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Identity Theft in Health and Human Services Programs
Medicaid and Public Assistance Fraud Oversight Task Force
December 2004


December 1, 2004

The Honorable David Dewhurst
The Honorable Tom Craddick
Members of the 79th Legislature

Fellow Texans:

In accordance with the requirements in House Bill 2292 section 2.143, 78th Legislature, Regular Session, and as the chairman of the Medicaid and Public Assistance Fraud Oversight Task Force, I am pleased to present the Task Force's report on Identity Theft in Health and Human Services programs.

The report reviews the procedures and documentation the state uses to confirm the identity of recipients of Medicaid and other benefits. In addition, it provides substantive recommendations for strengthening the state's fraud prevention efforts.

As the Legislature works to make every program more accountable to taxpayers, I will remain available to answer any questions concerning this review. Please let me know if I can be of further assistance.

Sincerely,
[signed]
Billy Hamilton
Deputy Texas Comptroller


Identity Theft in Health and Human Services

In 2003, the 78th Texas Legislature passed House Bill (H.B.) 2292, which significantly changed the way health and human service agencies provide benefits to needy Texans. H.B. 2292 charged the Medicaid and Public Assistance Fraud Oversight Task Force with conducting a study on the procedures and documentation requirements the state uses to confirm a person's identity for establishing qualification for Medicaid and other benefits.

This report, which includes input from the Texas Health and Human Service Commission (HHSC), the Texas Department of State Health Service (DSHS), the Texas Comptroller of Public Accounts (CPA) and other agencies, includes recommendations for preventing identity fraud and abuse in Medicaid and other health and human services programs.[1]

The task force looked at fraud in the current eligibility system and at the effects it has on services. The task force also looked at the ways federal, state and law enforcement agencies share identification data such as drivers license numbers, Social Security numbers and birth certificates. The state should make using consistent eligibility documentation across all health and human services programs a key priority. If the state used a universally accepted document list, like the Internal Revenue Service uses, it would help reduce fraud and streamline the eligibility process.[2]


Identity Theft vs. Privacy

Identity theft topped the list of consumer fraud complaints to the Federal Trade Commission (FTC) in 2003, accounting for more than half of all the complaints tracked by the federal agency. There were 214,905 cases recorded in 2003, up from 161,836 in 2002 for a 33 percent increase. The FTC reported that identity fraud cost victims, businesses and financial institutions $50 billion in 2003.

As a result, President George W. Bush signed the Identity Theft Penalty Enhancement Act in July 2004. The Act added two years to prison sentences for criminals convicted of using stolen credit card numbers and other personal data to commit crimes. Violators who use that data to commit "terrorist offenses" would get an additional five years. The law also orders the U.S. Sentencing Commission to consider increasing the penalties for employees who steal sensitive data from their own companies. Rep. John Carter (R-Texas), the bill's sponsor, said the signing was "one of the shots taken in a battle that we've got to win."[3] While identity theft is a major problem in the nation, all citizens have the right to privacy. Services and benefits, which require a government or business to gather information to verify a person's identity, must ensure recipients' privacy.

Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 addressed methods for identifying and properly managing sensitive health records. This federal law established national data interchange standards that states must follow.

In Texas, S.B. 1591, passed by the 76th Texas Legislature in 1999, established the National Data Interchange Standards (NDIS) Task Force to ensure development of a coordinated strategy for the state's implementation of these standards.

The task force is comprised of the administrative head (or a designee) of the following agencies:

  • Texas Comptroller of Public Accounts
  • Employees Retirement System
  • Texas Department of State Health Services
  • Texas Health Care Information Council
  • Health and Human Services Commission
  • Texas Department of Information Resources
  • Texas Higher Education Coordinating Board
  • State Office of Risk Management
  • Texas Department of Insurance
  • Texas Workers' Compensation Commission
  • Teacher Retirement System
  • Texas Department of Aging and Disability Services

The roles and responsibilities of the NDIS Task Force include:

  • acting as an advisory body;
  • overseeing the analysis of standards, legal requirements and health care payment and information systems;
  • recommending needed legislation;
  • providing a forum for exchanging information; and
  • developing a plan for integrating the provisions established by HIPAA for agencies that handle health-related information.

HHSC implemented the HIPAA Privacy Rule by the April 14, 2003 compliance date. The regulation requires the Medicaid program to implement a comprehensive approach to protecting the privacy of personal health information (PHI). This will require state agencies to update state polices, procedures and processes for handling PHI. It will require staff training as well as the development and implementation of privacy policies and procedures, particularly those related to identity verification.

Effective security measures or appropriate records transmission are an integral part of ensuring the privacy of PHI. HHSC is developing remediation strategies that will allow it to implement the HIPAA Security Rule. The required compliance date for HIPAA Security Rule provisions is April 21, 2005. Like the HIPAA Privacy Rule, the HIPAA Security Rule mandates the use of certain administrative, physical and technical safeguards to protect confidentiality.


Identity Fraud in Texas Health and Human Services

Verifying a person's identity to determine eligibility for state health and human service benefits has become increasingly important to states due to the increase in caseloads. Many states are significantly increasing their fraud and abuse prevention efforts in health and human services to ensure benefits are delivered only to those that need them and are truly entitled to them. In 2003, the Texas Legislature passed a number of bills that increased fraud prevention efforts in Texas. None was more significant than H.B. 2292, which not only changed the way health and human services are structured and delivered, but also consolidated all fraud and abuse prevention efforts across the health and human service enterprise under the newly formed Office of the Inspector General (HHSC-OIG) at the Texas Health and Human Services Commission (HHSC). H.B. 2292 increased the size of the Medicaid Fraud Control Unit at the Office of the Attorney

General (OAG) and clarified and strengthened the powers and duties of both offices.

In addition, H.B. 2292 provided HHSC with the authority to develop an integrated eligibility and enrollment system. This system uses new technology to streamline and safeguard the eligibility process. Specifically, HHSC is using the Texas Integrated Eligibility Redesign System (TIERS) and the Medicaid Integrity Pilot (MIP).

Identification Verification Procedures

The current process for determining an individual's identity for health and human service benefits is as follows:

  • for Temporary Assistance to Needy Families (TANF) and Medicaid, eligibility determination policy requires verification of the person's identity at the initial application, if it is questionable;
  • for food stamps, at the initial application staff members must verify the identity of the person interviewed -- if the person interviewed is an authorized representative for the applicant, staff members must verify both the authorized representative and applicant's identification;
  • at re-certification for Food Stamps, the agency must verify a person's identity if it was not previously verified -- for example, if the person interviewed at re-certification is not the same person who was interviewed at the initial application, the agency must verify that person's identification;
  • certain adults applying for TANF and food stamps must have their finger images made—this image is compared with the image for other food stamp and TANF recipients to ensure that the agency does not issue duplicate benefits; and
  • federal regulations governing the Woman and Infant Child (WIC) program require an applicant and a parent or guardian to present documentation of his or her identity at the initial application and at every subsequent certification. The regulations do not require verification by a third party nor do they require the agency to make or retain copies of the verification. WIC staff members document the type of identifying documents used by their description on a WIC form. DSHS notifies WIC service delivery providers of the forms of identification that they can accept. The policy is subject to approval by U.S. Department of Agriculture (USDA).

For a list of the identification documents accepted by TANF, food stamps, Medicaid and WIC, see Appendix A.

Scope and Type of Identity Fraud

According to HHSC-OIG, most eligibility fraud cases involve recipients providing false information or withholding information to obtain additional benefits from food stamps or TANF. This usually involves misrepresentation of income and resources or the misuse of benefits. TANF funds are not restricted by use, so fraud in that program is limited to misrepresentations of eligibility, not misuse of benefits. Food stamp transactions are limited to purchases of food, so misuse can occur if a recipient uses those benefits to obtain an item that is not allowed under the program. Generally, inappropriate use of food stamp benefits involves the sale of benefits by a recipient to a retailer in exchange for cash.

For Medicaid, the overwhelming majority of eligibility fraud referred to prosecutors by HHSC-OIG is from cases where a recipient obtained TANF benefits by fraud and is therefore ineligible for Medicaid. In those cases, the state has paid Medicaid premiums and, in some cases, reimbursed providers for services rendered. Depending on the circumstances, either or both of those amounts may be considered fraudulent. In general, if HHSC-OIG investigators determine that fraud has occurred with food stamps, TANF or Medicaid, they check all three programs. Medicaid card sharing is also a problem. Typically, an eligible recipient shares a card with another individual. HHSC-OIG investigated over 7,300 cases in which an individual misrepresented their income, resources or household makeup, resulting in the recovery of over $11 million in 2004.

HHSC-OIG has investigated cases in which the recipient tried to assist a friend; there have also been instances in which the proof of eligibility was sold to another individual who wanted acute care services. However, these types of identity fraud have been relatively uncommon compared to other types of fraud. In fact, according to HHSC-OIG, these types of fraud are so rare that they do not have a separate category, which calculates its overall prevalence. Instead, it is rolled up into an "other" category, which includes identity theft and several other types of fraud and represents 187 cases and approximately $282,000 in recoveries for 2004.[4]

Since WIC serves illegal and undocumented aliens, the scope of the ineligible client problem is different than with Food Stamps, TANF and Medicaid. Confirming a client's identity is important to investigators attempting to properly identify suspected offenders. WIC does not have a photo identification component, and grocers who accept the vouchers rarely ask for the identification WIC does issue. The grocery cashier is supposed to compare the signatures on the identification card and the signed voucher, but this often does not occur and when it does occur it is not the most effective means to determine the identity of the client.

DSHS finds most eligibility errors by sampling client records. Initial certification documentation is seldom a factor in such errors; they are more likely to occur during income eligibility calculations. There are probably some cases where WIC applicants provide falsified ID documents, but this is difficult for service providers to detect and ID is not required at grocery stores when clients use paper vouchers, or when a client uses a personal identification number to make an electronic benefits transfer. HHSC-OIG usually finds clients who used falsified IDs for the initial WIC application when it responds to tips from the public or investigates income eligibility.

After a client is eligible for services and returns for recurring WIC services such as nutrition education classes and food benefits, the client must present either a WIC-issued ID or a picture ID such as a drivers' license. This will change with Electronic Benefit Transfer (EBT) when the PIN number on the WIC smart card can verify the ID. Federal regulations allow clients to use proxies to gain access to WIC services at the clinic and to shop for WIC foods at the grocery store.

Integrated Eligibility and Enrollment

HHSC is consolidating local field offices into call centers to streamline the eligibility process. As part of this system, the agency call centers will handle eligibility, but applicants will still submit documentation, which will be stored in the Texas Integrated Eligibility Redesign System (TIERS) system.

In addition, the HHSC Office of Eligibility Services (OES) established a Medicaid Integrity pilot project that uses finger imaging technology to verify that Medicaid cards are used only by eligible recipients. ID cards include the user's finger image. Medical providers swipe the card at the point of service to verify that the finger image on the card is the same as the user's.[5]

TIERS

According to HHSC, Texas spent $210 million on the TIERS project between September 1999 and February 2004. HHSC estimates that the amount spent since September 1999 will reach $296 million by October 2005, when TIERS is supposed to go online statewide. This makes TIERS the largest information technology project under development in Texas.

When TIERS is operational, it will fully automate the eligibility process for health and human services programs and will determine who should get TANF, food stamps, Medicaid and other benefits. It will replace the 28-year-old state computer system that is currently tracking and determining eligibility. Continued problems with the administration and software of the system, however, have delayed implementation. On September 1, 2003, the Department of Human Services (DHS) transferred responsibility for TIERS to HHSC as a result of the consolidation of Texas' health and human services agencies.[6]

The State Auditor's Office (SAO) was unable to complete an audit of TIERS required by its 2003 audit plan because of extensive changes to the system. However, preliminary work not subjected to all the tests and verifications of an audit helped the agency identify potential problems and risks in all phases of contract administration.

Implementing the TIERS system will not only drastically change the eligibility and tracking process for health and human service benefits in the state of Texas, it will also have an effect on the authentication of documents used for determining eligibility. It includes imaged or scanned copies of the documents used to verity eligibility for Medicaid and other health and human service programs. These electronic documents will likely streamline HHSC-OIG fraud prevention efforts because it will speed up and ease HHSC-OIG investigators access to the current eligibility system by allowing them to review computer files instead of looking at hundreds of paper files.[7]


Front-End Authentication and Fraud Prevention System Pilot

The Front-End Authentication and Fraud Prevention System Pilot, generally referred to as the Medicaid Integrity Pilot (MIP) is a Medicaid pilot program that addresses provider fraud and appropriate cases of third-party and recipient fraud before it can be perpetrated by would-be offenders. As required by H.B. 2292, smart card and biometric (finger image) technologies provide client authentication. HHSC-OES has implemented this pilot in six Texas counties and will use the results to determine if the technology should be recommended to augment and/or replace current fraud and abuse detection systems.

The pilot program includes:

  • smart cards for all Medicaid clients participating in the pilot;
  • a smart card reader and biometric reader in the office of participating Medicaid providers;
  • a secure host system that is compliant with HIPAA;
  • client biometric information that shall only be placed on the smart card; and
  • a performance monitoring system to support evaluation of the pilot.

The pilot program allows HHSC-OES to issue smart cards that will capture the finger images of the selected Medicaid recipients upon enrollment. These recipients participating in the pilot present the smart card to medical providers who are in the pilot to begin a transaction and then use the smart card to complete the transaction. The smart card with the biometric identifier will show:

  • that the person requesting the service or benefit is the person who was issued the card and enrolled after eligibility determination;
  • that the person was at the provider's office or place of service, eliminating the opportunity for a service provider to bill for services not rendered or deplete benefits from a card without the presence of the beneficiary; and
  • the person's times for check-in and check-out, eliminating the opportunity for a service provider to bill for higher services than those he or she actually received.

The biometric authentication concept demonstrated in MIP would not require agencies to develop new procedures to confirm client identity at the time a client applies for benefits. Enhanced technology available to HHSC through the data broker application will allow faster and more extensive data collection for applicants needing medical and financial assistance. The biometric system would then authenticate, at the time of service, that the individual receiving services or benefits is the same individual who submitted the application and was certified for benefits.

In a statewide implementation, the smart card would replace the Medicaid Identification and Eligibility form 3087, and would include Electronic Medicaid Eligibility Verification (EMEV) in addition to the finger image authentication. A simplified Medicaid authentication and eligibility verification process could include the following steps:

  • the client presents an MIP card to provider for check-in;
  • the provider inserts card into a reader;
  • the client places a finger on the scanner;
  • the client authentication process is launched;
  • the EMEV process to confirm client eligibility is automatically launched;
  • was the client identification and eligibility confirmed?;
    --if YES, the provider conducts services as required;
    --if NO, the specific provider would follow its own internal process to confirm identification or provide services at risk of non-payment. This may involve the presentation of a state driver's license or some other form of photo identification. In such cases, if services were provided and billed to Medicaid, these cases may be flagged for HHSC-OIG review;
  • services are completed; and
  • the client presents the MIP card to the provider for check-out.

If the pilot determines that the use of MIP was successful, the agency plans to expand this program statewide and to develop it as part of a universal services card. The universal services card concept would allow clients to use one card for all state and federal services and benefits.

USDA has not determined if it is legal to use fingerprint images of WIC clients. Even if fingerprint technology is approved by the USDA for WIC and a universal card is issued by HHSC, it remains to be seen how this would work for WIC ID documentation. A key use of the fingerprint, if ultimately allowed by USDA, could be in detecting people enrolled in more than one WIC site who are fraudulently receiving duplicate benefits.

A key issue regarding fingerprint imaging of WIC clients is that WIC serves undocumented persons and capturing a fingerprint could keep eligible people from applying to the program. The program's services are critical from a preventive health aspect; for example pregnant women need the healthy foods WIC provides to have healthy children. These infants will likely be born in the U.S. and be American citizens and be entitled to potentially costly Medicaid services for health problems that could have been prevented by participation in the WIC program. Under the provisions of the Child Nutrition Act of 1966, as amended, and federal regulations governing the WIC Program, a state or a state agency administering WIC may limit program participation to U.S. citizens, nationals and qualified aliens as these terms are described in the Immigration and Nationality Laws. To date, no state or state agency has chosen to do so because it is believed this would result in increases in administrative costs to determine citizenship and immigration status; the loss of federal funds as caseloads decrease and the state's federal allocation is reduced over time; and increases in Medicaid costs.


Database Collaboration

The process used most often by HHSC to detect fraud and abuse in health and human services is referred to as "pay and chase," or when agencies catch fraud on the back-end. What this means is that most fraud and abuse control systems allow the fraud to occur and then once a pattern of fraudulent activities has occurred, the system catches the individual and requires him or her to pay back the money. Unfortunately, many who engage in fraud use the money or services as fast as they get it, so there is nothing for them to pay back once they are caught. To help address this problem, health and human service agencies must be more proactive and prevent fraud before it starts. To do this, health and human service entities around the country are tapping into databases to improve the eligibility process.

In Texas, the HHSC-OES uses the Texas Works Advisor, which provides access to official and private databases, including credit bureaus, to help verify eligibility. This system cannot verify identity, but future enhancements to the data broker system could allow the advisor to import images such as driver's licenses, birth certificates and Texas identification cards into the system. Agencies can use Texas Works Advisor to view demographic information and cross reference the Social Security number.

In addition, HHSC-OIG participates in several computer data matches for detecting waste patterns, abuse and fraud. However, the agency does not use data matches to verify the identity of clients for determining eligibility.

Unemployment Insurance Program

The Texas Workforce Commission (TWC) administers the state's unemployment insurance (UI) program, which was established in 1935 to help ensure workers' financial security. The U.S. Department of Labor (DOL) and the states jointly administer this complex program, which provides temporary cash benefits to workers who lose their jobs through no fault of their own. Generally, states are responsible for designing and implementing programs to determine eligibility, based on DOL guidelines.[8]

Comptroller Carole Keeton Strayhorn recommended in the 2003 report Limited Government, Unlimited Opportunity that TWC implement more effective fraud detection systems to improve program integrity and UI Trust Fund solvency.[9] UI fraud cases involve individuals who work while receiving benefits; who claim UI while on vacation or while otherwise not attached to the labor market; or who misrepresent their identities to claim benefits. Other methods include fictitious employer schemes and the use of illegal aliens to claim benefits in "kickback" schemes. Agency errors and inaccurate employer information or data that is delivered to the proper agency too late can also cause improper overpayments.[10]

By controlling benefit payments, ensuring claimant eligibility and protecting UI funds from fraud and potential overpayments, Texas can help keep the state UI trust fund solvent while keeping employer taxes to a minimum.[11]

TWC informs claimants of their responsibilities and established a series of steps for verifying applicant eligibility. The steps are:

  • TWC's automated benefits system provides intake staff members with access to claimant wage and employment history information when claimants first apply for benefits;
  • since May 1998, TWC has maintained six UI Tele-Centers to process unemployment claims and updates over the telephone; TWC processes claims only after confirming the caller's identity;
  • all claimants receive "benefits rights" information that also identifies penalties for providing false information, failing to report earnings or not seeking work;
  • claimants must certify that they understand the program's eligibility requirements and assert that their claim is valid and the payment is proper when they endorse UI checks;
  • claimants must participate in reemployment activities designed by local work force development boards promptly after filing their initial claims; a daily cross-match with the TWC benefits and WorkinTexas.com systems determine whether this requirement has been met; and
  • TWC investigates claimants who turn down job offers or fail to report for required reemployment services and may discontinue their benefits.[12]

TWC has made a number of encouraging improvements to its integrity program since 2000. Notably, TWC worked closely with the DOL-OIG to develop the Fictitious Employer Detection System (FEDS), a computer program that helps agencies detect certain types of employer fraud.[13]

TWC provided the Comptroller's office with a list of eligibility, fraud detection and overpayment recovery strategies the agency uses:

  • when TWC detects an overpayment, it notifies the claimant by mail and telephone—the agency assigns potentially improper UI payments to 62 investigators, 29 of whom are in the Central Office and 33 who are in the Tele-Centers;
  • TWC's Tax Department verifies wage record accuracy through the agency's benefits system and the UI wage reporting database;
  • TWC contacts claimants' former employers when undocumented wages are identified; if the wage discrepancies are not resolved, the Tax Department's field auditors conduct an investigation;
  • TWC cross-matches claimants' Social Security numbers through an electronic data exchange with the Social Security Administration to verify identity;
  • TWC uses several cross-matching programs that compare the information provided by each applicant for UI benefits with data systems in the state—these programs allow the agency to verify that all wages were reported and were accurate, to verify that an applicant is not receiving UI benefits in another state and to verify that applicants are not working;
  • TWC uses the U.S. Immigration and Naturalization Service's Systematic Alien Verification to Entitlement program to automatically verify the identity of foreign claimants and their eligibility to work in the U.S.;
  • the agency pursues overpayment collections through follow-up calls and collections letters;
  • TWC's automated and WorkinTexas.com systems identify UI claimants who have not completed a required application for work search services through their local work force board in a timely fashion, and automatically holds claimants ineligible for benefits until the work application is completed. Investigators also examine samples of claimant records to ensure that they made an active search for suitable work as required by law while receiving benefits;
  • all former claimants with outstanding overpayment debt are "flagged" in the UI benefits system so that TWC can reduce any new claim by the amount of the outstanding overpayment;
  • TWC files legal documents to attempt to recover claimant overpayments resulting from fraud or a significant amount of underreported earnings. If the recipient does not return the overpayment within 30 days, TWC files an abstract of assessment with the claimant's county clerk to place a lien against his or her property;
  • TWC has a toll-free phone number for employers and others to report fraud and improper payments and has added a "tip line" link on its agency Web site to allow visitors to report fraud.[14]
  • TWC aggressively seeks criminal prosecution of individuals involved in egregious cases of UI fraud; and
  • TWC has implemented a variety of other enhancements through its UI Apply for Benefits Internet application.

DPS License Requirements

The Texas Department of Public Safety (DPS) has a tiered method of documentation for verifying the identity of applicants seeking a driver's license. Every original applicant must present one piece of primary identification; or one piece of secondary identification plus two pieces of support identification; or two pieces of secondary identification.[15]

Items Required to Prove Identity For Texas Driver's License or Identification Card
Primary

Texas driver's license or identification card within two years of expiration;

unexpired U.S. passport;

U.S. citizenship (naturalization) certificate with a photo;

current U.S. immigration document with verified data and photo; or

current U.S. military ID card, (active, reserve or retired) with photo.

Secondary
(Recorded Government Documents)

Original or certified copy of birth certificate;

original or certified copy of U.S. Department of State certification of birth;

current driver's license or photo ID issued by another state or Canadian province.;

original or certified court order with name and date-of-birth; and

for applicants born before 1961, an original or certified copy of Form DD-214 or an original or certified copy of other state or federal record with name and date of birth.

Supporting Identification
(Other records or documents that aid in establishing identity)

School records;

insurance policies for people who are at least two years old;

a vehicle title;

military records;

a current military dependent ID card;

an original or certified copy of a marriage license or divorce decree;

a voter registration card;

a Social Security card;

a pilot's license;

a concealed handgun license;

a Texas driver's license temporary receipt;

an expired driver's license or ID from another state, Washington D.C., or a Canadian province within two years of expiration;

a foreign passport with or without a U.S. Visa; and

a consular document issued by a state or national government.


Recommendations

HHSC should develop a list of acceptable identification documents that can be used to determine an individual's eligibility for all health and human service benefits.

The State of Texas requires different identification documents for various services. HHSC should develop a list of accepted and approved identification documents much like the ones used by the Internal Revenue Service and the Texas Department of Public Safety's Driver's License Division. By adopting a list of approved identification documents, HHSC could help streamline and safeguard the eligibility process.


HHSC should adopt a tiered method of documentation to verify the identity of applicants for health and human service benefits.

A tiered method of documentation to verify the identity of applicants for health and human service benefits would allow for flexibility while ensuring the security of the eligibility process.


HHSC should work with TWC to enhance and update the HHSC system for determining eligibility.

By updating its eligibility determination system to cross match recipients' social security numbers, employment history and unemployment benefits with existing databases at TWC, HHSC can further protect the state's valuable resources.


HHSC should immediately modify the Texas Works Advisor system to accept digital images of identification documents to assist in the initial eligibility determination process.



Endnotes

[1]House Bill 2292 Section 2.143, 78th Regular Legislative Session, June 2003.

[2]Medicaid and Public Assistance Fraud Oversight Task Force Subcommittee Meeting Notes, February 17, 2004

[3]"Bush Signs Identity Theft Bill," Washington Post, by David McGuire, July 15, 2004.

[4]Texas Health and Human Services Commission, Ad-hoc Data, November 16, 2004.

[5]Telephone interview with Leslie Dehay, Office of Eligibility Services, Health and Human Services Commission, Austin, Texas, July 20, 2004.

[6]Texas State Auditor's Office, A Report on Contract Administration for the Texas Integrated Eligibility Redesign System, Report Number 04-034 (Austin, Texas, May 2004) <http://www.sao.state.tx.us/Reports/report.cfm/report/04-034/src/list>.

[7]Telephone interview with Leslie Dehay, Office of Eligibility Services, Health and Human Services Commission, Austin, Texas, July 20, 2004.

[8]Telephone interview with Steve Riley, director of Tax, UI Insurance and Regulation Division, Texas Workforce Commission, September 12, 2002.

[9]Texas Comptroller of Public Accounts, Limited Government, Unlimited Opportunity, "Issue GG32: Improve the Integrity of the Unemployment Insurance Trust Fund," (Austin, Texas, January 2003), p. 351. <http://www.window.state.tx.us/etexas2003/gg32.html>.

[10]U.S. Department of Labor, Office of Inspector General, Unemployment Insurance Integrity: Fraud and Vulnerabilities in the System (Washington, D.C., March 31, 1999), pp. 1-5.

[11]U.S. General Accounting Office, Unemployment Insurance: Increased Focus on Program Integrity Could Reduce Billions in Overpayments, p. 1, 2003.

[12]Materials provided by Cassie Carlson Reed, executive director of the Texas Workforce Commission, July 15, 2002.

[13]Telephone interview with Steve Riley, director of Tax, UI Insurance and Regulation Division, Texas Workforce Commission, September 12, 2002.

[14]Materials provided by Cassie Carlson Reed.

[15]Texas Department of Public Safety, Rule §15.24, Identification of Applicants, Title 37, Part I, Chapter 15, Subchapter B.



Appendix A

Program-by-Program Protocol and Verification Matrix
Program Protocol Acceptable Documents Copied and in File?
Food Stamps Verify the identity of the person interviewed.

If the authorized representative (AR) applies for the household, verify the identity of both the AR and the person he or she represents.

Exception: If there isn't time to verify both, verify the AR only.

At recertification, verify the identity of the person interviewed if they were not previously verified.

  • Valid drivers license or Department of Public Safety (DPS) ID card
  • Birth certificate
  • Hospital or birth records
  • Adoption papers or records
  • Work or school ID card
  • Voter registration ID card
  • Wage stubs
  • U.S. passport
  • Self-declaration of driver's license or DPS ID number already on file, along with other identifying information (i.e., social security number and date of birth)
  • Self-declaration of driver's license or DPS ID number listed on Data Broker, along with other identifying information (i.e., social security number and date of birth)
Yes
TANF If questionable, verify the identity of the person interviewed. Same as above Yes
Medicaid All Medicaid Programs --

If questionable, verify the identity of the person interviewed.

Identity of a pregnant woman must be verified at the time of her application.

Same as above Yes
CHIP Self Declaration N/A No
WIC At each certification and subsequent certification:

NOTE: Verification is not required by a third party.

Staff members record the type of ID presented. They enter it on a paper form and put it in the automation system.

Clients sign a statement that says the information they provided is true.

Each adult and child applicant must present ID. A parent or guardian applying on behalf of a child must also present an ID for himself or herself.

  • Birth certificate
  • Hospital records
  • Baptismal certificate
  • Marriage license
  • Driver's license
  • WIC ID card
  • Immunization card
  • School or employee ID card with a picture
  • Military ID
  • Other official ID with a picture
  • Passport or immigration records
  • Medicaid, food stamps or TANF letter
  • Indigent health care ID
  • Check stub with name printed on it
  • Voter registration card
  • Local agency clinic card
  • Supplemental Security Income letter
  • Social Security Card
  • Housing or rental lease
  • Loan papers from a lending institution
  • Property tax receipt
  • Self declaration in limited circumstances
  • WIC Lone Star Card and demonstration of knowledge of PIN -- currently applicable only in EBT pilot
  • Local service delivery providers can add other documents with prior approval from DSHS.
No