February 13, 2014

CalFresh Program Guide Letter #597

 

Subject

CalFresh Integrity Plan and Fraud Determination Updates

 

References

All County Letters 13-45; 13-54; and 13-89, CalFresh Special Notice 10-12.

 

Purpose

To provide instructions regarding:

         The Warning Letters sent to recipients by the California Department of Social Services (CDSS) concerning Electronic Benefit Transfer (EBT) cards with unusual transactionsat a disqualified retailer;

         Excessive number of EBT card replacements;

         Clarification on steps which should be taken in determining when it is appropriate to make a Public Assistance Fraud (PAF) referral in the CalFresh program; and

         The updated processes for the Nation Wide Prisoner Match (NPM) and the Integrated Fraud Detection System (IFD).

 

Background

The United States Department of Agriculture (USDA), Food and Nutrition Service (FNS) has issued instructions about permanently disqualified EBT retailers, otherwise known as ALERT cases. The ALERT system is designed to enhance program integrity and eliminate fraud and abuse by identifying recipients who may be engaged in illegal trafficking at the disqualified CalFresh retailers.

The CDSS and the County will:

         Issue warning letters to recipients identified in the ALERT EBT transaction reports;

         Take investigative actions to determine potential trafficking; and

         Pursue prosecutions or administrative disqualifications if applicable.

DEFINITION OF TRAFFICKING

The buying, selling, stealing, or otherwise effecting an exchange of SNAP (CalFresh) benefits issued and accessed via EBT cards, card numbers and personal identification numbers (PINs), or by manual voucher and signature, for cash or consideration other than eligible food, either directly indirectly, in complicity or collusion with others, or acting alone. (See 63-451.8)

 

Required Actions for ALERTS

A copy of each ALERT Warning Letter will be sent to the County and shall be retained in the recipientís case file. If a Warning Letter is returned as undeliverable, the CDSS will contact the PAFD to request an updated address or aid status

ALERTS will be sent directly to the County of San Diegoís Public Assistance Fraud Division (PAFD) who will record and report back to CDSS the outcomes of any investigations.The CDSS will issue a Warning Letter to the recipient within 30 days from receipt of an ALERT case from FNS.

 

Excessive Card Replacements

CDSS will send a warning letter to any EBT cardholder who has at least four or more card replacements (for active cards that have at least one transaction) for four consecutive months. This is the criteria established by California which defines what is considered excessive card replacements.

CDSS will issue the Warning Letters to recipients within 30 days from the date it identifies the clients who have met the excessive card replacement criteria.A copy of each recipient Warning Letter will be sent to the County to be retained in the recipientís case file. If a Warning Letter is returned as undeliverable, the CDSS will forward the undeliverable mail to the County for follow-up.

If the recipient requests two or more additional cards within two months after the Warning Letter has been issued or returned, the CDSS will provide that information to the County. The County may issue a letter for the recipient to contact the local office, and will also refer the matter to the PAFD for possible investigation.

 

Referrals for investigation

Referrals for investigation shall be made when there is reason to suspect that fraud exists or has been attempted by the applicant/recipient.

Prior to determining if a PAFD referral is necessary, however, the worker will interview the client to clarify the allegation, inconsistencies or questionable information, as needed.Information that is questionable may not, in and of itself, be grounds for a fraud referral; yet, it may be grounds for further exploration.Where verification is required to resolve questionable information, the worker must document why the information was considered questionable, or at a minimum indicate where there is an inconsistency, and what documentation was used to resolve the questionable information.

Staff should also consider whether the recipients reporting responsibilities (Rights & Responsibilities) were reviewed in his/her chosen language and that the individual expressed that he/she understood their responsibilities. Staff will consider other circumstances such as interpretive services provided and domestic violence concerns prior to referral for investigation.

 

Questionable Information

Workers should only verify mandatory eligibility factors.However, that does not preclude contacting the household to clarify any questionable information affecting eligibility.

To be considered questionable, the information on the application or any information reported by the household during the certification period must be inconsistent with statements made by the applicant or recipient and/or inconsistent with other information received previously (see 63-117.23).Once a worker determines that information provided is questionable, and it would affect a householdís eligibility or benefit level, then it must be verified after it has been documented in Case Comments.

 

Data Matches

Data Matches such as the Nation Wide Prison Match (NPM) and the Integrated Fraud Detection System (IFD) are abstracts that match Federal and State resources to assist in ensuring Program Integrity and determining compliance of the various regulations.

 

Summary of Changes

The following changes have been made in the CalFresh Program Guide

 

Section

Changes/Updates

63-402.1 Ė 63-402.15

Updated section with current CalWIN/EPPIC and FRC procedures for EBT issuance and replacement of benefits

63-402.14

Added information on Excessive Card Replacements

63-702.4

Included information on Annual Fraud Training requirements

63-703.1

         Added information regarding only verifying mandatory factors of eligibility

         Added information on resolving questionable information

         Included criteria for reasonable grounds for an investigation

63-704.1

Added a link to How To #180 for FRTS access

63-704.2

Incorporated information from Special Notice 10-12 that CalWORKs Project 100% should not be applied to CalFresh Eligibility

63-704.3

         Provided steps to determine if a referral is necessary

         Included reminder regarding language barriers and clients comprehension of reporting responsibilities

         Included other considerations such as applicant or recipients learning disabilities/mental health issues

         Added Domestic Violence considerations prior to fraud referrals

63-704.5

Added information regarding overissuances including a reminder that IPVs are not determined by the HSS

63-704.6

Added examples of potential referrals for investigation

63-705.4

Added information regarding CDSS ALERT cases.

63-708.7

Added IFD to the Data Matches chapter

Changes to the CalFresh Program Guide are noted with highlighted text.

 

Special Notice 10-12 was deleted from the PG

 

Automation Impact

No Impact

 

Document Capture

CDSS ALERTS: Until they are uploaded to CalWIN, the CDSS ALERT notices (see samples under Attachment A) will be sent directly to the EBT coordinator who will forward them to the Document Processing Center.The ALERTS will be imaged under the category of NOA/Client Correspondence.

 

IFD/ Overissuance: All documentation used to determine an overissuance must be imaged and kept in the case record.

 

Other Programs Impact

No Impact

 

Quality Control Impact

Quality Control (QC) will cite the appropriate error when the requirements have not been followed or are followed incorrectly.

 

Director Approval

 

 

Rick Wanne, MA, MFT

Eligibility Operations Director

MH/DH