Report 2009-101 Recommendations and Responses in 2014-041

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 2013-041 Response Not Implemented as of Most Recent Response
Department of Social Services 4 15 14 11 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

Fully Implemented November 2009. CDSS has reviewed the original recommendation and determined that the recommendation was completed in 2009. See All County Information Notice (ACIN) I-81-09 (Attachment A).

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

Since 2012, CDSS has generated county specific cost analysis reports using the formula developed in 2009. These reports are shared and discussed with the counties as part of the Income and Eligibility Verification System (IEVS) compliance reviews. Any best practices identified during that discussion is then shared at regional roundtables with county concurrence and for similarly situated counties. CDSS has determined this recommendation to be fully implemented.

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

Partially Corrected. CDSS will be adding program integrity resource materials to the CDSS website by December 2014 for statewide use. These materials include program integrity policy and operational guidelines, training tools, and contact information. The website may include anti-fraud cost effective practices. However, because CDSS recognizes that a strategy that works well in one county may not be as effective in another county, the Department will share the best practices but not require that counties replicate specific practices.

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

The revisions to the Department of Public Assistance (DPA) 266 report and instructions have been delayed due to other program priorities and proposed federal reporting changes that will affect the DPA 266. CDSS does not have a specific date when the federal changes will take effect. Currently there is no need for regular workgroup meetings. Once the DPA 266 is ready for review, CDSS will consult with all appropriate program integrity stakeholders.

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

CDSS has reviewed its previous response and finds this recommendation fully implemented. The Department has established protocols for the completion of all IEVS compliance reviews. The focus of this review is the timely processing of the matches. See attached County Match Documentation spreadsheet (Attachment C). If, through the compliance review, it is discovered that the county is not following up timely on a match report, the finding(s) is/are documented and the county must submit a Corrective Action Plan (CAP). CDSS staff monitor the completion of the CAP.

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

CDSS has reviewed its previous responses and finds this recommendation fully implemented. The Department continually works with its data source entities to improve the data formats. As this is an appropriate ongoing process, CDSS concludes that this recommendation is fully implemented.

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

During the IEVS compliance review, CDSS obtains county established thresholds for prosecution. This threshold determines which fully investigated cases will be referred for prosecution. However, since there is no direct relationship between the prosecution threshold criteria and the county's determination to investigate potential fraud, CDSS concludes that there is no further action needed.

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

CDSS has concluded that, at this time, there is no need for regulation changes. However, CDSS has determined that a more effective approach to improve the use of ADHs is through statewide training. In addition to training that was conducted in late 2013, CDSS has considered this an ongoing effort and provided additional trainings in 2014.

Recommendation To: Social Services, Department of

Recognizing that the deterrence effect is difficult to measure, Social Services should develop a method that allows it to gauge the cost effectiveness of SFIS. Social Services should include in its efforts to measure cost effectiveness the administrative cost that counties incur for using SFIS. Based on its results, Social Services should determine whether the continued use of SFIS is justified.

Response

Previous Response: Social Services believes that a new independent cost-benefit analysis of Statewide Fingerprint Imaging System (SFIS) would not be beneficial because it believes that the studies it has conducted, including the original evaluation it performed in 1997, justifies the deterrence value of SFIS. (2011-406, p. 212)

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

CDSS completed the steering committee recommendations (as identified numerically in the steering committee report). Specifically, the outstanding recommendations since the last update were as follows:

2. CDSS Fraud Bureau should establish a standard method of computing county cost-savings. Fully Implemented. November 2009

3. CDSS Fraud Bureau should establish a standard definition of an Early Fraud versus Ongoing Fraud Case. Partially Implemented. July 2015

4. The CDSS Fraud Bureau should provide regular reports for counties to use in monitoring the cost-effectiveness of their program integrity efforts. Fully Implemented. January 2012

5. The CDSS Fraud Bureau should maintain a central repository of fraud training ideas and materials created by counties and accessible to other counties via the Fraud Bureau website. Partially Implemented. December 2014.

6. The CDSS Fraud Bureau and State Hearings Division should provide training and program guidelines on Administrative Disqualification Hearings (ADH) to assist the counties. Fully Implemented. Late 2013

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

During the IEVS compliance reviews, CDSS reminds counties to review their reports for accuracy and consistency prior to submitting them to CDSS. CDSS also sends emails to those counties who are late in submitting their reports and, on occasion, a reminder of the upcoming report due date (Attachment B).

Current Status of Recommendations

All Recommendations in 2014-041