Work First 140 – Automated Inquiry and Match Procedures

XV. NATIONAL DIRECTORY OF NEW HIRE (NDNH)

The National Directory of New Hire (NDNH) is a national database of employment information, managed by the Federal Office of Child Support Enforcement (OCSE) and the Administration for Children and Families (ACF). The NDNH provides employment information on all employers, including multi-state employers, out of state employers, the Federal government and the military. This monthly computer check will assist in:

• Proper case processing

• Fraud detection and prevention and

• in increasing the work participation rate

The NDNH match will only be run on Adult WFFA recipients, not applicants.

This match will occur in addition to the State Directory of New Hires (ACTS New Hire) match, which is available through On Line Verification (OLV).

Each month a file containing the active Adult WFFA population will be submitted for matching purposes by the Division of Information and Resource Management (DIRM) to the Federal Office of Child Support Enforcement. The file to be matched will be for active cases for the prior month. For example, the caseload will be matched on March 31 for cases active in the month of February. The data received as a result of the NDNH match contains leads on employment. The information requires independent verification prior to any case action. The NDNH match results are stored in the Client Services Data Warehouse (CSDW), where it is available for access by designated Work First staff.

A. Security Procedures

Information contained within the National Directory of New Hire is considered Personally Identifiable Information (PII) and is therefore protected by the Federal Privacy Act. As a result, the information is subject to specific procedures to ensure the administrative, technical and physical security of the data matched and the results of the matching program.

1. Each County Director must ensure the physical, technical and administrative safeguarding of the TANF-NDNH data match results on behalf of the agency. The county agency is responsible for designating one person in the Work First program as the control person for the retrieval, printing and distribution of individual match results from the TANF-NDNH (figure 1).

Each local department of social services will provide initial security awareness training to all users with access to the TANF-NDNH data prior to access to the data. This should include all staff and any other individuals with access to this data because of their job responsibilities. A review of the security procedures must be conducted annually, and employees are required to sign an Agreement to Safeguard Confidential Data (figure 2) at both the initial training and the annual refresher training.

Work First staff with access to the individual match results must safeguard the data while it is in his/her office. This includes keeping the data in a locked location when not in use. If screen prints of the data are routed to a shared printer in a common area, retrieve screen prints immediately. The information must be protected from unauthorized disclosure at all times.

2. The staff designated as the NDNH Control Person must ensure that:

a. The reports remain under lock and key when a caseworker is not using them;

b. The reports are acted on within the time frames allowed;

c. All caseworker copies of the report are returned and filed with the control copy; and

d. TANF NDNH match results are not destroyed until all copies of the report are returned.

To ensure only individuals who are allowed access to the individual match results handle this information, a log must be maintained by the designated control person. The log must indicate who receives copies of the individual match results, the date of receipt and date of return for all hard copies. Once the match results have been reviewed and the Work First worker has taken appropriate action, all copies of the match results must be returned to the designated control person and is destroyed (figure 3).

B. County Action Requirements

Only one (1) person per county may have access to the NDNH match data in CSDW. The local county department of social services Security Officer is responsible for requesting access to the data on behalf of the county designated staff. The Information Resource Access Authorization Form (IRAAF) must be used for all access requests. The designated user’s supervisor and the Security Officer, who will maintain a record of the form, must sign the IRAAF. The Security Officer will fax a signed copy to 919-334-1265. Also, the local Security Officer is responsible for ensuring all users participate in security training and maintaining proof of participation in training and the non-disclosure oaths.

Once access has been authorized, the NDNH match results are available through CSDW / Corporate Documents in a folder entitled “State Sanctioned NDNH Queries”.

The data load schedule and the latest data available can be viewed by accessing the following links:

TANF-NDNH Match Schedule:

http://www.csdw.status.dhhs.state.nc.us/csdwstatus/CSDWLoadSchedule.asp

Operations Page - under TANF Header:

http://www.csdw.status.dhhs.state.nc.us/etlreport/operationalstatus.asp

C. Time Standards for Completing TANF-NDNH Match Results

Complete appropriate action on the TANF-NDNH match results within 30 calendar days from the run date on the CSDW query. If outside verification is needed, appropriate action may occur outside of the 30^-day time standard. Once the verifications are received, take appropriate action within ten calendar days.

D. Work First Caseworker Responsibilities

The caseworker must safeguard the data while in his /her office. This includes keeping the data in a locked location when not in use. The caseworker can only have access to data that apply to their specific work assignment. The information obtained form the NDNH match is considered employment leads and must be independently verified by the caseworker.

The caseworker must review the information to determine the recipient’s current employment status (i.e. no longer employed, never employed, or currently employed) and/or Unemployment Benefit status. The NDNH Tracking sheet (figure 4) may be used to document all case action relating to the match results. Take action based on the verified results, not the TANF-NDNH match results.

Follow the steps outlined below to process individual match results.

1. If the Work First participant has employment and/or UIB benefits reported on the TANF-NDNH individual match results, the caseworker must independently verify the information.

A. Check the case file to see if the employment and/or UIB benefits have been previously reported. If the information has been previously reported and documented, no further action is required. If the information has not been previously reported, verify the change according to verification procedures in the Work First Manual.

1. Once the information is received, document in the case file that the information has been provided and take appropriate action. The source of the information is no longer the TANF-NDNH. At this point, the verified information should be shared with other program areas within the agency (such as Medicaid, FNS, etc.).

2. If the client refuses to provide the information, issue a DSS-8110 to propose termination of the case.

Refer to Section 114- Income and Budgeting and Section 202- Changes in Situation for additional information.

B. If appropriate, follow procedures in Section 263 – Financial Responsibility for over issuance and in Section 207, Fraud and Intentional Program Violations, for suspected fraud.

Note: Do not place copies of the TANF-NDNH match results in the family’s case record.

2. Disclosure

The returned match results are considered leads and cannot to be shared with other programs until the information has been verified.

A. The caseworker may disclose the information from the TANF-NDNH individual match results to the individual reported on the match or the individual’s protective payee.

B. If the case is prosecuted for fraud, verifications received as a result of the TANF-NDNH match may be used. However, information may not be disclosed to any legal counsel in the case of fraud claims. It may not be stated the information was obtained from the TANF-NDNH to individuals other than the client involved in the case. The caseworker may only state the information was verified through the source (i.e. employer).

C. If there is a hearing or appeal, the information obtained from the TANF-NDNH may be presented as evidence, if necessary.

D. The TANF-NDNH individual match information cannot be shared with other programs. However, once the results of the TANF-NDNH data match are independently verified, the verified information must be shared with other programs.

Example: You receive a New Hire employment match and confirm that the person is employed by contacting the employer. The verified information can be shared with other programs and the wage data used to modify all types of benefits s/he receives.

The only actions that can be taken from having access to TANF-NDNH are POST verification. Any actions related to the verifications are allowable for TANF, Food and Nutrition Services, etc. that is an appropriate action within the rules of the program (adjusting for work participation rate changes, closing cases for earnings, re-budgeting, evaluating for Job Bonus and supportive services such as childcare, etc).

3. Retention and Destruction of NDNH Match Data

Once all case files have been reviewed and appropriate actions taken the caseworker must return the hard copy of the NDNH match results to the designated control person. The control person is responsible for ensuring all hard copies are destroyed immediately. The designated control person must document the destruction of the match results using the Log for Destruction of Match Results (figure 3). The NDNH Worker Activity Log (figure 4), the Log for Destruction of NDNH Match Results (figure 3) and the Control Log for Distribution of Match Results (figure1) must be retained for audit and monitoring purposes.

The NDNH hard copies may be destroyed by one of the following methods.

1. Incineration - Ensure all pages are consumed.

2. Shredding - In order to make reconstruction difficult, the paper should be inserted so that lines are perpendicular to the cutting line. The paper should be shredded into strips that are no wider than 5/16 inch.

3. All electronic extracts of NDNH match results must be erased within 30 days of receipt of match data.

NDNH match results are retained in Client Services Data Warehouse for a period of two 2 years.