Assess whether identity proofing exceptions are being abused (be2ffa)

SITUATION After an identity-proofing vendor outage that opened a manual path, TANF work-hours that cannot be corroborated is what housing-subsidy fraud investigator can touch in a housing authority with overlapping subsidy households. Public Benefits will live with Pay or continue versus Recoup on this Recoupment and Policy file.

DECISION Housing-subsidy fraud investigator in a housing authority with overlapping subsidy households must choose Pay or continue / Recoup / Deny / Hold using TANF work-hours that cannot be corroborated after an identity-proofing vendor outage that opened a manual path.

HYPOTHESES TO TEST 1. An identity-proofing vendor outage that opened a manual path is noise around an already-controlled Recoupment and Policy process in a housing authority with overlapping subsidy households, given TANF work-hours that cannot be corroborated. 2. An identity-proofing vendor outage that opened a manual path is the event in TANF work-hours that cannot be corroborated that forces Pay or continue for housing-subsidy fraud investigator under Public Benefits. 3. TANF work-hours that cannot be corroborated shows a one-file miss after an identity-proofing vendor outage that opened a manual path, not a Recoupment and Policy program failure. 4. TANF work-hours that cannot be corroborated cannot decide identity proofing exceptions are yet after an identity-proofing vendor outage that opened a manual path; hold is the only Public Benefits close a housing authority with overlapping subsidy households can defend.

ANALYSIS REQUIRED 1. Trace the notice and appeal path housing-subsidy fraud investigator must preserve. 2. Test eligibility, recoupment, and improper-payment facts in TANF work-hours that cannot be corroborated after an identity-proofing vendor outage that opened a manual path. 3. Quantify overpayment if identity proofing exceptions are is wrong. 4. For this Public Benefits Recoupment and Policy file, read TANF work-hours that cannot be corroborated against an identity-proofing vendor outage that opened a manual path and write the one fact that would move identity proofing exceptions are for housing-subsidy fraud investigator.

RECOMMENDATION Choose Pay or continue / Recoup / Deny / Hold on this Public Benefits / Recoupment and Policy packet (TANF work-hours that cannot be corroborated after an identity-proofing vendor outage that opened a manual path). If TANF work-hours that cannot be corroborated cannot force a Public Benefits label under Recoupment and Policy, stop. If TANF work-hours that cannot be corroborated after an identity-proofing vendor outage that opened a manual path cannot support Pay or continue versus Recoup on this Public Benefits Recoupment and Policy close, housing-subsidy fraud investigator must do not pay, recoup, or deny beyond the eligibility record.