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Separation of Duties Frequently Asked Questions October 13, 2016

Separation of Duties Frequently Asked Questions October 13, 2016 Maggie Mack | WIC Nutrition Services Manager. Objectives of this Presentation. Review Separation of Duties FAQs Document sent to WIC directors prior to this call. Collect additional questions to be added to the FAQs.

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Separation of Duties Frequently Asked Questions October 13, 2016

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  1. Separation of Duties Frequently Asked Questions October 13, 2016 Maggie Mack | WIC Nutrition Services Manager

  2. Objectives of this Presentation • Review Separation of Duties FAQs • Document sent to WIC directors prior to this call. • Collect additional questions to be added to the FAQs

  3. Disclaimer • The updated USDA regulations on Separation of Duties are new to all of us. • Questions received regarding Separation of Duties get discussed with all team leads. • Questions asked during this call will be documented and need to be discussed internally prior to issuing a response. • Pending questions will be added to FAQs document.

  4. Q. What are the minimum standards that qualify for a customer service/audit call? • A minimum standard shall be that contact is made with either the 1st or 2nd Authorized Representative (AR). To further clarify, contact means the auditor has actually spoken with the 1st or 2nd AR, not just leave a message. At minimum, one question to ask is, “How was your WIC appointment at XX clinic on [date]?”

  5. Q. When conducting customer service/audit calls, if we contact a client after certification and are unable to reach by phone, can we mail a letter to the authorized representative asking them to contact us regarding their certification experience? • You may mail the authorized representative provided they gave permission for WIC to send mailings. You must still make contact and hear back from the authorized representative in order for it to count towards your review percentage. Local agencies should consider the administrative burden in doing mailings as well as the additional costs for postage.

  6. Q. What happens if we are unable to reach and make contact with the authorized representative when conducting a customer service/audit call? • If you are unable to reach an authorized representative, that certification cannot be used as part of the needed percentage for the review.  Local agencies shall document on the report that they attempted to contact but were unable to reach. 

  7. Q. If we are unable to reach and make contact with the authorized representative when conducting a customer service/audit call, is the certification no longer valid? • The certification remains valid, even if contact is not made with the authorized representative for the review.  The local agency just cannot to use this family as part of the review percentage.

  8. Q. What should we do when conducting customer service/audit calls and the authorized representative(s) don’t speak English? • It is recommended to have someone who is bilingual in English and Spanish conduct the customer service/audit calls, if possible.  Local agencies also have the option of language line services for authorized representatives who speak Spanish or other languages.  In the cases in which bilingual staff or interpreters are unavailable, it is recommended to choose another family to contact and not include that certification as part of your review percentage.

  9. Q. Can we conduct customer service/audit calls daily instead of waiting two weeks? • Yes, minimum requirement is 2 weeks but they may be conducted more frequently.

  10. Q. What standard HANDS report(s) will be available to local agencies to monitor separation of duties? • The state office is currently working to design a standard report in HANDS that will assist local agencies in monitoring and conducting separation of duties reviews. More information to come.

  11. Q. Will local agencies be able to request ad hoc reports on a regular basis for separation of duties monitoring? • We currently do not have the capacity to run frequent ad hoc queries or to send them out to individual agencies/clinics. The state office is currently working to design a standard report in HANDS that will assist local agencies in monitoring and conducting separation of duties reviews. More information to come.

  12. Q. How are local agencies supposed to track the reviews that are completed? • The state office is currently working to design a standard report in HANDS that will assist local agencies in monitoring and conducting separation of duties reviews. The local agency shall use this report to track and log reviews completed. (Similar to the void report)

  13. Q. What are other agencies with one-man clinics planning to do for the new separation of duties policies? • The following is a preliminary list of different options local agencies with one-man clinics are currently exploring; • Send two people to clinic at same time for less days/month. For example, if an agency normally would send one person for one day every week, they will now send two people to the clinic for one day every other week. • Conduct customer service/audit calls to verify client exists and that they were actually at the clinic on day of certification. • Use a secure webcam in which staff would hold up the pay stub to webcam for the income verifier at another clinic to look over, verify, and enter into HANDS.

  14. Q. Can local agencies use a secure eFax system that sends a scanned copy via email to staff at another site to enter the information into HANDS? • No, this is not allowable as it goes against the policy of not scanning/copying eligibility documents and increases likelihood of client confidentiality breaches.

  15. Q. Can local agencies scan eligibility documents directly into HANDS and have another staff member at a separate clinic verify and enter the information into HANDS? • No, this is not allowable as it goes against the policy of not scanning/copying eligibility documents and increases likelihood of client confidentiality breaches. There is also not enough storage space within HANDS to support this amount of scanned documents.

  16. Q. Can local agencies use webcams where staff would hold up the pay stubs to the webcam for the income verifier at another clinic to look over? • A secure webcam option is allowable. Local agencies will need to use a secure program and consider the feasibility and how it will look and function in the clinic setting. The main thing that needs to happen in HANDS for separation of duties is a separate person inputs the income information and another person completes the assessment.

  17. Additional Questions • What additional questions do you have that can be added to the FAQs?

  18. THANK YOU Maggie Mack | WIC Nutrition Services Manager Margaret.Mack@azdhs.gov | 602-542-2980 azhealth.gov @azdhs facebook.com/azdhs azwic.gov

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