Assess whether identity proofing exceptions are being abused (3c1748)

SITUATION Housing-subsidy fraud investigator owns this Compliance and Integrity Operations review in a state SNAP agency after an EBT skimming wave. Two Section 8 files with the same landlord and overlapping tenants is the triggering event; issuance file-control totals that will not balance is the evidence for whether identity proofing exceptions are being abused.

DECISION Housing-subsidy fraud investigator in a state SNAP agency after an EBT skimming wave must choose Pay or continue / Recoup / Deny / Hold using issuance file-control totals that will not balance after two Section 8 files with the same landlord and overlapping tenants.

HYPOTHESES TO TEST 1. Authorize Pay or continue now; issuance file-control totals that will not balance already has the discriminator after two Section 8 files with the same landlord and overlapping tenants. 2. Keep Recoup in force until issuance file-control totals that will not balance is completed after two Section 8 files with the same landlord and overlapping tenants for housing-subsidy fraud investigator. 3. Treat issuance file-control totals that will not balance as Deny because both readings appear after two Section 8 files with the same landlord and overlapping tenants. 4. Refuse a Public Benefits close: housing-subsidy fraud investigator does not have the decision identity proofing exceptions are turns on in issuance file-control totals that will not balance.

ANALYSIS REQUIRED 1. Trace the notice and appeal path housing-subsidy fraud investigator must preserve. 2. Test eligibility, recoupment, and improper-payment facts in issuance file-control totals that will not balance after two Section 8 files with the same landlord and overlapping tenants. 3. Quantify overpayment if identity proofing exceptions are is wrong. 4. For this Public Benefits Compliance and Integrity Operations file, read issuance file-control totals that will not balance against two Section 8 files with the same landlord and overlapping tenants 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 / Compliance and Integrity Operations packet (issuance file-control totals that will not balance after two Section 8 files with the same landlord and overlapping tenants). The follow-on Compliance and Integrity Operations action is what housing-subsidy fraud 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 issuance file-control totals that will not balance, then the action for housing-subsidy fraud investigator - Hypothesis scorecard against issuance file-control totals that will not balance: supported / rejected / untestable - Regulatory or exam hook Compliance and Integrity Operations would cite - Compliance and Integrity Operations finding in issuance file-control totals that will not balance that a second reviewer can re-perform