Central PA AGA – Feb 16, 2012

DEPARTMENT OF HEALTH &HUMAN SERVICES

PROGRAM INTEGRITY INITIATIVE

MOLLY DAWSONDIRECTOR,

HHS FINANCIAL POLICY & REPORTING

Central PA AGA – Feb 16, 2012

Overview

• Background of Program Integrity at HHS• What is Program Integrity?• Purpose of Program Integrity• Relationship of Program Integrity and FMFIA• How Does Program Integrity Work?• How Can You Bring Program Integrity to Your

Organization?

Central PA AGA – Feb 16, 2012

Background on the HHS Program Integrity Initiative

•May 13, 2010 Secretary Sebelius announced the HHS Program Integrity Initiative

• Congress allocates more money in the federal budget for HHS than any other Department

•More than $900 Billion dollars in public investments each year

• Given the Department’s mission to protect all Americans’ health and provide essential human services, HHS leadership is committed to ensuring program dollars are not lost due to fraud, theft, mismanagement, etc.

Central PA AGA – Feb 16, 2012

• In line with the HHS mission

• Effectively, Efficiently, and Ethically

• HHS and External Entities working together

What is Program Integrity?

PROGRAM INTEGRITY

BOTTOM LINE: MAKE HHS MONEY GO

FURTHER!

Central PA AGA – Feb 16, 2012

What is Program Integrity?HHS Official Definition

“The operation of HHS’ programs, by both HHS and our external partners, in an effective, efficient, and ethical manner and without conflict of interest or the appearance of conflict of interest, in accordance with applicable laws and regulations. In line with HHS program mission, goals, and objectives, the intended recipients are provided the proper payments, services and benefits while ensuring quality, safety, and access.”

Central PA AGA – Feb 16, 2012

Purpose of Program Integrity?• Meet taxpayers’ expectations that tax dollars are

spent properly;• Make sure the correct population is served;• Ensure that recipients can and are managing

federal funding in an effective and prudent manner, including the federal dollars managed by sub-recipients; • Ensure maximum impact of federal dollars; and • Minimize risk of program failure or bad publicity.

Program Operations Business Functions &

Taxpayers People Served

ContractorsRegional Offices

GranteesStaffDivisions

OperatingDivisions

Central PA AGA – Feb 16, 2012

Program Integrity vs Ethics• Not legally mandated

• Focus on program, not individuals

• Improve effectiveness and efficiency

• Does not govern behavior

Central PA AGA – Feb 16, 2012

Program Integrity & FMFIA• FMFIA, When Done Properly Supports

Program Integrity• Program Integrity is a Subset of the

Annual FMFIA Assessment• Program Integrity Evaluates Internal,

External, and Inherent Risk• Program Integrity Requires Participation

of External Partners to be Successful

Central PA AGA – Feb 16, 2012

How is HHS Enhancing Program Integrity?

• Established the Secretary’s Council on Program Integrity–Comprised of Division Heads–Each Division Head is Directly Accountable

• Established Sub-group – Program Integrity Coordinating Council (PICC)–Comprised of a Direct Report Representative from each

Division –Responsible for Implementing the Initiative in the Division –PICC Meets Monthly

• Address Program Integrity Issues• Share best practices

Central PA AGA – Feb 16, 2012

Office of Program Integrity Coordination (OPIC)

• OPIC was formed to coordinate the Department’s program integrity efforts

• OPIC also has responsibility for implementing the Improper Payments Information Act and associated directives

Central PA AGA – Feb 16, 2012

VisionInstill program integrity into every aspect of our culture to achieve HHS' mission with unprecedented accountability for taxpayer funds

MissionStrengthen program integrity within HHS program operations for effective, efficient and ethical use of funds to help protect the health of all Americans and provide essential human services

Goals

Reduce risk for HHS programs by enhancing program integrity activities

Increase program integrity awareness throughout HHS Headquarters and Regional Offices

Ensure taxpayer dollars are spent the way they were intended

HHS Program Integrity InitiativeWhat is It?

Central PA AGA – Feb 16, 2012

Each Program Integrity Review follows the 4 stages of the Program Integrity Lifecycle (shown to left).

Stage 1 – Identify Risks

Stage 2 – Develop Risk Response Strategy and Corresponding Metrics

Stage 3 – Implement Response Strategy

Stage 4 - Measure and Test Efficacy of Response strategy; Modify as Necessary

THE PROGRAM INTEGRITY LIFECYCLE

MONITOR RISKS IDENTIFY

RISKS

DEVELOP RISK

RESPONSE STRATEGY

IMPLEMENT RISK

RESPONSE STRATEGY

STAGE 1

STAGE 3

STAGE 2

STAGE 4

Each program will follow the same general review cycle.

Central PA AGA – Feb 16, 2012

Step Objective Time* Program Participation

1 Kick-Off Meeting

Create a uniform understanding of the program integrity review process, roles and responsibilities, timelines, and specific deliverables

1 hr

Staff from each program office/division that are responsible for executing day-to-day program functions; Core program integrity team members.

2 Process Mapping

Create an illustrated depiction of work performed by program staff and discuss areas of the process where risks may occur

4 hrs

Staff from each program office/division who are responsible for executing sub-processes. Also, staff with an enterprise view of the program.

3 Specific Risk Identification

Identify and discuss specific risks to each program that, if realized, could adversely impact the program’s ability to carry out its mission.

4 hrs

Staff representing a cross-section of program operations. May include staff from other offices, such as grants management and/or regions.

4 Capabilities Assessment

Discuss and evaluate each program’s capabilities around assessment, management, and monitoring of risk.

2 hrs Staff with a holistic view of the program.

5 Data Validation

Review and validated data collected by Program Integrity Review Tool 1

week Program leadership

RISK ASSESSMENT PROCESS: A STEP-BY-STEP OVERVIEW

*Minimum time expectations for program involvement. The exact time – both duration and number of sessions - will vary by program.

Central PA AGA – Feb 16, 2012

What Does it Take to Enhance Program Integrity?

•Dedicate sufficient time/resources• Integrate program integrity into program operations•Assist outside partners (states, grantees, contractors, etc) in understanding and applying program integrity principles•Each program conducts a risk assessment to identify programmatic vulnerabilities

Central PA AGA – Feb 16, 2012

How Can You Promote Program Integrity Within Your Organization?

You can:• Assess the way you perform your job • Look for ways to be more effective and efficient• Suggest areas and innovative ways where the

organization can be more effective and efficient• Work with your external partners (e.g., grantees,

contractors)• Share your best practices throughout your organization• Ask yourself constantly: “What would I do differently if I

were using my own money?”

Central PA AGA – Feb 16, 2012

QUESTIONS?