NY PIA by keralaguest


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

HHS is requiring further detail from States on their FY2011 plans for preventing and detecting fraud, abuse,
and improper payments. HHS is also requiring that States highlight and describe all elements of this FY2011
plan which represent improvements or changes to the State’s FY2010 plan for preventing and detecting fraud,
abuse and improper payment prevention.

State, Tribe or Territory (and                                                                           Date/Fiscal Year:
                                                                New York State
grant official):                                                                                         September 1, 2010
                                                      Phyllis Morris, LIHEAP Coordinator
                                                                                                         FFY 2011


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 FY2010 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, State monitoring                                                                                 and strategies
                                      describe the plan and timeline
assessments, Inspector General
                                      for doing so in FY2011.
reviews, or other Government
Agency reviews of LIHEAP agency

New York State’s LIHEAP program                                          N/A
is audited annually under the
Single Audit Act. No Single Audit
findings of material weaknesses,
reportable conditions or
questioned costs were identified
for FFY 2010 or the prior three

OTDA conducts annual on-site
monitoring reviews of at least ten
local social services districts. No
                                                                                                         The timely and
findings of material weaknesses,
                                                                                                         thorough resolution of
reportable conditions or
                                                                                                         weaknesses or
questioned costs were identified
                                                                                                         reportable conditions
for FFY 2010 or the prior three
                                                                                                         as revealed by the
During FFY 2010, OTDA                 Each vendor that had
completed reviews of 50 LIHEAP        overcharged LIHEAP clients was
vendors. For each vendor, OTDA        instructed to issue a credit to
sampled 15 payment records.           the individual customer’s
OTDA found that four of the 50        account and also make account
vendors had charged LIHEAP            adjustments to other HEAP
clients more than the margin          clients in their customer base.
over rack or discount off retail      In addition, they were
price required under the terms of     instructed to submit a
the NYS LIHEAP vendor                 description of how they would
agreement (see Attachment I).         ensure that OTDA HEAP pricing
The total amount of overcharges        policies would be adhered to in
was approximately $6,500.              the future.

In 2009, the U.S. Government           With regard to the GAO
Accountability Office (GAO)            finding, we instructed Albany
reviewed the potential for LIHEAP      County to take action to
fraud and abuse in seven states,       recover the erroneously issued
including New York State. The          benefit (see Attachment II),
only NYS specific finding that was     and Albany County is pursuing
shared with us was that a $240         recovery (see Attachment III).
regular 2007-08 HEAP benefit and       New York State’s LIHEAP
a $425 emergency 2007-08 HEAP          application clearly asks the
benefit were provided to an            applicant to list only those
Albany County applicant who            people living in the same house
included two incarcerated              or apartment. When an
individuals as members of her          applicant lists adult children
household on her application.          without income, our
The household would not have           procedures (as described in our
been income eligible for a HEAP        HEAP Manual) direct the
crisis benefit without the             certifier to require the
inclusion of two household             applicant to provide a signed
members who were incarcerated          statement for any adult
at the time of application. While      household member with zero
GAO’s report states that 9             income stating the adult has no
percent of households receiving        income. This procedure was
LIHEAP benefits in the selected        not followed in this case.
states contained invalid identify
information, we were not
provided with the data behind
this assertion and therefore do
not know whether any of these
households were New York State

DHHS conducted an on-site
review of New York State’s HEAP
program in 2007. HHS’s only
finding was that local offices for
the aging were using LIHEAP
weatherization funds for non-
energy related repairs. This was
an issue that OTDA had identified
shortly before the HHS review,
and a written directive was
issued to all local aging offices to
clarify that LIHEAP
weatherization funds may only
be used for energy related and
energy conserving repairs.

In 2007, OTDA conducted a
review of the New York State
Division of Housing and
Community Renewal’s
administration of LIHEAP funded
weatherization programs and of
the New York State Office for the
Aging’s administration of LIHEAP
funded outreach and
weatherization referral and
packaging programs.
Other than finding that some
local offices for the aging were
using LIHEAP weatherization
funds for non-energy related
repairs, which had already been
addressed, no other findings of
material weaknesses, reportable
conditions or questioned costs
were identified.

Describe the State's FY2010
                                                                        If you don't have a firm
strategies that will continue in      Please highlight any strategies
                                                                        compliance monitoring system
FY2011 for monitoring                 for compliance monitoring                                            Necessary outcomes
                                                                        in place for FY11, please
compliance with State and             from your plan which will be                                         from these systems
                                                                        describe how the State is
Federal LIHEAP policies and           newly implemented as of                                              and strategies
                                                                        verifying that LIHEAP policy and
procedures by the State and local     FY2011.
                                                                        procedures are being followed.
administering agencies.
At a minimum, OTDA conducts           All of these strategies are       N/A
annual on-site reviews of at least    currently in place.
ten local social services districts
to monitor compliance with State
and Federal LIHEAP policies and
procedures. Districts are chosen
for review based upon factors
that include, but are not limited
to, the number of application
approvals during the immediately
preceding HEAP program year
and non-compliance in resolving
issues identified in previous
monitoring reviews.

During FFY 2011, OTDA will
continue to review a sample of
HEAP vendors to ensure
compliance with the terms and
                                                                                                           A sound methodology,
conditions of the New York State
                                                                                                           with a schedule for
LIHEAP vendor agreement.
                                                                                                           regular monitoring
                                                                                                           and a more effective
New York State’s HEAP program
                                                                                                           monitoring tool to
is audited annually under the
                                                                                                           gather information.
Single Audit Act.

An annual audit of local
administering agencies is

OTDA conducts periodic reviews
of the New York State Division of
Housing and Community
Renewal’s administration of
LIHEAP funded weatherization
programs and of the New York
State Office for the Aging’s
administration of LIHEAP funded
outreach and weatherization
referral and packaging programs
to ensure that funds are
obligated and expended in
compliance with LIHEAP rules.

                                                                                     If you don't have any tools
                                                                                     or mechanisms available
For FY2010 activities continuing in FY2011,
                                                    Please highlight any tools       to the public to prevent
please describe all (a) mechanisms available
                                                    or mechanisms from your          fraud or improper             Necessary
to the public for reporting cases of
                                                    plan which will be newly         payments, please describe     outcomes of these
suspected LIHEAP fraud, waste or abuse?
                                                    implemented in FY2011,           your plan for involving all   strategies and
[These may include telephone hotlines,
                                                    and the timeline for that        citizens and stakeholders     systems
websites, email addresses, etc.] (b)
                                                    implementation.                  involved with your
strategies for advertising these resources.
                                                                                     program in detecting
OTDA has a Reporting Welfare Fraud form             An enhancement to the             N/A
(see Attachment IV) that is accessible from         OTDA internet site for FFY
the OTDA internet site at                           2011 will permit the
http://otda.ny.gov/main/resources/welfare-          Reporting Welfare Fraud
fraud/ which allows the public to report            form to be submitted
suspected instances of welfare fraud and            directly online. Once
abuse. The form is currently available in PDF       submitted, the information
format, which requires that it be printed and       will be automatically
mailed. Once submitted, the information is          matched to a database of
manually checked against a database of              recipients to determine if
recipients to determine if the individual           the individual about whom
about whom the fraud allegation was made            the fraud allegation was
is known to the Welfare Management                  made is known to the
System (WMS) database. Those individuals            Welfare Management
who are known to WMS are flagged for                System database. Those                                         Clear lines of
review by OTDA’s Office of Audit and Quality        individuals that do match                                      communication for
Improvement (A&QI) staff, who then                  will be flagged for review                                     citizens, grantees,
determine if the allegation should be               by OTDA A&QI staff, who                                        clients, and
referred to the local district for                  will then determine if the                                     employees to use in
investigation. The local district                   allegation should be                                           pointing out
investigators, in turn, review the fraud            referred to the local district                                 potential cases of
allegation and return the results of the            for investigation. The local                                   fraud or improper
investigation back to OTDA. OTDA manually           district investigators, in                                     payments to State
tracks the results of the fraud allegation          turn, will be able to access                                   administrators.
submissions and subsequent investigations.          the system to review the
                                                    fraud allegation and enter
The public may also report fraud directly to        the results of the
local social service district fraud units as well   investigation directly into
as through hotlines or websites that certain        the system. System-
districts have.                                     generated and ad-hoc
                                                    reporting capabilities will
In addition, the NYS Welfare Inspector              allow OTDA and local
General’s Office has a process to report            district staff to track and
fraud through its hotline at:                       report the results of the
http://www.owig.state.ny.us/                        fraud allegation
owig/complaint_form.asp .                           submissions and
                                                    subsequent investigations.

                                                                        If you don't have a system in
                                                                        place for verifying applicant's
Describe all FY2010 State policies   Please highlight any policy or
                                                                        identities, please explain why     Necessary outcomes
continuing in FY2011 for how         strategy from your plan which
                                                                        and how the State is ensuring      from these systems
identities of applicants and         will be newly implemented in
                                                                        that only authentic and eligible   and strategies
household members are verified.      FY2011.
                                                                        applicants are receiving
Household composition must be        Because HHS is now permitting      N/A
documented for each LIHEAP           states to require all members
household member at the point        of the household applying for
of initial application with one of   LIHEAP assistance to provide
the following:                       their Social Security Number,
                                     for FFY 2011, New York State
        Driver’s license            will be sending the SSN for all
        Birth certificate           household members to SSA for
        Baptismal certificate       validation while in prior years,
        School records              NYS could only validate the SSN
        Collateral contacts with    with SSA for the household
         landlords                   members who voluntarily
        Social Security card        provided their SSN.
        Marriage certificate
        Passport

For FFY 2010, New York State
requested, but did not require,
Social Security Numbers (SSNs) of
household members applying
only for HEAP. For FFY 2011, New                                                                           To ensure that
York State will require SSNs for                                                                           program benefits are
all household members applying                                                                             provided to eligible
for HEAP. For FFY 2010 and                                                                                 individuals.
continuing into FFY 2011, the
SSNs for individuals who are
categorically income eligible for
HEAP by virtue of their receipt of
Safety Net Assistance, Family
Assistance, Supplemental
Security Income or Supplemental
Nutrition Assistance Program
benefits are obtained at the point
the individuals apply for one or
more of these other programs.
All SSNs are verified with the
Social Security Administration
(SSA) for validity.

NYS’s Welfare Management
System (WMS) performs an
electronic clearance process for
all new applicants to provide
local district workers with
information about the applicant’s
current and past involvement as
an applicant or recipient of
assistance. Search criteria consist
of matching name, gender, date
of birth, Social Security Number
and Client Identification Number
(if previously assigned). Rigid
controls and edits have been
established to insure that each
applicant has only one Client
Identification Number (CIN) and
that the demographic
information associated with that
applicant and CIN is accurate.

                                                                        If the State is not requiring
Describe the State's FY2011
                                    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 FY2011,        explain what supplementary      and strategies
members applying for LIHEAP
                                    or remaining the same.              measures are being employed
                                                                        to prevent fraud.
For FFY 2011, New York State will   For FFY 2010, New York State        N/A
require Social Security Numbers     requested, but did not require,
(SSNs) for all household members    Social Security Numbers (SSNs)
applying for HEAP.                  of household members
                                    applying only for HEAP.
All SSNs are verified with the
Social Security Administration      For FFY 2010 and continuing
(SSA) for validity.                 into FFY 2011, the SSNs for
                                                                                                        All valid household
                                    individuals who are
                                                                                                        members are reported
                                    categorically income eligible for
                                                                                                        for correct benefit
                                    HEAP by virtue of their receipt
                                    of Safety Net Assistance, Family
                                    Assistance, Supplemental
                                    Security Income or
                                    Supplemental Nutrition
                                    Assistance Program benefits
                                    are obtained at the point the
                                    individuals apply for one or
                                    more of these other programs.

Describe if and how the State
used existing government
                                                                       If the State 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 FY2010 and
                                    existing government databases      with existing government         from these systems
continuing in FY2011. (Social
                                    will be newly implemented in       databases, please describe how   and strategies
Security Administration
                                    FY2011.                            the State will supplement this
Enumeration Verification System,
                                                                       fraud prevention strategy.
prisoner databases, Government
death records, etc.)
SSN Validation: Household           Because HHS is now permitting      N/A
members applying for HEAP with      states to require all members
SSNs present undergo a batch        of the household applying for
processing activity known as SSN    LIHEAP assistance to provide
validation whereby WMS sends        their Social Security Number,
Social Security Numbers (SSNs)      for FFY 2011, New York State
with associated demographic         will be sending the SSN for all
data to the Social Security         household members to SSA for
Administration (SSA) for            validation while in prior years,
comparison. If the SSN and          NYS could only validate the SSN
demographic data that is            with SSA for the household
associated with an individual on    members who voluntarily
WMS matches the information on      provided their SSN.
file with the SSA, then that
individual's SSN Code is changed
to ‘8’ (SSN validated) in WMS. If
the SSN is not validated by SSA,
the SSN Code is changed to a
different value to indicate the
reason the SSN was not
validated. SSN validation occurs
                                                                                                        Use of all available
on a weekly basis and again on a
                                                                                                        database systems to
monthly basis for a recheck
                                                                                                        make sound eligibility
regardless of their existing
validation code.

SSA Death Match: Household
members applying for HEAP with
SSNs present are part of a
monthly match whereby WMS
sends to SSA individuals with
SSNs present and, if SSA records
indicate that that individual has
been reported as deceased, for
Temporary Assistance (TA) and
Food Stamp (FS) cases receiving
HEAP, single-individual cases are
automatically closed and multi-
individual cases are reported to
local districts for appropriate
action (i.e. deletion of the
deceased individual and possible
grant recalculation).

TA/FS Prison Match: On a
monthly basis, TA and FS
individuals (who may also be in
receipt of HEAP benefits) are
matched with New York State
Department of Criminal Justice
Services (DCJS) and New York
State Division of Correctional
Services (DOCS) databases to
determine if those individuals are
currently incarcerated. If a match
is found, a monthly auto-close
process occurs for single-
individual cases, closing their TA
and/or FS case and their
corresponding categorical income
eligibility for HEAP. Districts are
notified of all cases closed as part
of this process. State staff from
OTDA’s Office of Audit and
Quality Improvement (A&QI)
receive lists of multi-person cases
and refer these cases to local
districts for investigation.

                                                                            If the State won't be using new
Describe how the State or
                                      Please highlight any policies or      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                                                                                   and strategies
                                      implemented in FY2011.                State be verifying that
FY2010 and continuing in FY2011.
New York State did not use State      Because the data is not real-         New York State will verify
directories of new hires or similar   time, New York State will not         applicant and household
systems to confirm income             be using State directories of         member incomes in FFY 2011
eligibility for HEAP in FFY 2010,     new hires or similar systems to       for households not in receipt of
and does not plan to do so in FFY     confirm income eligibility for        recurring TA, FS or code A SSI in
2011. The data in such systems is     HEAP in FFY 2011.                     accordance with the procedures
not real-time and therefore does                                            in the New York State HEAP          Effective income
not provide New York State with       If SSA were to permit states to       manual (see Attachment V).          determination
the ability to correctly confirm      use the State OnLine Query                                                achieved through
income eligibility at the point in    (SOLQ) system to determine                                                coordination across
time when an applicant applies        initial and ongoing eligibility for                                       program lines.
for what is, for the vast majority    HEAP, New York State would
of New York State’s HEAP              use this real-time system to
recipients, a one-time per year       enable local social services
HEAP benefit.                         districts and alternate certifiers
                                      to confirm income eligibility for
                                      HEAP starting in FFY 2011.


Describe the financial and                                             If you don't have relevant
operating controls in place in      Please highlight any controls or   physical or operational controls
                                                                                                          Necessary outcomes
FY2010 that will continue in        strategies from your plan which    in place to ensure the security
                                                                                                          from these systems
FY2011 to protect client            will be newly implemented as       and confidentiality of private
                                                                                                          and strategies
information against improper use    of FY2011.                         information disclosed by
or disclosure.                                                         applicants, please explain why.

                                    The stringent controls in place    N/A
Access to HEAP case information
                                    in FFY 2010 will be continued in
and issuance of HEAP payments is
                                    FFY 2011.
limited to specific staff members
in OTDA and in the local social
services districts through the
Terminal Transaction Security
System (TTSS), a sub-system of
WMS. TTSS is the security system
that controls and monitors access
to State legacy
systems/centralized data base
information on an operational
needs basis. All system users are
assigned User IDs which allow
limited access to HEAP
information and, depending on
functions assigned that User ID,
may allow the ability to issue                                                                            Clear and secure
HEAP payments. TTSS manages                                                                               methods that
day-to-day security-related data                                                                          maintain
and activities needed to meet                                                                             confidentiality and
user access requirements by                                                                               safeguard the private
applying and adhering to the                                                                              information of
shared security mandate of                                                                                applicants.
granting access permissions and
entitlements based on the
fundamental principle of least
privilege, i.e. granting the
minimum access required to
perform one's job duties when
requesting, creating and
managing user accounts and
New York State Social Services
Law section 136 and regulations
under 18 NYCRR 357 provide for
the safeguarding of confidential
information received from
applicants and recipients of
public assistance and care

                                                                        If the State doesn't have policy
Describe FY2010 State policies                                          in place to protect against
                                     Please highlight any fraud
continuing in FY2011 for                                                improper payments when
                                     prevention efforts relating to                                        Necessary outcomes
protecting against fraud when                                           making payments or providing
                                     making payments or providing                                          from these systems
making payments, or providing                                           benefits on behalf of clients,
                                     benefits which will be newly                                          and strategies
benefits to energy vendors on                                           what supplementary steps is
                                     implemented in FY2011.
behalf of clients.                                                      the State taking to ensure
                                                                        program integrity.
To insure accountability and to      The stringent controls in place     N/A
protect against internal             in FFY 2010 will be continued in
fraudulent transactions, WMS         FFY 2011.
has in place a system to track the
User ID, Date, Time and Terminal
used by individual workers who
may inquire into or enter data,
including the issuance of HEAP
benefits, into the WMS database.
In instances of suspected fraud or
abuse of the system, reports can
be generated to identify
individuals who may attempt to
perform such unwarranted
transactions. Additionally, all
transactions generate a “tagged
user” through WMS’ Local Data
Feedback (LDF) process to
identify, for local district
management staff, the origin of
any transactions performed on
the system.                                                                                                Authorized energy
WMS has in place numerous on-                                                                              vendors are receiving
line and batch processing edits to                                                                         payments on behalf of
prevent the accidental or                                                                                  LIHEAP eligible clients.
purposeful issuance of duplicate
HEAP benefits, and New York
City’s HEAP system checks for
duplicate names and addresses
prior to payment issuance. On
WMS, only one regular HEAP
benefit (Pay Type H1) may be
issued per case during each HEAP
benefit year and, additionally,
the Benefit Issuance and Control
Subsystem (BICS) contains edits
and controls to prevent duplicate
issuances for various other HEAP
single-issue payment types.
Additionally, WMS edits insure
that payments authorized must
match stored budgets contained
in its Automated Budget and
Eligibility Logic (ABEL) budgeting
During FFY 2011, OTDA will
continue to review a sample of
HEAP vendors to ensure
compliance with the terms and
conditions of the New York State
LIHEAP vendor agreement.

Describe the State's FY2010
                                                                      If you don't have a firm plan for
procedures continuing in FY2011
                                                                      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
                                                                      vendors, please describe how
fuel dealers of heating oil,      newly implemented in FY2011.                                            and strategies
                                                                      the State is ensuring program
propane, wood and other un-
regulated energy utilities.
Same as in LIHEAP BENEFITS        The stringent controls in place     N/A                                 Participating vendors
POLICY, above                     in FFY 2010 will be continued in                                        are thoroughly
                                  FFY 2011.                                                               researched and
                                                                                                          inspected before
                                                                                                          benefits are issued.

Describe State FY2010 policies                                           If you don't have a system in
continuing in FY2011 for verifying   Please highlight any policies for   place for verifying vendor
                                                                                                         Necessary outcomes
the authenticity of energy           verifying vendor authenticity       authenticity, please describe
                                                                                                         from these systems
vendors being paid under LIHEAP,     which will be newly                 how the State can ensure that
                                                                                                         and strategies
as part of the State’s procedure     implemented in FY2011.              funds are being distributed
for averting fraud.                                                      through valid intermediaries?
All HEAP vendors must provide:       For FFY 2011, New York State        N/A
                                     will begin using Internet search
       Federal tax ID number        engines to check the validity of
       Proof of insurance           the addresses provided by fuel
       Proof of licensing           vendors applying to be HEAP
                                                                                                         An effective process
                                     vendors as part of our efforts
                                                                                                         that effectively
During FFY 2011, OTDA will           to validate vendor authenticity.
                                                                                                         confirms the existence
continue to conduct on-site
                                                                                                         of entities receiving
reviews of a sample of HEAP
                                                                                                         federal funds.
vendors to ensure compliance
with the terms and conditions of
the New York State HEAP vendor
agreement and to verify the
authenticity of HEAP vendors.


                                                                         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
FY2010 plan continuing in FY2011
                                        elements of your training        employees, clients or energy
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 FY2011.     expected of them and what
the eligibility process, (c) clients,
                                                                         tactics they are permitted to
and (d) energy vendors

OTDA conducts training sessions         The comprehensive training       N/A
in August of each year to train         and technical assistance in
local social services district and      place in FFY 2010 will be
alternate certifier staff on the        continued in FFY 2011.
changes for the upcoming HEAP
season. In addition, New York
State provides new HEAP
certifiers with the opportunity to
attend HEAP Basic Certification
Training, which provides in-depth
training on correctly determining
HEAP eligibility and on using the
benefit authorization systems

OTDA provides local district and
alternate certifier staff with a
HEAP Manual that is updated
annually, and which provides                                                                                The timely and
detailed instructions on correctly                                                                          thorough resolution of
determining and documenting                                                                                 weaknesses or
eligibility and on correctly                                                                                reportable conditions
authorizing payments to energy                                                                              as revealed by the
vendors on behalf of eligible                                                                               audit.
clients. The instructions in the
HEAP Manual and additional
policy and procedural
requirements are provided to
local districts in writing on a
regular basis throughout the

OTDA also holds vendor meetings
to instruct HEAP vendors on the
correct procedures and policies to
follow in determining the correct
price to charge HEAP recipients,
in applying HEAP benefits and in
making LIHEAP funded fuel
All HEAP applicants are provided
with a client notice that describes
the benefit amount if the client
has been determined eligible.
For clients that are not eligible,
the client notice provides the
reason why the client is not
eligible. If the benefit is being
directly issued to the client’s
energy vendor on behalf of the
client, the client notice provides
the name of the vendor where
the benefit is being sent. Clients
therefore have the information
necessary to inform their certifier
if the payment is not being sent
to the correct vendor. All
individuals in receipt of a HEAP
benefit in the prior year are sent
a HEAP application for the
current year and a cover letter is
included with the application that
provides details on eligibility
requirements, and any
documentation or eligibility
changes from the prior year.
New York State also has a HEAP
hotline that clients may call if
they are in need of information
or assistance.

                                                                      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 FY2010
                                    in FY2011.                        ensure that LIHEAP funds are       and strategies
 that will continue into FY 2011.
                                                                      properly audited under the
                                                                      Single Audit Act requirements.

 Local administering agencies       The audit processes in place in   N/A
 were audited in accordance with    FFY 2010 will be continued in
 the requirements in OMB Circular   FFY 2011.
 A-133 in FFY 2010, and will
 continue to be audited in                                                                               Reduce improper
 accordance with these                                                                                   payments, maintain
 requirements in FFY 2011.                                                                               local agency integrity,
 OMB Circular A-133 requires non-                                                                        and benefits awarded
 Federal entities that expend                                                                            to eligible households.
 $500,000 or more in a year in
 Federal awards to have a single
 or program-specific audit
 conducted for that year.

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.

To top