Common use of Other Supporting Justifications Clause in Contracts

Other Supporting Justifications. This matching program supports compliance with the Payment Integrity Information Act of 2019 (PIIA) which focuses on preventing improper payments to ensure funding serves its intended purpose as first set out in E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009). Payment integrity is a top priority. OMB guidance provides the framework to reduce the administrative burden, allow agencies to focus on identifying, assessing, prioritizing, and responding to payment integrity risks, and address the underlying causes of improper payments. See OMB Memorandum M-21-19, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement (March 5, 2021). Because the UC program has been identified as susceptible to significant improper payments, the matching program facilitates compliance with the applicable requirements of 31 U.S.C. §§ 3351-3358. DOL mandated use of the NDNH for the BAM program in 2007 (see UIPL No. 3-07, Change 1) to detect benefit year earnings (BYE) overpayments beginning in December 2011 (see UIPL No. 19-11). This mandate is based on the Department’s administrative authority granted under Section 303(a)(1) of the Social Security Act and Sections 3306(h) and 3304(a)(4) of the Internal Revenue Code. Studies done by DOL confirm that use of NDNH results in earlier detection of improper payments, prevents future overpayments, and increases the likelihood of overpayment recovery. NDNH is a centralized database of wage and employment information and, as such, provides an effective and efficient means to obtain income information, preferable to other means of obtaining the same information. The matching program will assist the state agency in detecting fraud, waste, and abuse and will enhance program integrity by strengthening the state agency’s oversight and management of the UC program. It will serve as a deterrent to some individuals who otherwise may fraudulently apply for and receive UC benefits and it will provide information to reduce erroneous payments. The program will also provide useful information on the employment and earnings of UC applicants and recipients, specifically: 1) those who are employed with the federal government; 2) those who are employed in another state, including those who have been rehired by a previous employer after having been separated from such prior employment for at least 60 consecutive days (Pub. L. 112-40, effective April 21, 2012, amending subsection 453A(a)(2) of the Social Security Act, 42 U.S.C. § 653a(a)(2)); and 3) those whose information is not readily available through the State Directory of New Hires, state workforce agencies, or other data reporting systems. The positive results of the previous matching programs between the state agency and OCSE further justify the proposed matching program. See section II.A and the cost-benefit analysis at Appendix B to this agreement.

Other Supporting Justifications. This matching program supports compliance with the Payment Integrity Information Act of 2019 (PIIA) which focuses on preventing improper payments to ensure funding serves its intended purpose as first set out in E.O. 13520, Reducing Improper Payments and Eliminating Waste in Federal Programs, 74 FR 62201 (Nov. 25, 2009). Payment integrity is a top priority. OMB guidance provides the framework to reduce the administrative burden, allow agencies to focus on identifying, assessing, prioritizing, and responding to payment integrity risks, and address the underlying causes of improper payments. See OMB Memorandum M-21-19, Transmittal of Appendix C to Circular A-123, Requirements for Payment Integrity Improvement (March 5, 2021). Because the UC TANF program has been identified as susceptible to significant improper payments, the matching program facilitates compliance with the applicable requirements of 31 U.S.C. §§ 3351-3358. DOL mandated use Identifying employment status and wages of adult TANF applicants and recipients assists the NDNH for state agency to provide proper case management and work supports to stabilize employment, increase earnings, reduce dependency on public assistance, and lead to self- sufficiency. The program also improves the BAM program state agency’s ability to report adult TANF applicants’ and recipients’ employment status and earnings and work participation to the Office of Family Assistance, in 2007 accordance with subsection 411(a)(1)(A)(iv) and (see UIPL No. 3-07, Change 1) to detect benefit year earnings (BYE) overpayments beginning in December 2011 (see UIPL No. 19-11). This mandate is based on the Department’s administrative authority granted under Section 303(a)(1xi) of the Social Security Act and Sections 3306(hAct. 42 U.S.C. § 611(a)(1)(A)(iv) and 3304(a)(4) of the Internal Revenue Code. Studies done by DOL confirm that use of NDNH results in earlier detection of improper payments, prevents future overpayments, and increases the likelihood of overpayment recovery(xi). NDNH is a centralized database of wage and employment information and, as such, provides an effective and efficient means to obtain income information, preferable to other means of obtaining the same information. The matching program will assist the state agency in detecting fraud, waste, and abuse and will enhance program integrity by strengthening the state agency’s oversight and management of the UC TANF program. It will serve as a deterrent to some individuals who otherwise may fraudulently apply for and receive UC TANF benefits and it will provide information to reduce erroneous payments. The program will also provide useful information on the employment and earnings of UC TANF applicants and recipients, specifically: 1) those who are employed with the federal government; 2) those who are employed in another state, including those who have been rehired by a previous employer after having been separated from such prior employment for at least 60 consecutive days (Pub. L. 112-40, effective April 21, 2012, amending subsection 453A(a)(2) of the Social Security Act, 42 U.S.C. § 653a(a)(2)); and 3) those whose information is not readily available through the State Directory of New Hires, state workforce agencies, or other data reporting systems. The positive results of the previous matching programs between the state agency and OCSE further justify the proposed matching program. See program (see section II.A and the cost-benefit analysis at Appendix B to this agreement).