Tuesday 9/11/12 1:30
Fran Heil and Dave Young (FNS)
Completion rates should be at 98% or above.
FNS has been monitoring this rate for some time and is concerned about the increases with the drops. They are trying to figure it out. And they have discovered multiple reasons. Staff turnover contributes. They have instructed regions to complete reviews to determine what the problems with completion rate are. These QC ME reviews are often welcomed because information is shared about improving the completion rate. FNS is always willing to provide technical assistance.
The FNS Office of Research and Analysis will be examining the issue of completion rates. They will be conducting a study as to the who, what, when, where, how and why of the existing completion rate issue.
Dave -( PowerPoint will be added to the PartnerWeb soon)
Required at 98% minimum - if 95% or below, requires data analysis and corrective action plan. In FY11, the national average was 92.84%.
There is an adjustment to the regression rate if completion rate below 95%
In last 5 years there has been an improvement in the national average.
For States with a large sample size (1080 annual reviews), 2 cases per month will place you at 98% and 5 cases per month will place you below 95%.
NSTR versus Incomplete - difference is in attempts to locate the client. For NSTR you must make 2 attempts to locate. These attempts must be made with contacts who are likely to know the location of a client. In order to qualify, there must be feedback from the source. Therefore, documentation of the reviewer is critical. Automation can assist in these location attempts.
Likely conclusion can be a great source to complete a case missing minimum information. But you must follow the rules to get there.
Regulations for NSTR are located at 310 Section 330-338 & 7 CFR 275.12(g)(2) - If clients have moved out of state, the case is NSTR. If client is hospitalized, the case is NSTR.
Unable to Locate NSTR - HB 310, 442.1 - rarely seen anymore because of electronic case records. Usely a falsified case in today's world.
UTL - you must be abel to document 2 elements of eligibility and have 2 attempts to loccate for NSTR to apply.
What is difference between UTL for NSTR and Incomplete? creating confusion, FNS is looking at 310 modification to clarify.
There can be no direct client contact in a NSTR disposition.
If case is NSTR, cannot be completed.
If incomplete, contact with the state eligibility staff is allowed in efforts to locate the client and to advise them on the client's non-cooperation. In all cases where the client has refused to cooperate or failed to cooperate, the SAQC MUST attempt to complete the case. Example case where client had completed a recert and 15 days later was pulled for QC. Client refused to cooperate but all asects of eligibiilty was verified at recent recert. Case can be completed with likely conclusion.
Verifications must be reviewed to determine if it meets the verification requirement and it does not conflict with any other evidence.
Example: Case was incomplete due to missing rent verification. However, the rent in and of itself doe not change the outcome of the allotment when a budget is completed. Therefore, likely conclusion could be utilized to complete the case.
Judging the reliability of the evidence - Recently a case was re-reviewed where a homeless client was being dropped as incomplete. One of the contacts was a priest in charge of a local homeless shelter. QC asked him to let the client know that QC was looking for him. Priest got back to QC that he had passed on the message and QC had documented this. Changed the outcome from UTL to refusal to cooperate. QC staff must use prudent judgment and clearly document.
Waivers have been creating problems for the QC review process. State waivers are for the benefit of eligibility processing usually. QC has their own verification standards which must be adhered to.
The worksheet is required for dropped cases. It is part of the review process. The 380 worksheet documents the work SAQC did to attempt to complete the review for both internal state staff and FNSQC. Document the worksheet clearly.
Likely conclusion - must attempt to verify all elements - document all efforts to verify elements - cannot use likely conclusion for non-citizen status, IEVS bank accounts and employment, vehicles, SSNs and work requirements.
Always use what information is available to you.
Questions:
Q: Gary from Minnesota - Homeless ABAWDS what would you suggest be used as a second contact if they have general address as a postal address. A: Dave - NY has a homeless department. Use a local homeless shelter contact, soup kitchen, use relative contact identified in the case record. Last resort, use the local certification office to determine if they have had any recent contact with the client.
Q: NSTR - did not access benefits in review month in 2 following months, what about $16 households who stockpile their benefits. Are they still NSTR? A: Dave - Yes
Q: Coment about EBT benefits and access - if clients don't access EBT within 90 days, the account goes off line and the EBT card had to be reactivated.
Q: Mentioned about the rent and could not verify but did not make a difference in the allotment, what about income. We have been told that if the income could not be verified, the case could not be completed. seems like a double standard. A: You must be able to complete a comparison 1. Bottom line.
Q: Gary from Minnesota - follow up with likely conclusion - they were told by their regional re-reviewer that likely conclusion could not be used for comp I. A: Fran - comp I must be completed. Not trying to get into dispute about what they were told by regional staff.
Fran is trying to determine what prevents state staff from being able to complete a case. He needs to know what is preventing cases from being completed so they can adjust policy is needed.
Completion of comp I is critical for ability to complete a review. You must be able to complete comp I for case to be completed.
Q: Bob from Alaska - states are in a catch 22 situation. If they don't complete, the FNSQC could complete with likely conclusion and regress the finding. A: Dave - yes. That is why you should arbitrate the FNSQC finding if necessary. (Side note - in these types of disagrees, you can only arbitrate the disposition on the case. You cannot arbitrate the error finding amount.)
Q: Collins from Arkansas - States would love to have a committment that something will be send to the regions to ensure that everyone is on the same page. Arbitration is a labor intensive process. A: Fran will commit to having a conference call with regional FNS staff.
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