Assess whether identity proofing exceptions are being abused (bba22e)

SITUATION SNAP trafficking investigator in a TANF office with thin work-participation documentation has one working extract — identity-proofing exception queue — after an identity-proofing vendor outage that opened a manual path. If identity-proofing exception queue cannot support identity proofing exceptions are, the only defensible Public Benefits output is hold.

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

HYPOTHESES TO TEST 1. Authorize Pay or continue now; identity-proofing exception queue already has the discriminator after an identity-proofing vendor outage that opened a manual path. 2. Keep Recoup in force until identity-proofing exception queue is completed after an identity-proofing vendor outage that opened a manual path for SNAP trafficking investigator. 3. Treat identity-proofing exception queue 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 identity-proofing exception queue.

ANALYSIS REQUIRED 1. Test eligibility, recoupment, and improper-payment facts in identity-proofing exception queue after an identity-proofing vendor outage that opened a manual path. 2. Quantify overpayment if identity proofing exceptions are is wrong. 3. Separate a case-level error from a program-design failure in a TANF office with thin work-participation documentation. 4. For this Public Benefits Recoupment and Policy file, read identity-proofing exception queue 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 Release Pay or continue for this Public Benefits Recoupment and Policy file only when identity-proofing exception queue after an identity-proofing vendor outage that opened a manual path names the fact identity proofing exceptions are requires. SNAP trafficking investigator in a TANF office with thin work-participation documentation should withhold Pay or continue while that fact is still a hole in identity-proofing exception queue.

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