1. August 15 & 16, 2012 FFY2013 EAP Annual Training FFY2013 EAP Annual Training Part 7: Data Practices; Local Plan; Communication, Information & Reports; Self Monitoring; State Monitoring

2. August 15 & 16, 2012 FFY2013 EAP Annual Training 2 Data Practices

3. August 15 & 16, 2012 FFY2013 EAP Annual Training 3 Highlights  Third Parties Under Contract  E-Mail Data Privacy  Record Retention Requirements  Destruction of Records  Penalty for Violations of the Minnesota Government Data Practices Act (MGDPA) Data Practices

4. August 15 & 16, 2012 FFY2013 EAP Annual Training 4  Third parties under contract with a government agency must also follow the MGDPA. Government entities may contract with private parties to fulfill government functions (Minn. Stat §13.05, subd. 11).  In that capacity, a private party will likely create, collect, receive, store, use, maintain or disseminate government data  If a government entity contracts with a private contractor, all of the government data are subject to the classifications in the MGDPA and other state and federal laws Third Parties Under Contract

5. August 15 & 16, 2012 FFY2013 EAP Annual Training 5 Maintain Data Privacy on E-mails  Use only household numbers for identification when possible, including any reference in the subject line or attachments  Use secure e-mail practices when private household data is included  Use secure e-mail practices to send new energy vendor information containing Tax IDs or Social Security Numbers E-Mail Data Privacy

6. August 15 & 16, 2012 FFY2013 EAP Annual Training 6 To Maintain Data Privacy on E-mails To Maintain Data Privacy on E-mails (cont.)  Remind energy vendors to use only household numbers and account numbers when communicating via e-mail about a customer  Contact DOC for help if an energy vendor does not cooperate with data privacy requirements, as required by the energy vendor agreement  Violation will result in EAP program finding E-Mail Data Privacy

7. August 15 & 16, 2012 FFY2013 EAP Annual Training 7  Energy Programs records must be maintained for at least six years after the program has been closed out and audited  Upon written notice from the state or federal agency, retain records for the period of time stated in the written notice  Should a Service Provider be required to keep these records for a longer period of time, the DOC will send written notice to do so Record Retention Requirements

8. August 15 & 16, 2012 FFY2013 EAP Annual Training 8 When disposing of records containing private data, the records must be destroyed in a way that prevents their contents from being determined, under Minn. Stat. §138.17 Destruction of Records

9. August 15 & 16, 2012 FFY2013 EAP Annual Training 9  Government entities and their contractors may be subject to penalties when violations of the MGDPA occur  Minn. Stat. §13.08 states: “… a responsible authority or government entity which violates any provision of this chapter is liable to a person or representative of a decedent who suffers any damage as a result of the violation, and the person damaged or a representative in the case of private data on decedents…may bring an action against the responsible authority or government entity to cover any damages sustained, plus costs and reasonable attorney fees.” Penalty for Violations of the MGDPA

10. August 15 & 16, 2012 FFY2013 EAP Annual Training 10  “In the case of a willful violation, the government entity shall, in addition, be liable to exemplary damages of not less than $1,000, nor more than $15,000 for each violation ”  There may be additional penalties including suspension without pay or dismissal  If in doubt, check with your agency’s data practices compliance official  Ask DOC EAP staff Penalty for Violations of the MGDPA

11. August 15 & 16, 2012 FFY2013 EAP Annual Training 11 SP Security Administrator Authorization Includes  Editing existing users as duties change  Disabling eHEAT administrators and users:  Immediately upon permanently leaving a position requiring eHEAT access  Immediately upon administrative leave, suspension, etc.  Immediately when no longer employed by the Service Provider  If on other leave, laid off, on extended vacation, or temporarily reassigned to non-EAP duties for 30 days or longer  Re-enabling users when they return to work  Editing existing roles as new functions are assigned or no longer performed Note: Failure to disable eHEAT access as required is a violation of data security policy and will result in an EAP compliance finding Roles and Responsibilities

12. August 15 & 16, 2012 FFY2013 EAP Annual Training 12 Q&A Chapter 13 Data Practices

13. August 15 & 16, 2012 FFY2013 EAP Annual Training 13 FFY2013 EAP Local Plan

14. August 15 & 16, 2012 FFY2013 EAP Annual Training 14 2. Risk Assessment Local Plan question Does the Service Provider have the capacity to identify, prioritize and mitigate program risks to maintain the continuity of EAP? FFY2013 EAP Local Plan

15. August 15 & 16, 2012 FFY2013 EAP Annual Training 15 2. Risk Assessment (4 parts) 2.1. Risk Management 2.2. Incident Management 2.3. Conflicts of Interest 2.4. Disaster Planning 2013 Updates  External and Internal Risk occurrences are in one form  List of 19 possible risk occurrences are provided FFY2013 EAP Local Plan

16. August 15 & 16, 2012 FFY2013 EAP Annual Training Risk Competence 2.1. Risk Management /Analysis (6 activity areas) FFY2013 EAP Local Plan Risk Occurrence Result of Occurrence Probability of Occurrence Severity of Impact ResponseIndicators Risk occurrence : Identify risk events that occur when things are different than planned Result of occurrence : Assess the impact of the risk occurrence Probability of occurrence: Determine the likelihood of the risk occurrence Severity of the impact: Determine the level/degree of the impact of the risk occurrence Response: M itigate or contain risk to an acceptable level Indicators: Describe how the event becomes known

17. August 15 & 16, 2012 FFY2013 EAP Annual Training 17

18. August 15 & 16, 2012 FFY2013 EAP Annual Training 18

19. August 15 & 16, 2012 FFY2013 EAP Annual Training 19

20. August 15 & 16, 2012 FFY2013 EAP Annual Training 20 2.2. Incident Management (how to identify, review, process, respond, follow-up) 2.3. Business Conflicts of Interest (SP, employee, vendors, contractors) 2.4. Disaster (uncontrolled circumstances) Planning 2.4.1. Community Disaster (participation in community emergency response and services) 2.4.2. Service Provider Disaster Plan (continuity of the program) FFY2013 EAP Local Plan

21. August 15 & 16, 2012 FFY2013 EAP Annual Training 21

22. August 15 & 16, 2012 FFY2013 EAP Annual Training 22 Q&A FFY2013 EAP Local Plan

23. August 15 & 16, 2012 FFY2013 EAP Annual Training 23 Chapter 14 Communication, Information and Reports

24. August 15 & 16, 2012 FFY2013 EAP Annual Training 24 Key Points  Timely reporting is critical  Accurate reporting is critical  Timely and accurate reporting prevents larger problems  EAP Coordinators communication role within their SP  Stakeholders  SP Outreach--we have limited funding so target Chapter 14 Communication, Information and Reports

25. August 15 & 16, 2012 FFY2013 EAP Annual Training 25 FFY2013 EAP Local Plan

26. August 15 & 16, 2012 FFY2013 EAP Annual Training 26 4. Communication & Information Local Plan question Does the SP have a system in place to communicate EAP policies and procedures to staff and stakeholders so they understand what is expected of them? 2013 Updates 4.4.6. Website standard question removed WACT questions removed 5.1.2 List of 9 Self Monitoring activities are provided 5.2 Energy Vendor Management is improved FFY2013 EAP Local Plan

27. August 15 & 16, 2012 FFY2013 EAP Annual Training 27 4. Communication & Information (4 parts) 4.1. Phone Service 4.1. Household Access to Energy Assistance Applications 4.1. Equal Access to Services 4.1. Outreach and Collaboration 4.1.1. Community Assessment 4.1.1. Targeted Populations and Veterans Outreach 4.1.1. New Outreach to Targeted Populations and Veterans 4.1.1. Successful Outreach 4.1.1. Collaboration FFY2013 EAP Local Plan

28. August 15 & 16, 2012 FFY2013 EAP Annual Training 28

29. August 15 & 16, 2012 FFY2013 EAP Annual Training 29

30. August 15 & 16, 2012 FFY2013 EAP Annual Training 30

31. August 15 & 16, 2012 FFY2013 EAP Annual Training 31 Q&A FFY2013 EAP Local Plan

32. August 15 & 16, 2012 FFY2013 EAP Annual Training 32 Self-Monitoring

33. August 15 & 16, 2012 FFY2013 EAP Annual Training 33 Outline  What we mean and how it fits  Expectations  Best practices Self-Monitoring

34. August 15 & 16, 2012 FFY2013 EAP Annual Training 34 Objective Monitoring is an ongoing activity meant to assess program processes and activities and ensure that funds are being spent according to policy EAP Service Providers have a responsibility to monitor and be monitored for compliance with program requirements Self-Monitoring

35. August 15 & 16, 2012 FFY2013 EAP Annual Training 35 Internal Controls Framework 1.Control Environment 2.Risk Assessment 3.Control Activities 4.Information & Communication 5.Monitoring Self-Monitoring

36. August 15 & 16, 2012 FFY2013 EAP Annual Training 36 a

37. August 15 & 16, 2012 FFY2013 EAP Annual Training 37 5. Monitoring Federal, State and Departmental State OfficeService Provider (SP)  HHS  OLA  Self Monitoring  Government Accountability Office  Program Audit  Quality & Performance Control  Desk Monitoring  Staff Meetings  Vendor Monitoring  Self Monitoring of controls  Agency Fiscal Audit  Respond to Program Audit Self-Monitoring

38. August 15 & 16, 2012 FFY2013 EAP Annual Training 38 Intentions  Assure proper implementation of EAP  Address problems early before they become critical  Assure program integrity and audit-ability  Assure quality customer service including timely service  Assure equitable use of funds through fiscal and program controls  Assure consistent statewide program delivery  Assure health and safety of applicant households Self-Monitoring

39. August 15 & 16, 2012 FFY2013 EAP Annual Training 39 Performance Measures and Quality Assurance Service Providers should have systems in place to assure :  Monitoring applications for timeliness  Weekly Targets and Rate of Incidence goals  Checking applications for accuracy  Verification of accuracy and completeness  Coordination for after hours emergencies  Accurate and timely reports to the DOC Self-Monitoring

40. August 15 & 16, 2012 FFY2013 EAP Annual Training 40 Monitoring Applications for Timeliness  HHS considers EAP a health and safety program  Processing application in timely fashion is not only important, but is also required in emergency situations Best Practices (from FFY12 Local Plans):  “Applications are date stamped and logged in upon arrival. They are also signed and dated by workers upon certification and approval for payment. Application timeliness is monitored via eHEAT data analysis.”  Random sample verification (10%) Self-Monitoring

41. August 15 & 16, 2012 FFY2013 EAP Annual Training 41 Check Applications for Accuracy & Completeness  Accurate applications + accurate data entry = accurate benefits  Ensures that benefits are preserved for truly eligible households  Ensures program integrity and conserves resources Best Practices:  “Applications are certified and approved for payment or denial by two different employees. Data is analyzed periodically for anomalies.” (validation)  Random sample verification (10%)  Encourage employees to double-check if they are unsure Self-Monitoring

42. August 15 & 16, 2012 FFY2013 EAP Annual Training 42 Weekly Targets and Rate of Incidence Goals  Each SP works with a unique mix of households  WACTs and ROIs are meant to help you assess whether or not you are reaching your households Best Practices:  WACTs: Check eHEAT on a weekly basis to see if weekly application targets are achieved. If not, identify possible reasons and adjust accordingly.  ROIs: Check eHEAT monthly to determine if targeted groups are represented in applicant pool. If not, focus outreach towards underrepresented groups. Self-Monitoring

43. August 15 & 16, 2012 FFY2013 EAP Annual Training 43 Coordination for After Hours Emergencies  EAP is required to resolve life threatening emergencies within 18 hours and non-life threatening emergencies within 48 hours Best Practices:  Enter into eHEAT immediately; use to check timeliness  Keep a log of emergency requests with date/time of request and resolution, as well as name of respondent  Regularly (weekly) evaluate if timelines are being met  When not met, determine why and act accordingly Self-Monitoring

44. August 15 & 16, 2012 FFY2013 EAP Annual Training 44 Accurate and Timely Reports to DOC Quality & Performance Controls reporting focuses on:  Timeliness, consistency and accuracy  Continuous improvement  Program Resource Management Best Practices:  “Timely reporting to DOC is assured with the use of Outlook and staff coordination”  Submit in the proper format  Enter notes in eHEAT Self-Monitoring

45. August 15 & 16, 2012 FFY2013 EAP Annual Training 45 Accurate and Timely Reports to DOC Best Practices (Continued):  Mark your calendars (set an alarm) & have a second person verify report accuracy  Evaluate performance  Identify strengths and weaknesses  Develop procedures to improve Self-Monitoring

46. August 15 & 16, 2012 FFY2013 EAP Annual Training 46 Performance Measures and Quality Assurance Self-Monitoring

47. August 15 & 16, 2012 FFY2013 EAP Annual Training 47 What Other Performance Measures Do You Use? From the Local Plans  “eHEAT data and DOC-supplied reports are utilized to track agency accuracy and staff productivity” To consider  Customer service: quality as well as quantity/timeliness  Community needs assessments  Outreach: Go beyond inputs/outputs (e.g., # of events, # of fliers, etc.) and focus on outcomes  Want help with demographic (population) info? Contact me. Self-Monitoring

48. August 15 & 16, 2012 FFY2013 EAP Annual Training 48 Electric Mismatch Search  To assure that consumption is based on information accurately reflecting the household’s situation (daily) Data Entry Check  To assure that data entry is being done correctly (10% daily per specialist) Aging Application Search  To ensure timely application processing/payment (monthly) Self-Monitoring: SP Best Practices

49. August 15 & 16, 2012 FFY2013 EAP Annual Training 49 Certification Check  To assure that files are being completed correctly (10% daily per specialist) Review Denials  For accuracy, missed info, over-income (monthly) Refund Search  To assure that refunds are being processed in a timely, accurate manner (weekly) Self-Monitoring: SP Best Practices

50. August 15 & 16, 2012 FFY2013 EAP Annual Training 50 Payment Search  To assure that payments are being made in timely, accurate manner (weekly) In-Progress Crisis Report  To assure that all HH events are complete and Crisis is applied to prevent disconnections (every other day) Direct Payment Certify Batch  Review for accuracy, third party vendors (daily) Self-Monitoring: SP Best Practices

51. August 15 & 16, 2012 FFY2013 EAP Annual Training 51 ERR  Nearly all ERR installs and repairs over $1,000 are issued inspections  Contractors provide permits for all installs  Invoices are reviewed for price and work performed to ensure that ERR dollars are well spent  Award of install leveraged against cost of service call in order to keep costs low Self-Monitoring: SP Best Practices

52. August 15 & 16, 2012 FFY2013 EAP Annual Training 52 A16 Check  To assure that A16 activities are being recorded correctly (periodic review of entries) Consider  Using customer surveys to:  Identify community needs related to home energy use  Develop specific outreach, advocacy, and referral activities to meet identified needs  Measure effectiveness of developed activities Self-Monitoring: SP Best Practices

53. August 15 & 16, 2012 FFY2013 EAP Annual Training 53 Q&A Self-Monitoring

54. August 15 & 16, 2012 FFY2013 EAP Annual Training 54 State Monitoring

55. August 15 & 16, 2012 FFY2013 EAP Annual Training 55 Finding’s Monitoring Effects & National Efforts Federal  GAO  Program Integrity Working Group Final Report  HHS monitoring State  OLA Finding  Internal Controls Assessments State Monitoring

56. August 15 & 16, 2012 FFY2013 EAP Annual Training 56 Finding’s Monitoring Effects & National Efforts  Some improvements have already been implemented  Some improvements are in planning stages  Some improvements are unknown  National Program Integrity Working Group report  State internal controls assessment  Some improvements can be done by SPs State Monitoring

57. August 15 & 16, 2012 FFY2013 EAP Annual Training 57 Chapter 17 Monitoring

58. August 15 & 16, 2012 FFY2013 EAP Annual Training 58  Why monitor?  Process  Hot Topics for FFY13 Chapter 17 Monitoring

59. August 15 & 16, 2012 FFY2013 EAP Annual Training 59 Intentions  Conduct oversight to reduce risks to the program  Measure SP’s competency for delivering EAP  Assure program integrity and audit-ability Chapter 17 Monitoring

60. August 15 & 16, 2012 FFY2013 EAP Annual Training 60 Values  Compliance with program policies and procedures  Efficient SPs as a way to assure households are well served  Consistency of major program activities and services in line with compliance requirements  SPs’ ability to develop locally based programs to serve their areas within their organizational culture  Being good stewards of resources Chapter 17 Monitoring

61. August 15 & 16, 2012 FFY2013 EAP Annual Training 61 Chapter 17 Monitoring

62. August 15 & 16, 2012 FFY2013 EAP Annual Training 62 Process  Desk review  Targeted information gathering  Reports  On site monitoring  Initial monitoring visit  Full monitoring visit  Compliance visit Chapter 17 Monitoring

63. August 15 & 16, 2012 FFY2013 EAP Annual Training 63 Initial Monitoring Focus  Review findings and recommendations from previous year(s)  File review  Ensure SP has necessary resources and is ready for FFY13  Review Local Plan – address questions, concerns or changes  Provide Training and Technical Assistance (T&TA) Prior to visit -- send to Program Performance Auditor  Questions -- policy changes, eHEAT, other  T&TA requests Chapter 17 Monitoring

64. August 15 & 16, 2012 FFY2013 EAP Annual Training 64 Initial Monitoring Scheduling  Program Performance Auditors contact SPs in September to schedule Initial Monitoring Visits (IMV)  Goal is to finish IMVs before Thanksgiving Chapter 17 Monitoring

65. August 15 & 16, 2012 FFY2013 EAP Annual Training 65 Full Monitoring Visit Focus  In-depth review of SP’s program implementation  File review of Primary Heat, Crisis and ERR  Review payroll records  Inventory  Additional documentation as requested Chapter 17 Monitoring

66. August 15 & 16, 2012 FFY2013 EAP Annual Training 66 Full Monitoring Visit Prior to visit -- send to Program Performance Auditor  Full Monitoring Tool (FMT)  Questions -- policy changes, eHEAT, other  T&TA requests Chapter 17 Monitoring

67. August 15 & 16, 2012 FFY2013 EAP Annual Training 67 Full Monitoring Visit Scheduling  Program Performance Auditors contact SPs in November to schedule Full Monitoring Visits (FMV)  The goal is to finish FMVs before May 1 Chapter 17 Monitoring

68. August 15 & 16, 2012 FFY2013 EAP Annual Training 68 Full Monitoring Visit Provide the following for Program Performance Auditor  Work space  Access to EAP files and records  Access to EAP Coordinator – and other staff as needed  Secure internet access  Temporary password for network access Chapter 17 Monitoring

69. August 15 & 16, 2012 FFY2013 EAP Annual Training 69 Full Monitoring Visit  Incorporates discoveries—desk monitoring, incidents  Interview SP staff  EAP Coordinator  Executive Director  Fiscal Staff  Others as necessary  File review  Primary Heat  Crisis  ERR Chapter 17 Monitoring

70. August 15 & 16, 2012 FFY2013 EAP Annual Training 70 Full Monitoring Visit File review  Pattern and outlier analysis  Random sample  Data entry accuracy  Check for conflicts of interest  Documentation Chapter 17 Monitoring

71. August 15 & 16, 2012 FFY2013 EAP Annual Training 71 Full Monitoring Visit Primary Heat file review  Eligibility determination  Consumption determination  Sample size determined by SP size  Documentation  SP file  eHEAT Chapter 17 Monitoring

72. August 15 & 16, 2012 FFY2013 EAP Annual Training 72 Full Monitoring Visit Primary Heat file review  Self employment  No income  Denied  All with consumption greater than $5000 Chapter 17 Monitoring

73. August 15 & 16, 2012 FFY2013 EAP Annual Training 73 Full Monitoring Visit Crisis file review  Proof of household’s eligibility  SP verification with vendor  Accuracy of Crisis benefit amount  Documentation  SP file  eHEAT  All employee Crisis files  DOC verification with vendor Chapter 17 Monitoring

74. August 15 & 16, 2012 FFY2013 EAP Annual Training 74 Full Monitoring Visit ERR file review  Proper forms included in file  Verification of need for repair or replacement  Accuracy of ERR benefit amount  Documentation  SP file  eHEAT  All ERR payments $5000 or greater  All employee ERR files Chapter 17 Monitoring

75. August 15 & 16, 2012 FFY2013 EAP Annual Training 75 Full Monitoring Visit  SP Disclosure Letter  New in FFY12  Due 7 days after conclusion of visit  Program Audit Report (PAR)  Within 45 days of conclusion of visit  Findings, Recommendations, Corrective Actions  SP response to findings and recommendations  Due 14 days after PAR issued Chapter 17 Monitoring

76. August 15 & 16, 2012 FFY2013 EAP Annual Training 76 Program Audit Reports SPs with findings/recommendations Findings Only2 Recommendations Only11 Findings and Recommendations12 No Findings or Recommendations11

77. August 15 & 16, 2012 FFY2013 EAP Annual Training 77 Program Audit Reports SPs with findings/recommendations Findings and/or Recommendations25 No Findings or Recommendations11

78. August 15 & 16, 2012 FFY2013 EAP Annual Training 78 Hot Topics for FFY13  Crisis  ERR  Employee Applications  Documentation  Other areas as determined through Internal Controls Assessment Chapter 17 Monitoring

79. August 15 & 16, 2012 FFY2013 EAP Annual Training 79 Questions During the Program Year  DOC EAP staff are here to help you!  Call or email your Program Performance Auditor  Can also email your questions to eap.mail  Please copy your Program Performance Auditor  Emails with private household data must be sent via secure email Chapter 17 Monitoring

80. August 15 & 16, 2012 FFY2013 EAP Annual Training 80 Chapter 17 Monitoring