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AGENCY TESTIMONY
Challenges in implementing proposed legislation
0:15:07
·
3 min
Jill Berry outlines several challenges and concerns regarding the implementation of the proposed legislation, focusing on legal, technical, and practical obstacles. She emphasizes the complexity of the benefits system and the need to adhere to existing regulations.
- DSS must adhere to state and federal regulations governing applications, enrollment, documentation, and timelines.
- Privacy concerns and legal restrictions limit the sharing of sensitive information across agencies and programs.
- Providing receipts and copies of documents for all applications presents logistical challenges, especially for home visits and applications involving sensitive health information.
Jill Berry
0:15:07
We appreciate the goals of easing the benefits application process, reducing the administrative burden placed on applicants, and offering clarity to applicants as to documentation required in a timely fashion.
0:15:22
However, DSS is obligated to adhere to the rubric set out by state and federal authorities governing applications, enrollment, documentation, and timelines.
0:15:34
For instance, the USDA Food and Nutrition Service, FNS, has been specific about what our website looks like and what is permissible and impermissible with respect to application submission.
0:15:48
For example names, addresses, and signatures.
0:15:51
Next given the multitude of benefits HRA administers not to mention other city benefits administered by other agencies it is difficult to see the nexus between those diverse programs that would create a common application that is streamlined to support efficient application and assessment.
0:16:12
Certain programs such as Medicaid may require protected health information to be submitted submitted that is protected by state and federal confidentiality protections.
0:16:23
Additionally the federal government closely monitors and protects the use of information submitted in support of a snap application.
0:16:32
State and federal privacy laws currently bar us from sharing data across certain agency databases without authorization.
0:16:41
Those privacy considerations preclude certain protected information from crossing certain boundaries even within DSS, let alone aggregating sensitive information about individuals residence history, income tax payments, or earnings histories on the scale required for automatic enrollment.
0:17:02
Lastly, these bills would substantially impact the processes and workflow DSS uses to assess eligibility, process applications, and make a determination on an application.
0:17:15
Providing a receipt and copies of documents submitted may seem like a simple request at first.
0:17:21
To the extent we can we are providing receipts.
0:17:25
For applicants using Access HRA a receipt which shows the date the application was submitted is made available upon submission of the application.
0:17:37
For a client who comes in person and applies for benefits a receipt is made available upon request.
0:17:44
Our goal is to keep clients informed throughout the application process.
0:17:49
This includes when possible making them aware of what documentation is outstanding in cash assistance and snap applications for instance.
0:18:00
In other applications we handle this receipt and copies mandate is much more complicated such as for Medicaid applications where a caseworker is conducting a home visit for a client with a medical or mental health condition or disability.
0:18:15
The caseworker will not have the ability to print a receipt nor will they be able to scan and provide copies of submitted documents while submitting while visiting the client in their home.
0:18:26
In many cases, the documentation would need to be mailed to a client once submitted.
0:18:32
There are significant privacy concerns especially as it relates to sending personal health information in the mail.
0:18:40
Such information could be varied as social security numbers, lab test results, diagnostic information, notes from healthcare providers, referral and discharge summaries, prescription details, or information about health conditions.
0:18:57
If such documents get into the hands of the wrong person they could be used for nefarious purposes.