8/20/13 QC SNAP TAG Meeting - Notes provided by Christine Hurschman (DE)

8/20/13 – FNS SNAP QC TAG Meeting – Patrick Lucrezio and Dave Young CAPER error rate - people didn't know the error causal breakdown. FNS surprised that unclear notices 2% of error but alarmed at other items like no notice going out at all, or verifications were in the record and not acted on. There is no legislation for Negatives to be sanctioned, so State IT want to wait until after ARA is in place to be able to make any changes to comply with notice requirements. Participants indicate this is a resource issue for States. Policy FNS has asked regional staff for good and bad notices - think they would need to go through notices and give a policy memo on good notices and what they expect to be in notices. Would be suggestion of the Memo. Hope would be to get to DSS (local State agency) policy units engaged. FNS wants field workers to really work on their processing of information - such as enter information right away. Collins Greer comment - feels that QC is now dictating policy to field. FNS - feel that processing is addressed in CFR regulations and it isn't something that QC just came up with. Certain elements of the regulations were not looked at in previous QC review methodologies. Carolyn (MD) comment – Some regional offices are looking at cases differently than other regions. FNS – Doesn’t feel this is true as regression across the country was fairly consistent. Some regions had higher regressions and those cases went to arbitration and lost. Most region within 3-4% in regression - they are not looking at the reasons behind the regression or that the same notice is either called valid or invalid between regions. Don't believe the differences are so broad to throw off statistics. John (VA) comment - most States lose in arbitration (except Delaware). FNS - feel that the regional offices are coding things correctly and that you don't always win Arbitrations. Patricia (NC) comment - questions from States FNS - will not comment on an arbitrator decision How specific do you have to be on a notice - subjectivity should be easily understandable and shouldn't have things that are conflicting information. You can give more than one reason on notice as long as all are correct. Example: the household provides some but not all of the verifications requested and case is denied for non-cooperation. Notice should say what specific verifications that they haven’t given you to make it understandable. If all verifications are missing, then you would be ok to say "you did not return verifications". If some of the verifications were provided then the notice should specify which verification(s) were missing. Every State is telling the client up front of all the verifications, but should be saying specifically what is still missing. FNS Dave Young - Say that their certification people are put in the position that the reason the adequacy is not important because QC isn't looking at it. Now QC has changed and we are all adapting. FNS Patrick Lucrezio - pick the big problems first then the other things later. Use the breakdown of causal factors to assist you. Notice issues are just a little bit higher than Eligibility problems. Maybe not get so upset about it when you have other problems to work on. Recommends use of the 10-day waiver to deny early as a tool to use to get the work out. Collins Greer (AK) comment - thinks there is a FNS change in philosophy over the last year and is a different than what was explained in the beginning of FY12. Q+A's that were released - some regions were told to hold on different questions FNS - question number 8 about the client moving out of State. Notice would acceptable to say that no member eligible. But should say that moved out of state. That is the one that should change in the Q+A. That is the only one that is going to change. Clarification on Q+A - question 7 living with mom - household eligible for expedited. No have to have an interview before determining expedited. Policy memo feb 6-06 with regard to expedite the interview is a requirement and cannot determine eligible for expedite. ex - living w mom and has income, cannot expedite without finding out if mom has income; cannot just consider him separate household. (IS UNDER 22?) FNS Patrick Lucrezio - feels guidance is hard to be broad and all are specific to the situation. Maybe in future, summit specific questions with layers. 310 is not certification policy. it belongs with policy not QC. Won’t put in certification policy in the 310-manual FNS Patrick Lucrezio - Identify the element that had the most impact on the case so field can do corrective action. The predominant causal factors are the egregious problems. Question: may mean more if got hold harmless. FNS Patrick Lucrezio - no hold harmless periods available but States can submit questions to region and get an answer in writing. FNS Patrick Lucrezio – States can submit question from region - now is not sent to all regions, FNS will consider disseminating informal opinion. Question: if income listed on notice is slightly off by $1, then invalid negative occurs FNS Patrick Lucrezio - If you are being specific enough to list the income, why wouldn't it be accurate? FNS Patrick Lucrezio - completion rate study – some site visits to get an idea of how States are improving their completion rates. Surveys will be conducted in every state by phone. You don't know what you don’t know. It is something to help. They are taking into consideration State busy and want to get good information. For corrective action on negatives; if have negative error should do corrective action plan over 1%. The responses should be from policy on the errors but be realistic. FNS Dave Young - There are no QC errors. There are errors in the certification that are discovered by QC. Somebody screwed up and it wasn't us. Will give breakout of the CAPER rate. When they broke out four categories based on State reported data, and it was problematic. The instructions do say that you use the one that was the most likely the major cause of the error. Consider is important for corrective action. The data should still give you accurate data as to where the error is coming from, and can break them down into smaller percentages and can double check what the errors are from. FNS Dave Young - said that the evaluation of negatives was not thought through. He thinks eligibility is first then timeliness. But other States have other opinions. Will be drafting changes to coding which will better show multi errors.