Social Services should track counties' prosecution thresholds for welfare fraud cases and determine whether they affect counties' decisions to investigate potential fraud, with a focus on determining best practices and cost-effective thresholds. If Social Services' analysis determines that varying prosecution thresholds do affect counties' decisions, it should then work with counties to implement the consistent use of these cost-effective prosecution thresholds.
Disagree with recommendation.
See response to Recommendation 4.
Counties are mandated to make a fraud referral for investigation regardless of any prosecution threshold (MPP Section 20-005.1). Therefore, counties' prosecution thresholds cannot affect counties' decisions to investigate potential fraud.
Social Services cites its own policy manual when indicating that counties are mandated to make a fraud referral regardless of any prosecution threshold. Our recommendation is asking Social Services to re-evaluate this policy and potentially establish prosecution thresholds based on fraud totals that are cost effective to pursue. Instead of gathering information to evaluate the feasibility of this potential approach, Social Services simply reiterates its existing policy.
Social Services reasserts its position that there is no direct relationship between a prosecution threshold and counties' decision to investigate welfare fraud. As the Department has explained previously, counties have an obligation to make a fraud referral for investigation regardless of any prosecution threshold.
Similar to its previous response, this response by Social Services is supposition. Our recommendation is for Social Services to analyze actual county practices in order to determine whether or not counties' prosecution thresholds affect counties' decisions to investigate potential fraud.
See initial response.
Social Services reasserts that there is no direct relationship between prosecution thresholds and counties' decisions to investigate welfare fraud. However, and as we explained in our comments on the initial response that Social Services provided in the follow-up audit report, Social Services has not taken any action to track how counties determine prosecution thresholds and the effects those thresholds on counties' decisions to investigate potential welfare fraud. We continue to expect Social Services to demonstrate the presence or absence of this effect through an analysis of actual county practices, rather than through supposition.
Agency responses received are posted verbatim.