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TitleThe Bureau of Program Integrity's 2013-2014 Review of the Department of Transitional Assistance ...
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Office of the Inspector General
Commonwealth of Massachusetts

Glenn A. Cunha

Inspector General

The Bureau of Program Integrity’s

2013-2014 Review of the Department

of Transitional Assistance

February 28, 2014

One Ashburton Place, Room 1311 | Boston, MA 02108 | (617) 727-9140 |

Page 73


TAOs created forms without approval from the Central Office. In order to design the document

index in myWorkspace, the Department reviewed and modified a significant number of forms,

and provided EOHHS and PCG with a central list of documents. Now that the Department has


TAOs. As the Department continues with modernization efforts, the Department will need to

make similar (and more complex) decisions to streamline operations and commit to uniformity in

all aspects of eligibility processing.

As discussed above, EDM has the potential to benefit the Department and its business processes

by eliminating both paper files and the need for recipients to provide the same verification

documents on multiple occasions. EDM promotes efficient use of resources by providing

immediate access to key eligibility documentation, but the transition to EDM will involve

splitting case files into electronic and paper components and could bring confusion and


C. Business Process Redesign

After EDM is fully implemented, the Department will transition into broader Business Process

Redesign (BPR) which involves identifying, analyzing and redesigning business processes in

order to improve efficiency, quality of service, accuracy and timeliness.76

According to the Department, BPR planning and implementation will continue through

September 2014. As of this report, the Department reported plans to implement the

intake/ongoing model, as recommended by external consultants and the USDA, throughout the

TAOs. However, the Department is still refining specifics for the scope and application of the

model, specifically whether it will apply only to SNAP cases or to cash assistance cases as well.

For functional support, the Department has indicated that it will continue to partner with EOHHS

ill streamline the eligibility determination process by prompting

staff to complete verification steps based on documents received and eligibility deadlines. Here,

too, the Bureau has identified concerns about the challenges of transforming long-standing,

disparate business practices at TAOS within a short period of time. The changes are long

overdue, but the implementation will be complex, and the Department will need to coordinate all

of its leadership, policy, operations and training resources effectively.

VI. Observations and Analysis: Internal Controls

In this section of the report, the Bureau focuses on the legislative mandate to review the

management and operations of the Department and recommend whether they support eligibility

processing and fraud identification. As part of its review, the Bureau will explain the concept of

internal controls, describe the standards for internal controls that apply to Commonwealth


to focus specifically on internal controls as they influence all areas of management and

operations, and therefore serve as an instructive point of reference for a broader analysis. The


See USDA report, supra.

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Department has started working towards creating a framework for internal controls, but must

build a much more functional infrastructure based on detailed and comprehensive controls.

A. Introduction to Internal Controls

Internal controls are management and oversight processes designed to promote effective

operations, consistent business practices, efficient use of resources and compliance with

applicable laws and regulations. A framework of internal controls provides an essential

infrastructure for an organization to achieve its goals and fulfill its mission. There is a common

misconception that internal controls requirements apply only to accounting and audit functions.

The concept of internal controls is much broader, and involves basic concepts of strategic

planning and oversight.77

In Chapter 647 of the Acts of 1989, the Legislature set forth several minimum requirements for

internal controls at state agencies. Pursuant to the statute, state agencies must design and

structure systems of internal controls according to guidance issued by the Office of the

Comptroller. Each agency must identify a senior manager to ensure compliance with this

legislation, to oversee internal controls systems and to evaluate and address ongoing internal

controls concerns. Additionally, each agency must document its procedures related to internal


In accordance with the statute, the Office of the Comptroller promulgated a guidebook called

detailed instructions on how to implement controls into the management and operations of

Commonwealth agencies.78 states that every employee of a state

agency must be responsible for developing, implementing and monitoring internal controls. As

for managers, this is a core function and not an extraneous


B. Analysis

To guide this analysis

several key components for internal controls:

organizational culture; setting objectives; risk identification; risk assessment; risk response;

control activities; information and communication; and monitoring. These components are


See Office of the Comptroller -7. Throughout its guide, the

Office of the Comptroller relies on and incorporates standards set by the Committee of Sponsoring Organizations of

the Treadway Commission (COSO). COSO is a national, private sector organization dedicated to improving the

quality of financial reporting.


revise and publish internal control guidelines mandated by chapter six hundred and forty-seven of the acts of

nineteen hundred and eighty-

See id. at 25-30.

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Massachusetts Department of Corrections
The state Department of Corrections sends the Department of list of all indivduals incarcerated in a state correctional facility. The
Department then compares this list against its list of recipients.


SSA Prisoner Verification
The Department sends a list of all recipients to federal Social Security Administration (SSA). The SSA compares that file to a list it
maintains of incarcerated individuals throughout the country. The SSA then sends a list of those recipients that match back to DTA.


Hampden County House of Corrections
A monthly incoming batch match whereby the Hampden County House of Corrections sends a list of all incarcerations for the previous


Berkshire County House of Corrections
A monthly incoming batch match whereby the Berkshire County House of Corrections sends a list of all incarcerations for the previous


Plymouth County House of Corrections
A monthly incoming batch match whereby the Plymouth County House of Corrections sends a list of all incarcerations for the previous


Rhode Island Department of CorrectionsThe Department receives information on individuals incarcerated in Rhode Island and compares it to a list of recipients. Monthly

Parole Violator The Department matches with the state Criminal Systems History Board to obtain information on recipients who may be parole violators. Weekly

CJIS Warrant Inbound
The Department sends a list of recipients to the federal Criminal Justice Information Services (CJIS) which identifies any recipients that have
outstanding warrants.


SSA 40 Quarter
A match the Department uses with the federal Social Security Administration (SSA) to verify whether a Legal Permanent Resident has
worked the required 40 quarters in order to become eligible for SNAP and TAFDC benefits.


National Change of Address
The Department utilizes the National Change of Address (NCOA) database maintained by the United States Postal Service (USPS) to update
mailing addresses. When a recipient updates their mailing address with the USPS, the address will be updated in the NCOA database which
the Department will then use to update recipient addresses in BEACON.


Other Matches

Prisoner Matches

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