In 2012, the LIHEAP Clearinghouse conducted a survey of 22 tribal grantees as part of its work with the LIHEAP Program Integrity Working Group. The Clearinghouse also reviewed these tribes' Program Integrity Assessments for FY 2011.
The following summarizes the results.
Social Security number (SSN) Requirements
Nearly all tribes surveyed require SSNs from some or all household members. Some require photo identification with SSN or only photo identification. Some of the small tribes don't require SSNs and others began asking for them in FY 2011. Strategies are summarized below:
- 88 percent - require SSNs for at least 1 member of household
- 37 percent - require SSNs for all household members
- 4 percent - SSNs not required
- 12 percent - require SSN card or other SSA documentation
- 21 percent - accept copies of SSN cards for all household members
- 4 percent - require SSN card for applicant, SSNs for other household members
- 8 percent - SSN request is new for FY 2011
As a rule, tribes pointed out that tribal enrollment is not based on identification, but on documentation of tribal heritage. According to many tribal officials, it is extremely rare, if not unheard of, for an applicant to try to assume another person's identity for the purpose of joining tribal rolls. Provided that SSNs are listed on the tribal enrollment records, these records are (or could be) valuable resources for identifying and verifying LIHEAP applicants.
Verifying SSNs Through Third-Party Databases
A majority of tribes reported that they did not use third-party databases to check SSNs, citing expense and concerns over releasing information. Some intake personnel said the information obtained through cross-checking — whether the SSN is active and corresponds to the applicant's name — wouldn't necessarily confirm the applicant's identity.
Some tribes have their own databases, which are used to cross-check and verify client information (name, address, mailing address, age, SSN, and income) among tribally-administered assistance programs. Some tribes have other procedures, such as email, faxing, and telephone calls, to cross-check information with other tribal-administered assistance programs and, in a few cases, state-administered programs. SSN verifications are summarized below:
- 76 percent - do not use third-party databases
- 8 percent - cross-check with tribal database
- 12 percent - cross-check manually with other programs
- 4 percent - check through state LIHEAP database
A majority of tribes, especially smaller tribes, said they rely on long-standing good relationships with other public assistance personnel, both tribal and state, in order to cross-check client information on a case-by-case basis.
Alaska tribes have the option of entering into an agreement with the state Division of Public Assistance to gain viewing access to SNAP, TANF and other public assistance programs. One Alaskan tribe said the state SSA and Unemployment Insurance charge a fee for verifications.
Effective FY 2011, the Lumbee Tribe of North Carolina had access to the state's Department of Health and Human Services, the LIHEAP grantee, application database to check for duplicate crisis applications. It also can access the state's online database for Supplemental Security Income, unemployment, TANF and SNAP to verify household income, SSNs and birth dates. The parties signed an agreement outlining state and tribal responsibilities, the records access policies, funding allocations, reporting requirements, confidentiality, and liabilities. The state also provided training to the tribe.
A number of tribes said they would institute a check with SSA or other databases if it were required, but cited concerns due to their limited administrative budgets. Others said that negotiations to develop Memorandums of Understanding (MOUs) with state agencies in order to provide tribal access to databases had fallen through.
The most consistent finding among the tribes was that they all relied upon tribal enrollment status as the primary source of identity verification. As is the case with most program integrity issues, tribal enrollment procedures vary widely, depending on the size of the program and the size of the tribe or tribal association.
Many tribes require a tribal enrollment card or other documentation that proves enrollment. A third of the tribes stressed that intake staff reside in communities within the reservation and know many applicants personally. Identity documentation is summarized below:
- 100 percent - tribal enrollment
- 33 percent - intake officers who are members of small communities
- 66 percent - Social Security numbers
- 16 percent- driver's license or other picture ID
Most tribes use pay stubs, income tax records, etc., to verify income. On some reservations, most of the employment is with the tribal government, which means the income is not available on state databases. Some tribes require proof that the applicant is registered with the tribal employment office or in school. Some reservations have seasonal employment, such as fishing, which often pay in cash and is hard to track. About one-third of tribes cross-check income information with other tribal or state public assistance programs, usually via telephone, email, or fax. A few cross-check information with other tribal-administered public agencies via a tribal database. Few tribal programs have made arrangements to track information through state and other third-party databases. Some can verify information with non-tribal employers, such as state unemployment offices, mostly through letters. Income verification is summarized below:
- 75 percent - pay stubs, tax returns, other documentation
- 33 percent - other tribal or state programs by telephone, email or fax
- 8 percent - tribal database
- 8 percent - state or other third-party databases
- 4 percent - contact non-tribal employers
- 4 percent - must show registration with employment agency or school
For more information on eligibility verification, please see this page in the State section of the website.