Work First 263 - Financial Responsibility: Part I - Overpayments

Change #1-2009

March 1, 2009

I. RESPONSIBILITY AND REQUIREMENTS

County Departments of Social Services (DSS) are required to recover overpayments and to correct underpayments. It is the responsibility of county Work First staff to refer possible claims to the Program Integrity section. It is the responsibility of the program integrity section to act on these referrals.

A. Counties must take prompt action to collect any overpayments of Work First Family Assistance (WFFA) or Benefit Diversion (BD). Prompt action is defined as within the second quarter following the quarter in which the overpayment is first identified. Collect the overpayment from Benefit Diversion only if the family unit was monetary ineligible for WFFA. Non financial services are not subject to collection.

B. If an overpayment occurs due to county responsible overpayment (AE) in complying with program regulations, the overpayment must be entered in the Enterprise Program Integrity Control System (EPICS) and recouped by state office adjustment.

Inadvertent Household Error (IHE) may occur if an overpayment occurs because of a State or county error in processing the payment. Counties may recoup the overpayment amount from the recipient, only if the recipient was properly notified. The notification requirements are in Notice and Hearings Process (264)

C. Unless the county board or its designee determines that an overpayment results from suspected fraud, all overpayments are collected according to the policy in this section. When there is suspected Intentional Program Violation (IPV) the policy in Fraud and Intentional Program Violation (207) must be followed.

D. Overpayments must be collected from:

The payee or any Work First recipient if at the time the overpayment was:

• 18 years of age or older,

• Lived with the overpaid family unit, and was part of the overpaid family unit.

If the payee was not included in the assistance unit, recoupment is the only collection method that cannot be used.

E. All county and recipient responsible overpayments must be reported to the Division of Social Services. (Refer to VI, VII, and VIII. Below).

F. When an overpayment and underpayment occur during the same period, the difference must be reconciled. (Refer to Part III. Reconciliation).

G. For cases in which overpayments are identified, counties must maintain sufficient documentation to substantiate legally that an overpayment occurred. If such documentation is not available, counties will not be able to collect the overpayment. In addition, the DHHS Controller’s Office must have documentation of a valid EIS Case ID Number.

Sufficient documentation consists of copies or original profiles, budgets showing the overpayment calculation, verifications used for the overpayment, etc. Neither a ledger card showing the overpayment information, nor the Claim Detail screen in EPICS is sufficient documentation to substantiate the overpayment.