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DSL Memo Series 2002-15
ACTION MEMO

October 15, 2002

STATE OF WISCONSIN
Department of Health and Family Services
Division of Supportive Living

To:
County Departments of Human Services Directors
County Departments of Social Services Directors
County IM Managers

From:
Sinikka McCabe, Administrator

Re: FINDINGS OF SSA REVIEW OF INTERIM ASSISTANCE REIMBURSEMENT (IAR) IN WISCONSIN AND MEASURES TO BE TAKEN BY COUNTIES

Document Summary

This memo contains findings and corrective measures to be taken by county agencies subsequent to the Social Security Administration's (SSA) recent review of Interim Assistance Reimbursement (IAR) cases in Wisconsin.

The Social Security Administration (SSA) recently completed its review of Interim Assistance Reimbursement (IAR) cases in Wisconsin. The review occurred during the months of May 2002 through August 2002 and involved review of 112 cases of IAR that occurred during the months of January through August 2000. The findings subsequent to this review have been released to the Department of Health and Family Services (DHS ).

The SSA found that county agencies were generally performing well in paying individuals timely and reporting to the SSA Regional Office as required. However, there are four areas where the required IAR procedures are not being consistently followed. Several of these areas constitute serious errors. The SSA has required the Department to communicate the errors and the correct procedures to all counties in order to eliminate the occurrence of these errors in the future. In addition, the Department will contact county agency directors regarding plans of correction for specific instances of error that were identified part of SSA's review. Please review your county's procedures and modify them if necessary to comply with the federal requirements.

Errors in the four areas noted by SSA, along with correct procedures, are as follows:

Problems Area 1 - Incorrect Payment to Individuals

The SSA noted five instances in which the county recovered assistance from SSI for a month for which SSI was not received. Often, counties begin providing assistance under IAR to an individual the same month that the individual applies for SSI. However, SSI payments begin for an eligible individual the month following the month of application for SSI. When the initial SSI payment is received at the county agency, the county may only recover assistance it provided to the individual during the same month(s) the individual was eligible for SSI. The only exception occurs if a county agency has a welfare payment in process that could not be stopped at the time the IAR check was received. This payment can be included in the reimbursement due to the county. The case file should include documentation to reflect this situation.

Problem Area 2 - Delayed Payments to Individuals

The SSA noted seven instances in five counties where the county delayed payments to individuals for periods of time from 11 to 37 workdays. Any excess amounts of SSI due to individuals must be paid within 10 workdays of receipt of the IAR check at the agency. In addition, if the county agency receives an IAR check, but does not receive the SSA-8125 notice from SSA, they should contact the local SSA office and request a manual replacement SSA-8125 so that payment to the individual may be processed timely.

 Problem Area 3 - No Apportionment Notice or Incomplete Notices in File

The SSA noted 33 instances in 12 counties where proof of written notice of apportionment and/or appeal rights was lacking. The SSA has categorized this finding as a serious problem. A complete written notice, including appeal rights, must be issued to the individual in all cases when a county receives an IAR check. This requirement also includes instances when the IAR payment is received in installments or when the entire amount of the IAR check is due the agency. In all cases a written notice to the SSI recipient is required with a copy included in the case file.

Problem Area 4 - Copy of Claimant Authorization Not in File

The SSA noted one instance where the claimant authorization was missing from the county file. While this appears to be an isolated case, agencies are generally reminded to maintain a copy of the individual's authorization in the county agency file.

The Department requests that all county agencies review the contents of DSL Administrator's
Memo 2002-08, Revised Interim Assistance (IAR) Agreement, and the findings noted by SSA, above. Please take immediate steps to modify your agency's procedures to comply with these expectations. Thank you for your assistance and cooperation with this request.

Please contact Kathleen Luedtke at (608) 266-6890 if you have questions about the contents of this memo.

REGIONAL OFFICE CONTACT:
Area Administration Team

CENTRAL OFFICE CONTACT:
Kathleen Luedtke
SSI Coordinator
(608) 266-6890

cc: Area Administrators/Assistant Area Administrators
Bureau Directors
County Departments of Community Programs Directors
County Departments of Developmental Disabilities
Services Directors
County Long Term Support Coordinators
Licensing Chiefs/Section Chiefs
Tribal Chairpersons/Human Services Facilitators
Bureau Director, Health Care Eligibility

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