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: Reporting Fraud statement is on: All benefit confirmation letters that are sent to clients upon being certified for a grant. DHS website; Report Fraud | RI Department of Human Services Ways to report fraud are posted on the subrecipients' websites and/or in their intake offices. Ways to report fraud is covered at our annual vendor meeting and distributed as part of the meeting materials. 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 Government-issued identification Required Required Required 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: Applicants attest that everything on their application is true and accurate. This includes the social security numbers they provide. Applicants must provide Social Security numbers for the Applicant and each Household Member along with proof of the Social Security numbers. Proof may be a copy of the Social Security cards or an official document from a government agency that has the Social Security number on it. For each Household Member besides the Applicant, provide one of the following documents: - Official Birth Certificate - United States Passport - A driver’s license - Any official document from a government agency - State identification card - Certificate of U.S. Citizenship - U.S. Military photo identification - Certificate of Naturalization - Other immigration documentation 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: If a household member is being supported by another person we require the other person to fill out a form stating their name, address, phone number, as well as the they type of support (cash, food, rent), the time period, and the amount. 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: Currently, we do not have electronic data match capability but in FFY 2026, we plan to do a pilot process where the subrecipients will upload their applicant files to one of the verification data systems that RI DHS uses in their eligibility system. This pilot was planned for FFY 2025 but was delayed. 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: Currently, we do not have an electronic identification verification process but in FFY 2026, we plan to do a pilot process where the subrecipients will upload their applicant files to one of the verification data systems that RI DHS uses in their eligibility system. This pilot was planned for FFY 2025 but was delayed. 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: Heating oil vendors are required to supply a copy of their Rhode Island Petroleum Dealer's License with their vendor agreement each year. Propane and wood vendors are required to supply a copy of their resale certificate. 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: Intake staff has access to utility database to verify the name, residence, and account number of the applicant. 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: Deliverable vendors must send subrecipients delivery tickets showing that the deliveries were made to the household. These tickets are input into the LIHEAP system and tracked so that any remaining balance is accounted for. Subrecipients send deliverable vendors Remaining Balance Reports. 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 Overpayment due to error: 1. If subrecipient error results in overpayment of LIHEAP benefits, the subrecipient must recall of overpaid funds. If this results in a household receiving a shut off notice, the subrecipient must use its non-federal funds to repay the vendor the recalled amount, request repayment of excess funds from the household, assure the Household has continual access to heat. 2. If vendor error results in overpayment of LIHEAP benefits, subrecipient must recall the LIHEAP funds overpaid to or on behalf of the household. 3. If the household received a direct overpayment of LIHEAP benefits, written notification must be provided to the household which includes the following information (as needed): Request repayment of excess funds, clarify the household’s rights and responsibilities, offer a meeting, and allow installment payments if needed. If the household and subrecipient can agree on a reasonable timetable, include this in repayment request to the household. In all cases, if repayment by the household poses a hardship for the household, the subrecipient shall terminate recovery procedures when the household declares and describes the hardship in a written, signed and dated statement. The statement shall be retained in the household file. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? Indefinitely, see notes in other 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 a LIHEAP client is found guilty of fraud and the payment of benefits has not exceeded $1,000, if the client applies the following year, the award will be reduced by 50%. If there is a second instance of fraud, the Applicant will not be eligible for LIHEAP assistance. Vendor agree in the annual vendor agreement that they understands that if the State of Rhode Island has reason to believe that the Vendor may have misrepresented, violated, or attempted to violate any part of this Agreement, the Vendor is subject to having their participation as a supplier in the energy assistance program immediately suspended. Suspected violations of Rhode Island law shall be investigated, and if appropriate, prosecuted. Vendors found in violation shall be barred from participation in the energy assistance program for five years. 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.