Cherokee Nation
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- Website: Summer EBT Program
- Hotline: 539-234-3265 or 800-256-0671 ext. 5275
- Email: wicsebtc@cherokee.org
DATE: | August 1, 2005 |
MEMO CODE: | QC-05-01 |
SUBJECT: | Integrity of the Quality Control Review Process |
The Food and Nutrition Service (FNS) and state agencies share a common goal to improve payment accuracy. However, attempts to achieve this goal must not compromise the objective nature of the food stamp quality control (QC) process. The specific purpose of QC is to obtain an accurate measure of error rates. A state agency administering the Food Stamp Program is responsible for insuring that its QC sample and reviews remain free from unacceptable bias. If a state or local agency treats QC sampled cases differently from non-sampled cases or treats certain sampled QC cases differently from other QC sampled cases, the review results will not mirror the overall level of accuracy of a caseload. It does not matter whether such actions are intentional or unintentional. It is a form of bias and may compromise the QC sample.
FNS is responsible for overseeing the QC system and providing guidance to state agencies on designing and administering review systems. Without consistent, unbiased standards for sampling and reviewing cases, the integrity of the system would be compromised. Under such circumstances, if a state agency’s error rate becomes questionable due to the introduction of unacceptable bias, FNS has the authority to assign an error rate to a state agency. This action may also result in a suspension or disallowance of federal funding.
The following types of actions represent examples of activities that produce an unacceptable bias in the QC system:
In addition, questions have arisen on the appropriateness of some activities undertaken by error review committees. The error review committee’s role is primarily one of reviewing cases to assess for future corrective action planning, not to review individual error cases to assess the potential for reducing or eliminating errors in a sampled individual case. Error review committees should incorporate and maintain procedures that minimize the likelihood of unacceptable bias being introduced into the QC review process. Attached is a document recently released by FNS as one of the ten keys to payment accuracy that, in addition to outlining the effectiveness of the committees, includes a discussion on inappropriate local office involvement in this process.
Thank you for your attention to this important matter. We know that states share our commitment to a fair and unbiased QC system. If you have any questions or concerns on this issue, I urge you to contact your appropriate FNS regional office.
Karen J. Walker
Director
Program Accountability Division
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.