13.1.4  Program Integrity Management

Program integrity responsibilities can be divided into five general categories:

Prevention: Ensure that fraud, waste, and abuse can be prevented up front through front-end verification, error-prone profiles, case comment review, and clear communication to applicants about program rules and responsibilities.

Detection: Use data exchanges and other sources to detect red flags and conflicting information that can indicate fraud, waste, or abuse.

Investigation: Investigate any fraud referrals or questionable information to determine if fraud, waste, or abuse has taken place.

Sanctions: Assess and establish appropriate penalties for any violation of program rules, including an Intentional Program Violation or a referral for prosecution.

Collections: Establish and collect overpayments if W-2Wisconsin Works payments were issued in error either intentionally or inadvertently. This also includes collections via lien, levy, or tax intercept for delinquent cases.

The W-2 agency must differentiate between the following types of program integrity duties:

1. Routine verification for eligibility determination conducted on all applications and reviews detailed in Chapters 1, 2, 3, and 17;

2. Selection of cases that exhibit error-prone case characteristics for referral to FEVFront end-verification ;

3. Selection of potential fraud cases for referral to fraud investigation;

4. Establishment of IPVIntentional Program Violations;

5. Initiation of overpayment claims and collections; and

6. Referral of cases to the local District Attorney’s office for criminal prosecution.

Separation of these activities is necessary for proper reporting in the Benefit Recovery and Investigation Tracking System (BRITS).

History: Release 25-01.