Expected to Work/Barriers to Full Employment Policy & Procedures

Published Date: April 25, 2012
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19 Administrative Procedures

Substantiation and Verification

Introduction

INTENT

To ensure appropriate substantiation and verification of client circumstances for determining program eligibility and benefits.

POLICY

Rationale

Clients are responsible to establish their identity and to prove they meet all eligibility conditions. Clients must provide information to their worker that substantiates their circumstances both at intake and throughout their involvement with Alberta Community and Social Services.

Workers are responsible to determine eligibility and issue the appropriate level of financial and other benefits to meet the client’s needs by verifying the required information and substantiation that the client has provided regarding their circumstances.

Guiding Principles

Requirements for substantiation and verification outlined in this section are based on the following guiding principles:

Benefits Requested Are Valid
The worker obtains substantiation that assists in determining:

  • If the benefit the client requests is a valid need
  • Whether all resources of the client have been accessed
  • Whether the most reasonable and economical alternative was chosen

Standard Requirements Are Met
To ensure substantiation and verification activities are value added, the standard requirement is stated in policy. Workers use discretion to determine if the standard requirement is adequate for certain situations or if additional substantiation is required. Workers may ask for additional substantiation in situations where:

  • Eligibility cannot be determined without further documentation
  • The worker has reason to believe the client is withholding information or providing inaccurate information

Activities Are Value Added
Workers consider whether the substantiation they are requesting in addition to the standard requirement is necessary so that activities are:

  • Not duplicated
  • Do not unnecessarily increase workload
  • Do not unnecessarily increase paper collection and retention, and
  • Do not create unnecessary hardship for the client

Activities Facilitate Ability to Prosecute Fraud Cases
Substantiation and verification activities assist fraud investigators in prosecuting fraud cases so workers must ensure:

  • Documents provided by clients are legible, date stamped and initialed by the worker accepting the documents 
  • Photocopies are clear
  • Copies of photo ID are signed and dated by the worker who accepts them
  • Photographs and signatures are compared to ensure client’s identity, and
  • Documents are accurately filed according to file standards

PROCEDURE

Substantiation

Clients provide evidence (documented or supported otherwise) to substantiate Personal and Family/Household Information, Assets, Income, Eligibility and Needs when applying for benefits and when changes in circumstances occur.

Clients may be allowed a period of time to provide substantiation when they are unable to produce the required documents unless eligibility cannot be determined without the substantiation (e.g., photo ID, photograph). Workers determine the appropriate amount of time allowed to obtain the documentation depending on the circumstances.

Before issuing Income Support (IS) benefits to a client who does not have and/or is unable to produce the required substantiation, the worker:

  1. Documents in Mobius Notes:

     

    • The reason(s) why the client is unable to produce the required documents
    • The action(s) the client is taking to obtain the required documents
    • The estimated time required for the client to obtain the required documents

     

  2. Places a hold on benefits in the ARC system.

     

  3. If the client is reporting through CRC, leaves the Cheque Release Flag for the next period of assistance at N and indicates on the comments line on the CRC Processing screen that no further benefits are to be issued until the required documents are received or until proof of attempts to get the required documents is received (an example of proof is a copy of an application for a birth certificate).

Failure to produce necessary documents or evidence of attempts to obtain such documents may constitute non-compliance and could result in the reduction, suspension or discontinuation of benefits.

For monthly reporting, entry in the Automated Reporting for Clients (ARC) is considered the substantiating method for employment activity and changes in family/household size, shelter and assets. However, clients are advised they may be asked at any time during their involvement with the department to produce evidence to substantiate their circumstances.

Clients who are exempt from monthly reporting are advised to inform their worker of changes in their circumstances by telephoning or writing their worker immediately. These clients are also required to complete an annual report to substantiate their circumstances.

Note
In situations where a client has a financial administrator or trustee, the financial administrator or trustee is responsible to provide the required substantiation on the client’s behalf.

Verification

Workers verify the client’s Personal and Family/Household Information, Assets, Income, Eligibility and Needs by:

  • Examining the substantiating documents presented by the client
  • Taking into consideration information obtained from other sources
  • Direct observation
  • Recording the information and their observations in Mobius Notes
  • Ensuring substantiating documents comply with IS Policy and Procedures

Workers may contact a source such as an employer, landlord, vendor, etc. directly if:

  • The client is unable to obtain the required documents, or
  • The worker has reason to believe the documents submitted are inaccurate or forged.

If a worker has reason to believe a client is providing inaccurate or false information, the worker may refer the case to Fraud Investigation.

Note
Clients reporting through ARC will be subject to verification by a post payment verification and eligibility review.

Guidelines

The following chart outlines a range of guidelines for substantiation and verification activities that may be considered. The chart contains examples only and is not all-inclusive.

Standard Requirement Worker Responsibility
Verbal statement of client Worker documents client’s statement in Mobius Notes
Observations by the worker Worker documents observations in Mobius Notes
Worker knowledge Worker knows from past experience or substantiation that client’s statement is true and documents this in Mobius Notes
Client’s signature on the EMP 3428 Income Support Application or declaration though monthly reporting Worker accepts client’s signature on EMP 3428 Income Support Application or the information provided through their monthly reporting
Written statement from client Worker reviews the statement and accepts client’s signature on statement
Client provides original documents Worker reviews such items as ID, receipts, pay stubs
Client is required to have departmental forms completed EMP 114 Statement of Net Earnings, EMP 0207 Medical Report and reviews the completed forms
Client provides written statement from a 3rd party Worker requests client to provide letter from bank (e.g., LIRA is locked in), letter from employer (e.g., mandatory deductions) and reviews
Client provides legal documents Worker requests documents such as Decree Nisi, bankruptcy, income tax assessment and reviews
Client completes sworn statement or statutory declaration Worker requests client to complete EMP 0151A Statutory Declaration

 

Note
Workers enter the date of their discussion with the client if they are documenting in
Mobius Notes on a date different from the date the discussion took place.