LIHEAP eligibility workers have access to additional information received through other major programs such as Numident thro Social Security verification system, IRS information on income and assets, and PARIS interface information. They may also access SAVE to determ alien status. In FY2022, LIHEAP became part of SPACES (Self-Service Portal and Consolidated Eligibility System). Medicaid, Child Care Assistance, S TANF are also included in SPACES. All individuals entered into SPACES go through a file clearance process that checks if the individual is already known to the system. When is known to the system, all prior applications and information are associated with that individual. In addition to the file clearance process, SPACES with the Social Security Administration (SSA). Search results from this interface provide verification of an individual’s social security number whe Additional interfaces such as ND Vital Records, Job Services of ND, ND Motor Vehicle and ND Game and Fish can also be used to verify identity. The following interfaces are included as part of SPACES to verify information needed to determine eligibility: Birth/Death records (ND Vital Records) • Health Insurance • ND Child Support • ND Department of Corrections • ND Motor Vehicle/Watercraft (ND Motor Vehicle/Game & Fish) • ND State Director of New Hire • ND State Hospital (Admission/Discharge) • ND Unemployment Insurance Benefits (Job Service) • Social Security Administration • SNAP Intentional Program Violations • WSI Medical Claims Status • Request UPA • Request 40 Quarters • Access to these interfaces is provided to workers based on their role (i.e., eligibility worker). LIHEAP also allows for other means of verification, such as hard copy verification from applicants or third parties, to support eligibility dete 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: In addition, LIHEAP eligibility workers have access to additional information received through other major programs such as Numident thro Social Security verification system, IRS information on income and assets, and PARIS interface information. They may also access SAVE to determ alien status. In FY2022, LIHEAP became part of SPACES (Self-Service Portal and Consolidated Eligibility System). Medicaid, Child Care Assistance, S TANF are also included in SPACES. All individuals entered into SPACES go through a file clearance process that checks if the individual is already known to the system. When is known to the system, all prior applications and information are associated with that individual. In addition to the file clearance process, SPACES with the Social Security Administration (SSA). Search results from this interface provide verification of an individual’s social security number whe Additional interfaces such as ND Vital Records, Job Services of ND, ND Motor Vehicle and ND Game and Fish can also be used to verify identity. The following interfaces are included as part of SPACES to verify information needed to determine eligibility: Birth/Death records (ND Vital Records) • Health Insurance • ND Child Support • ND Department of Corrections • ND Motor Vehicle/Watercraft (ND Motor Vehicle/Game & Fish) • ND State Director of New Hire • ND State Hospital (Admission/Discharge) • ND Unemployment Insurance Benefits (Job Service) • Social Security Administration • SNAP Intentional Program Violations • WSI Medical Claims Status • Request UPA • Request 40 Quarters • Access to these interfaces is provided to workers based on their role (i.e., eligibility worker). LIHEAP also allows for other means of verification, such as hard copy verification from applicants or third parties, to support eligibility dete 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: DHHS took significant steps in safeguarding client’s privacy in 2011 with its SSN suppression initiative. All written communications being identify the client with a system-assigned “billing number” rather than a Social Security Number. This will continue ongoing. Economic Assistance Policy Division addresses safeguarding of client information in Administrative Procedural manual 448-01 which may North Dakota Department of Human Services website at https://www.nd.gov/dhs/policymanuals/44801/44801.htm The Economic Assistance Policy Division Administrative Procedural manual 448-01 is utilized to provide county eligibility workers with gu policy and procedures of client information. In addition, eligibility workers and Economic Assistance staff are required to take an online Safeguard training annually. The training includ information must be safeguarded and penalties for improper disclosure. 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: North Dakota's status as a rural state lends a generous hand to vendor authenticity. A majority of the vendors in the state are small 'mom and businesses that have been established in the communities for many years and, in many cases, generations. Vendors of fuels other than the four prima (natural gas, electricity, propane and fuel oil), serve less than one percent of our clients (Wood vendors, in particular, are rare because of the dearth state). When a client buys fuel from one of these vendors, it is common practice for the eligibility worker to check with local sources to determine th of the vendor. Eligibility workers have developed an excellent working relationship with vendors in their areas as most of the vendors and their employees rural community. Vendor reputations are generally very well known to county staff. 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: Applicants are asked to include a copy of their current heating bill with their application. This serves to verify heating vendor's authenticity a that the proper vendor is authorized to submit heating bills on behalf of the client. LIHEAP benefits are based on a percentage co-payment between the client and LIHEAP. The percentage for which the client is responsible by the household’s income, household size, type of fuel and type of dwelling. The vendor sends the household’s bill directly to the DHHS central of DHHS remits payment to the vendor for the LIHEAP share. With the bill coming directly to the central office, DHHS is able to review them for pot irregularities prior to any payment being made. In addition, SPACES also includes substantial edits to spot irregularities and prevent duplicate payments. 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: Applicants are asked to include a copy of their current heating bill with their application. This serves to verify heating vendor's authenticity a that the proper vendor is authorized to submit heating bills on behalf of the client. LIHEAP benefits are based on a percentage co-payment between the client and LIHEAP. The percentage for which the client is responsible by the household’s income, household size, type of fuel and type of dwelling. The vendor sends the household’s bill directly to the DHHS central of DHHS remits payment to the vendor for the LIHEAP share. With the bill coming directly to the central office, DHS is able to review them for poten irregularities prior to any payment being made. Unregulated energy vendors, primarily of deliverable fuels, tend to be located in North Dakota’s rural areas. In addition to the billing procedures described above, SPACES incorporates a substantial number of edits to spot irregularities and assure tha payments are not issued. These edits apply to all vendors. 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 See Section J.4. (Erroneous Payments) of attached state plan of operation 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.