Common use of Other Supporting Justifications Clause in Contracts

Other Supporting Justifications. The Improper Payments Information Act of 2002, Pub. L. 107-300, the Improper Payments Elimination and Recovery Act of 2010, Pub. L. 111-204, and the Improper Payments Elimination and Recovery Improvement Act of 2012, Pub. L. 112-248, require federal agencies to identify programs susceptible to significant improper payments and to report to Congress on efforts to reduce such payments. The Office of Management and Budget issued implementing guidance to federal agencies in Appendix C to Circular A- 123, Requirements for Effective Estimation and Remediation of Improper Payments, (October 20, 2014). The Supplemental Nutrition Assistance Program (SNAP) was reauthorized on February 7, 2014, as part of the Agricultural Act of 2014, P.L.113-79. States are now required to verify wage data of adult household members through the NDNH, and to determine eligibility and the correct amount of SNAP benefits at the time of certification. See 7 U.S.C. §2020(e)(24). State agencies are authorized under 453(j)(10) of the Social Security Act to conduct an information comparison with the NDNH. 42 U.S.C. §653(j)(10). The 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 enhancing program integrity by strengthening the state agency’s oversight and management of the program. It will serve as a deterrent to some individuals who otherwise may fraudulently apply for and receive SNAP benefits, and it will provide information to reduce erroneous payments. The program will also provide useful information on the employment and earnings of SNAP 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.C. and Appendix A of this agreement.)

Other Supporting Justifications. The This matching program is futher justified because it supports compliance with Executive Order 13520, Reducing Improper Payments Information Act Payments, 74 FR 62201 (Nov. 25, 2009), which policies state that federal programs should continue to serve their intended beneficiaries, but provide for public scrutiny of 2002significant payment errors and eliminate the highest improper payments; establish accountability for reducing improper payments; and coordinate federal, Pub. L. 107-300, the Improper Payments Elimination and Recovery Act of 2010, Pub. L. 111-204state, and the Improper Payments Elimination local government action in identifying and Recovery Improvement Act eliminating improper payments, and implementing guidelines in OMB Memorandum M-18-20, Transmittal of 2012, Pub. L. 112-248, require federal agencies to identify programs susceptible to significant improper payments and to report to Congress on efforts to reduce such payments. The Office of Management and Budget issued implementing guidance to federal agencies in Appendix C to Circular A- 123A-123, Requirements for Effective Estimation and Remediation of Improper PaymentsPayment Integrity Improvement (June 26, (October 20, 20142018). The matching program facilitates compliance with the applicable requirements of 31 U.S.C. §§ 3351-3358. States are statutorily required to verify wage data of adult household members through the NDNH, to determine eligibility and the correct amount of SNAP benefits at the time of certification as a result of the reauthorization of the Supplemental Nutrition Assistance Program (SNAP) was reauthorized on February 7, 2014, as part of the Agricultural Act of 2014, P.L.113-79. States are now required to verify wage data of adult household members through the NDNH, and to determine eligibility and the correct amount of SNAP benefits at the time of certification. See 7 U.S.C. §§ 2020(e)(24). State agencies are authorized under 453(j)(10) of the Social Security Act to conduct an information comparison with the NDNH. 42 U.S.C. §§ 653(j)(10). The 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 enhancing will enhance program integrity by strengthening the state agency’s oversight and management of the programSNAP. It will serve as a deterrent to some individuals who otherwise may fraudulently apply for and receive SNAP benefits, and it will provide information to reduce erroneous payments. The program will also provide useful information on the employment and earnings of SNAP 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.C. II.A and the cost benefit analysis at Appendix A of B to this agreement.)