1. Central PA AGA – Feb 16, 2012 D EPARTMENT OF H EALTH &H UMAN S ERVICES P ROGRAM I NTEGRITY I NITIATIVE M OLLY D AWSON D IRECTOR, HHS F INANCIAL P OLICY & R EPORTING

2. Central PA AGA – Feb 16, 2012 Overview Background of Program Integrity at HHS What is Program Integrity? Purpose of Program Integrity Relationship of Program Integrity and FMFIA How Does Program Integrity Work? How Can You Bring Program Integrity to Your Organization?

3. Central PA AGA – Feb 16, 2012 Background on the HHS Program Integrity Initiative May 13, 2010 Secretary Sebelius announced the HHS Program Integrity Initiative Congress allocates more money in the federal budget for HHS than any other Department More than $900 Billion dollars in public investments each year Given the Departments mission to protect all Americans health and provide essential human services, HHS leadership is committed to ensuring program dollars are not lost due to fraud, theft, mismanagement, etc.

4. Central PA AGA – Feb 16, 2012 In line with the HHS mission Effectively, Efficiently, and Ethically HHS and External Entities working together What is Program Integrity? PROGRAM INTEGRITY B OTTOM L INE : M AKE HHS MONEY GO FURTHER !

5. Central PA AGA – Feb 16, 2012 What is Program Integrity? HHS Official Definition The operation of HHS programs, by both HHS and our external partners, in an effective, efficient, and ethical manner and without conflict of interest or the appearance of conflict of interest, in accordance with applicable laws and regulations. In line with HHS program mission, goals, and objectives, the intended recipients are provided the proper payments, services and benefits while ensuring quality, safety, and access.

6. Central PA AGA – Feb 16, 2012 Purpose of Program Integrity? Meet taxpayers expectations that tax dollars are spent properly; Make sure the correct population is served; Ensure that recipients can and are managing federal funding in an effective and prudent manner, including the federal dollars managed by sub-recipients; Ensure maximum impact of federal dollars; and Minimize risk of program failure or bad publicity.

7. & Taxpayers People Served Contractors Regional Offices Grantees Staff Divisions Operating Divisions

8. Central PA AGA – Feb 16, 2012 Program Integrity vs Ethics Not legally mandated Focus on program, not individuals Improve effectiveness and efficiency Does not govern behavior

9. Central PA AGA – Feb 16, 2012 Program Integrity & FMFIA FMFIA, When Done Properly Supports Program Integrity Program Integrity is a Subset of the Annual FMFIA Assessment Program Integrity Evaluates Internal, External, and Inherent Risk Program Integrity Requires Participation of External Partners to be Successful

10. Central PA AGA – Feb 16, 2012 How is HHS Enhancing Program Integrity? Established the Secretarys Council on Program Integrity – Comprised of Division Heads – Each Division Head is Directly Accountable Established Sub-group – Program Integrity Coordinating Council (PICC) – Comprised of a Direct Report Representative from each Division – Responsible for Implementing the Initiative in the Division – PICC Meets Monthly Address Program Integrity Issues Share best practices

11. Central PA AGA – Feb 16, 2012 Office of Program Integrity Coordination (OPIC) OPIC was formed to coordinate the Departments program integrity efforts OPIC also has responsibility for implementing the Improper Payments Information Act and associated directives

12. Central PA AGA – Feb 16, 2012 Vision Instill program integrity into every aspect of our culture to achieve HHS' mission with unprecedented accountability for taxpayer funds Mission Strengthen program integrity within HHS program operations for effective, efficient and ethical use of funds to help protect the health of all Americans and provide essential human services Goals Reduce risk for HHS programs by enhancing program integrity activities Increase program integrity awareness throughout HHS Headquarters and Regional Offices Ensure taxpayer dollars are spent the way they were intended HHS Program Integrity Initiative What is It?

13. Central PA AGA – Feb 16, 2012 Each Program Integrity Review follows the 4 stages of the Program Integrity Lifecycle (shown to left). Stage 1 – Identify Risks Stage 2 – Develop Risk Response Strategy and Corresponding Metrics Stage 3 – Implement Response Strategy Stage 4 - Measure and Test Efficacy of Response strategy; Modify as Necessary T HE P ROGRAM I NTEGRITY L IFECYCLE M ONITOR R ISKS I DENTIFY R ISKS D EVELOP R ISK R ESPONSE S TRATEGY I MPLEMENT R ISK R ESPONSE S TRATEGY STAGE 1 STAGE 3 STAGE 2 STAGE 4 Each program will follow the same general review cycle.

14. Central PA AGA – Feb 16, 2012 StepObjectiveTime*Program Participation 1 Kick-Off Meeting Create a uniform understanding of the program integrity review process, roles and responsibilities, timelines, and specific deliverables 1 hr Staff from each program office/division that are responsible for executing day- to-day program functions; Core program integrity team members. 2 Process Mapping Create an illustrated depiction of work performed by program staff and discuss areas of the process where risks may occur 4 hrs Staff from each program office/division who are responsible for executing sub- processes. Also, staff with an enterprise view of the program. 3 Specific Risk Identification Identify and discuss specific risks to each program that, if realized, could adversely impact the programs ability to carry out its mission. 4 hrs Staff representing a cross-section of program operations. May include staff from other offices, such as grants management and/or regions. 4 Capabilities Assessment Discuss and evaluate each programs capabilities around assessment, management, and monitoring of risk. 2 hrs Staff with a holistic view of the program. 5 Data Validation Review and validated data collected by Program Integrity Review Tool 1 week Program leadership R ISK A SSESSMENT P ROCESS : A S TEP - BY -S TEP O VERVIEW *Minimum time expectations for program involvement. The exact time – both duration and number of sessions - will vary by program.

15. Central PA AGA – Feb 16, 2012 What Does it Take to Enhance Program Integrity? Dedicate sufficient time/resources Integrate program integrity into program operations Assist outside partners (states, grantees, contractors, etc) in understanding and applying program integrity principles Each program conducts a risk assessment to identify programmatic vulnerabilities

16. Central PA AGA – Feb 16, 2012 How Can You Promote Program Integrity Within Your Organization? You can: Assess the way you perform your job Look for ways to be more effective and efficient Suggest areas and innovative ways where the organization can be more effective and efficient Work with your external partners (e.g., grantees, contractors) Share your best practices throughout your organization Ask yourself constantly: What would I do differently if I were using my own money?

17. Central PA AGA – Feb 16, 2012