Other Supporting Justifications. States must verify client circumstances when determining their eligibility for public assistance benefits. The parties to this agreement determined a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the necessary information to identify individuals who may be ineligible for public assistance benefits (i.e., to verify client declarations of income circumstances). The principal alternative to using a computer matching program for identifying such individuals is to conduct a manual comparison of all DoD pay/retirement/survivor pay files with SPAA records of those individuals currently receiving public assistance under a State-administered Federal benefit program. Conducting a manual match, however, would clearly impose a considerable administrative burden, constitute a greater intrusion of the individual's privacy, and result in additional delay in the eventual recovery of any outstanding debts. By contrast, when using computer matching, the information on successful matches (hits) can be provided within thirty (30) days of receipt of an electronic file of SPAA beneficiaries. The 2001 Government Accountability Office (GAO) report, Paris Project Can Help States Reduce Improper Payment Benefit Payments (GAO-01-923), projects that if states include Temporary Assistance for Needy Families (TANF), Medicaid and SNAP activities in their matching projects, the gross savings will result in a savings-to-cost ratio of 11:1 (GAO 01-935, pp. 14, 15). All savings are in program dollars, because there is no cost paid by the states to either ACF or DMDC to participate in the matching program.
Other Supporting Justifications. States are required to verify client circumstances when determining an applicant’s eligibility for public assistance benefits. The parties to this agreement have determined that a computer matching program is the most efficient, expeditious, and cost-effective means of verifying client declarations of income circumstances. The principal alternative to using a computer matching program for identifying such individuals would be to conduct a manual match; however, this would clearly impose a considerable administrative burden, constitute a greater intrusion of individual’s privacy, and would result in delayed identification of ineligible individuals.
Other Supporting Justifications. This matching program supports compliance with E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009), which states the policies of federal programs that serve their intended beneficiaries; provide public scrutiny of significant payment errors and eliminate the highest improper payments; establish accountability for reducing improper payments; and coordinate federal, state, and local government action in identifying and eliminating improper payments, and implementing guidelines in OMB Memorandum X-00-00, Xxxxxxxxxxx xx Xxxxxxxx C to Circular A-123, Requirements for Payment Integrity Improvement, (June 26, 2018). HUD-specific statutory and regulatory requirements further justify the matching program and the analysis of employment and income reporting. HUD is required to establish procedures, which are appropriate and necessary to assure that income information provided to PHAs and MF business partners by families applying for or receiving assistance is complete and accurate. HUD must randomly, regularly, and periodically select a sample of families and obtain information from external agency data sources pertaining to the individuals within the families only for the purpose of verifying incomes, data concerning unemployment compensation and Federal income taxes in order to determine eligibility of families for benefits (and the amount of benefits, if any). 42 U.S.C. § 1437f(k). HUD program administrators are required to use accurate income amounts in determining housing rental assistance. See 24 CFR § 5.659 and Chapter 5, Section 3: Verification of the Occupancy Requirements of Subsidized Multifamily Housing Programs, 4350.3 REV-1. For the public housing and tenant-based Section 8 programs, PHAs are required to use accurate income amounts in determining housing rental assistance and verifying a family’s annual income and other factors that affect the determination of adjusted income or income-based rent. 24 CFR §§ 960.259 and 982.516. As of January 2021, HUD estimates a total subsidy error associated with incorrect or fraudulent reporting to be approximately $400 million and estimates 250,000 households have incorrectly reported income. HUD also estimates that approximately five percent of the households participating in PIH and MF Housing programs, respectively, may not have disclosed all wage, employment, unemployment compensation benefits, or Social Security benefits. The NDNH is a centralized databa...
Other Supporting Justifications. Another basis for evaluating the matching program is to compare the cost of conducting the matches manually with the costs of conducting computerized matching. TRICARE has approximately 9,900,000 beneficiaries eligible for Medicare Parts A & B, who are matched electronically on a weekly basis to validate continued Medicare Part A and B coverage. As shown in Key Elements 1 and 2 above, the costs of matching such records in automated fashion are estimated to be $139,161. Alternatively, if a manual match were to be conducted, we would estimate at least $31,004,015 per year in manual labor. Assuming an individual can manually search and provide response on Medicare A/B coverage for 2 records a minute, they could search: • 960 records per day (8 hour day) • 4,800 records per week (5 days) • 19,200 records per month (4 weeks) Assuming the frequency of the match decreases from weekly matching to monthly matching, 9.9M records to be searched at an average of 19200 records per month by 1 individual, 515.6 FTEs would be required to manually search the 9.9M records every month. Assuming staff performing the work include employees located in the Washington- Baltimore-Arlington, DC-MD-VA-WV-PA geographic locality at a GS-9/1, $60,129/year. 515.6 FTE x $60,129/year = $31,004,015 Cost Category Amount CMS Personnel Costs $112,002 DoD Personnel Costs $11,140 CMS Computer Cost $7,562 DoD Computer Cost $4,697 DoD Administrative Cost $3,760 TOTAL COST $139,161 Attachment 1
Other Supporting Justifications. Even though the Marketplace matching programs are not demonstrated to be cost-effective, ample justification exists in the CBA sections III (Benefits) and IV (Other Benefits and Mitigating Factors) to justify DIB approval of the matching programs, including the following:
Other Supporting Justifications. The Improper Payments Information Act of 2002, Pub. L. 107-300, the Improper Payments Elimination and Recovery Act of 2010, Pub. L. 111-204, and the Improper Payments Elimination and Recovery Improvement Act of 2012, Pub. L. 112-248, require federal agencies to identify programs susceptible to significant improper payments and to report to agencies and to report to Congress of efforts to reduce such payments. The Office of Management and Budget issued implementing guidance to federal agencies in Appendix C to Circular A-123, Requirements for Effective Estimation and Remediation of Improper Payments, (amended October 20, 2014). SSA conducts a CBA for each year of the match program resulting in the conclusion that the agency has avoided or recovered substantial payments far above the cost of the matching program. The NDNH is the only nationally centralized directory of new hire, quarterly wage, and unemployment insurance information and, as such, provides an effective, efficient, and comprehensive method of collecting and comparing this information. SSA’s use of NDNH information supports program accuracy, program administration, and reduces overpayments. There is no other administrative activity that can accomplish the same purpose and provide the same security safeguards with the same degree of efficiency.
Other Supporting Justifications. This matching program supports compliance with the Payment Integrity Information Act of 2019 (PIIA) which focuses on preventing improper payments to ensure funding serves its intended purpose as first set out in E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009). Payment integrity is a top priority. OMB guidance provides the framework to reduce the administrative burden, allow agencies to focus on identifying, assessing, prioritizing, and responding to payment integrity risks, and address the underlying causes of improper payments. See OMB Memorandum M-21-19, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement (March 5, 2021). Because the UC program has been identified as susceptible to significant improper payments, the matching program facilitates compliance with the applicable requirements of 31 U.S.C. §§ 3351-3358. DOL mandated use of the NDNH for the BAM program in 2007 (see UIPL No. 3-07, Change 1) to detect benefit year earnings (BYE) overpayments beginning in December 2011 (see UIPL No. 19-11). This mandate is based on the Department’s administrative authority granted under Section 303(a)(1) of the Social Security Act and Sections 3306(h) and 3304(a)(4) of the Internal Revenue Code. Studies done by DOL confirm that use of NDNH results in earlier detection of improper payments, prevents future overpayments, and increases the likelihood of overpayment recovery. NDNH is a centralized database of wage and employment information and, as such, provides an effective and efficient means to obtain income information, preferable to other means of obtaining the same information. The matching program will assist the state agency in detecting fraud, waste, and abuse and will enhance program integrity by strengthening the state agency’s oversight and management of the UC program. It will serve as a deterrent to some individuals who otherwise may fraudulently apply for and receive UC benefits and it will provide information to reduce erroneous payments. The program will also provide useful information on the employment and earnings of UC applicants and recipients, specifically: 1) those who are employed with the federal government; 2) those who are employed in another state, including those who have been rehired by a previous employer after having been separated from such prior employment for at least 60 consecutive days (Pub. L. 112-40, effective April 21, 2012, am...
Other Supporting Justifications. This matching program supports compliance with the Payment Integrity Act of 2019 (PIIA) (31 U.S.C. §§ 3352 et seq.) which focuses on preventing improper payments to ensure funding is serving its intended purpose as first set out in E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009), which states the policies of federal programs that serve their intended beneficiaries provide public scrutiny of significant payment errors and eliminate the highest improper payments; establish accountability for reducing improper payments; and coordinate federal, state, and local government action in identifying and eliminating improper payments, and implementing guidelines in OMB Memorandum M-18-20, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement, (June 26, 2018). Payment integrity is a top priority, and OMB guidance provides the framework to reduce the administrative burden, allowing agencies to focus on identifying, assessing, prioritizing, and responding to payment integrity risks and the underlying causes of improper payments. See OMB Memorandum M-21-19, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement (March 5, 2021). HUD specific statutory and regulatory requirements further justify the matching program and the analysis of employment and income reporting. HUD must establish procedures to ensure that families applying for or receiving assistance provide complete and accurate income information to PHAs and MF business partners. HUD must randomly, regularly, and periodically select a sample of families and obtain information from external agency data sources pertaining to the individuals within the families only for the purpose of verifying incomes, data concerning unemployment compensation, and Federal income taxes in order to determine eligibility of families for benefits (and the amount of benefits, if any). 42 U.S.C. § 1437f(k). HUD program administrators must use accurate income amounts to determine housing rental assistance. See 24 CFR § 5.659 and Chapter 5, Section 3: Verification of the Occupancy Requirements of Subsidized Multifamily Housing Programs, 4350.3 REV-1. For the public housing and tenant-based Section 8 programs, PHAs must use accurate income amounts to determine housing rental assistance and verify a family’s annual income and other factors that affect the determination of adjusted income or income-based ren...
Other Supporting Justifications. Although the CBA does not demonstrate that this matching program is likely to be cost-effective, the program is justified for other reasons, as explained in this section. In accordance with 5 U.S.C. § 552a(u)(4)(B), the DIB may waive the requirements of a CBA if it determines in writing, in accordance with guidelines prescribed by the Director of the OMB, that a CBA is not required.
Other Supporting Justifications. The matching program reduces the enrollment burden on Medicare beneficiaries and expedites the enrollment process. Additionally, this matching program ensures a correct Extra Help program eligibility determination while reducing the level of effort SSA Field Offices (FO) expend to manually verify all income and resource allegations on the initial Extra Help application and during subsequent eligibility redeterminations. FOs perform fewer manual verifications when data exchanges verify alleged income. Appendix D outlines the business need for this data exchange. SSA benefits from administrative savings by avoiding the cost of manual development of income and resources reported on initial and redetermination applications. SSA estimates that the benefit-to-cost ratio for this matching operation is 17.6:1. The NDNH is the only nationally centralized directory of new hire, QW, and UI information and, as such, provides an effective, efficient, and comprehensive method of collecting and comparing this information. SSA’s use of NDNH information supports program accuracy, program administration, and reduces overpayments. SSA uses NDNH information to verify an individual’s statement of income and resources, as attested to by the individual under the Extra Help program. Applicants must make attestations under penalty of perjury and SSA is responsible for verifying applicants’ income and resource allegations. There is no other administrative activity that can accomplish the same purpose and provide the same security safeguards with the same degree of efficiency.
