Quality Assurance

Revised April 29, 2013

WAC 388-464-0001

Requirement to cooperate with quality assurance.

CLARIFYING INFORMATION

1. As a condition of receiving federal funds for the administration of the food assistance program (Basic Food Program/Supplemental Nutrition Assistance Program - SNAP) the federal government requires states to maintain a Quality Control system. The Quality Assurance (QA) section must:

   1. Review a statistically valid statewide sample,

   2. Compile and analyze review findings to determine numbers and types of errors, and;

   3. Aid in establishing corrective action plans.

2. Review sampling:

   1. The Review Sample Time Period covers the federal fiscal year (FFY) which runs from October 1^st of one calendar year through September 30^th of the following year.

   2. Cases are selected for review at random from active recipients of food and cash assistance benefits. This is identified as the active sample.

   3. A random negative sample is also drawn from denied, terminated, and suspended case actions.

3. Case review process:

   1. The QA review process typically includes:

      1. An electronic file and case record review.

      2. A field investigation including an in person interview with the recipient.

      3. Verification of all eligibility factors.

      4. A determination of the correctness of payment and benefit eligibility.

      5. A report of the findings to ESA's Community Services Division (CSD), Aging Disability Services Administration's Home and Community Services (ADSA/HCS) and to the federal government.

4. Federal quality control review:

   1. Federal quality control staff reviews a random sample of cases completed by state QA to validate the review findings.

   2. If Federal quality control results are different than the original state findings, and state QA agrees with those results, QA will notify ESA/CSD or ADSA/HCS for necessary action(s).

5. Exempt errors:  Food assistance errors, with the exception of ineligible cases in any amount, that result in an error amount of less than $51.00 are not counted in the federal QC error rate.

WORKER RESPONSIBILITIES

1. Non-cooperation and QC sanction:

   1. If the household refuses to cooperate in the QC review process, the QA reviewer will notify the appropriate agency contact person  immediately. The notice will contain:

      1. The specific reason(s) for the non-cooperation determination;

      2. The period of ineligibility;

      3. What the client can do to end the QC sanction; and

      4. The phone number and QA reviewer name for future contact.

   2. Upon receipt of the notice of non-cooperation the FSS must take the following action:

      1. Notify the client immediately that the entire food assistance household or TANF/SFA assistance unit  benefits will be terminated. The effective date of termination is the first of the month following the end of the 10-day advance notice period. The notice should contain the following:

         • The specific reason for the non-cooperation determination;

         • The QC sanction time period and if the client is non-cooperating for both food assistance and TANF/SFA , include both time periods;

         • What the client must do to end the QC sanction;

         • That an overpayment may have occurred, and;

         • The phone number of the QA reviewer/unit.

   3. The FSS must terminate benefits unless QA notifies the FSS the QC sanction is lifted.

   4. If unable to terminate TANF/SFA benefits prior to the first of the month, the FSS should take the following action for TANF/SFA assistance units:

      1. Establish an overpayment from the first of the month following QA's determination of non-cooperation for TANF/SFA, and;

      2. Include the advance notice time period.

   5. For food assistance household's, the FSS must terminate benefits effective the first of the month following the end of the 10-day advance notice period.

2. Period of Non-Cooperation QA Sanction: 

   A household that is sanctioned for not cooperating in the Basic Food quality control review is ineligible for one hundred twenty-five (125) days after the end of the annual federal review period in which the case was selected for review, unless the household cooperates with QA before the end of the federal review period.  The annual federal review period begins October 1 and ends September 30 each year (e.g., federal fiscal year 2012 (FFY 2012) begins October 1, 2011 and ends September 30, 2012).  

3. Re-application after termination due to QC non-cooperation sanction:
   1. If an applicant that has been terminated from assistance due to a QC non-cooperation sanction reapplies before the end of the QC sanction period, review the case record for a notice of cooperation from QA. If there is none, notify the QA reviewer/unit the client is reapplying and document the response from QA on the narrative screen in ACES.
      1. If the applicant has cooperated with QA, determine eligibility in accordance with the procedures found in the Applications category of this manual.
      2. If the applicant has not cooperated with QA,
         1. Pend the application for cooperation with QA but request the necessary verification of current circumstances;
         2. Refer the applicant to QA to complete the QC review process; and
         3. Authorize assistance effective the date all eligibility factors are met, including cooperation with QA. For food assistance issue benefits according to instructions found in the Issuance category of this manual.
      3. If the applicant continues to not cooperate with QA, deny the application no later than 30 days from the date of application.
   2. For an applicant who reapplies after the QC sanction period expires, verify all eligibility requirements. After the QC sanction period expires, no referral to QA is necessary.

   3. If the individual cooperates with QA after the sanction has begun, the individual must complete a new application to be eligible for benefits. 

     4.    Quality assurance review findings:

a.       Quality assurance reviews focus on correctness of eligibility and payment in a specific review month. The findings from the review are reported via the DSHS 05-012A(X), which is electronically transmitted to the ECR.

b.      For correct cases, no action is required by the FSS unless other information is supplied which affects the client's eligibility. The FSS is responsible for evaluating the information and taking appropriate action.

c.       For error cases, the report from QA should contain information specifying;

                                                                                i.            The type (overpayment, underpayment, ineligible, denied, terminated, or suspended) and dollar amount of the error, if appropriate;

                                                                              ii.            The applicable rule citation;

                                                                            iii.            A narrative explaining how the error was discovered;

                                                                            iv.            A listing of Federal reporting codes indicating:

§  Element and nature codes (program requirements);

§  Type of error (agency or recipient responsibility);

§  Discovery (how the error was identified);

§  Verification (how the information supporting the error finding was verified: e.g., from what source); and,

§  Occurrence (relationship between error and most recent action on case).

5. Processing Basic Food Error Cases (Federal Quality Control Reviews):

a.    QA will inform CSD or HCS when a case error is identified.  At this point, CSD or HCS will have the opportunity to review the error and provide comments to the QA manager; comments may be made prior to and at the Process Review Panel.  

                      i.        The FSS will not process the case error at this point and will not contact the household for information related to the error.  

                    ii.        The FSS may have contact with the household related to ongoing eligibility, such as conducting an eligibility review.

b.    All QA error cases are reviewed by the Basic Food Process Review Panel before the cases are finalized and reported to USDA/FNS.

c.    Once the error has been finalized, the FSS will take appropriate action on the case, including computing and establishing an overpayment or issuing an underpayment if necessary.

d.    CSD or HCS will initiate corrective action, including:

                      i.        Error analysis

                    ii.        Changing procedures where appropriate

                   iii.        Providing training

e.    In some cases, after completion of the error review process, ESA/CSD, ADSA/HCS, and QA may be in disagreement over the error findings.  The Director of the Office of Quality Assurance will be responsible for issuing a final decision.

ACES PROCEDURES

See Quality Assurance / Quality Control

See Disqualified / Sanctioned Assistance Unit / Individual - Non-cooperation - Quality Assurance (QA)