SEPARATION OF DUTIESCONFLICT OF INTEREST

POTENTIAL FRAUD

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OIG 2013 Vendor Management AuditGAO 2013 Income Eligibility Determination Audit

Missouri Vendor Management Evaluation- August,2013

Missouri State Technical Assistance Review ME- March, 2014Local Agency Review- March 3 – 7State Agency Review- March 24 – 28

ME Updates TrainingJanuary/February- Nutrition ME TrainingMarch- Administration ME Training 2

7CFR 246.4 (26)State Plan must include:The State agency's policies and procedures for preventing conflicts of interest at the local agency or clinic level in a reasonable manner. At a minimum, this plan must prohibit the following WIC certification practices by local agency or clinic employees, or provide effective alternative policies and procedures when such prohibition is not possible:(i) Certifying oneself;(ii) Certifying relatives or close friends; or,(iii) One employee determining eligibility for all certification criteria and issuing food instruments, cash-value vouchers or supplemental food for the same participant.

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WOM ER# 1.07000 Program Integrity

Conflict of Interest Separation of Duties Potential Fraud

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The LWP shall ensure WIC employees are not providing WIC services to themselves, their relatives, and/or their close friends, including the following functions:

Determine Eligibility Health Assessment Nutrition Education Issue Food Instruments Re-evaluate Food Package Serve as proxy unless signed form on file.

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What you must do if any employee, relative, or close friend is applying for or receiving benefits:

Notify your WIC CoordinatorReceive Services during Normal Clinic HoursSchedule appointments when other employees can perform the functions.Records must be made available at monitoring.

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QUESTIONS?

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Revisions have been made to the following policies:Local WIC Provider (LWP) Personnel: WIC Coordinator ER#1.01250 Appropriate Tasks: Administrative/Clerical ER#1.01400

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During the certification process the LWP employeeshall not determine eligibility for identity, residency, and income, and also issue food instruments to the same participant.

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LWPs shall ensure compliance with separation of duties in the Certification process.

Separation of Duties designation in the LAP each year.

Report any changes which will affect separation of duties to your TA Team.

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Any time a clinic site has fewer than two WIC employees performing certification duties, the WIC Coordinator or designee shall conduct a review of ten (10) randomly selected participant records certified at that clinic during the previous six months.Document record reviews on the Separation of Duties Exception Log.

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State TA staff must be notified when:

Only one WIC employee is available to perform certification duties on regular basisNo other WIC employee available to perform review.

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When only one employee is performing certification duties temporarily, the state TA staff must be notified and will review a minimum of ten (10) randomly selected participant records in MOWINS every six months.Document record reviews on the Separation of Duties Exception Log.

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When compliance cannot be achieved, inform the state WIC office and establish appropriate controls:Review 10 records every 6 months Separation of Duties Exception LogSignature of Reviewer on the logAvailable for WIC contract monitoring Report evidence of potential fraud to WIC state office

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LWP staff must run Last Certification Date List in Crystal Reports to select 10 participant records to review and document on the Exceptions Log.Select records to review by:Agencies with one staff satellite use clinic #Agencies taking walk-ins on non-clinic days with only one staff use dates

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Record the following on the Exception Log:SWID of Each Participant Record ReviewedDoes Cert History tab show two different User

IDs?FIs Issued With Proofs MissingMissing Data Participant Signature PresentGeneral Note Indicates 2nd Person Verified a

Proof

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Check Either:No Indication of FraudPotential Fraud and/or abuse

If potential fraud is indicated, send to WIC State Office:Documentation of reviewNature of fraud detectedDollar amount of loss Reviewer must sign Exception Log

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WIC Clinic one day per week.Clerk and CPA, with Nutritionist working only 1 day per month. CPA is WIC Coordinator.Clerk and CPA are full time employees of Health Department. Agency takes walk-ins. Clerk completes all demographics and CPA or Nutritionist prints checks.Walk-ins on other days - Clerk completes demographics and CPA prints checks. No Review of records is required.

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WIC Clinic one day per week. Clerk and CPA are full time employees. Nutritionist works 1 day per month. CPA is WIC Coordinator. Walk-ins on non-WIC days. Clerk completes demographics. CPA or Nutritionist confirms ID or residency or income proof, notes review of proof in MOWINS General Notes and provides nutrition education. Clerk prints FIs.Walk-ins on other days - Clerk completes demographics. CPA confirms ID or residency or income proof, notes review of proof in MOWINS General Notes and provides nutrition education. Clerk prints FIs.No Review of records required.

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WIC Clinic one day per week .Clerk and CPA, with Nutritionist working only 1 day per month. CPA is WIC Coordinator.Walk-Ins seen other days by CPA only who also works in the health dept. Clerk completes demographics. CPA confirms ID or residency or income proof, notes review of proof in MOWINS General Notes and provides nutrition education. Clerk prints FIs.  Walk-ins on other days – CPA completes certification and prints FIs. Nutritionist or Clerk reviews 10 records every 6 months.

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WIC Clinic one day per weekCertifier and HPA, with Nutritionist working only 1 day per month. Certifier is WIC Coordinator. HPA only works WIC Clinic days. Walk-Ins other days. Certifier completes demographics. HPA or Nutritionist confirms ID or residency or income proof and notes in MOWINS General Note. Certifier or HPA prints FIs. Walk-ins on other days - Certifier completes certification and prints FIs. HPA or Nutrition Coordinator reviews 10 files every 6 months

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WIC Clinic 5 days per week with 7:30 to 5:30 hours. Certifier and CPA. Nutritionist 3 days per month. Certifier or CPA is the only staff in clinic for 2 hours per day. Certifier is the WIC Coordinator Certifier completes demographics. CPA or Nutritionist confirms ID or residency or income proof and notes in MOWINS General Notes. Certifier prints FIs.For hours when only 1 staff working in clinic, Certifier or CPA completes certification and prints FIs and Nutritionist reviews 10 records every 6 months.

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WIC Clinic 5 days per week. Multiple Clerks/Multiple Nutritionists every day. Nutritionist is WIC Coordinator. Clerk completes all demographics. Nutritionist prints checks.

Clerk completes demographics. Another Clerk confirms ID or residency or income proof, notes in MOWINS General Notes and prints FIs. Clerk completes demographics. Nutritionist confirms ID or residency or income proof and notes in MOWINS General Notes.Clerk or Nutritionist prints FIs. No Review of records required.

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WIC Clinic Saturday hours.Certifier is the only WIC staff working in the clinic.WIC Coordinator works only weekdays in the clinic. Certifier completes certification and prints FIs.WIC Coordinator reviews 10 records every 6 months.

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WIC Satellite Clinic 1 day per month.Certifier or CPA only in satellite clinic. WIC Coordinator works at main site. Certifier or CPA completes certification and prints FIs.WIC Coordinator reviews 10 records every 6 months.

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WIC Clinic 4 days per weekClerk, Certifier and CPA, with Nutritionist working only 2 days per week

Clerk completes demographics. Certifier , CPA or Nutritionist confirms ID proof and notes in MOWINS General Notes . Anyone may print FIs.

Clerk completes all demographics and Certifier, CPA or Nutritionist may print FIs. No Review of records required.

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WIC Clinic 1 day per week.Nutritionist is the only WIC employee, as there is a vacant WIC Certifier/WIC Coordinator position.

Nutritionist completes the certification and issues FIs. Assigned TA staff would review 10 records every 6 months and complete the Exception Log. Clinic would retain the Exception Log for monitoring.

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QUESTIONS?

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Food Instrument Issuance ER#3.04800Ensure program integrity and preventing

conflict of interest.Comply with Separation of Duties related to

accountability and control of FIs.

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Participant Fraud - “Buying or selling WIC Food Instruments (FIs), foods or formula or allowing someone else to do so, posting WIC FIs, foods or formula for sale in newspapers or on the internet, giving away WIC FIs, foods or formula or altering WIC FIs in any way.”

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Employee Fraud – “The intentional conduct of a State, local agency or clinic employee which violates program regulations, policies, or procedures, including misappropriating or altering FIs or cash-value vouchers, entering false or misleading information in case records, or creating case records for fictitious participants.”

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The online fraud reporting tool link is located on the main WIC web page at: http://health.mo.gov/living/families/wic/index.php

The direct link to the reporting tool is: http://health.mo.gov/living/families/wic/wicfraudform.php

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Information regarding reporting sources is kept confidential and reports can be made anonymously.

The state WIC office receives daily notices of any allegations of fraud that are reported on the website.

All fraud reports are investigated by the State WIC office and entered in the fraud tracking database.

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QUESTIONS?

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