13.2.2  Error-Prone Profile

13.2.2.1 Annual Review of Error-Prone Profile

13.2.2.2 Prohibited Error-Prone Profile Characteristics

13.2.2.3 General Characteristics

13.2.2.4 Residence

13.2.2.5 Household Composition

13.2.2.6 Assets

13.2.2.7 Earned Income

13.2.2.8 Unearned Income

An error-prone profile is a list of characteristics recognized by the W-2Wisconsin Works agency as indicators of potential fraud or error(s) on a case. It allows the W-2 agency to prioritize administrative and investigative resources to cases with a high potential for error or fraud.

Agencies are encouraged to add criteria specific to situations applicable to the W-2 agency and its service area to the error-prone profile. For example, if there is a high number of jobs in the area that provide opportunities for earning tips, the error-prone profile may include reporting zero tip income when working a job that routinely receives tips.

13.2.2.1 Annual Review of Error-Prone Profile

FEVFront end-verification may reveal that some chosen error-prone profile characteristics are irrelevant and may not indicate potential fraud or error. Error-prone profile criteria are likely to change over time as conducting FEV reveals more accurate characteristics.

The W-2 agency is required to evaluate its error-prone profile annually to determine if the profile is identifying errors successfully. The recommended target is that 30% of cases referred to FEV should result in a referral for fraud investigation. If the W-2 agency does not meet the 30% target, it may remove characteristics that are not error-prone and add alternative characteristics.

13.2.2.2 Prohibited Error-Prone Profile Characteristics

The following characteristics must never be used when developing an error-prone profile:

1. Race;

2. Color;

3. National origin;

4. Ethnic background;

5. Sexual orientation;

6. Religion;

7. Age;

8. Political belief;

9. Disability;

10. Association with a person with a disability;

11. Marital status;

12. Tribal association;

13. Citizenship status;

14. Employment history;

15. Migrant farm worker status;

16. Gender identification or expression;

17. Criminal background; and

18. Personal knowledge/relationship of the applicant or participant.

13.2.2.3 General Characteristics

General error-prone indicators include:

·        Individual has provided contradictory information or made statements inconsistent with information provided during a previous contact in the application or review;

·        Case was previously closed for loss of contact or failure to provide essential information;

·        Case in which fraud was previously alleged or committed;

·        Case in which information provided by the applicant is incomplete or not clear;

·        Case was previously referred for FEV, which resulted in either denial or reduction of benefits; and

·        Case was flagged for potential error via the automated process for identifying error-prone cases in CWWCARES Worker Web.

13.2.2.4 Residence

Error-prone indicators for residence include:

·        Conflicting documentation or verification differing from what is reported by the individual;

·        Recent arrival (within the prior three months) in the agency’s county, not including refugees, migrant farm workers, people who are homeless, and residents of shelters;

·        Highly mobile families who rarely stay in one location for more than two or three months, not including people in unstable housing situations; and  

·        Frequent or prolonged visits outside of the W-2 Geographic Area.

13.2.2.5 Household Composition

Error-prone indicators for household composition include:

·        Employable household members listed on the application and then later reported to have moved;

·        Collateral contact statement (see 13.2.1.3.1) is inconsistent with the individual’s statement of household size;

·        Landlord's address is same as the individual’s, but the landlord is not included as a household member;

·        Landlord is the absent parent or ex-spouse;

·        Individual reports someone else pays the rent for several months, but that person is not listed in the home;

·        Household reports large increases or decreases in household size or a frequently fluctuating household size;

·        Other household member(s) included on a JALJob Access Loan or EAEmergency Assistance application, but not on the W-2 application; and

·        Other household member(s) included on a FoodShare or BadgerCare case, but not reported to be in the household for a W-2 application.

13.2.2.6 Assets

Error-prone indicators for assets include:

·        Individual reports no assets or resources on the application, but has no unpaid bills;

·        Individual reports no vehicle, but provides no other explanation for their transportation method;

·        Individual claims no income for an extended period of time, but offers no other explanation of how needs were met before applying;

·        Information provided by the individual shows a substantial reduction in assets just prior to application for assistance; and

·        Reported assets are very near or equal to the asset limits.

13.2.2.7 Earned Income

Error-prone indicators for earned income include:

·        Reported income is different than IRS records or state tax forms;

·        Individual’s expenses are being met, although their reported income is not enough to satisfy their financial obligations;

·        Self-employment income reported to have stopped (potential business assets available);

·        Individual reports zero income but states someone else is paying the bills;

·        Household that has an adult wage earner who becomes unemployed and reports no unemployment benefits or reports that unemployment benefits have stopped, but employment has not resumed;

·        Bank statement shows multiple deposits of $600 or more from mobile payment apps such as Apple Pay, Zelle, Venmo, PayPal, or Cash App, but no self-employment has been reported;

·        Increase in\\ nonparticipation without attempts from the individual to provide good cause; and

·        Application for JAL or EA indicates an increase in earned income not previously reported.

13.2.2.8 Unearned Income

Error-prone indicators for unearned income include:

·        Household member claims disability, but does not report SSI, SSDI, or worker’s compensation;

·        Application for JAL or EA indicates source(s) of unearned income not previously reported; and

·        Individual owns one or more rental properties.

Note: If any of the case characteristics listed in 13.2.2.3-13.2.2.8 can be explained by a barrier such as a recent trauma, domestic violence, or homelessness, it must not be considered part of an error-prone case and must not be referred for investigation. Please see 9.1 for more information on participant barriers.

History: Release 25-01; Release 16-01.