Identity: According to the LIHEAP Program Integrity Working Group (LPIWG) and subsequent research by the LIHEAP Clearinghouse, LIHEAP grantees vary widely in the extent to which they collect and verify client information, including identity information, through third-party sources such as Social Security Administration (SSA). This is largely due to their information technology capabilities and the extent to which they can partner with other state agencies that operate human service programs and already collect client identity data.
However, through Clearinghouse research of Program Integrity Assessments (PIAs) and other LIHEAP documents, some trends have been documented as of FY 2013. (Note: Research is currently ongoing by HHS/Division of Energy Assistance to determine the extent to which SSNs are verified by third-party systems; therefore, the following summary is a reflection of trends as of FY 2013, rather than a definitive survey.)
At least 28 states and the District of Columbia indicated they conduct third-party verifications of some SSNs primarily by cross-checking their state's "master" database, that is, the database that includes recipients of SNAP, TANF, Medicaid, and other means-tested programs. In most of these states, SSNs of the applicant and all household members are required and presumably are submitted for verification. States varied as to what programs and databases are accessible to LIHEAP. In some states, the LIHEAP office is fully or partially integrated with larger programs such as SNAP and/or TANF, which helped streamline with verification process.
It is not clear from the PIAs and other state information what percent of households are verified through cross-checking the state's welfare database. It is clear that some states have access to other SSN data exchanges where they can check SSNs of those not found on the welfare database. In their PIAs, some states pointed to the value of SSA's real-time online exchange called the State Online Query System (SOLQ), but noted that it is not available to LIHEAP workers due to federal law. This was also pointed out in the LPIWG report (Pages 10 and 29). As New York stated in its response to the GAO report, (Appendix 7):
"SSA does not allow states to use the State OnLine Query (SOLQ) system to determine initial and ongoing eligibility for LIHEAP. Elderly and disabled applicants often leave their Social Security or SSI/SSDI benefit amount blank on their LIHEAP application. If SOLQ were to be available for LIHEAP, the certifier would be able to find out the correct income amount via SOLQ, thus expediting the processing of the LIHEAP application as well as ensuring the accuracy of the applicant's income as well as the accuracy of their Social Security number."
About 14 states indicated they do not conduct third-party verification; rather, they rely primarily upon client documents. Several indicated they do not have the IT capability to cross-check SSNs with third parties, but are working to obtain funding and/or partnerships and agreement with other agencies in order to implement verification.
Six states are in a mixed category, i.e., they verified some SSNs or other client data, but they did not require SSNs from all applicant households.
Three states said they do not have the authority to request or require SSNs; two of these say they are awaiting a federal mandate on the issue.
The SSA has a number of electronic data exchange systems providing different types of information, including, but not limited to, SSNs, earnings from Social Security and Supplemental Security Income, death records, and incarceration data. Click here for a list of these.
States use information from a variety of these data exchanges, depending on what is included in their information exchange agreement (see example here).
Most of the state LIHEAP offices that conduct data exchanges with SSA have had agreements in place for many years. The agreements are usually between SSA and the state's welfare agency and/or another department that deals with information technology, with LIHEAP and other programs included in the agreement, and, therefore, having permission to use the exchanges for specific purposes. In general, LIHEAP directors have not been directly involved in establishing exchange agreements and are not familiar with the processes involved or the costs of any system enhancements needed to conduct the verifications.
However, this has changed since the GAO report, and a handful of state LIHEAP directors, (e.g., Minnesota, Massachusetts, New Jersey, Wisconsin) have been actively involved in setting up SSA data exchanges to enhance their internal controls and program integrity. For more information on these, contact the Clearinghouse.
Click here for state examples of identity verification procedures.
(j) In verifying income eligibility for purposes of subsection (b)(2)(B), the State may apply procedures and policies consistent with procedures and policies used by the State agency administering programs under part A of title IV of the Social Security Act, under title XX of the Social Security Act, under subtitle B of title VI of this Act (relating to community services block grant program), under any other provision of law which carries out programs which were administered under the Economic Opportunity Act of 1964 before the date of the enactment of this Act, or under other income assistance or service programs (as determined by the State).
The LPIWG observed that income verification creates many challenges for LIHEAP providers. As with identity verification, cross-checking multiple databases may be necessary. For example, income information from an SSA exchange only provides income for Social Security recipients, state wage or employment data is limited to wage earners, and information from the state welfare agency is only for households receiving certain benefits through that agency.
As with identity verification, research is currently ongoing by HHS/DEA to determine the extent to which states are verifying income through third-party sources, as well as to identify best practices. However, through Clearinghouse and HHS/DEA review of PIAs and other LIHEAP documents, some trends have been documented.
According to a review of 2012 PIAs by HHS/DEA, at least 30 states used a database to verify client income information.
- 19 used a state computer system
- 13 used unemployment verification with their department of labor
- 9 used a state directory of new hires
- 6 used other database not identified
According to PIAs, other states relied for the most part on client documents, including, but not limited to, paycheck stubs, benefit or award letters substantiating benefits from Social Security, TANF, SNAP, etc. and tax returns.
In the case of clients claiming zero income, some states have the ability to cross check these claims with the state department that has wage or income data such as the employment security or revenue/ tax department.
Click here for state examples of income verification.
The group recommended that grantees require applicants to provide their home energy bill or other documentation of energy responsibility as well as validate the documentation with vendors, preferably through an automated data exchange.
In order to prove home energy obligation, it is standard practice for grantees to require applicants to provide a copy of their most recent home energy (heating or cooling) bill which should show the name, current address and account number for the applicant's main heating source. Some may also request a copy of the electric bill if it is separate from the heating bill. If heat is included in the rent, applicants are asked for verification from their landlord, such as a lease agreement, that heating expenses are included in the rent.
Some states have the ability to electronically transfer a list of households they've determined eligible to the vendor listing the customer's name, address, account number, SSN number or other identification information. The vendor responds by either approving or denying the customer and, if the latter, sends the state a report stating the reason, e.g., the account is inactive or the customer is not in their records, etc.
However, as pointed out by the LPIWG, these kind of electronic exchanges are only possible between the state and the larger utilities. For states with many smaller vendors, especially delivered fuel vendors, such exchanges are not feasible due to the large number of vendors, limited staff time and limited vendor IT capabilities. In such cases, states send the vendor the customer information by fax or by mail.
Client Address: The LPIWG also highlighted the importance of cross-checking client addresses, preferably through address standardization software. Such cross-checking is critical in checking for duplicate, falsified or non-existent addresses and in preventing a household from receiving more than one payment. Because there is a high level of transience in the LIHEAP population, members stated that accurate address information is critical. Some states check for duplicate addresses using software available from the Postal Service or private vendors such as Pitney Bowes. The group also recommended that addresses be is validated with the vendor whenever possible.
Other Verification Issues: The GAO report identified cases of incarcerated or deceased individuals receiving LIHEAP benefits. Some states are able to check their department of corrections database for incarcerated individuals, along with their state's vital records department for death records. Others report that efforts are currently underway to get such data from these departments. Some also check with the SSA, which also has incarceration data and a death index, although a few have reported that the data is either out of date or inaccurate. For incarceration data, a few states use an online private source called Vinelink.