To ensure the accuracy and consistency of the information on welfare fraud activities that counties report and that Social Services subsequently reports to the federal government, the Legislature, and internal users, Social Services should incorporate the upcoming federal changes to the revision of its instructions for completing the counties' investigation activity reports. In the interim, Social Services should issue clarifications for the most common errors Social Services observes counties make in reporting their investigation activities.
The United States Department of Agriculture Food and Nutrition Service (USDA/FNS) issued Administrative Notice 16-39 informing states of a revised FNS-366B Program Activity Statement. The revised FNS-366B requests SNAP (CalFresh) fraud investigation data not currently captured on the State Fraud Investigation Activity Report (DPA 266) that all counties submit to CDSS monthly. In response to the Administrative Notice, CDSS has been engaged with all 58 counties, established a statewide workgroup and revising the DPA 266 to capture the required data elements needed for the FNS-366B reports. The revised DPA 266 report will be operational by December 31, 2017. CDSS issued a "California Department of Social Services Fraud Investigation Activity Report (DPA 266) Common Reporting Errors, Questions and Answers" report to all counties in March 2016. DPA 266 link: http://www.cdss.ca.gov/Portals/9/DSSDB/AutomatedForms/DPA266.xls?ver=2017-02-28-144047-573
The USDA/FNS indicates that states should use the revised FNS-366B for the federal fiscal year beginning October 1, 2016. Therefore, to appropriately implement the revised federal reporting, the department should have engaged in an effort to revise the DPA 266 report before the new federal reporting requirements took effect in October 1, 2016.
A revised Department of Public Assistance (DPA) 266 form (Fraud Investigation Activity Report) will be completed by January 2017. CDSS will issue new instructions to the counties before counties begin using the new form. Due to county and consortia programming requirements, implementation may take up to 18 months.
CDSS notified the counties on March 2, 2016 of common reporting errors and provided Frequently Asked Questions (FAQs) for their use.
Although Social Services issued clarifications to its reporting instructions as we had recommended, it has not revised its reporting instructions to incorporate clarifications for common reporting errors as well as the new federal reporting instructions.
In order to complete the internal review of the All County Letter (ACL), CDSS is rescheduling the release date of the ACL to stakeholders for feedback to January 2016.
CDSS is beginning to identify common errors and will disseminate, via county notification, instruction on how to prevent and correct those errors.
Agency responses received are posted verbatim.