February 28, 2014
For the full report see:
In 2013, the Massachusetts State Legislature created the Bureau of Program Integrity (Bureau) within the Office of the Inspector General to broadly monitor the quality, efficiency and integrity of public benefits programs administered by the Executive Office of Health and Human Services. The Legislature mandated that the Bureau review and report on the Department of Transitional Assistance (Department), with a focus on management and operations and program integrity.
As a starting point for this report, the Bureau reviewed eligibility processing initiatives for the Transitional Aid to Families with Dependent Children (TAFDC) program that the Department has implemented since the Inspector General’s 2013 Report entitled, “Review of Eligibility for the Transitional Aid to Families with Dependent Children Program.” The Bureau focused on three specific eligibility factors emphasized in the Inspector General’s 2013 Report: (1) Social Security numbers (SSNs), (2) address verification and (3) motor vehicle asset verification. These factors are integral to establishing eligibility for benefits. The Bureau did not identify any major flaws in the Department’s eligibility processing, but determined that the quality of the processing should be improved with clear and effective policies and procedures and some basic adjustments to the Department’s database.
In 2013, in response to longstanding concerns about SSNs, the Department implemented a regular, monthly data match with the Social Security Administration to validate SSNs for all recipients. These data matches are generally effective and minimize the previously identified concern that recipients are intentionally withholding or otherwise failing to provide valid SSNs during intake and eligibility redeterminations. There is a small group of TAFDC recipients with nine-digit temporary identification numbers that remain in place after data matching occurs. These identifiers are for recipients who qualify for an exemption to the SSN requirement (such as infant dependents and eligible non-citizens). The Bureau recommends that the Department update obsolete and unclear policies and procedures for monitoring temporary identifiers and verifying SSN exemptions.
The Bureau found overall Department compliance with eligibility regulations related to verification of Massachusetts addresses for TAFDC recipients. Based on a recommendation in the Inspector General’s 2013 report, the Department made changes to address verification forms. The Bureau recommends further revisions to the forms and a regulatory change to promote recipient accountability.
The Bureau’s examination of the verification process for motor vehicle assets focused on the implementation of a new data match with the Registry of Motor Vehicles (RMV). This data match displays a list of potential motor vehicle assets for a recipient in the Department’s database. However, the list on the database does not include sufficient information about each vehicle, and the directives for using the list to verify vehicle assets were unclear. To resolve these issues, the Bureau recommends changes to the Department’s database and more detailed, documented procedures.
The Bureau next reviewed program integrity processes. Program integrity referrals include all overpayments, whether the result of Department error, unintentional recipient violation, or intentional program violation. The Bureau found that there was a significant increase in the total number of program integrity referrals in 2013 (including referrals for TAFDC, SNAP and other programs). The Department relies on data matches identifying sources of income or employment for recipients as critical and objective sources of information for program integrity referrals. Program integrity processing includes both automated and manual workflows, and some of the manual workflows create an ongoing risk of backlog. The ultimate goal of program integrity processing is to accurately identify and penalize recipients who have committed intentional program violations. The Bureau reviewed a representative sample of TAFDC cases with intentional program violation findings and discovered that some ineligible recipients collected benefits for extended periods of time because staff failed to review data matches that showed unreported income for the recipients. To improve the processing of program integrity referrals, instead of hiring additional investigators, the Bureau recommends that the Department foster collaboration between field and program integrity staff, develop a new training curriculum on program integrity processes and pursue systems enhancements to automate manual workflows. The Bureau also recommends that the Department establish rigorous standards for case monitoring and quality control.
Finally, the Bureau reviewed the Department’s overall management and operations, focusing on the Department’s organizational structure, business process modernization efforts and internal controls. In response to longstanding concerns, the Department revised its organizational structure and began implementing Electronic Document Management. These initiatives bring potential for improving the Department’s operations and management systems, but the Department must integrate internal controls into all of its structures, operations and policies to effect lasting change. The Department must continually improve eligibility and program integrity processes in a timely and strategic manner, rather than allow longstanding issues to lapse into major flaws.
For overall improvement in eligibility processes, program integrity processes and program management, the Bureau recommends that the Department focus on the following:
- Communicating clear, effective and accessible policies and procedures;
- Integrating eligibility and program integrity workflows into a comprehensive system of internal controls;
- Performing relevant and effective data analysis;
- Establishing minimum standards for management and oversight;
- Engaging in ongoing risk-assessment and problem-solving efforts; and
- Implementing systems enhancements that correspond to business priorities, with a focus on automating essential processes.