NORTH DAKOTA DEPARTMENT OF HUMAN SERVICES
BISMARCK, NORTH DAKOTA
March 9, 2004

IM #4945

TO:		County Director
EA Policy Regional Representatives

FROM:	Blaine Nordwall, Director, Economic Assistance Policy

SUBJECT:	New Initiative to Reduce Agency Errors
		Establishing Claims 430-05-80-20 
		Underpayments 430-05-90

PROGRAMS:	Food Stamp Program

RETENTION: 	Until Manualized

NEW INITIATIVE TO REDUCE AGENCY ERRORS

A new initiative to reduce errors (with emphasis on agency caused errors) is being implemented effective October 1, 2003 for (federal fiscal year 2004). During FFY 2003 70% (51 of 73) of the errors found by Quality Control were agency errors.  Total dollars issued in error was $6,266.00.   Of this amount, $2,429 was client error and $3,837.00 was agency error.  The break down for the $3,837.00 attributable to the agency is as follows:

•	Reported information disregarded or not applied - $1,674.00 – 21 cases
•	Failure to follow-up on inconsistent or incomplete information - $550.00 – 7 cases
•	Failure to follow-up on impending change - $161.00 – 2 cases
•	Failure to verify required information - $182.00 – 2 cases
•	Policy incorrectly applied - $1,129.00 – 17 cases
•	Other - $141.00 – 2 cases

To date in FFY 2004, a total of eleven (11) errors have been cited by Quality Control. Of this number, agency errors account for 64% (7 of 11) of these errors. Agency/client caused errors account for 18% (2 of 11) and client caused errors account for 18% (2 of 11) of the total errors. Twelve (12) additional errors are pending error resolution of which most are agency errors.

Under this initiative, county offices are required to review all cases determined to be in error by Quality Control (including findings of $25 or less) with county eligibility staff.  Quality Control findings that are $25 or less are included in Section 621.3 of the FNS Quality Control 310 Handbook are not required to be reviewed under this initiative. In these cases the difference between the Quality Control budget, which used actual income and expenses for the review month and the county agency authorized budget is $25 or less. QC will add comments to the QC Results screen for these cases, indicating a county review of the finding is not required.

Quality Control findings that are $25 or less included in Section 622.3 of the FNS Quality Control 310 Handbook are required to be reviewed under this initiative. In these cases the difference between Quality Control’s best prospection budget and county agency’s authorized budget resulted in a finding that is below the $25 tolerance level, resulting in no countable error for QC purposes. QC will add additional information to the QC Results screen describing the items that caused the error. The county will use this information to complete the review of the error.

This review should occur during a staff meeting that includes all eligibility staff. The purpose of this review is to establish what caused the error to happen, to review policy that was incorrectly applied and to establish procedures to ensure that all reported information is acted on and that inconsistent or incomplete information is followed up on. The purpose of this review is not to place blame or embarrass a worker, but rather to brainstorm to develop procedures and practices that can be implemented and used by all staff to prevent the reoccurrence of the same error. By doing this review in a regularly scheduled staff meeting, it provides an opportunity to include training on policy. It also ensures that all eligibility staff has a clear understanding of policy. When county staff have input into the development of the procedures there is buy-in and ownership by the staff.  We strongly encourage counties to review all correct cases reviewed by Quality Control and these be included in this process and that staff be recognized for their work.
  
Effective with the Quality Control review month of October, 2003, counties are required to provide a written synopsis of the review of the completed error cases and advise the State Food Stamp Office within 30 days of the review findings of what procedures have been implemented to ensure that the error does not reoccur. This timeframe does not replace or change the QC requirement that the county respond to agree or disagree with an error finding within 20 days.  A draft of the new standardized form (Quality Improvement Report) is provided for county use to ensure uniformity statewide.  It is recommended that this report be completed during a staff meeting. The supervisor or lead worker would assist in the completion of the report. If there is no supervisor or lead worker in the county, the county director should assist the worker. All responses will be analyzed and best practices will be shared with all county offices.  The new form will be made available as an e-form as soon as possible.

A listing of all cases found in error by QC to date for FFY 2004 will be sent to each county office. 

We know that caseloads are increasing and resources are stretched.   However, we must make every effort to address this problem and take a proactive approach to it.  We have control over agency errors. With the new performance based bonus system, approximately 50% of all states in the country have the potential to be fiscally sanctioned.  We must all work together and do all that we can to ensure that the correct benefits are issued the first time.  

Establishing Claims 430-05-80-20 and Underpayments 430-05-90

Current policy at 430-05-80-20 states that all claims must be established before the last day of the quarter following the quarter in which the overpayment or trafficking incident was discovered. 
Effective March 1, 2004 the exception to this policy is Quality Control reviews in which corrective action is required.  Corrective action (claims or underpayments) as a result of a Quality Control review must be completed within 30 days of receiving the Quality Control finding.
Verification necessary to complete corrective action on these cases can be obtained from the Quality Control State Office.  Since Quality Control gathered the verification we should not be requesting that verification from the client unless Quality Control does not have the verification or the verification is questionable.  Please e-mail Brenda Holzworth, Quality Control Director, at soholb@state.nd.us to request verifications.  
This change is being made as part of the new initiative as corrective action is part of the review process for the QC Cases.
If you have any questions please contact your regional representative.