Presentation to: Presented by: Date: Office of Inspector General Updates Nutrition Services Directors Ondray Jennings, Deputy Inspector General December 9, 2014

Increase in Participant Investigations Proactive Participant Projects Data Analysis Increase in Referrals from Outside Entities

Participant Case Updates July 1, 2014 thru Present Clinic Voucher Integrity Check 10 Covert Non-High Risk List 1 Data Analysis 8 DPH OIG Investigation 37 Health Districts 3 High Risk List 1 Hotline 11 Internal State Agency 1 Internet Social Media 10 Total Participant Investigations 82

Social Media Investigations Internet and Social Media Investigations involve the sale or attempted sale of WIC vouchers or items purchased with WIC vouchers. Internet and Social Media Investigations may also involve the solicitation to purchase WIC vouchers. USDA’s Increased Emphasis Warning Letters

Substantiated Investigations Upon completion of the investigation, OIG will provide the NSD with investigative documents to support the fraud allegations. These documents will include all evidence that supports the findings, as well as the Memorandum that contains the total claim amount.

Districts Involvement OIG will forward substantiated fraud claims to the local agency for final disposition to include all supporting evidence and case findings. Local agency will be responsible for notifying the participant of the claim amount. All DPH employees shall cooperate and assist the Inspector General as requested with any type of investigation regarding alleged misconduct or criminal offenses. Employees shall be available for interviews as requested, truthfully answer questions related to the performance of their duties and DPH business, produce documents, and submit to polygraph examination, as requested (HR ). CA-1

Repayment Letters Within seven (7) days of advisement from the state agency as to the dollar amount of any dual participation, the local agency shall issue a letter by mail advising the WIC participant of the determination of dual participation and any intentional misrepresentation; the dollar amount of the improperly obtained WIC benefits; and a demand for repayment of the total dollar amount (see Attachment CA- 11 and CA-12 for Sample Letters). The letter shall include advisement as to disqualification or denial/termination of WIC participation and as to the WIC participant’s right to a fair hearing. In no instance will repayment arrangements be extended beyond ninety (90) days from the date of notification to the WIC participant.

Participant Abuse Participant fraud and abuse, such as using WIC benefits in any way other than the method and purpose for which they were intended, violates WIC regulations and constitutes a participant violation under 7 CFR Making a verbal offer of sale to another individual or posting WIC foods, benefits and/or EBT cards for sale in print or online, or allowing someone else to do so, is evidence that the participant committed a participant violation. The State Agency shall sanction and issue claims against participants for all program violations. Participant violations listed in CFR is not an exhaustive list of participant violations

PROCEDURES FOR REPAYMENT OF WIC FUNDS Repayments will be submitted to the local agency and must be in the form of a cashier's check or money order payable to: DPH/ Georgia WIC Program. 1.The local agency will immediately forward all repayments received to Program Administration (Anthony McGaughey) for processing. 2.If total payment is not made within the ninety (90) day timeframe, the local agency will notify Georgia WIC Program OIG, which will in turn, proceed with recovery actions prescribed under Georgia Statute. When appropriate, Georgia WIC Program must refer participants who violate Georgia WIC Program requirements to federal, state or local authorities for prosecution under applicable statutes (7 C.F.R. § (ii) (5). 3.Georgia WIC Program shall continue collection procedures until it determines it is no longer cost effective. Georgia WIC Program Abuse Claims Payment Report will be used to document repayment of funds (see Attachment CA-14) Georgia WIC Program will maintain records of all participant abuse regardless of dollar amount.

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