Assess whether identity proofing exceptions are being abused (906c4a)

SITUATION TANF work-requirement monitor in a UI shop after a synthetic-identity filing spike has one working extract — housing overlapping-address and income file — after an identity-proofing vendor outage that opened a manual path. If housing overlapping-address and income file cannot support identity proofing exceptions are, the only defensible Public Benefits output is hold.

DECISION TANF work-requirement monitor in a UI shop after a synthetic-identity filing spike must choose Pay or continue / Recoup / Deny / Hold using housing overlapping-address and income file after an identity-proofing vendor outage that opened a manual path.

HYPOTHESES TO TEST 1. Housing overlapping-address and income file reads as Pay or continue once an identity-proofing vendor outage that opened a manual path is lined up to the same Public Benefits population. 2. Housing overlapping-address and income file is closer to Recoup after an identity-proofing vendor outage that opened a manual path; Pay or continue would over-claim this Compliance and Integrity Operations extract. 3. Deny is still live in housing overlapping-address and income file for TANF work-requirement monitor in a UI shop after a synthetic-identity filing spike. 4. Housing overlapping-address and income file is missing the fact TANF work-requirement monitor needs after an identity-proofing vendor outage that opened a manual path; stop this Public Benefits close.

ANALYSIS REQUIRED 1. Separate a case-level error from a program-design failure in a UI shop after a synthetic-identity filing spike. 2. Match household facts in housing overlapping-address and income file to the rule that pays the benefit. 3. Trace the notice and appeal path TANF work-requirement monitor must preserve. 4. For this Public Benefits Compliance and Integrity Operations file, read housing overlapping-address and income file against an identity-proofing vendor outage that opened a manual path and write the one fact that would move identity proofing exceptions are for TANF work-requirement monitor.

RECOMMENDATION Choose Pay or continue / Recoup / Deny / Hold on this Public Benefits / Compliance and Integrity Operations packet (housing overlapping-address and income file after an identity-proofing vendor outage that opened a manual path). If housing overlapping-address and income file cannot force a Public Benefits label under Compliance and Integrity Operations, stop. If housing overlapping-address and income file after an identity-proofing vendor outage that opened a manual path cannot support Pay or continue versus Recoup on this Public Benefits Compliance and Integrity Operations close, TANF work-requirement monitor must do not pay, recoup, or deny beyond the eligibility record.