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: Issues related to benefit fraud or abuse and household eligibility most often are referred to the Fuel and Utility Office. The Fuel and Utility Office investigates all reports of fraud or abuse of benefits. When a viable finding is made, the case and supporting documentation is forwarded to either the Economic Services Divsion (ESD) Fraud Unit or the Assistant Attorney General's Office. Typically, 'client' fraud is referred to the ESD Fraud Unit and 'dealer' fraud is referred to the AAG's Office. 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: Fuel suppliers and utility companies certified by the Fuel & Utility Office to participate in the LIHEAP program are a frequent source of information or concerns regarding client eligibility that might be fraud. Through formal email notices several times a year from the Fuel and Utility Office, certified fuel suppliers are advised to report concerns of fraud, duplicate benefits, household compostion or housing data that is at variance with the information that ESD maintains. Certified fuel suppliers operate under a confidentiality clause in their certification. 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 Social Security Number (Without Required Required Required 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: 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: LIHEAP winter (Seasonal) fuel assistance eligibility is processed by Benefit Programs Specialists in the DCF Economic ServicesDivision. Benefits for LIHEAP, SNAP (3SqsVT), TANF (Reach Up in Vermont) and health care programs all utilitize the same eligibility mainframedatabase. 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: 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: Vendors of firewood and wood pellets are not required to be certified with the Fuel & Utility Office. Due to supply and variations in quality and quantity, firewood and pellet clients have greater success in obtaining quality product when all suppliers in the market are accessible to them. 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: Some items checked above may be performed on a sample basis at the end of the winter heating season. 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: Benefits are paid directly to clients that heat with firewood or wood pellets. Some items checked above may be performed on a sample basis. 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 party in question is contacted by phone and/or in writing. They are advised of the issues and specific actions are outlined with aspecific date for compliance. The party is advised that failure to respond or comply will escalate the case either to the ESD Fraud Unit or theAssistant Attorney General. Most cases are resolved at this basic communication level. 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.