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 VDSS has a customer service toll-free number/hotline that in addition to general customer service inquiries can be used to report suspected fraud, abuse and waste. The number is included on the VDSS public website. Information on how to report fraud, abuse, and/or waste is included on pre-printed applications and EAP Fact Sheets. Additionally, there is information on both the public and internal VDSS EAP websites as well as the EAP information sheet regarding the reporting of fraud, abuse, and/or waste. A state employee fraud, waste and abuse hotline is also available for anonymous reporting using one of the following: a toll free number 1- 800-723-1615; a fax number of (804) 371-0165 an email to COVHotline@osig.virginia.gov; or by mail at State Fraud, Waste, and AbuseHotline, PO Box 1151, Richmond, VA, 23218. 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: 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: Income is also verified through public assistance records (SNAP, TANF, and Medicaid) which may include income verified through various third party sources including the Work Number (third party employment information provided by TALX Corporation). 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: EAP staff use Systems Partnering in a Demographic Repository (SPIDeR) to verify income from employment, unemployment, SocialSecurity, and child support. SPIDeR is a web-based system which benefits users by effectively facilitating communication between applications (systems). The following systems are currently partnered with SPIDeR and can be viewed by EAP staff: VaCMS, APECS (Automated Program for the Enforcement of Child Support); SDX (State Data Ex hange); VEC (Virginia Employment Commission); and the Work Number (3rd Party Employment information provided by TALX Corporation). 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: The VDSS requires the household provide the Social Security Number (SSN) of all household members for all three EAP components (Heating, Crisis, and Cooling) with the following exceptions: children who are under age 18; individuals who receive Social Security benefits or public assistance; and individuals who hold a “qualified” alien status. Note: individuals who receive public assistance have already provided their SSN to the LDSS. Although HHS does not require SSNs, with the launch of EAP in VaCMS, SSNs for individual household members are collected. In the former legacy system, SSN for applicant and spouse were the only SSNs captured in the system even though SSNs may have been included on the application. The VDSS requires that the SSN be provided – verification of the number is not required. However, the majority of LIHEAP recipients also receive other types of public assistance which require verification of the SSN. 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: VDSS state and local staff must complete an annual online security training which includes guidance/policy on the protection and securityof personal data/information. VDSS security protocol limits system access to individuals who require access to perform their jobs. System access, which is based on least privilidge, includes all systems: eligibility, verification, and financial. Section 63.2-102 of the Code of Virginia provides statutory requirements for allowing access to records and information for public assistance programs and child support enforcement as well as the penalty for disclosure and any confidential information. 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: Prior to becoming an approved vendor, all businesses are required to provide Virginia Taxation and IRS documents to the VDSS. Additionally, all vendors who provi e certain types of repair/replacement services for heating/cooling equipment must provide proof of current licensure to provide these services. 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: 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: Payments are issued upon receipt of the credit authorization and metered delivery ticket. 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 The LDSS must recover overpayments from the client or vendor when the improper payment is the result of an error on the part of the client or vendor. The LDSS will make arrangements for voluntary repayment of the amount of the overpayment. If this fails, the LDSS will initiate action in accordance with the Code of Virginia, to collect the amount as a debt, unless the administrative cost of such action would exceed the amount of the overpayment. The LDSS will not correct underpayments to the household based on client error. In cases of vendor or client fraud, the LDSS will follow the recovery procedures prescribed by the court. Clients found to have committed fraud are banned from LIHEAP assistance. For how long is a household banned? For 12 months 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.