Report 2009-101 Recommendations and Responses in 2012-041

Report 2009-101: Department of Social Services: For the CalWORKs and Food Stamp Programs, It Lacks Assessments of Cost-Effectiveness and Misses Opportunities to Improve Counties' Antifraud Efforts

Department Number of Years Reported As Not Fully Implemented Total Recommendations to Department Not Implemented After One Year Not Implemented as of Most Recent Response
Department of Social Services 2 15 13 10

Recommendation To: Social Services, Department of

To ensure that all counties consistently gauge the cost-effectiveness of their early fraud activities and ongoing investigation efforts for the CalWORKs and food stamp programs, Social Services should work with the counties to develop a formula to regularly perform a cost-effectiveness analysis using information that the counties currently submit.

Response

The CDSS has developed a Statewide Fraud Savings Cost Calculations report based on the methodology outlined in the All County Information Notice (ACIN) No. I-81-09 (see Attachment A). This report will show the fraud cost savings based on early and ongoing fraud activities for CalWORKs and CalFresh that will be derived from the revised Department of Public Assistance (DPA) 266 report. The data will be tracked for each individual county and also combined into a statewide report. This report will provide data to perform the cost effective analysis. CDSS is currently sharing a draft report with a sampling of counties to solicit their feedback on the usefulness of the report.

Recommendation To: Social Services, Department of

To make certain that counties receive the greatest benefit from the resources they spend on antifraud efforts related to CalWORKs and food stamp cases, Social Services should, using the results from the recommended cost-effectiveness analysis, determine why some counties' efforts to combat welfare fraud are more cost-effective than others.

Response

The state received federal approval and funding for its system approach to implement federal health care reform under the Affordability Care Act (ACA). Because the federal ACA rules require the establishment of an automated system for eligibility with access to federal and state verification source data, the Administration is exploring whether it will be able to leverage verification processes that will be built for California Healthcare Eligibility, Enrollment and Retention System (CalHEERS).

Recommendation To: Social Services, Department of

To make certain that counties receive the greatest benefit from the resources they spend on antifraud efforts related to CalWORKs and food stamp cases, Social Services should seek to replicate the most cost-effective practices among all counties.

Response

The CDSS' extranet site is in the final design and testing phase. The CDSS is concurrently preparing a letter to the Special Investigative Units (SIUs) that will communicate the purpose of the extranet and usage instructions. Deployment of the extranet is anticipated for January 2013. The extranet site will be a repository for counties to post their best practices and training on fraud investigations, Income Eligibility and Verification System (IVES) process, etc.

Recommendation To: Social Services, Department of

To make certain that counties receive the greatest benefit from the resources they spend on antifraud efforts related to CalWORKs and food stamp cases, Social Services should continue to address the recommendations of the steering committee and promptly act on the remaining recommendations

Response

Since the BSA issued its report in November 2009, the CDSS has created a data warehouse that produces reports that are used to compare county performance in the areas of fraud activities.

In addition, the CDSS anticipates launching an extranet site in January 2013 that will be a repository for counties to post their best practices and training on fraud investigations, IEVS processes, etc. See updated response to Recommendation No. 3 for additional information.

Many of the BSA recommendations cannot be accomplished before the resolution of the analysis identified in our updated response to Recommendation No. 2.

Recommendation To: Social Services, Department of

To ensure the accuracy and consistency of the information on welfare fraud activities that counties report and that Social Services subsequently reports to the federal government, the Legislature, and internal users, Social Services should take the following steps: Remind counties that they are responsible for reviewing the accuracy and consistency of investigation activity reports before submission.

Response

As a result of the 2009 BSA Audit, all IEVS reviews conducted by the CDSS now include an evaluation of the counties' Department of Public Assistance (DPA) 266 Fraud Investigation Activity Reports. If the evaluation reveals that a county is not submitting accurate or timely data, the county is required to submit revised DPA 266 reports.

The CDSS is also in the process of finalizing significant revisions to the DPA 266 report and the instructions for its completion. The CDSS anticipates release of the revised DPA 266 and instructions to the counties in the spring of 2013. Following this release, the CDSS will provide technical assistance and training to counties throughout the state. This will ensure counties are thoroughly trained on how to complete the report accurately.

Recommendation To: Social Services, Department of

To ensure the accuracy and consistency of the information on welfare fraud activities that counties report and that Social Services subsequently reports to the federal government, the Legislature, and internal users, Social Services should provide counties with feedback on how to correct and prevent errors that it detects during this review.

Response

The CDSS continues to work with counties to provide feedback on how to correct and prevent errors that it detects during an Income Eligibility and Verification System (IEVS) review. If county reporting errors are found during the state's IEVS review, the CDSS provides immediate feedback to the county, and the county is required to submit corrected Department of Public Assistance (DPA) 266 reports.

Recommendation To: Social Services, Department of

To ensure the accuracy and consistency of the information on welfare fraud activities that counties report and that Social Services subsequently reports to the federal government, the Legislature, and internal users, Social Services should continue with regular meetings of its workgroup to further its efforts to clarify its instructions for completing the counties' investigation activity reports.

Response

A workgroup comprised of county Special Investigative Units (SIUs) and CDSS staff worked to clarify the instructions for the revised Department of Public Assistance (DPA) 266 report. The final draft version of the report is currently under review by counties. Please refer to the updated response for Recommendation No. 5.

Recommendation To: Social Services, Department of

To ensure that counties are consistently following up on all match lists, Social Services should remind counties of their responsibility under state regulations to follow up diligently on all match lists. Further, it should work with counties to determine why poor follow-up exists and address those reasons.

Response

Assembly Bill 6 (Chapter 501, Statutes 2011) changed the rules for CalWORKs and CalFresh clients from quarterly to semi-annual reporting as of 2013. This new rule has required the CDSS to assess the impact of these reporting changes on the requirements and timeframes associated with counties' review of IEVS matches. Once that analysis is completed, the CDSS anticipates releasing applicable instructions, subject to the analysis described in the response to Recommendation No. 2.

Recommendation To: Social Services, Department of

To ensure that counties are consistently following up on all match lists, Social Services should revive its efforts to work with counties and federal agencies to address the counties' concerns about match list formats and criteria.

Response

Please see the response to Recommendation No. 2.

Recommendation To: Social Services, Department of

Social Services should track how counties determine prosecution thresholds for welfare fraud cases and determine the effects of these thresholds on counties' decisions to investigate potential fraud, with a focus on determining best practices and cost-effective methods. It should then work with counties to implement the consistent use of these cost-effective methods.

Response

Please see response to Recommendation No. 2.

Recommendation To: Social Services, Department of

Social Services should either ensure that counties follow state regulations regarding the use of administrative disqualification hearings or pursue changing the regulations.

Response

The internal workgroup to develop improvements to the administrative disqualification hearing (ADH) process has not been convened due to limited staff resources and other workload priorities. Development of the All County Information Notice (ACIN) to remind counties of the state mandate to use the ADH process has been put on hold pending the establishment of the workgroup. In order to complete other recommendations identified in this report, CDSS anticipates convening the workgroup no earlier than Fall, 2013.

Current Status of Recommendations

All Recommendations in 2012-041