General Overview of Eligibility Verification
Low Income Home Energy Assistance Program: Greater Fraud Prevention Controls Are Needed - GAO, June 2010
LIHEAP Program Integrity Working Group Final Report - April 2012
2014 State LIHEAP Program Integrity Assessments
What is verification?
Verification of eligibility is critical to establishing and maintaining program integrity by ensuring that LIHEAP benefits go only to those who are eligible.
According to the HHS Division of Energy Assistance, verification means cross checking original documents regarding identity and income with the original source or a reputable third party. In LIHEAP-IM-2011-7, which was dated April 6, 2011, HHS also pointed out to states that documentation is not the same as verification: e.g., "Verification requires documentation to be checked against an independent source, and does not include mere inspection of documentation."
When the Government Accountability Office (GAO) released its June 2010 report "Low Income Home Energy Assistance Program: Greater Fraud Prevention Controls Are Needed," the GAO cited the lack of "third-party validation systems" to verify identity and income as a major contributing factor to the fraudulent applications it identified in the report.
The GAO did not define third-party validation/verification, but it recommended that its feasibility be investigated, stating that HHS should:
- Evaluate the feasibility (including consideration of any costs and operational and system modifications) of validating applicant and household member identity information with SSA (Social Security Administration)
- Evaluate the feasibility of using third-party sources (e.g., State Directory of New Hires) at a minimum on a random or risk basis, to provide assurance that individuals do not exceed maximum income thresholds. (Page 15)
The GAO further stressed the desirability of independent verifications:
"We support any initiatives, such as EVS and State OnLine Query, that are allowed by federal law to provide the states the necessary information from SSA. Lack of validation of identity and income information were two of the major problems that we identified in our investigation of LIHEAP." (Page 16)
Verification Through Other Programs
The state of Virginia, in its response to the GAO report, asked if cross-checking client information against other state program databases was an acceptable method of verification. Virginia, along with many other states, verifies LIHEAP applicant and household member SSNs, and sometimes income, by cross-checking LIHEAP client information with its welfare department's "master" database of other program recipients (SNAP, TANF, Medicaid, etc.,), because many LIHEAP applicants are also recipients of one or more of these programs.
Information from those programs has presumably already been verified with SSA or other sources. For example, Virginia noted that both the TANF and SNAP programs require SSNs for all household members which are subsequently verified through the SSA. In such cases, no further verification is done by the LIHEAP office because it relies on the accuracy of the other program's verification systems. For applicants not receiving those programs, Virginia utilizes a separate Social Security Administration data exchange.
The GAO response was: "We did not determine that qualifying LIHEAP recipients based on their eligibility for such programs is prone to excessive fraudulent activity." (Appendix 4, page 52)
As part of its response to the GAO report and recommendations, HHS/DEA did the following:
- Issued guidance to states via an Information Memorandum (IM) dated May 5, 2010, including new guidance affirming that states may use Social Security Numbers (SSN) to validate that individuals and households receiving LIHEAP benefits are eligible and in need of the services (The memorandum concluded that HHS lacked the authority to require states to mandate provision of SSNs but states do have the authority under the Privacy Act to choose to require the provision of SSNs.)
- Issued guidance to states in the above-mentioned IM encouraging them to exercise diligence when qualifying LIHEAP applicants by making use of government systems, such as prisoner databases and the Social Security Enumeration Verification System to ensure validity of applicants and household members and decrease error
- Issued an Action Transmittal (AT) requiring that states report on their systems for ensuring program integrity, including provisions to prevent waste, fraud and abuse, and provisions to assure LIHEAP vendor validity as a supplement to their FY 2011 state plans, which were due to HHS September 1, 2010, and have continued each year. Termed Program Integrity Assessments (PIAs), the FY 2011 assessments are a benchmark for strategies as of that year, while also reflecting states' plans for the coming year. Each subsequent year's PIAs marks the progress states have obtained. Click here for current PIAs.
- Implemented a LIHEAP Program Integrity Working Group (LPIWG) whose purpose was to collect information on program integrity systems that detect, prevent and correct waste, fraud, and abuse in public benefits programs, focusing on the LIHEAP program, as well as address possible waste, fraud, and abuse by clients, vendors, and program staff. Some of the group's observations and recommendations are referenced in the LIHEAP Program Integrity Working Group Final Report.