Assess whether identity proofing exceptions are being abused (2fcca6)

SITUATION In a TANF office with thin work-participation documentation, disability CDR medical-evidence pack is the evidence after an identity-proofing vendor outage that opened a manual path. SNAP trafficking investigator has to pick Pay or continue or Recoup for this Public Benefits Recoupment and Policy close using disability CDR medical-evidence pack.

DECISION SNAP trafficking investigator in a TANF office with thin work-participation documentation must choose Pay or continue / Recoup / Deny / Hold using disability CDR medical-evidence pack after an identity-proofing vendor outage that opened a manual path.

HYPOTHESES TO TEST 1. Authorize Pay or continue now; disability CDR medical-evidence pack already has the discriminator after an identity-proofing vendor outage that opened a manual path. 2. Keep Recoup in force until disability CDR medical-evidence pack is completed after an identity-proofing vendor outage that opened a manual path for SNAP trafficking investigator. 3. Treat disability CDR medical-evidence pack as Deny because both readings appear after an identity-proofing vendor outage that opened a manual path. 4. Refuse a Public Benefits close: SNAP trafficking investigator does not have the decision identity proofing exceptions are turns on in disability CDR medical-evidence pack.

ANALYSIS REQUIRED 1. Separate a case-level error from a program-design failure in a TANF office with thin work-participation documentation. 2. Match household facts in disability CDR medical-evidence pack to the rule that pays the benefit. 3. Trace the notice and appeal path SNAP trafficking investigator must preserve. 4. For this Public Benefits Recoupment and Policy file, read disability CDR medical-evidence pack against an identity-proofing vendor outage that opened a manual path and write the one fact that would move identity proofing exceptions are for SNAP trafficking investigator.

RECOMMENDATION Choose Pay or continue / Recoup / Deny / Hold on this Public Benefits / Recoupment and Policy packet (disability CDR medical-evidence pack after an identity-proofing vendor outage that opened a manual path). The follow-on Recoupment and Policy action is what SNAP trafficking investigator does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Public Benefits option on identity proofing exceptions are, then the evidence in disability CDR medical-evidence pack, then the action for SNAP trafficking investigator - Hypothesis scorecard against disability CDR medical-evidence pack: supported / rejected / untestable - Regulatory or exam hook Recoupment and Policy would cite - Recoupment and Policy finding in disability CDR medical-evidence pack that a second reviewer can re-perform