IN THIS TRAINING…
Introduction to Organizational Structure History of our Agency Mission, Vision and Brand Promise of DCSS and BPAI
12/18 2.1 9/2018
ORG CHART BPAI HISTORY
Inception to 1993 1993 to 2016 July 2016
9/2018 PRIOR TO 2016 DCSS BRAND PROMISE
Public Assistance Fraud Investigations “Help today for a successful tomorrow by empowering our team to Early Fraud Full Field Prevention/Detection have a positive impact.”
9/2018 9/2018
HOLISTIC APPROACH TO BPAI VISION, MISSION, & BRAND PROMISE PROGRAM INTEGRITY
Vision Deterrence
Enhance the well-being of the communities we serve by ensuring the integrity of public Prosecution Prevention assistance programs, ensuring benefits go to San Diegans in need.
Mission
Conduct timely and fair investigations to safeguard the integrity of public assistance programs, ensuring benefits go to San Diegans in need. Investigation Detection Brand Promise
Safeguard program integrity in a professional and respectful manner…every person, every time. Analysis Mitigation
9/2018 9/2018 INTERGENERATIONAL POVERTY TODAY
Bureau of Public Assistance Investigations
Early Fraud Investigations
Early Community Homeless Team Allegation Team Intervention Long Term Fraud Non-Coop Team Action Team Team
9/2018 9/2018
HISTORY
10/2019 8/2018 LAW ENFORCEMENT CODE OF ETHICS LAW ENFORCEMENT CODE OF ETHICS
As a Law Enforcement Officer, my fundamental duty is to serve mankind; to safeguard lives and property; to protect the I will keep my private life unsullied as an example to all; innocent against deception, the weak against oppression or maintain courageous calm in the face of danger, scorn, or intimidation, and the peaceful against violence or disorder; and ridicule; develop self-restraint; and be constantly mindful of the to respect the Constitutional rights of all men to liberty, equality welfare of others. Honest in thought and deed in both my and justice. personal and official life, I will be exemplary in obeying the laws of the land and the regulations of my department. Whatever I see or hear of a confidential nature or that is confided to me in my official capacity will be kept ever secret unless revelation is necessary in the performance of my duty.
8/2018 8/2018
LAW ENFORCEMENT CODE OF ETHICS LAW ENFORCEMENT CODE OF ETHICS
I will never act officiously or permit personal feelings, prejudices, animosities, or friendships to influence my I recognize the badge of my office as a symbol of public faith, decisions. With no compromise for crime and with relentless and I accept it as a public trust to be held so long as I am true prosecution of criminals, I will enforce the law courteously and to the ethics of the police service. I will constantly strive to appropriately without fear or favor, malice or ill will, never achieve these objectives and ideals, dedicating myself before employing unnecessary force or violence and never accepting God to my chosen profession...law enforcement. gratuities.
8/2018 8/2018 OUR BADGE TARNISHING OF THE BADGE
Intimidation Fear Road Rage Free Stuff Personal Gain Other Employment
8/2018 8/2018
HOW WILL YOU REPRESENT OUR BADGE?
Procedural Justice overview IN THIS TRAINING… DEFINITIONS
Overview of Police Legitimacy and Procedural Justice Legitimacy: The public view of the police as entitled CoSD Customer Service Initiative (HEART) to exercise authority in order to maintain social “Community Bank Account” order, manage conflicts, and solve problems in the community. How does this relate?
Procedural Justice: The procedures used by peace officers where citizens are treated fairly and with proper respect as human beings.
WHAT DOES PROCEDURAL JUSTICE TENETS PROCEDURAL JUSTICE LOOK LIKE?
VOICE – Allow participant to voice their point of view. Engage in active listening. . Remember perception matters . Platinum Rule NEUTRALITY– Unbiased decision making. Consistency, and transparency. RESPECT – Treating a person with dignity, showing empathy, and respecting rights. TRUSTWORTHINESS – Consistently try to do what is best for people. Caring and positive intent.
Video link HEART CUSTOMER SERVICE
Video link Video Link
HEART RESOURCES COMMUNITY BANK ACCOUNT
Withdrawal Deposit PERCEPTION IS EVERYTHING HOW DOES THIS RELATE?
“I know I’m on Welfare, but I’m also an American” How can our work promote awareness of program integrity and empower individuals to make choices that lead to self-sufficient, and safe communities?
IN THIS TRAINING…
Purpose of the Interview Location of interview Talking Points Offering Resources
Early Fraud
10/2019 9/2018 PURPOSE TALKING POINTS - THEMES
• First Impression Why do we do Early Fraud interviews?
• Build Rapport
• Educate
TALKING POINTS - CONTINUED SERVICE ACRONYM
• How to Report Fraud
Much of what we reviewed in this training can be • Review summarized in the acronym “SIERRA”: • Review case details for changes. S - Smile I -Introduce • Conclusion E - Explain • ACCESS, 2-1-1, explain what happens next. R –Rapport R-Respect A - Adapt IN THIS TRAINING…
Early Fraud Expectations Report Contents and Documentation Civil Rights - Interpreters Disposition Codes Evidence Basics
10/2019 6/2019
“CAT” EXPECTATIONS “CAT” EXPECTATIONS
Review the referral.
Make every effort to conduct a face to face interview with applicant, and be flexible
Try to interview the applicant on the first referral
8/2018 8/20188/201/ 18 ALLEGATION EXPECTATIONS PRELIMINARY REPORTS
Investigate the allegation thoroughly. . Interview witnesses and obtain evidence to prove or disprove the allegation of fraud
. If applicant or recipient chooses not to participate in an interview, the investigation continues without an interview
. Goal is to determine if the allegation is unfounded or actionable.
8/2018
PRELIMINARY REPORTS PRELIMINARY REPORTS
The purpose of the Preliminary Report is to Information that must be included clearly communicate the details of your . Name of applicant investigation. . Full address where interview occurred (or indicate a phone interview) . Date and time of interviews or attempts, and time interview was completed . Records check was conducted and results of check . Language, and if an interpreter was used Your report may be used as evidence in court . If a walk-through was completed, and why or administrative hearings. . Abbreviations only when necessary . Avoid using all caps
12/2018 PRELIMINARY REPORTS CIVIL RIGHTS - INTERPRETERS
Allegations: Findings must address the Consent form 20-49 HHSA “Civil Rights-Interpreters” must be obtained from the customer when individuals other than HHSA allegation, and note if more discrepancies employees or HHSA approved interpretation vendors are used were found as interpreters.
P100: If you are requesting the HSS generate a new referral, explain why.
8/09/2018 8/2018 click to access form
CIVIL RIGHTS – UNITED LANGUAGE SAMPLE PRELIMINARY REPORT GROUP
ULG is our contracted interpreter service FINDINGS: Skyler WHITE requested her application for CW be withdrawn. AP in the home. When using ULG, note the following: FACTS: Home visit to 3828 Piermont DR San Diego, 97111 8/20/18 2pm. I .Language used identified and interviewed Skyler WHITE who was home with her son, Walter JR. .Interpreter ID number WHITE told me her husband, Walter White DOB 9/7/58, left the home a week ago and hasn’t returned. WHITE claims she is meeting her needs by having her .Length of call brother-in-law Hank Schrader live with her and pay part of the rent. White reports one vehicle, a 1991 Jeep Grand Wagoneer, and employment part-time with A-1 Carwash as a cashier. When asked about pursuing Child Support from AP, White became visibly nervous and said “she needs to think about it because her husband might be mad”. During interview a man walked into the room carrying You must document in your report when ULG is pizza, wearing a J.P. Wynne High School ID badge for Walter White (AP). I asked if he lived in the home and he said “yes”. WHITE then asked to withdraw her used for interpreter services. application.
5/19 CASE NOTES UPLOADED TO PTS DISPOSITION CODES DEFINED
The following items should be included in PTS: Actionable . FRTS Referral face sheet . Information not reported to HHSA that may impact eligibility . Notes, regardless of brevity . Documented intentional avoidance for a mandatory P100 . Photos used in investigation (without identifying information) . Applicant withdraws due to actionable findings. . Preliminary Report . HHSA 20-49 Form (when applicable) Insufficient evidence . Unable to substantiate the allegation of fraud Do not include: . CLETS printouts of any kind . When PAI suggests HSS generate another referral (P100) . SDLaw printouts . CalPhoto printouts Investigation to continue . Warrant/POs – should be included in your narrative . Used only by Investigations to communicate to HHSA
12/2018 12/2018
DISPOSITION CODES DEFINED EVIDENCE BASICS
Unfounded (No Fraud) Types of Evidence . Allegation of fraud was unfounded . DIRECT: that which directly proves a fact without inference or . All information verified for P100 presumption . REAL (PHYSICAL): tangible objects Withdrawal . CIRCUMSTANTIAL: that which proves a fact indirectly, with inference . When applicant withdraws and it is NOT related to your (e.g., tax returns, DMV records, school information, rental documents) investigation . TESTIMONIAL (ORAL): includes prop 115 No P100 Interview Conducted . CORROBORATIVE: supports direct or circumstantial . Attempts have been made to interview applicant, and the applicant fails to respond. . Documented intentional avoidance by the applicant may be reported as actionable.
12/2018 EVIDENCE BASICS QUIZ
Use of Evidence FINDINGS: P100. Skyler WHITE requested her application for CW . Prove or disprove an allegation be withdrawn. . Impeach recipient or witness FACTS: Home visit to 3828 Piermont DR San Diego, 97111 8/20/18 2pm. I identified and spoke with Skyler White. She stated that she was no longer interested in receiving CW How reliable is your evidence? benefits because she applied for a job at Target and she thinks . Consider the source she will be hired. No further investigation conducted. . Conflict of interest? Disposition Code a. Actionable; b. Insufficient evidence; c. Investigation to Continue; d. Unfounded (No Fraud); e. Withdrawal; f. No P100 Interview Conducted
Report 1
QUIZ QUIZ
FINDINGS: P100 completed. No discrepancies found at this time. FINDINGS: Insufficient evidence to determine care and control of Walter FACTS: Home visit to 3828 Piermont DR San Diego, 97111 Jr. 8/20/18 2pm. I identified and interviewed Skyler WHITE who told FACTS: Home visit to 3828 Piermont DR San Diego, 97111 8/20/18 2pm. I identified and interviewed Skyler WHITE who was home with her son, me the following: White lives with her son Walter JR (present). Walter JR. WHITE told me she and her husband Walter White separated a WHITE told me her husband, Walter White DOB 9/7/58, left the year ago and share custody of Walter Jr 50/50. WHITE stated that she home a week ago and hasn’t returned. WHITE claims she is has her son from Sunday morning to Thurs school drop off. AP has him meeting her needs by having her brother-in-law Hank Schrader live the rest of the time. WHITE claims she is meeting her needs by having with her and pay part of the rent. Hank was present. WHITE reports her brother-in-law Hank Schrader live with her and pay part of the rent. one vehicle, a 1991 Jeep Grand Wagoneer, and employment part- White reports one vehicle, a 1991 Jeep Grand Wagoneer, and time with A-1 Carwash as a cashier. Records check: No employment part-time with A-1 Carwash as a cashier. WHITE showed me disqualifying records or additional vehicles found. court documents with custody listed as 50/50 and custody schedule. I spoke with AP Walter White who confirmed the custody arrangement, but said they don’t always stick to it. Records check: no disqualifying Disposition Code records, or additional vehicles found. a. Actionable; b. Insufficient evidence; c. Investigation to Continue; d. Unfounded (No Fraud); e. Withdrawal; f. No P100 Interview Disposition Code Conducted a. Actionable; b. Insufficient evidence; c. Investigation to Continue; d. Unfounded (No Fraud); e. Withdrawal; f. No P100 Interview Conducted
8/09/2018 Report 2 QUIZ QUIZ
FINDINGS: P100. Unable to make contact with applicant FINDINGS: Skyler WHITE does not have care and control of her son FACTS: Home visit to c/a 3828 Piermont DR San Diego, 97111 Walter Jr. 8/20/18 2pm. No one was home. I left my business card for FACTS: Home visit to 3828 Piermont DR San Diego, 97111 7/20/18 2pm. I identified and interviewed Skyler WHITE. She claimed to live with her applicant Skyler WHITE. Phone call to only number I could locate son Walter Jr. but he was not present. She stated that her son just for WHITE 867-5309 pm 08/20/2018 at 4pm. I left a VM. Home changed schools but did not know the name of the school. WHITE told me visit to c/a 08/21/18 at 8am. No one was home. I left another her husband, Walter White DOB 9/7/58, left the home a week ago and business card. On 08/24/2018 at 10am, I attempted to contact hasn’t returned. WHITE claims she is meeting her needs by having her WHITE by phone. No answer. I left a VM asking WHITE to contact brother-in-law Hank Schrader live with her and pay part of the rent. White me by 5pm on the same day. As of 08/25/2018, I have been reports one vehicle, a 1991 Jeep Grand Wagoneer, and employment part- unable to make contact with WHITE. Records check: no issues time with A-1 Carwash as a cashier. Since WHITE’s son was not present found. and she did not know the school he attends, I asked to see his belongings. WHITE could only show me a single shirt and pair of shoes. I spoke with neighbors who stated that they had not seen Walter Jr for a Disposition Code few weeks. I called AP and he stated that Walter Jr lives w/ him F/T a. Actionable; b. Insufficient evidence; c. Investigation to Continue; since the beginning of the month and is enrolled in school in Temecula. d. Unfounded (No Fraud); e. Withdrawal; f. No P100 Interview Disposition Code Conducted a. Actionable; b. Insufficient evidence; c. Investigation to Continue; d. Unfounded (No Fraud); e. Withdrawal; f. No P100 Interview Conducted
Report 3 Report 4
QUIZ QUIZ
If you are assigned an allegation referral for unreported income True or False? and find that the AP is listed on the apartment lease, you should: The only requirement on attempting to contact a client on a P100 referral is to make 2 home visit attempts. A. End your investigation, complete your preliminary report and ask for a new referral to be generated for AP in the home. B. End your investigation with this information only and make it actionable for AP in the home. C. Continue with your investigation on the same referral to ascertain if there is unreported income or if AP is living in the home.
Question 5 Question 6 QUIZ
True or False?
If you have an allegation referral and the applicant refuses to speak with you, you should conclude your investigation. PAI SAFETY
Pt.1
Question 7 10/2019
IN THIS TRAINING… INTRODUCTION
Introduction to Officer Safety “Officer Safety” is the state of mental, physical, and Situational Awareness tactical preparedness to potential threats and Preparing for the field dangerous situations. Driving
As a PAI, your first responsibility is to protect your own safety both on and off duty.
6/2019 6/2019 COMPLACENCY SITUATIONAL AWARENESS
Complacency: A feeling of satisfaction, often No matter how many cases you have gone out on, or combined with a lack of awareness of pending trouble how many people you have interviewed you must never or controversy. become complacent or dismissive about what potential there is for danger.
WIN – “What’s Important Now?”
6/2019 6/2019
COOPER’S COLORS COOPER’S COLORS
Cooper’s Color Chart is a tool to break down situational awareness into four levels of escalating degrees.
6/2019 6/2019 FIELD PREPARATION FIELD PREPARATION
Know your case load Automated Regional Justice Information System (ARJIS) .Subscribe to BOLOs in your area Have a safety routine .Make checking Officer Safety BOLOs a part of your routine.
Detailed Plan of the Day
6/2019 6/2019
VEHICLE OPERATION
6/2019 12/18 2.1 IN THIS TRAINING… TYPES OF PUBLIC ASSISTANCE
CalWORKs (California Work Opportunity and Responsibility for Kids) Types of Public Assistance . Cash aid Elements of Public Assistance Fraud . Welfare to Work (child care etc.) Introduction to W&I and Penal Code . Homeless Assistance Motivating Factors
12/18
TYPES OF PUBLIC ASSISTANCE TYPES OF PUBLIC ASSISTANCE
CalFresh (SNAP) – Nutrition Assistance General Relief –Not eligible to CalWORKs . Cash Aid . Agreement to repay the County BENEFIT ISSUANCE OUR ROLE
Electronic Benefit Transfer . CalWORKs, CalFresh, General Relief We do not determine eligibility We verify facts, and resolve discrepancies
ELEMENTS OF PUBLIC ASSISTANCE DISCUSSION FRAUD
PAUSE SLIDESHOW ٶٶ ELEMENTS OF PUBLIC ASSISTANCE DISCUSSION FRAUD
False representation of a MATERIAL FACT
Personn mmakingakakining ffafalselslse rerrepresentationeprpreesseenntaattiioonn MUST KNOW IT IS FALSE
Falsee rrepresentationeprpreseseenntaatitionon mmadeada e wiwwithitht thethee SPECIFIC INTENT TO DECEIVE THE COUNTY
Countynty RELIED ON THE REPRESENTATION MADE
Countynty waswasa HARMED BY THE MISREPRESENTATION- REPRESENTATION (funds)(f(fununds)
PAUSE SLIDESHOW ٶٶ
WELFAREWELFARE & IINSTITUTIONSNSTITUTIONS CCODEODE PENAL CODE VIOLATIONS
TheThe ranrangege ooff issues addressedaddressed in this Code incluincludesdes The Penal Code of California forms the basis for the servicesservices relatinrelatingg to welfare, dependent children, application of criminal law in the State of California. mentalmental health, handicappehandicapped,d, elderly, delinquency, It was originally enacted in 1872 as one of the fosterffoosster care, Medi-Cal,Medi-Cal, foodfood stamps, rehabilitation, original four California Codes andand lonlong-termg-term care,care, etc. TheThe W&IW&I CodeCode is where mostmost public assistance PC 118 is almost always charged simultaneously relatedrreellated offenses are charged.charged. with W&I 10980.
SeeSee SectionSection 1098010980
12/18/18 12/18 MOTIVATING FACTORS QUESTIONS?
BPAI safeguards program integrity in a professional and respectful manner… every person, every time.
IN THIS TRAINING…
Overview of Early Fraud Timeline/Flow of an Early Fraud Referral Types of Early Fraud Referrals History Walk-throughs – when are they needed?
Introduction
3/2019 1.2.2 4/2019 OVERVIEW OF EARLY FRAUD OVERVIEW OF EARLY FRAUD
Proactiveactive RoleRole Early Fraud avoids the higher costs associated with long-term Doess nnotot delay bbenefitse investigation, prosecutionprosecution,, and collection activactivities
Discrepanciesrep found early
3/2019 9/2018
OVERVIEW OF EARLY FRAUD OVERVIEW OF EARLY FRAUD
Your first impression will influence how the public views BPAI, Early Fraud is an administrative extension of the initial the County of San Diego, and Law Enforcement in general. eligibility determination process.
The applicant interview is conducted to: . provide fraud awareness education . confirm factual information . resolve discrepancies . provide additional resources OVERVIEW OF EARLY FRAUD EARLY FRAUD CASE TIMELINE
Cite a specific allegation of fraud . In San Diego County, we also have “CAT” referrals for new cases in which fraud is not suspected
Generated while cases are pending approval, or recently granted (within 90 days)
From a variety of sources, such as: . HHSA Eligibility Staff . Welfare Fraud Hotline . Investigative Staff
4/2019 12/2018
EARLY FRAUD REFERRAL TYPES HISTORY
“CAT” Referrals
Allegation Referrals
8/09/2018 EARLY FRAUD REFERRAL TYPES DISCUSSION
“CAT” Referral Criteria . New application (no assistance in last 12 months) . No suspicion of fraud . CalWORKs only . Applicant only . HHSA will not make a determination on the case until a this is completed.
PAUSE SLIDESHOW ٶٶ
EARLY FRAUD REFERRAL TYPES DISCUSSION
Allegation Referrals . HSS identifies discrepancies . 90 days of application/renewal . Discrepancies involve eligibility factors . HSS articulates a reasonable suspicion that discrepancies exist
PAUSE SLIDESHOW ٶٶ 8/2018 WALK-THROUGHS WALK-THROUGHS
A walk-through during a home visit is a tool to be used only Walk-through only occurs in the area for which the applicant when necessary to ensure the facts of the case are as has control reported. . A roommate or family member cannot give permission when the applicant is not present Walk-throughs are not mandatory.
Take the following steps when conducting a walk-through: . Explain why . Ask Permission . Document why the walk-through was conducted in your report
QUESTIONS?
CONFIDENTIALITY
BPAI safeguards program integrity in a professional and respectful manner… every person, every time. Overview
10/2019 IN THIS TRAINING… INTRODUCTION
Introduction Laws and regulations governing confidentiality of Welfare & Institutions Code 10850 welfare information exist to protect recipients HHSA Regulations against identification,eexploitation, or embarrassment that could result from the release of What Records CAN Be Disclosed? information identifying them as a welfare recipient. What Records CANNOT Be Disclosed? Scenarios
8/9/2018 8/9/2018
W&I CODE 10850 HHSA REGULATIONS
Policies and regulations regarding confidentiality of welfare records can be found in the HHSA Program Welfare & Institutions Code 10850 Guides. . CalWORKs – 19-000 . CalFresh – 63-350 . General Relief – 90-050
8/9/2018 8/9/2018 WHAT CAN BE DISCLOSED? WHAT CAN BE DISCLOSED?
Information obtained during an investigation which is not Information in connection with an investigation, part of the HHSA records. prosecution (civil or criminal) with a nexus to any of the HHSA public assistance programs. Public assistance data to other public social services agencies or other SIUs for the agency’s specific use. Records a recipient/applicant has agreed to be disclosed by signing a “Release of Information” form specific to that purpose. Information specified in W&I Code 10850.3 and 10850.7
Records released in joint investigations with other General data which does not identify a specific law enforcement agencies. individual(s).
8/2018 Continued on next slide 8/2018 Continued on next slide
WHAT CAN BE DISCLOSED? WHAT CANNOT BE DISCLOSED?
Records to local public housing authorities, County Records or data on any individual(s) to the general Auditor/Controller, County Council, Health Services, public, or legislative body. DCSS. Any release of records which are not within the Information to law enforcement (only with approval from administration of public assistance programs, except their immediate supervisor), when a felony or authorized by law. misdemeanor arrest warrant has been issued or if information is requested on a fleeing felon and/or Any information in HHSA records that is considered probation/parole violator. “privileged communication”. HHSA also has internal procedures for processing requests from law enforcement agencies (see W&I Information or records from the Internal Revenue Service 10850.3 and 10850.31). (IRS)
8/2018 8/2018 Continued on next slide WHAT CANNOT BE DISCLOSED? CONFIDENTIALITY
BPAI policy can dictate that we are stricter than State statutes with regard to confidentiality. Notify your supervisor Complainant information (except when in court). before releasing any records to outside agencies.
Investigation reports and/or investigative notes (until The guidelines for what records can or cannot be disclosed as trial/administrative hearing). provided in this training is intended as a summary of the most common situations.
All BPAI staff should review the governing policies thoroughly Summaries and/or computer printouts of in order to have a clear understanding of confidentiality as it confidential communications and records from law relates to public assistance records, and refer to those policies if a situation arises which is not covered in this enforcement specific resources (DMV, CII, police overview. reports, etc.).
8/2018 Continued on next slide 8/2018
SCENARIOS
CIVIL RIGHTS
BPAI
10/2019 IN THIS TRAINING… CIVIL RIGHTS
BPAI Civil Rights Liaison:
Meet the BPAI Civil Rights Liaison Review key points applicable to BPAI Q&A
8/9/2018
CIVIL RIGHTS - DOCUMENTATION CIVIL RIGHTS - DOCUMENTATION
All contacts with an applicant/recipient must be documented Consent form 20-49 HHSA “Civil Rights-Interpreters” must be on how the applicant/recipient’s language interpretation obtained from the applicant/recipient when individuals other needs were met, including client’s acceptance or denial of than HHSA employees or HHSA approved interpretation language services. vendors are used as interpreters. Interpreters in this capacity are chosen and provided by the applicant/recipient. Bilingual staff must specify in their reports that they used their bilingual skills to meet the language needs of non- In addition to the applicant/recipient, the chosen interpreter English speaking applicant/recipients. must sign and date the form acknowledging his/her confidentiality. This must be documented in the investigators Examples: report. “client prefers Spanish for written and oral communications” “conducted in Farsi by bilingual investigator” *Reminder: The 20-49 is not required for any interpreters provided by HHSA, which would include HHSA bilingual staff “client offered interpretive services/accepted” as well as HHSA approved interpretation vendors. CIVIL RIGHTS CIVIL RIGHTS
SERVICE ANIMALS SERVICE ANIMALS Beginning on March 15, 2011, only DOGS are recognized as Service Animals under the ADA. When it is not obvious what service an animal provides, only There is no requirement for any special “certification” as a limited inquiries are allowed. Staff may ask two questions service animal. A service animal may be trained by a non- ONLY: certified professional, a friend, a family member, or the person with the disability. 1. Is the dog a service animal required because of a disability? Generally, HHSA must permit service animals to accompany people with disabilities in all areas where members of the 2. What work or task has the dog been trained to perform? public are allowed to go.
CIVIL RIGHTS CIVIL RIGHTS
SERVICE ANIMALS EMOTIONAL SUPPORT ANIMALS:
Provide comfort to a person with a psychiatric/emotional Staff CANNOT: disability, but are not necessarily trained to perform specific tasks to assist them. ask about the person’s disability Are not covered under laws that apply specifically to Service Animals, but may be allowed to accompany individuals in require medical documentation, housing or public accommodations as “reasonable require a special identification card or training documentation accommodations” for the individual’s psychiatric disability. for the dog, or Are sometimes referred to by other terms, including ask that the dog demonstrate the work or task. “companion”, “comfort”, or “therapy” animals.
Note: Staff may encounter situations involving emotional support animals and should accommodate as appropriate QUIZ QUESTIONS?
IN THIS TRAINING…
HEART – Customer Service for Investigators First 30 – Factors to Consider . Building Rapport . Body Language . Tone of Voice . Identification . Wording . Interview Psychology
10/2019 9/2018 HEART FIRST 30 – BUILDING RAPPORT
Emphasis on education, and building rapport in Early Fraud How we act during the first 30 seconds of our Follow HEART and Procedural Justice principals. contacts will impact how the rest of the interview goes – either positively or negatively.
Factors to consider when contacting an applicant: . Body Language . Tone of voice . How you identify yourself . Phrases, wording . Why are you there? (why do they think you’re there?)
8/2018
BODY LANGUAGE TONE OF VOICE
It’s not what you say, it’s how you say it! TONE OF VOICE WORDING
How you word things can have an impact on communication. . Use simple, plain language . Some words have negative overtones . Be aware of education level . Avoid using jargon
IDENTIFYING YOURSELF INTERVIEW PSYCHOLOGY
Why is building rapport important? How do you identity yourself?
“Othello Error” What are some ways to make a good impression with your introduction? When the applicant is comfortablee . Information is more reliable Does what you say vary depending on the situation? . Their memory is better . They are more cooperative QUIZ
10/2019
IN THIS TRAINING… ADMINISTRATIVE INVESTIGATIONS
The difference between administrative and criminal Usually non-adversarial in nature investigations? Involves more interviews rather than interrogations How does this relate to your work at BPAI? Doesn’t affect a person’s liberty/freedom Interview or Interrogation? Burdens of Proof (Early Fraud vs. Investigations) FOCUS: violations of policy, rules, or regulations.
9/2018 CRIMINAL INVESTIGATIONS AT BPAI
Can become adversarial in nature Early Fraud is administrative in nature Can involve interviews and interrogations Can affect a person’s liberty/freedom Investigations cases have the potential for prosecution FOCUS: violations of criminal statutes (W&I, Penal Code).
9/2018 9/2018
INTERVIEW OR INTERROGATION? BURDENS OF PROOF
The majority of the conversations you have with applicants should be INTERVIEWS.
INTERROGATIONS . What’s the difference?
12/2018 12/2018 BURDENS OF PROOF
Special Considerations and Planning
12/2018 10/2019
IN THIS TRAINING… HOMELESS INTERVIEWS
Homeless Interviews Homeless P100 Referrals Regional Considerations – Military Bases, Tribal Land . PAI will contact applicant over the phone and conduct a phone interview. DV and Treatment Centers . Only seen in-office if unable to contact by phone, or at Plan of the Day (POD) other location. . HSS schedules in-office interview.
Homeless Allegation Referrals . No interview scheduled. . Use investigative resources and interview over phone or in person as necessary.
8/2018 6/2019 INTERVIEWING PROCEDURES ON CAMP PENDLETON TRIBAL LANDS
Provide staff at gate your BPAI credentials upon your arrival. Advise that if you are working an Early Fraud case, you are • E-mail the liaison with brief there to verify information only as this is a non-criminal explanation of reason for visit, investigation. the address and if it’s for an If it is a criminal investigation, contact the Base Magistrate early fraud or criminal prior to your arrival to advise of your case. They will explain investigation. their protocol and ways they can assist with your investigation. • The liaison will respond with how to proceed.
8/2018 8/2018
DV AND TREATMENT CENTERS PLAN OF THE DAY (POD)
Most staff at domestic violence shelters, homeless shelters PODs are daily investigative work plans sent to your supervisor. and treatment centers will not confirm or deny if a person is a resident without a signed release of information. If residency PODs are used to: needs to be verified, residents can request a verification from . Monitor the approximate location of staff for safety purposes. the program that indicates they are residents. . Assist the SPAI in workflow and case assignment.
PROCEDURE: For security purposes, most DV shelters will not allow their . Send your POD to your SPAI or designee by e-mail, daily residents to give out the shelter address or meet anyone at . Subject line: POD – INV# - DATE (Ex. POD – WF17 – 8/3/18) the shelter. These clients are often given an address to use . Include (at a minimum): for mailing. . FRTS Number . Address of interview . The POD should be in anticipated sequential order Safe at Home – California’s Confidential Mail Program . Update your POD if changes occur during the day
8/2018 8/2018 IN THIS TRAINING…
Our role working with HHSA Representing BPAI at FRCs HHSA Liaisons Resolving Training Issues Office Hours Working with Ride-along Expectations HHSA
10/2019 8/2018
OUR ROLE WITH HHSA OUR ROLE WITH HHSA
The Health and Human Services Agency (HHSA) is BPAI and HHSA work in partnership to ensure one of five groups of the San Diego County program integrity. government. HHSA provides a broad range of health and social services, promoting wellness, self- sufficiency, and a better quality of life for all individuals and familiesamilies in San DiDiegoeg County.
8/2018 12/2018 REPRESENTING BPAI HHSA LIAISON
PAIs are subject matter experts in the field of Public The BPAI FRC Liaison is the central point of contact Assistance Fraud. As such, other agencies, primarily between BPAI and each FRC. HHSA, rely on us as a resource for training and guidance. You are the first point of contact with your FRC As a PAI assigned to Early Fraud, you are expected to Liaison for issues that do not require a supervisor. model HEART principles in all contacts with HHSA staff.
It is also expected that PAIs will take initiative to Periodically check in with your Liaison to get FRC establish and maintain professional relationships updates or see if any BPAI support is needed. between HHSA and BPAI.
12/2018 9/2018
COMMUNICATING OFFICE HOURS TRAINING ISSUES
Let your supervisor know of any trainings issues at PAIs need to make themselves available at FRCs as a the FRC. resource to HHSA.
Your supervisor will work with the HHSA liaison.
Keep interactions with HSS staff positive.
12/2018 RIDE ALONG EXPECTATIONS RIDE ALONG EXPECTATIONS
Contact the HSS to coordinate your starting BPAI is mandated to provide initial fraud training to time/location/attire. new HSS staff. Before leaving for the field, providing a safety briefing Part of this training requirement may be accomplished through a PAI ride-along.
12/2018
RIDE ALONG EXPECTATIONS
Do not run CLETS or show CLETS info to the HSS
Review several fraud referrals with the HSS. Explain HHSA APPEALS the content needed, and why.
Overview
12/2018 10/2019 IN THIS TRAINING… INTRODUCTION
Introduction Applicants/recipients have the right to a fair hearing: What Happens When An Appeal Is Filed? . For any County action to deny, decrease, suspend, change, State Hearings or discontinue benefits. County Hearings Claimants are generally required to file a hearing Hearing Overview request within 90 days of receiving the Notice of Prepare To be A Witness Action. When You Testify . There is no deadline for filing if an adequate NOA was Evidence To Support County Action never sent.
8/2018 8/2018
WHAT HAPPENS WHEN AN APPEAL WHAT HAPPENS WHEN AN APPEAL IS FILED? IS FILED?
Aid Paid Pending (APP) Appeals Case Review . Case may remain active while the appeal outcome is pending. . Only when appeal is filed before the effective date of action, or if a NOA was not issued timely. . Conditional Withdrawal Appeals Case Review . Cases are assigned to a Program Specialist as soon as the Hearing Request is received.
8/2018 8/2018 STATE HEARINGS COUNTY HEARINGS
Appeal hearings are conducted by an Administrative Appeal hearing conducted and decided by a Program Law Judge (ALJ) Specialist The County is represented by an HHSA Program County programs: General Relief, County Medical Specialist. Services (CMS), IHSS Provider overpayments. State programs: CalWORKs/RCA, Foster Care, CAPI, CalFresh, Medi-Cal, IHSS, etc.
8/2018 8/2018
HEARING OVERVIEW PREPARE TO BE A WITNESS
Informal with a State ALJ, or County Hearing officer Preparation begins the moment you initiate your presiding as judge investigation. The hearing is recorded . Prepare complete and thorough reports Can be in-person, video conference, or over the phone . Be prepared to explain the reasons for your actions and All parties are placed under oath omissions The County and claimant can question witnesses Prior to offering testimony: The ALJ/Hearing Officer can ask questions . Know the case Evidence is presented . Review your report, notes, etc. A decision will be issued at a later date . Discuss the case with the Appeals Rep . Can be appealed to Superior Court
8/2018 8/2018 PREPARE TO BE A WITNESS WHEN YOU TESTIFY
Contact the Appeals Representative . Contact the Program Specialist identified on the AP18 to determine if any follow-up investigation is needed.
8/2018 8/2018
SUPPORTING EVIDENCE SUPPORTING EVIDENCE
A thorough investigation is more likely to hold up at Residency issues Absent Parent appeal. Keep the following in mind as good . Collateral contacts . DMV records supporting evidence: . Signed sworn statements . Employer records . School records . Lease agreements . Border crossing records . Collateral contacts . EBT usage patterns . Interview the AP
8/2018 8/2018 SUPPORTING EVIDENCE APPEAL PROCESS VIDEO
Child Out Unreported income . School records . Employer records . Court custody documents . Collateral contacts . Interview both (landlord, relatives) parents/guardians . Surveillance . Sworn statements . Bank records . Collateral contacts
8/2018 8/2018 VIDEO LINK
IN THIS TRAINING…
MANDATED Mandated Reporting Defined REPORTING Child Protective Services Adult Protective Services How to File a Report What Happens After a Report is Filed?
Annual Quiz Refresher
10/2019 9/2018 MANDATED REPORTING DEFINED CHILD WELFARE SERVICES
Who are Mandated Reporters? San Diego County Child Welfare Services (CWS) . Child Abuse and Neglect Reporting Act – Penal Code 1164-1174.3 . CWS investigates reports of suspected child abuse and neglect and intervenes with families who do not meet the minimum community All BPAI employees are Mandatory Reporters. standards of health and safety as required by law. . According to CA law – all employees of a law enforcement agency are . Vision: Every child grows up safe and nurtured. mandated reporters. . Priority is always to stabilize and preserve families if possible. . Penal Code 11164-11174 California law requires mandatory reporting of known or suspected: . Child abuse and neglect . Elder and dependent adult abuse
Failure to report is a crime
9/2018 9/2018
WHEN TO FILE A REPORT WHEN TO FILE A REPORT
The CA Penal Code defines child abuse as a Physical Injury Emotional Abuse which is inflicted by other than accidental means on a child by . Bizarre and cruel behavior another person. This also includes: . Caregiver’s actions have led to child’s severe anxiety, depression, . Emotional Abuse withdrawal, or aggressive behavior toward self or others . Sexual Abuse . Domestic Violence . Neglect . The child has witnessed or was involved in a physical altercation between adults in the home
Child abuse does not include: . Public fighting between minors . Spanking that is reasonable and age appropriate (does not expose the child to risk of serious injury) . Reasonable and necessary force used by a peace officer
9/2018 9/2018 WHEN TO FILE A REPORT WHEN TO FILE A REPORT
Sexual Abuse Commercial Sexual Exploitation of Children (trafficking) . Any sexual act on a child . Risk Factors: . Any known or highly suspected sexual abuse perpetrator living with a . History of abuse child . Running away from home . Children exhibiting sexual behavior outside of normal exploration or that involves coercion or violence . Homelessness . Engaging the child in pornography or involving obscene acts . Poor school attendance . Adults allowing children to see sexually explicit material, witness sexual . Substance abuse acts, or hear sexual language that is for the purpose of sexual . Interpersonal violence gratification of the adult . Criminal history Tips: . Relationships with much older adults . Do not interview the child regarding details of the abuse . Sending or receiving sexually explicit material via phone or computer . Do not notify the parent/caregiver of the disclosure . Do not have more than one Mandated Reporter speak to the child . Report the information using the same words and terminology used by the child
9/2018 9/2018
WHEN TO FILE A REPORT WHO FILES THE REPORT?
General Neglect The Mandated Reporter with the most information files the . Lack of supervision based on the maturity level/developmental report ability of the child . Children reporting lack of food accessible leading to hunger Only one report is needed from each agency . Inadequate mental, physical, or dental health care . Parental substance abuse (including prescription drug use, or prenatal drug use) that impacts the child Remember: . Clothes are ill-fitting, filthy, or inappropriate for weather . You must report a suspicion or disclosure to you of abuse or neglect . Hygiene is consistently bad (unbathed, matted and unwashed hair, . There must be a current child victim (under 18) body odor) . Historical/past abuse must be reported . CPS relies on you as their “eyes and ears” in the community
9/2018 9/2018 HOW TO FILE A REPORT HOW TO FILE A REPORT
You must make a report immediately (or as soon as CPS Social Workers gather as much information has possible to evaluate the level of risk. practically possible) by phone. Information Needed (Authorized by PC 11167) . Your name /agency name & phone number Written reports must be submitted on DOJ forms. The report . Name of child and DOB /age must be made to a county child welfare department, police or . Address of child /apartment # . Siblings / other children in the home sheriff’s department or to a county probation department. . Names of the parents or caregivers and if there are custody of visitation orders . Names and contact information for other relatives or extended family San Diego County Child Welfare Services members . (888) 242-5722 . Name of the school child attends and hours attended . Suspected Child Abuse Report (SS 8572) . Does child have active IEP/diagnosis . Developmental delays/medical concerns . Fax: (858) 467-0412 . Description of injury, behavior or concerns . E-Mail: [email protected] . Any relevant cultural factors of the family
9/2018 9/2018
WHAT HAPPENS NEXT? ADULT PROTECTIVE SERVICES
The Child Abuse Hotline Social Worker will gather as much San Diego County Adult Protective Services (APS) formation as possible to assess the level of risk and . APS serves adults 65 and older and dependent adults 18 and older, determine if the case meets the criteria for investigation. who are harmed, or threatened with harm, to ensure their right to . Not all reports are investigated. safety and dignity. APS investigates elder and dependent adult abuse, including cases of neglect and abandonment, as well as Cross reporting to other agencies physical, sexual and financial abuse. Feedback mailed to the Mandated Reporter . Penal Code 15630-15632
9/2018 9/2018 WHEN TO FILE A REPORT WHEN TO FILE A REPORT
The W&I Code 15630-15632 and Senate Bill 2199 defines abuse Physical Abuse of an elder or dependent adult abuse as: . Direct beatings . Physical Abuse . Lack of medical care or overmedication . Sexual Abuse . Sexual exploitation . Neglect . Financial Abuse Neglect . Abandonment, Isolation, Abduction . Denial of food, clothing, shelter, health care . Deprivation of goods or services that are necessary to avoid physical harm or mental suffering . Unable to provide for basic needs
A report is required if you: Financial Abuse . Witness an incident: . Theft . Receive information or evidence, whether visual or audible; . Misuse of funds or property . Or, an elder or dependent adult discloses an incident that appears to . Extortion, duress, fraud constitute abuse
9/2018 9/2018
WHEN TO FILE A REPORT WHEN TO FILE A REPORT
Abandonment Signs of trouble . Desertion or willful forsaking by anyone having responsibility or care . Injury that is inconsistent with the explanation for its cause . The elder or dependent adult has recently become confused or Isolation disoriented . Preventing a dependent adult from receiving mail, telephone calls, . The caregiver shows anger, indifference, aggressive behavior toward visitors the person . Personal belongings, papers, credit cards are missing Mental suffering . Hesitation from the elder to talk openly . The caregiver has a history of substance abuse, mental illness, . Verbal assaults criminal behavior or family violence . Threats . Lack of necessities, such as food, water, utilities, medications and . Fear medical care . Another person's name added to the client's bank account or important documents, or frequent checks made out to CASH
9/2018 9/2018 HOW TO FILE A REPORT WHAT HAPPENS NEXT?
You must make a report immediately (or as soon as The APS Social Worker will gather as much formation as practically possible) by phone. possible to assess the level of risk and determine if the case meets the criteria for investigation If the suspected abuse results in bodily injury, a telephone . The Mandated Reporter will be contacted after an APS worker has report shall be made to the local law enforcement agency been assigned to the case immediately, but also no later than within two (2) hours.
San Diego County APS . Suspected Dependent Adult/Elder Abuse Report . (800) 510-2020 . Online WebReferral – www.AISWebReferral.org
9/2018 9/2018
QUIZ QUIZ
California law requires Mandatory Reporting for which of the following incidents? a) Child abuse and neglect b) Elder financial abuse c) Suspected sexual trafficking of children d) All of the above
9/2018 QUIZ QUIZ
Mandated Reporters Include: A mandated reporter is not required to do which of a) Physicians the following? b) Teachers a) Report c) Employees of a law enforcement agency b) Investigate d) All of the above c) Call CPS or APS d) File a written report
9/2018 9/2018
QUIZ QUIZ
Which of the following are types of elder or Mandated Reporters are required to give their names dependent adult abuse? and are provided unqualified immunity from civil a) Financial Abuse liability. b) Abandonment a) True c) Isolation b) False d) All of the above e) None of the above
9/2018 9/2018 QUIZ QUIZ
A telephone report must be made within the If a victim does not want you to report, you should following time frame: not report. a) Within 48 hours a) True b) Within 30 days b) False c) Immediately or as soon as possible d) A telephone report is not required
9/2018 9/2018
QUIZ QUIZ
Which of the following is considered child abuse? Abuse reported to the Fraud Hotline: a) Public fighting between minors a) Doesn’t need to be reported because they could be lying b) Neglect b) If we didn’t see it, it didn’t happen c) Spanking that is reasonable & age appropriate and does c) Is not our responsibility, we do welfare fraud not expose the child to serious injury d) Must be reported by any staff member of BPAI d) Feeding a vegetarian diet e) Only needs to be reported if a Peace Officer sees it e) All of the above
9/2018 9/2018 QUIZ THANK YOU
Failure to report suspected abuse is a misdemeanor crime that may include jail time and a fine. a) True b) False
9/2018 9/2018
IN THIS TRAINING…
Field Contacts PAI Crimes in Progress SAFETY Off Duty Additional Resources Review
Pt.2
12/2018 2.10 6/2019 FIELD CONTACTS FIELD CONTACTS
Procedural Justice Use proven tactics in high risk situations: . Voice . Plan and consider alternatives before taking action . Neutrality . Wait for backup PAIs or LE to arrive . Respect . Position vehicles in safe locations . Trustworthiness . Cover and concealment . Maintain a position of advantage
Recognize your capabilities and the capabilities and limitations of the equipment we use
6/2019 6/2019
FIELD CONTACTS CRIMES IN PROGRESS
Type of Crime BE A GOOD WITNESS Time of Occurrence Location of Occurrence Suspect(s) Description: . Name, Sex, Race, Age, DOB, height, Weight, hair Color, eye Color, Complexion, Clothing (from head down), Other identifying characteristics. Vehicle Information: . Year, color, make, model (doors, equipment, damage, decals) Direction of travel Other Information: Weapons, mental illness, etc.
6/2019 OFF DUTY IN CLOSING
Create a culture of safety at work. . Be a good example to new staff . If you see someone being unsafe – say something
Procedural Justice . These principals not only keep you safer, they create a safer environment for all Law Enforcement.
6/2019 6/2019
ADDITIONAL RESOURCES
6/2019