Monday 9/10/12 - 1:30
Fran Heil, Lana Rae Tapia, Dave Young - FNS
(PowerPoint will be added to PartnerWeb soon) Fran - USDA promotes easy access to SNAP. Need to ensure individuals who need the program have access to it. Also, need to ensure that there is integrity within the program. Focus of the presentation will be on negatives. The switch in the focus of negative reviews was done intentional. FNS needs to monitor that programs are delivered with a high degree of customer service. This new process is simply a road to get us to a better place.
Pulled most recent data reveals these estimates based on State Reported data as submitted through 9/6/12. The SNAP negative error rate is approximately 22%. Based upon this, there is not a single state who is except from submitting a negative correction action plans. The following figures are based upon an analysis of reported error case: 60% of the problems are related directly to the notice being insufficient as described in the 310 Handbook (either the reason stated on the notice for the action is not specific, or the notice i not clear or the notice is not understandable or any combination of the three. About 12% of the errors are missing notices completely. About 29% of error cases had notices which were sufficient. Based on information from Item J codes, which does not include timeliness, about 82% of the errors stem from notices that are not meeting notice of adverse action (NOAA) requirements. About 8.5% stem from incorrect notice of missed interviews (NOMI). About 6.5% of error cases occured despite notices being completely correct. Looking closer at NOAA cases, about 10% of NOAA errors were missing notices or the notice was sent to an incorrect address. About 19% of NOAA notices did not comply with appropriate timeframes. About 37% of NOAA were not accurate or did not comtain the correct reason for the action. About 7.5% of NOAA notices were not clearly understandable. Proud to announce that NOMIs are no longer a problem which they have been in the past. About 2% of notices lacked the required regulatory statements. (Thanks to Jackson Crockett with FNS for providing verification/ clarifications on these statistics!)
This data supports that we still have a lot of system work to do.
Lana - Most of what she is saying, we already know. Effective 10/11, the review process for negatives changed. Basically the focus in on looking to see if agency's notice was valid. Expanded reviews have been elimanated and sampling is completed based upon the effective date. Valid negative actions require the notice be correct and action is valid.
There are 4 steps to the completion of a negative review. 1st step is to determine if the action is reviewable based on the 310 section 1332 - NSTR. Make sure you use this step and evaluate the case for NSTR. Step 2 is to determine if the action under review was valid. Ensure there something in the case record to support the action. Notices impact this step. Also, the timeiiness of the notice is evaluated. This is required under the Food Stamp Act of 1977 specifically 7 CRF 273.13 (a)(2). Is the notice easily understandable? Step 3 is optional. Involves making collateral contacts to support case determination. If utilized, make sure this step/action is well documented within the review file. Step 4 requires you to determine if the reviewable action was valid or invalid.
Always document the 245 so the person reviewing it can easily understand the case issues. And include corrective actions references.
Coding for the 245 was developed and expanded at request of state agencies to better determine root causes and error trending.
Questions:
Q: Dave Young indicates that PowerPoint will be on the PartnerWeb shortly.
Q: Sara from Wisconsin - Concerned about increase in their state error rate. Will there be information sharing for corrective action planning purposed esp. on late notices? A: Fran - He is taking the position that problems being identified by States are problems for the entire SNAP program. There is a payment accuracy workgroup which is meeting to discuss and refine this review process. Everyone needs to take look at what the SNAP regulations have always required. Identified problems will be resolved in multi-facet manner between States and FNS.
Q: Regarding the properly pended process from a State with a 60 days pending period. What is a possible improper pending error? A: Fran - In properly pended situations, a state agency has taken an action to request valid information necessary to determine SNAP eligibility. If state has allowed 10 days to return information, you should be in position to process the case within 30 days. If a case is properly pended, it is possible to have a valid negative action which exceeds the 30 days.
Q: If the stated income amount on a notice is incorrect, is there a variance tolerance allowed? A: Fran - The answer is no. FNS doesn't tell you that the amount of income has to be on the notice. But if it is, it must be correct. Per regulations, the notices must be correct, clear and understandable. "Clear and understandable" is subjective. His advise is that States not be too specific but be specific enough with their language on their notices. Clients should be able to understand the notice and why they are denied from program participation. The notices should contain sufficient information to reflect if it is something that they can do something about it to fix it or is it something they can control.
Q: Is it possible for FNS to publish income policy changes? Is there a set income calculation standard? A: Fran - States need to ask themselves if they are they doing it right? There are set standards in regulations. There may be options. Annual Thrifty Food Plans are published by FNS. There are general guidelines including conversion strategies and rounding methods. But there are also State options available. Regulations also allow for the TANF income determination standard to be used for the SNAP program. However, if federal staff determine differences, then there are problems for States
Q: Delaware - How are federal reviewers maintained between regions? Fran - He believes we are all on the same page. Regional reviewers have conference calls where questions were discussed and everyone is provided with same answers. There is consistency. FNSQC will be publishing a Q&A on PartnerWeb shortly which addresses questions which have come in from all States. Currently undergoing FNS management concurrence. Contains 38 questions with very specific answers. Open communication is most important thing through all of this. But doesn't want FNS to be dictatorial to States.
Q: Guidance is helpful with allocation of IS resources into the correct areas of concern.
Fran - FNSQC only 1/4 way through the analysis of federal re-review data for FY12 presently. Fran believes these negative review processing issues will be discussed for years.
Q: Will there be guidance in negative coding? We believe there are coding inconsistencies among States with how they are being applied and applied. Requests FNS use associated analysis with caution. A: Fran - Jessica Shehin has declared FY12 to be the base year. And FNS will approach cautiously. There will be no bonuses for FFY12 for most improved performance. It is a huge change for everyone. He understands that everyone may not be reporting in the same manner.
He asks States to use the FNSQCS data being provided. New negative reports are being offered. Use them. Wants states to improve and offer future best practices to everyone.
Q: Regarding coding on the 245, how to code when the reason on notice is correct but the timeliness is problematic. A: Fran - FNS has worked hard on coding. If you have situation which you think are insufficient with existing codes, please share them. Share with Fran and another panel member so your e-mail is not lost lost.
Q: Virginia from California - Has FNS thought about making FY12 a "hold harmless" period? What about batch printing which shows a 31st date when action was actually taken on the 30th day? A: Fran - FY12 is a base year. Keep in mind that there are no sanctions in place for negatives. Q: What about a corrective action plan exception for FY12? A: Fran - Let's work on getting it fixed. We try to see what can be done but plans are important sources of information. From Feds perspective they are not done until states are 9 months into the next FY. Afraid of overall impact if there is not a corrective action requirement. Customer service is important. Need to try to get everyone to a better place - clients and staff.
Q: Rosie from Idaho -Tragedy is that we can no longer identify the true "ineligibles" from the flawed notice events. This makes corrective action planning difficult. Workers may be processing correctly and cannot control the notice language. A: Fran - The old way didn't provide true data either. There could have been circumstances where client was in fact eligible but was told otherwise. Negative sampling was inconsistant and depending on how it was sampled, a State could get different results. There might be a way to determine these types of occurrences if coding was broken apart better. As discussed earlier, we need to figure out if codes does what we want it to. Send him examples and suggestions.
Q: Rosie from Idaho - All State IS resources are currently devoted to Health Care Reform. States have competing interests with limited resources. FNS needs to understand this when recommending system enhancements.
Q: Vesta from Maryland- The hard work of staff is lost in the details of error trending. There will be political fallout with the releases of the FY12 error notification letters to the Governor. Wants to be reinsured that the FNS letters next year will fully explain the true situation. A: Fran states everyone is aware and "gets it". FY12 FNS notification letters will explain the major change in the negative review perspective.
No comments:
Post a Comment