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2013

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									                                              OMB Approval No. 0970-0075, Expiration Date: 04/30/2014


                                                    ATTACHMENT 1
                                  MONTANA PROGRAM INTEGRITY ASSESSMENT SUPPLEMENT
                                    Low Income Home Energy Assistance Program (LIHEAP)

ABSTRACT:
HHS is requiring further detail from Grantees on their FY2013 plans for preventing and detecting
fraud, abuse, and improper payments. HHS is also requiring that Grantees highlight and describe all
elements of this FY2013 plan which represent improvements or changes to the Grantees’ FY2013
plan for preventing and detecting fraud, abuse and improper payment prevention.

Instructions: Please provide full descriptions of the Grantee’s plans and strategy for each area, and
attach/reference excerpts from relevant policy documents for each question/column. Responses must
explicitly explain whether any changes are planned for the new FY.

 State, Tribe or Territory (and                                                                                    Date/Fiscal Year:
 grant official):
                                                                                                                   2013
 State of Montana,
 DPHHS,
 Intergovernmental Human
 Services Bureau
 EIN: 81-030-2402
 LIHEAP (LIEAP) PROGRAM



 RECENT AUDIT FINDINGS

 Describe any audit findings of
 material weaknesses and
 reportable conditions,
                                           Please describe whether the
 questioned costs and other
                                           cited audit findings or relevant
 findings cited in FY2013 or the                                                                                   Necessary outcomes
                                           operations have been resolved           If there is no plan in place,
 prior three years, in annual                                                                                      from these systems
                                           or corrected. If not, please            please explain why not.
 audits, Grantee monitoring                                                                                        and strategies
                                           describe the plan and timeline
 assessments, Inspector General
                                           for doing so in FY2013.
 reviews, or other Government
 Agency reviews of LIHEAP agency
 finances.

 A Legislative Audit (2011) made
 recommendations regarding the
 following three issues:                                                                                           The Department is
                                                                                                                   managing federal awards
 Three agencies made overpayments          All erroneous benefits ($3,541 in                                       in compliance with laws,
 due to agency errors. There was no        LIHEAP benefits) have been repaid                                       regulations and the
 evidence of fraud and abuse. The          by the by the local agencies. The                                       provisions of contracts
 overpayments were identified in           Human and Community Services                                            associated with the
 monitoring reports and in corrective      Division (HCSD) has reviewed its                                        LIHEAP program.
 action plans. At the time of the audit,   corrective action practices to ensure
 the costs had not been returned to the    repayment is made in a timely
 department ($3,541)                       manner. Additional computer
                                               OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

                                            functionality and reports have been
                                            implemented to identify specific
                                            cases requiring reimbursement and
                                            areas of focus to review when
                                            monitoring. Compliance with
                                            corrective actions is tracked and
                                            follow-up reviews are conducted.

 The Department did not monitor one         All agencies are monitored once
 of its agencies within the 12 month        every calendar year. All
 period although activities for that year   weatherization monitoring reports
 were monitored shortly after the 12        are completed within 30 days based
 month period.                              upon the DOE WAP regulations.

 The Department exceeded the 10             In May of 2011 the Department
 percent limit for carrying grant           implemented corrective action to
 funding authority forward to the           reduce the excess carry forward. A
 following fiscal year. In federal fiscal   process has been implemented
 year 2010-2011 more than the 10            where the DPHHS Fiscal
 percent was carried forward in the         Department reviews the carry over
 amount of $322,474.                        limit. The additional review ensures
                                            compliance and accuracy.



Attachment – page 1 - None

  According to the Paperwork Reduction Act Of 1995 (Pub. L. 104-13), public reporting burden for this collection of
  information is estimated to average 1 hours per response, including the time for reviewing instructions, gathering and
  maintaining the data needed, and reviewing the collection of information.

  An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it
  displays a currently valid OMB control number.


 COMPLIANCE MONITORING
 Describe the Grantee's FY 2012
                                                                                   If you don't have a firm
 strategies that will continue in FY        Please highlight any strategies
                                                                                   compliance monitoring system
 2013 for monitoring compliance             for compliance monitoring                                                 Necessary outcomes
                                                                                   in place for FY 2012, please
 with State and Federal LIHEAP              from your plan which will be                                              from these systems
                                                                                   describe how the State is
 policies and procedures by the             newly implemented as of FY                                                and strategies
                                                                                   verifying that LIHEAP policy and
 Grantee and local administering            2013.
                                                                                   procedures are being followed.
 agencies.
 All LIHEAP (LIEAP) administering           Enhanced monitoring procedures         N/A (A compliance monitoring
                                                                                                                      By monitoring at least
 agencies are, by contract, required to     are in place and enhanced computer     system is in place.)
                                                                                                                      annually, the
 conduct the program in accordance          reporting and functionality allow
                                                                                                                      administering agency
 with office of Management and              monitors to conduct more specific
                                                                                                                      ensures that the program
 Budget (OMB) Circulars A-110, A-           thorough reviews.
                                                                                                                      will be operated in
 122 and A-133. The agencies are
                                                                                                                      compliance with federal
 required to submit final expense
                                                                                                                      rules and regulations.
 reports and provide appropriate
 reconciliations.
                                                                                                                      Montana operates a
                                                                                                                      statewide computer
 The Department is audited through the
                                                                                                                      system that is used to
 Legislative Auditor’s office on a two
                                                                                                                      gather information and
 year cycle. Administering Agencies
                                                                                                                      provide a monitoring
 are required, by contract, to conduct a
                                                                                                                      tool to evaluate integrity
 financial audit under the Single Audit
                                                                                                                      and performance.
 Act.
                                           OMB Approval No. 0970-0075, Expiration Date: 04/30/2014


The Department monitors agencies at
least on an annual basis. Each
administering agency is monitored on-
site by the Department at least on an
annual basis. Monitoring
encompasses review of procedural and
fiscal policy in compliance with
federal regulations for program
operations. Random case file reviews
are conducted to determine if client
eligibility was determined correctly.
Additional computer functionality and
reports have been implemented to
identify specific cases and areas of
focus to review when monitoring.
Compliance with corrective actions is
tracked and follow-up reviews are
conducted.

Department personnel participated in
both the LIHEAP Program Integrity
Work Group and the LIHEAP
Performance Measures Workgroup.




FRAUD REPORTING MECHANISMS
For FY 2012 activities continuing
in FY 2013, please describe all (a)                                            If you don't have any tools or
mechanisms available to the             Please highlight any tools or          mechanisms available to the
public for reporting cases of           mechanisms from your plan              public to prevent fraud or
                                                                                                                  Necessary outcomes
suspected LIHEAP fraud, waste or        which will be newly                    improper payments, please
                                                                                                                  of these strategies
abuse [These may include                implemented in FY 2013, and            describe your plan for involving
                                                                                                                  and systems
telephone hotlines, websites,           the timeline for that                  all citizens and stakeholders
email addresses, etc.]; (b)             implementation.                        involved with your program in
strategies for advertising these                                               detecting fraud.
resources.
The Montana LIEAP Policy manual         Montana will continue to review
states that any interested party may    and refine procedures as part of its                                      The Montana Citizen’s
report any individual appearing to      ongoing efforts.                                                          Advocate office provides
have received assistance under the                                                                                clear lines of
LIEAP program fraudulently to the                                                                                 communication between
local contractor and/or the                                                                                       the citizens and the
Department.                                                                                                       appropriate State
                                                                                                                  officials, grantees and
The Montana Citizen’s Advocate                                                                                    employees to ensure
office provides customer assistance                                                                               suspected fraud and
and access via telephone hotline; the                                                                             abuse can be directly
website and email are available to                                                                                reported.
citizens who wish to report problems,
questions or concerns. The Montana                                                                                Information regarding
Citizen’s Advocate Offices direct                                                                                 the Montana Citizen's
individuals or their question to the                                                                              Advocate is available on
proper State office. The Citizens                                                                                 the Department web-site.
Advocate office website has a direct
                                           OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

 link to the Montana DPHHS LIEAP                                                                              Complaints are
 homepage                                                                                                     investigated promptly to
                                                                                                              ensure programmatic
                                                                                                              compliance.




Attachment – page 2 - None


 VERIFYING APPLICANT IDENTITIES
                                                                            If you don't have a system in
                                                                            place for verifying applicant's
 Describe all FY 2012 Grantee            Please highlight any policy or
                                                                            identities, please explain why    Necessary outcomes
 policies continuing in FY2013 for       strategy from your plan which
                                                                            and how the Grantee is            from these systems
 how identities of applicants and        will be newly implemented in
                                                                            ensuring that only authentic      and strategies
 household members are verified.         FY 2013.
                                                                            and eligible applicants are
                                                                            receiving benefits.
 State policy requires Eligibility
 workers to verify income and
 resources with other databases. The
 Montana LIEAP program requires
 Social Security Numbers for all
 members of an applicant household.
 For those without SSN’s a process is                                                                         Montana has
 in place to require other proof of                                                                           implemented a LIHEAP
                                         The Department intends to expand                                     program match with the
 identification.
                                         the SSN verification process to                                      SSA system. The match
                                         receive benefit information.                                         with SSA allows IHEAP
 As of 2012, Montana’s LIHEAP
 computer system submits all                                                                                  offices to verify
 unverified Social Security Numbers to                                                                        household members
 SSA for matching. SSA returns a                                                                              social security numbers.
 report which includes exceptions. The
 exception report allows agencies to
 pursue resolution of erroneous
 information.


 SOCIAL SECURITY NUMBER REQUESTS
                                                                            If the Grantee is not requiring
 Describe the Grantee's FY 2013
                                         Please describe whether the        Social Security Numbers of
 policy in regards to requiring
                                         State's policy for requiring or    LIHEAP applicants and/or          Necessary outcomes
 Social Security Numbers from
                                         not requiring Social Security      household members, please         from these systems
 applicants and/or household
                                         numbers is new as of FY2013,       explain what supplementary        and strategies
 members applying for LIHEAP
                                         or remaining the same.             measures are being employed
 benefits.
                                                                            to prevent fraud.
                                               OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

 Montana’s Administrative Rules
 require all applicants and household
 members to supply social security
 numbers, and/or proof of U.S.                                                                                        In order to verify
 citizenship, or a birth certificates or                                                                              applicant and household
 photo identification for children in the                                                                             member identities in an
 household who are under age 18.             The LIEAP applicants are required                                        effort to prevent fraud,
                                            to provide SSNs for the entire entire                                     waste, and abuse,
 Montana Administrative rules state         household.                                                                Montana requires proof
 that if SSN’s or other acceptable proof                                                                              of identity for all
 of identity are not supplied, the                                                                                    applicants and household
 household can be denied LIEAP                                                                                        members.
 benefits.




Attachment – page 3 - None



 CROSS-CHECKING SOCIAL SECURITY NUMBERS AGAINST GOVERNMENT SYSTEMS/DATABASES
 Describe if and how the Grantee
 used existing government
                                                                                    If the Grantee won't be cross
 systems and databases to verify
                                            Please highlight which, if any,         checking Social Security
 applicant or household member
                                            policies or strategies for using        Numbers and ID information        Necessary outcomes
 identities in FY 2012 and
                                            existing government databases           with existing government          from these systems
 continuing in FY 2013. (Social
                                            will be newly implemented in            databases, please describe how    and strategies
 Security Administration
                                            FY 2013.                                the Grantee will supplement
 Enumeration Verification System,
                                                                                    this fraud prevention strategy.
 prisoner databases, Government
 death records, etc.)
 Montana LIEAP Policy required
 eligibility workers to check other state
 databases in an effort to verify
 identities, income and resources. The
 workers check the Public Assistance
 System which performs computer             Montana is considering options for                                        In an effort to prevent
 matching with SSA’s BENDEX                 matching with the Death Registry                                          fraud, waste, and abuse,
 system. Additionally, all household        System (MDRS) and other                                                   Montana developed a
 members over age 16 are checked            databases.                              N/A.                              LIHEAP program match
 through the state’s MISTICS system                                                                                   with the SSA system and
 which provides state wage and                                                                                        will consider pursuing
 unemployment information.                                                                                            matching other
                                                                                                                      government databases.
 In FY2012, the Montana LIEAP
 program changed from allowing Social
 Security Numbers to be optional to
 being mandatory.
                                                  OMB Approval No. 0970-0075, Expiration Date: 04/30/2014



 VERIFYING APPLICANT INCOME
                                                                                      If the Grantee won't be using
 Describe how the Grantee or
                                             Please highlight any policies or         new hire directories to verify
 designee used State Directories                                                                                              Necessary outcomes
                                             strategies for using new hire            applicant and household
 of new hires or similar systems to                                                                                           from these systems
                                             directories which will be newly          member incomes how will the
 confirm income eligibility in FY                                                                                             and strategies
                                             implemented in FY 2013.                  Grantee be verifying the that
 2012 and continuing in FY 2013.
                                                                                      information?
 Montana LIEAP Policy required
 eligibility workers to check other state
 databases in an effort to verify
 identities, income and resources. The
 workers check the Department of             Montana has the authority to use
 Labor (MISTICS) which provides              SSA’s SDX/BENDEX for
                                                                                      Montana is pursuing gaining access      Montana will continue
 wage and unemployment information           informing agencies about Title II
                                                                                      to the new hire directory however, at   strengthening our income
 for household members over 16 years         social security benefit entitlement
                                                                                      the current time we have been           verification processes
 of age. Additionally, all household         and changes on recipients for
                                                                                      denied access.                          and resources.
 members reporting they are                  retirement, disability, or survivor’s
 categorically eligible are verified         benefits.
 through the Public Assistance
 (CHIMES-EA) information.



Attachment – page 4 - None


 PRIVACY-PROTECTION AND CONFIDENTIALITY

                                                                                               If you don't have relevant physical
 Describe the financial and operating                                                                                                     Necessary
                                                   Please highlight any controls or            or operational controls in place to
 controls in place in FY 2012 that will                                                                                                   outcomes
                                                   strategies from your plan which             ensure the security and
 continue in FY 2013 to protect client                                                                                                    from these
                                                   will be newly implemented as of FY          confidentiality of private
 information against improper use or                                                                                                      systems and
                                                   2013.                                       information disclosed by applicants,
 disclosure.                                                                                                                              strategies
                                                                                               please explain why.
 Montana LIEAP policy manual requires
 workers to safeguard names, addresses,
                                                                                                                                          The outcome is
 SSNs, or other identifying information of
                                                                                                                                          to safeguard
 applicants for or recipients of the Low
                                                                                                                                          client
 Income Energy Assistance Program
                                                                                                                                          information and
 (LIEAP), including information related to
                                                                                                                                          ensure privacy
 the social and economic conditions or
                                                                                                                                          across the
 circumstances of individuals. The policy
                                                                                                                                          network. The
 specifically places restrictions on the use or
                                                    As new functionality is added to CDS                                                  computer
 disclosure of information concerning
                                                   the access is controlled through granting                                              system, security
 applicants and recipients of LIEAP to
                                                   rights/privileges to the new screens or     N/A. Policies are in place.                processes and
 ensure safeguarding of information.
                                                   modules to each individual as                                                          procedures as
                                                   appropriate.                                                                           well as the
 Agencies have a contractual obligation
                                                                                                                                          contracts are
 governing safeguarding of confidential
                                                                                                                                          updated and
 information obtained and used in the
                                                                                                                                          enhanced to
 performance of LIEAP duties. The contract
                                                                                                                                          meet changing
 specifies the policy for record retention and
                                                                                                                                          state and
 disposition.
                                                                                                                                          federal
                                                                                                                                          requirements.
 The DPHHS Security Division grants
 access to individuals through the Montana
                                               OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

UAM system. Each individual certifies
they will not release any confidential
information for any systems they may
access. The Central Database System
(CDS) is a statewide system that is used by
all agencies providing LIEAP services.
The CDS system has security at the module
level which limits the data that an
individual may access depending on their
assigned rights.


LIHEAP BENEFITS POLICY
                                                                                  If the Grantee doesn't have
Describe FY 2012 Grantee policies                                                 policy in place to protect
                                            Please highlight any fraud
continuing in FY 2013 for                                                         against improper payments
                                            prevention efforts relating to                                          Necessary outcomes
protecting against fraud when                                                     when making payments or
                                            making payments or providing                                            from these systems and
making payments, or providing                                                     providing benefits on behalf of
                                            benefits which will be newly                                            strategies
benefits to energy vendors on                                                     clients, what supplementary
                                            implemented in FY 2013.
behalf of clients.                                                                steps is the Grantee taking to
                                                                                  ensure program integrity.
As part of the eligibility determination
process applicants must provide proof
of their fuel obligation in the form of a
current fuel bill, fuel receipt or
statement from fuel vendor. In
Montana, LIEAP benefits are paid to
fuel vendors on behalf of eligible
clients with very few exceptions.
Montana LIEAP policy requires all
fuel vendors have a Department-
approved vendor application and
contract in place. The LIEAP benefit
is paid directly by state warrant to the
fuel vendor and must be applied
against the specific client’s unpaid
balance, including any future eligible                                                                              The Montana LIEAP
                                            The Montana LIEAP program will
energy costs of the household in                                                                                    program continues to work
                                            continue to work with additional
accordance with approved vendor                                                                                     with fuel vendors to receive
                                            fuel vendors to expand the number
contract. Any credit balance in excess                                                                              automated records which
                                            of vendors who are able to supply      N/A Policy in place.
of $50 attributable to the Low Income                                                                               more easily lend themselves
                                            automated records to the department
Energy Assistance Program (LIEAP)                                                                                   to verification, monitoring
                                            containing information on customer
benefit or adjusted award after the end                                                                             and reconciliation with
                                            accounts, usage and amount billed.
of the heating season must be returned                                                                              program records.
to the Department.

While performing agency monitoring,
state staff randomly visit local area
fuel vendors in the agency service area
to ensure an understanding of the
LIEAP program and to strengthen and
maintain contractor/sub-contractor
relationships.

Fuel vendors are held to the same
standards as are LIEAP recipients with
regard to fraud.
                                                OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

Attachment – page 5 - None


 PROCEDURES FOR UNREGULATED ENERGY VENDORS
 Describe the Grantee's FY 2012
                                                                                   If you don't have a firm plan for
 procedures continuing in FY 2013
                                                                                   averting fraud when dealing
 for averting fraud and improper             Please highlight any strategies                                           Necessary outcomes
                                                                                   with unregulated energy
 payments when dealing with bulk             policy in this area which will be                                         from these systems and
                                                                                   vendors, please describe how
 fuel dealers of heating oil,                newly implemented in FY 2013.                                             strategies
                                                                                   the Grantee is ensuring
 propane, wood and other un-
                                                                                   program integrity.
 regulated energy utilities.
 As noted, all fuel vendors must have a
 Department-approved vendor
 application and contract/agreement in
 place, whether regulated or non-
 regulated. The vendor must provide
 the EIN or tax id in order to be a
 viable vendor. The vendor agreement
 has been approved by the DPHHS
 Legal Department to ensure its
 legality. The vendor contract
 stipulates many conditions including
 requiring the vendor to agree that any
 funds paid by the Department will be
 used only to meet an eligible
 customer's home energy needs.

 In certain cases the providers of fuel or
 emergency relief are not authorized
 vendors. In emergencies or other
 authorized situations, the local agency
 obligates funds from a Contingency
 Revolving Fund (CRF) using a
 voucher system. Eligible LIEAP
 clients present the voucher to the                                                                                    Avert fraud and ensure that
                                                                                    N/A. Current contracts are/or
 provider of emergency relief and/or         We will investigate to determine if                                       no improper payments are
                                                                                   policies are in place.
 the fuel delivery.                          any additional changes or                                                 made in FY2013 and in the
                                             improvements seem appropriate.                                            future.
 If a voucher is used it specifies the
 amount of payment, the quantity and
 description of the goods or service and
 the name of the goods or service
 recipient. The client signs the voucher
 upon receipt of the authorized goods
 or service which is used as verification
 of receipt/delivery. The provider also
 signs the voucher as verification of
 providing the specified goods and/or
 service. Upon presenting the voucher
 to the agency, the provider will receive
 reimbursement through a CRF
 payment.

 If the client purchases the goods or
 service requiring cash on delivery of
 the fuel, the CRF payment is made to
 the client based upon the receipts
 provided.
                                             OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

CRF payments are also used for
payments to eligible wood clients,
tenant households and to reimburse
eligible households that do not have
the fuel account in a household
member’s name. Again payment is
made based upon proof of purchase.




VERIFYING THE AUTHENTICITY OF ENERGY VENDORS
Describe Grantee FY 2012 policies                                               If you don't have a system in
continuing in FY 2013 for                 Please highlight any policies for     place for verifying vendor
                                                                                                                       Necessary outcomes
verifying the authenticity of             verifying vendor authenticity         authenticity, please describe
                                                                                                                       from these systems and
energy vendors being paid under           which will be newly                   how the Grantee can ensure
                                                                                                                       strategies
LIHEAP, as part of the Grantee’s          implemented in FY 2013.               that funds are being distributed
procedure for averting fraud.                                                   through valid intermediaries?
Payments are made to vendors only
after clients have applied and been
approved for assistance and supplied a
copy of the most recent statement
received from their respective fuel
vendor. Income and resources are
verified using employment and public
assistance information computer
matches.

Verifying new vendors: A Low
Income Energy Assistance Program
Contractor Application and contract is
submitted by vendors wishing to
provide services to LIEAP Clients.
The vendor must submit a W-9 form
including the Contractor Taxpayer ID#
and the address where the 1099 form
will be sent.
                                           Research will be conducted to                                               Avert fraud and ensure that
The Contractor Taxpayer ID# is            determine if any additional changes    N/A. Current contracts/policies are   no improper payments are
verified using the IRS website and the    or improvements seem appropriate.     in place.                              made in FY2013 and in the
vendor record is flagged with the                                                                                      future.
appropriate tax designation. The
vendor is added to the State
accounting system allowing them to
receive LIHEAP payments on behalf
of approved clients. Vendors can be
added to the payment system only by
state staff specifically provided with
that role. All updates can be traced to
the individual who made them. The
state submits 1099 forms to the
vendors and IRS on an annual basis.


Local Agency Contact: The sub-
grantees maintain an ongoing
relationship with local area vendors
regarding client issues, leveraging
activities and negotiating discounts.
They make LIEAP applications
                                               OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

 available and encourage referrals. In
 the case of deliverable fuel, often the
 drivers give applications to customers
 they believe are in need of financial
 assistance.

 Monitoring vendors: State monitors
 select and review client records on-site
 at vendor locations. They print the
 records related to client payments and
 then monitor the vendor records to
 ensure payments are properly applied.
 They verify whether there are any
 credits and that any returns were made
 properly.

 Account not in HH members name:
 In those cases where the account is not
 in the household member’s name: - the
 eligible LIEAP household must
 provide verification that energy
 expenses have been paid to the fuel
 vendor to be reimbursed or the person
 responsible for the fuel account must
 become a vendor.



Attachment – page 6 - None



 TRAINING AND TECHNICAL ASSISTANCE

                                                                                 If you don't have a system in
 In regards to fraud prevention,
                                                                                 place for anti-fraud training or
 please describe elements of your
                                             Please highlight specific           technical assistance for
 FY 2012 plan continuing in FY
                                             elements of your training           employees, clients or energy
 2013 for training and providing                                                                                    Necessary outcomes
                                             regiment and technical              vendors, please describe your
 technical assistance to (a)                                                                                        from these systems
                                             assistance resources from your      strategy for ensuring all
 employees, (b) non-                                                                                                and strategies
                                             plan which will represent           employees understand what is
 governmental staff involved in
                                             newly implemented in FY 2013.       expected of them and what
 the eligibility process, (c) clients,
                                                                                 tactics they are permitted to
 and (d) energy vendors.
                                                                                 employ.

 Montana takes advantage of WebEx
 and Webinar presentations regarding
 training and technical assistance that is
 made available to both employees and
 agency staff through WIPFLI,                 In 2012, the SSN verification
 CAPLAW and other resources. This            process was implemented. Training                                      It is important to educate
 is offered to agencies to include non-      was conducted on this process.                                         employees, clients and
 governmental staff involved in the                                                                                 energy vendors to
 eligibility process. The trainings are                                                                             prevent fraud and abuse
 frequently paid for by the State LIEAP
 program.

 Prior to each heating season, training
                                              OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

is conducted to update agency staff,
including new hires, on policies,
procedures and related system
changes. This includes the sections
regarding fraud.

All LIHEAP policies and regulations
are developed with active input agency
staff and clients. Roundtable meetings
are held semi-annually to solicit their
input. Roundtables further provide the
opportunity for training and technical
assistance.

Each administering agency targets
client outreach and education activities
for all eligible households in
accordance with annual work plans
submitted by each. Each work plan
describes the eligible activity and then
how the activity will be conducted.
For example how they will educate
vendors about energy problems by
meeting face to face and establishing
client referral practices.

DPHHS monitoring staff randomly
selects vendors and conduct interviews
as part of the annual monitoring
reviews. They reaffirm policy and
provide technical assistance.




AUDITS OF LOCAL ADMINISTERING AGENCIES
                                                                                  If you don’t have specific audit
                                                                                  requirements for local
Please describe the annual audit
                                           Please describe new policies or        administering agencies, please     Necessary outcomes
requirements in place for local
                                           strategies to be implemented           explain how the Grantee will       from these systems
administering agencies in FY 2012
                                           in FY 2013.                            ensure that LIHEAP funds are       and strategies
that will continue into FY 2013.
                                                                                  properly audited under the
                                                                                  Single Audit Act requirements.
Agencies receiving $300,000 or more
in federal funds have a contractual
obligation regarding complying with
the accounting and audit requirements
of Federal OMB Circular A-133, A-           Policies will be developed to meet                                       Grantee will continue to
122 or Circular 87 as applicable.          new state or federal requirements or                                      ensure that LIHEAP
                                                                                   N/A. Specific requirements are
                                           to address any specific needs that                                        funds are properly
The agencies must submit copies of                                                currently in place.                audited under the Single
                                           arise in the administration of the
their annual A-133 audits to the           program.                                                                  Audit Act requirements.
Department for review action
regarding any findings.

The Montana Legislative Auditors
                                         OMB Approval No. 0970-0075, Expiration Date: 04/30/2014

 conduct reviews on a bi-annual basis
 to those Divisions meeting qualifying
 Cash Management Investment Act
 conditions.




Additional Information
Please attach further information that describes the Grantee’s Program Integrity Policies, including supporting
documentation from program manuals, including pages/sections from established LIHEAP policies and
procedures.

Attachment – page 7 - None

								
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