Integrity of the Quality Control Review Process
The Food and Nutrition Service (FNS) and State agencies share a common goal to improve payment accuracy. However, attempts to achieve this goal must not compromise the objective nature of the food stamp quality control (QC) process. The specific purpose of QC is to obtain an accurate measure of error rates. A State agency administering the Food Stamp Program is responsible for insuring that its QC sample and reviews remain free from unacceptable bias. If a State or local agency treats QC sampled cases differently from non-sampled cases or treats certain sampled QC cases differently from other QC sampled cases, the review results will not mirror the overall level of accuracy of a caseload. It does not matter whether such actions are intentional or unintentional. It is a form of bias and may compromise the QC sample.
FNS is responsible for overseeing the QC system and providing guidance to State agencies on designing and administering review systems. Without consistent, unbiased standards for sampling and reviewing cases, the integrity of the system would be compromised. Under such circumstances, if a State agency’s error rate becomes questionable due to the introduction of unacceptable bias, FNS has the authority to assign an error rate to a State agency. This action may also result in a suspension or disallowance of Federal funding.
The following types of actions represent examples of activities that produce an unacceptable bias in the QC system:
- The State or local agency adding documentation to, or removing documentation from, the official record of a sampled case.
- An eligibility or certification worker contacting a QC sampled household or collateral contact to obtain additional information in an attempt to clarify the household’s circumstances, get statements that would alter the findings of the QC reviewer, or coerce the household into saying or doing anything that might misrepresent the household’s circumstances. A local office may request that QC reexamine some aspect of the case, but QC makes the decision on the case based on QC policy and practices.
- A QC reviewer contacting the eligibility or certification worker responsible for administering the case selected for QC review. This also includes contacting any eligibility or certification staff who participated in the certification action under review. An exception is made for a situation where the QC reviewer needs assistance from a local office to locate, or gain the cooperation of the household. In such situations, contact must be strictly limited to locating the household or gaining its cooperation with the QC reviewer.
- The State or local agency asking or coercing a household to engage in any activity (such as not participating in the QC sample month) for the ultimate purpose of gaining a desired case disposition or finding in a QC review.
- The State or local agency reducing a household’s allotment for the sample month because of an apparent overpayment in a sampled case.
- Once the sample has been pulled, local offices should not review the cases, make changes that would affect the eligibility or benefits for the cases, or contact the household or a collateral contact prior to the QC review being conducted in order to make any changes to the case. This does not apply to routine case management changes such as filing household reports, acting on reported changes, issuing notices of expiration, or conducting recertification interviews. Normal case management activities should not be initiated or undertaken at an accelerated pace in order to affect the cases under review.
In addition, questions have arisen on the appropriateness of some activities undertaken by error review committees. The error review committee’s role is primarily one of reviewing cases to assess for future corrective action planning, not to review individual error cases to assess the potential for reducing or eliminating errors in a sampled individual case. Error review committees should incorporate and maintain procedures that minimize the likelihood of unacceptable bias being introduced into the QC review process. Attached is a document recently released by FNS as one of the ten keys to payment accuracy that, in addition to outlining the effectiveness of the committees, includes a discussion on inappropriate local office involvement in this process.
Thank you for your attention to this important matter. We know that States share our commitment to a fair and unbiased QC system. If you have any questions or concerns on this issue, I urge you to contact your appropriate FNS regional office.
Karen J. Walker
Program Accountability Division